Court filings: District Court, notice of filing, Arkansas Department of Education (ADE) semiannual monitoring report and executive summary; District Court, order; District Court, five notices of deposition; District Court, order; Court of Appeals, joint motion to postpone oral argument; District Court, order

The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. .... ..... IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION CEV FEB 3 1998 OFFICE OF DESEGREGATION MONITORINQ LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING The Arkansas Department of Education hereby gives notice of the filing of its February, 1998 Semiannual Monitoring Report and Executive Summary. Respectfully Submitted, WINSTON BRYANT Attorney General TIMO Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education CERTIFICATE OF SERVICE I, Timothy Gauger, certify that a copy of the foregoing document was served by first class mail on this 2nd day of February, 1998, on the following person(s) at the address(es) indicated: M. SamuelJones,m Wright, Lindsey & Jennings 2000 Boatmen's Bank Bldg. 200 W. Capitol Little Rock, AR 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Richard Roachell Roachell & Street 401 W. Capitol, Suite 504 Little Rock, AR 72201 Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Bldg. 400 W. Capitol Little Rock, AR 72201 Stephen W. Jones Jack, Lyon & Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Brown ODM 201 E. Markham, Ste. 510 Little Rock, AR 72201 FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS (. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION FEB O 2 1998 JA~i~ w ~CORMACI( QlER By.~ \d\J.../\~ LITTLE ROCK SCHOOL DISTRICT, Plaintiff, vs. * * * * * * * * * * * * * No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al., Defendants, MRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors. ORDER FEB o/ 199S OFFICE OF DESEGREGATION MmllTORlNG The Pulaski County Special School District ("PCSSD") has filed a supplement to past and ~W'1 pending claims against the state defendants. I Although this document has been filed, this Court has not docketed this document as and will not treat this document as a pending motion. Therefore, the other parties involved in this matter need not respond. If the PCSSD wishes to put these issues regarding the state defendants before the Court, the PCSSD may file a formal motion, accompanied by a proper brief in support pursuant to Local Rule 7.2, which sets forth the precise issues the PCSSD would like for this Court to consider. . ,.). SO ORDERED THIS ,;2-day of February 1998. ~Jr& UNITEDSTATES DISTRICJUDGE 1 Docket No. 3111. rHIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPU~/~H RULE 58 A~R 79(a) FRCP 0N 6./3 _ ., BY OEP CLERK JOHN W. WALKER, P.A. ATIORNEY AT LAw 1723 BROADWAY L!TILE ROCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE AUSTIN PORTER, JR. FEB 11 1998 OFFICE OF DESEGREGATION MONITORING M. Samual Jones III. WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue Suite 2200 Little Rock, Arkansas 72201-3699 February 9, 1998 Re: Little Rock School District v. Pulaski County Special School District No. 1. et al., United States District Court No. LR-C-82-866 - Dear Sam: Please let this letter serve as confirmation to our conversation that we had last week. John wants to take the depositions of the following persons on Thursday, February 12, 1998, commencing at 10:00 a .m.: a) Bobby Lester, b) Eddie Collins, c) Billy Bowles, d) Bobby Alton, and f) Gary Miller. I have prepared notices for the following persons with times therein mentioned. Should you have any questions or concerns regarding this matter, please do not hesitate to give me a call. /apj Enclosures cc: John W. Walker Sincerely, Austin Porter Jr. Attorney at Law IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATERINE KNIGHT, ET AL. TO: Bobby Lester Superintendent NOTICE OF DEPOSITION Pulaski County Special School District No. I 925 East Dixon Road Little Rock, Arkansas 72206 PLAINTIFF DEFENDANTS INTER VENO RS INTER VENO RS RECElVED FEB 1 i 1998 OFFICE OF DESEGREGATION MONITOR!!~ PLEASE TAKE NOTICE that pursuant to the provisions of the Federal Rules of Civil Procedure, the Joshua Intervenors, by and through their attorneys John W. Walker, P. A, will take the deposition of Bobby Lester, at the place and time identified below, before a Certified Court Reporter or some other officer authorized by law to administer oaths. Said deposition will be used both for discovery and/or as evidentiary purposes, to the full extent as may be allowed by the Federal Rules of Civil Procedure and the Federal Rules of Evidence. The deposition will take place on February 12, 1998 @ 10:00 a.m. at the law offices of JOHN W. WALKER, P.A., 1723 S. Broadway, Little Rock, Arkansas 72206. You are notified to appear and take part in the deposition. Respectfully submitted. John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 501-374-3758 By C.J::J {J R. Austin Porter Jr., #8145 CERTIFICATE OF SER VICE I, Austin Porter Jr., do hereby certify that a copy of the foregoing pleading has been served by United States Mail on this 9tJ+- day of February, 1998 on the following persons: Mr. Christopher Heller FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Timothy Gauger Assistant Attorney General 323 Center Street Suite 200 Little Rock, Arkansas 72201 Stephen W. Jones Attorney at Law 3400 TCBY Tower Building 425 West Capitol Avenue Little Rock, Arkansas 72201 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATERINE KNIGHT, ET AL. TO: NOTICE OF DEPOSITION Eddie Collins Director of Pupil Personnel Pulaski County Special School District No. 1 925 East Dixon Road Little Rock, Arkansas 72206 OrFiCE C. DESE6REG.ATIOM MONffOn.lNB PLAINTIFF DEFENDANTS INTERVENORS INTER VENO RS PLEASE TAKE NOTICE that pursuant to the provisions of the Federal Rules of Civil Procedure, the Joshua Intervenors, by and through their attorneys John W. Walker, P. A, will take the deposition of Eddie Collins, at the place and time identified below, before a Certified Court Reporter or some other officer authorized by law to administer oaths. Said deposition will be used both for discovery and/or as evidentiary purposes, to the full extent as may be allowed by the Federal Rules of Civil Procedure and the Federal Rules of Evidence. The deposition will take place on February 12, 1998 @ 11:30 a.m. at the law offices of JOHN W. WALKER, P.A., 1723 S. Broadway, Little Rock, Arkansas 72206. You are notified to appear and take part in the deposition. Respectfully submitted, John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 501-374-3758 By: /2b-()-Jtj )?. _ Austin Porter Jr., #8'6145 CERTIFICATE OF SER VICE I, Austin Porter Jr., do hereby certify that a copy of the foregoing pleading has been served by United States Mail on this ft-4-day of February, 1998 on the following persons: 1vfr. Christopher Heller FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Stephen W. Jones Attorney at Law 3400 TCBY Tower Building 425 West Capitol Avenue Little Rock, Arkansas 72201 Austin Porter Jr., No. 86145 . ' IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. iv!RS . LORENE JOSHUA, ET AL. KATERINE KNIGITT, ET AL. NOTICE OF DEPOSffiON TO: Billy Bowles Pulaski County Special School District No. 1 925 East Dixon Road Little Rock, Arkansas 72206 RECEPftED FEB 1 1 i99S OFFICE OF DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTER VENO RS INTERVENORS PLEASE TAKE NOTICE that pursuant to the provisions of the Federal Rules of Civil Procedure, the Joshua Intervenors, by and through their attorneys John W. Walker, P. A., will take the deposition of Billy Bowles, at the place and time identified below, before a Certified Court Reporter or some other officer authorized by law to administer oaths. Said deposition will be used both for discovery and/or as evidentiary purposes, to the full extent as may be allowed by the Federal Rules of Civil Procedure and the Federal Rules of Evidence. The deposition will take place on February 12, 1998 @ 1:45 p.m. at the law offices of .JOHN W. WALKER, P.A. , 1723 S. Broadway, Little Rock, Arkansas 72206. You are notified to appear and take part in the deposition. .. Respectfully submitted, John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 501-374-3758 By: ()JS ws ~ Austin Porte0r.,#86145 CERTIFICATE OF SER VICE I, Austin Porter Jr., do hereby certify that a copy of the foregoing pleading has been served by United States Mail on this 7~ay of February, 1998 on the following persons: Mr. Christopher Heller FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 W. Capitol, Suite 504 Little Rock, Arkansas 7220 l Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 7220 l Stephen W. Jones Attorney at Law 3400 TCBY Tower Building 425 West Capitol Avenue Little Rock, Arkansas 7220 l Austin P~rter Jr., No. 86145 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. lVfRS. LORENE JOSHUA, ET AL. KATERINE KNIGHT, ET AL. NOTICE OF DEPOSITION TO: Bobby Alton Pulaski County Special School District No. 1 925 East Dixon Road - Little Rock, Arkansas 72206 FEB 1 1 1998 OFFICE Or DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTER VENO RS INTER VENORS PLEASE TAKE NOTICE that pursuant to the provisions of the Federal Rules of Civil Procedure, the Joshua Intervenors, by and through their attorneys John W Walker, P. A., will take the deposition of Bobby Alton, at the place and time identified below, before a Certified Court Reporter or some other officer authorized by law to administer oaths. Said deposition will be used both for discovery and/or as evidentiary purposes, to the full extent as may be allowed by the Federal Rules of Civil Procedure and the Federal Rules of Evidence. The deposition will take place on February 12, 1998 @ 3:00 p.m. at the law offices of .JOHN W. WALKER, P.A. , 1723 S. Broadway, Little Rock, Arkansas 72206. You are notified to appear and take part in the deposition. Respectfully submitted, John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 501-374-3758 I ~/ - 1 By: --l ,c:r/ . Austin Porter Jr.,# 6145 CERTIFICATE OF SERVICE I, Austin Porter Jr., do her~by certify that a copy of the foregoing pleading has been served by United States Mail on this 7fay of February, 1998 on the following persons: Ivfr. Christopher Heller FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 1-fr. Richard W. Roachell Roachell and Street First Federal Plaza 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Stephen W. Jones Attorney at Law 3400 TCBY Tower Building 425 West Capitol Avenue Little Rock, Arkansas 72201 Austin Porter Jr., ~86145 ' ' IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. I, ET AL. l\1.1.RS . LORENE JOSHUA, ET AL. KATERINE KNIGHT, ET AL. NOTICE OF DEPOSITION TO: Gary Miller Pulaski County Special School District No. I 925 East Dixon Road - Little Rock, Arkansas 72206 OFFICE OF DESEGREGATION MO~IITORJUG PLAINTIFF DEFENDA.t'\J"'TS INTER VENO RS INTER VENO RS PLEASE TAKE NOTICE that pursuant to the provisions of the Federal Rules of Civil Procedure, the Joshua Intervenors, by and through their attorneys John \V. Walker. P. A., will take the deposition of Gary Miller, at the place and time identified below, before a Certified Court Reporter or some other officer authorized by law to administer oaths. Said deposition will be used both for discovery and/or as evidentiary purposes, to the full extent as may be allowed by the Federal Rules of Civil Procedure and the Federal Rules of Evidence. The deposition will take place on February 12, 1998 @, 3:30 p.m. at the law offices of .IOHN W. WALKER, P.A., 1723 S. Broadway, Little Rock, Arkansas 72206. You are notified to appear and take part in the deposition. Respectfully ~ubmitted, John W. Walker, PA. 1723 S. Broadway Little Rock. Arkansas 72206 501-374-3758 By: --\;:a,L--==---d----"--+---Austin Porter Jr., # 6145 CERTIFICATE OF SERVICE I, Austin Porter Jr., do hereby certify that a copy of the foregoing pleading has been served by United States Mail on this -2.._~y of February, 1998 on the following persons: Mr. Christopher Heller FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building Little Rock, Arkansas 7220 l Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 W. Capitol, Suite 504 Little Rock, Arkansas 7220 l Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock. Arkansas 72201 Stephen W. Jones Attorney at Law 3400 TCBY Tower Building 425 West Capitol Avenue Little Rock, Arkansas 72201 Austin Porter Jr., N'o. 86145 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * No. LR-C-82-866 * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * * MRS. LORENE JOSHUA, et al., * Intervenors, * * KATHERINE KNIGHT, et al., * Intervenors. * QRDER FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS FEB 1 3 1998 RECEIVED FEB 1 7 1998 OFFICE OF DESEGREGATION MONITORlNG Before the Court is a joint motion filed by ServiceMaster Management Services, Inc. - rserviceMaster") and the Little Rock School District ("LRSD"). ServiceMaster and the LRSD request that this Court dismiss without prejudice ServiceMaster as an intervening party in this proceeding. Both parties agree that ServiceMaster should now be dismissed from this proceeding because there are currently before the Court no disputes or issues regarding the arrangements between ServiceMaster and the LRSD. However, the LRSD has agreed that it shall notify general counsel's office of ServiceMaster as soon as practicable should any pleadings be filed with the Court, whether filed by the LRSD or other parties involved in this litigation, that relate to the LRSD's arrangements with ServiceMaster and that if such circumstances should arise, the LRSD will not object to a motion for leave to intervene filed by ServiceMaster. For good cause shown, this Court grants the parties' motion. ServiceMaster is hereby dismissed without prejudice as an intervening party in this case, pursuant to the conditions agreed upon by the LRSD and SeryiceMaster. SO ORDERED THIS /0--f\.._ day of February 1998. OJ-. 7U ~~* uNITEDST ATES n1sTRIC JUDGE rHIS DOCUMENT ENTERED ON DOCKET SHEET IN GC,Mf>UANCE W!::'LE 53 ANOJOR 79(a) FRCP -JN ,~//~ ev_V,....,\ _ _ 2 discriJtlinat i on by PCSSD against African-American students, to provide that no person is discriminated against on the basis of race, color or ethnicity in the operation of PCSSD and to provide an equal educational opportunity for all students attending PCSSD schools. 2.1.1. PCSSD shall retain a desegregation and/or education expert approved by Joshua to work with PCSSD in the development of the programs, policies and procedures to be implemented in accordance with this Plan and to assist PCSSD in devising remedies to problems concerning desegregation or racial discrimination which adversely affect African-American students. The minimum term of the expert shall be for a period of time of at least two (2) years. 2. 2. PCSSD shall implement programs, policies and/or procedures designed to improve and remediate (narrow the gap) the academic achievement of African-American students. 2. 2 .1. PCSSD shall continue to search for and implement programs, policies and/or procedures designed to improve and remediate the academic achievement of Afri can American students. The PCSSD will increase scrutiny at the system level of the implementation at the school level of the designated programs, policies and procedures. Any newly implemented programs shall have clearly stated goals that can 2 be measured in terms of student achievement. The student achievement measures shall have standardized scoring procedures and be sensitive to instructional effect, -including graduation rates and participation in upper level courses, by instructional and/or curricular change. 2.2.2. PCSSD will continue to brought about work with representatives of the University of Memphis to assess and possibly to increase the use of the "Success for All" program and other effective programs in the PCSSD. The program is now employed in t he Bates School. 2.2 . 3. PCSSD shall assess academic programs i mplemented herein after each year in order to determine the effectiveness of the programs in improving African-American student achievement. The assessment shall utilize either control groups, or predictive measures that allow comparison to actual versus predicted effect. PCSSD shall take appropriate action i n the form of program modification or program substitution. 2. 3. PCSSD shall implement programs, policies and/or pr ocedures designed to provide that PCSSD hires, assigns, utilizes and promotes qualified African-Americans in a fair and equitable manner . 2. 3 .1. PCSSD shall maintain in place its current policies and practices relating to the recruitment of AfricanAmerican teachers which have allowed PCSSD to maintain a 3 2.6.3. Regarding the issue of an ombudsman for the PCSSD, ODM will assist the parties by undertaking a comprehensive assessment of the ombudsman concept. At the conclusion of the assessment period ODM will, in consul tat ion with the parties and before the start of the 1998-99 school year, recommend a person to fill the position of ombudsman. As a result of ODM's assessment, ODM will be able to: a. Articulate the needs which may be met by an ombudsman; b. Define the role of the ombudsman; c. Identify the relationship the with key administrators, such ombudsman as the would have Assistant Superintendent for Pupil Personnel, the Superintendent, and the Board; d. Describe the decision-making processes in discipline matters; e. Identify the time commitments required of an ombudsman; f. Develop a comprehensive job description for an ombudsman; g. Recommend where the ombudsman will be placed; h. Recommend how the ombudsman will be paid. 2.6.4. PCSSD shall continue to work with students and their parents to assist those students who exhibit frequent misbehavior. 7 2.6.5. PCSSD shall create and maintain for each student a11 student disciplinary records . that note the reasons for punishment, the teacher and/or other staff members involved, and the school, race and sex of the student disciplined. Collection and assessment of this information allows the school principal, parents and other administrative staff, PACT and PASS, to analyze the reasons for the disciplinary action by race and sex, and to determine if particular teachers or staff members are experiencing problems that require attention. The Assistant Superintendents for Pupil Personnel and Desegregation shall analyze data, including a sample of files concerning particular instances of discipline, to determine whether District policies have been followed, and whether there are a disproportionate number of African- American students being disciplined by category (meaning male and female students). They will make written recommendations for the elimination of any disparities. 2.6.6. PCSSD shall conduct a comprehensive study of the disciplining of African-American students, particularly male students, at the secondary level. The participants (a minimum of twelve ( 12) , one-half designated by the Joshua Intervenors and one-half by PCSSD and the PACT and PASS, shall consider the causes for high rates of discipline for African-American - students and possible remedies. The panel shall, among other 8 2 .. 8. PCSSD shall continue to implement programs, policies and/or procedures during each of the next two years designed to promote and encourage parental and community involvement and support in the operation of PCSSD and the education of PCSSD students. 2.9. The PCSSD shall not intentionally implement any programs, policies and/or procedures designed to negatively effect the allocation of financial, technological and educational resources in the PCSSD. The resources referred to herein do not include salaries and similar benefits. Should Joshua bring to the attention of the PCSSD matters which constitute material misallocation of resources, the PCSSD shall address in writing those allegations within thirty (30) days. 2.10. PCSSD shall not implement any programs, policies and/or procedures designed to diminish the equitable maintenance and repair of PCSSD facilities. 2 .11. PCSSD shall continue to implement programs, policies and/or _procedures designed to eliminate racial discrimination in the provision of guidance and counseling services. 2.11.1. Guidance counselors shall work with students in an effort to provide for more equity in academic honors, awards and scholarships. The guidance counselors shall be provided in-service training by the multicultural education 10 - coordinator with the view toward providing those persons with more knowledge and information regarding historically black colleges, scholarship availability, student loans and college preparatory information which may be helpful in assisting students in considering their educational options. Special emphasis shall be placed upon identifying ways by which to assist counselors in their encouragement of students for qualifying and meeting the requirements of standardized tests such as the preliminary SAT and ACT. 2.12. PCSSD shall continue to implement programs, policies and/or procedures designed to provide students in each PCSSD school a learning environment free from discrimination. 2.12.1. PCSSD shall implement an ongoing training program through the United States Department of Justice, the Arkansas Department of Education and/or the National Conference of Christians and Jews in prejudice reduction and cultural sensitivity~ 2 . 12.2. PCSSD shall implement policies and procedures for investigating the causes of racial disparities in participation in instructional programs and activities and developing remedies where appropriate. This responsibility shall be undertaken by coordination between the multicultural education coordinator and the other Instructional Division coordinators/directors . 11 PCSSD shall implement programs, policies and/or procedures designed to provide that PCSSD substantially complies with its obligations under this Plan . 2.13.1 The PCSSD Superintendent shall be responsible for overseeing PCSSD's compliance with this Plan. SECTION 3 : STUDENT ASSIGNMENTS 3.1. Outside Students. PCSSD schools shall be open to students who reside outside Pulaski County where the acceptance of the transfer will improve the racial balance of the district as a whole and of the school to which the student wishes to transfer and subject to capacity limitations and to reasonable requirements established by PCSSD; and, 3.2 Transportation. PCSSD shall not provide transportation in the instances of (I) employee's child transfers and (ii) transfers from outside Pulaski County. SECTION 4 : SCHOOL CONSTRUCTION/CLOSING PCSSD shall have as its highest priority the construction of a school which replaces the Bates school. The initial site to be evaluated is in the proximity of 145th Street and 65/167. There shall be no new school construction or substantial expansion of existing schools which will precede this event. Moreover, the District shall not close schools which are located 12 - in pre~ominantly African-American areas absent reasons of compelling necessity (which does not include the opposition of white patrons to attending such schools). SECTION 5: RACIAL BALANCE This Plan recognizes that the desegregation of PCSSD does not require a particular racial balance at every PCSSD school or as obligating PCSSD to recruit students to obtain a particular racial balance in every PCSSD school. However, the goal of the PCSSD is to assign students, so that no school should have a racial minority enrollment which is below twenty percent (20%) of the total school enrollment except that this minimum shall not apply to Lawson and Bayo Meta. SECTION 6: HOUSING PCSSD and Joshua commit to promote housing desegregation within segregated neighborhoods. They pledge to work together and use their best efforts to dismantle, and prevent recurrence of, segregated housing patters. SECTION 6: INTERDISTRICT SCHOOLS PCSSD and LRSD shall operate Interdistrict Schools in accordance with the following: 13 6.~. PCSSD Interdistrict Schools. PCSSD shall operate Baker Elementary, Clinton Elementary, Crystal Hill Elementary and any new elementary school which may be constructed in the Chenal Valley area as Interdistrict Schools; except that Baker is not subject to the Interdistrict School racial balance goals. 6.2 LRSD Interdistrict Schools. LRSD shall operate King elementary, Romine Elementary and Washington Elementary as Interdistrict Schools; 6.3 Racial Composition. The ideal composition at interdistrict schools shall be as close to 50%-50% as possible with the majority race of the host district remaining the - majority race at the Interdistrict School; 6.4 Reserved Seats. PCSSD shall reserve at least 200 seats at Clinton Elementary and up to 399 seats at Crystal Hill Elementary for interdistrict transfer students from LRSD; 6.5 Recruitment. PCSSD and LRSD agree to implement programs at Interdistrict Schools designed to attract interdistrict transfer students and to work cooperatively to recruit interdistrict transfer students to interdistrict Schools; 6.6 Outside Students. Interdistrict Schools shall be open to students who reside outside Pulaski County where the acceptance of the transfer will assist the Interdistrict School in achieving its ideal racial composition; and, 14 6.7. Transportation. Transportation shall be provided by the PCSSD for interdistrict transfers from Pulaski County to Interdistrict Schools. SECTION 7: STUDENT ACHIEVEMENT. 7.1. Early Childhood Education. PCSSD shall implement an early childhood education program which includes and shall continue to include a HIPPY program in all of the elementary schools in the southeast sector of the PCSSD. PCSSD also contemplates retention of the four year-old program in the schools where they are presently being operated. PCSSD also supports the HEADSTART program which ahs been operated through the local Community Action Program. In the event that the agency does not continue HEADSTART, PCSSD commits to consider seeking funding and support to operate the program itself. 7.2. Reading/Language Arts. 7.2.1. Primary Grades. PCSSD shall implement at least the following strategies to improve the academic achievement of students in kindergarten through the third grade: a. Establish as a goal that by the completion of the third grade all students ~ill be reading independently and. show understanding of words on a page; 15 b . Focus teaching efforts on reading/language arts instruction by teaching science and social studies content through reading/language arts and mathematics experiences; c. Promote thematic instruction in the interdistrict schools and in those other schools where themes now exist; d. Identify clear objectives for student mastery of all three reading cueing systems (phonics, semantics and syntax) and of knowing-how-to-learn skills; e. Monitor the appropriateness of teaching/learning materials to achieving curricular objectives and the availability of such materials in all classrooms; f. Establish, where feasible, uninterrupted blocks of time for reading/language arts and mathematics instruction; g. Monitor student performance using appropriate assessment devices; h. Provide parents/guardians with better information about their child's academic achievement in order to help facilitate the academic development of the students; i. Provide pre-kindergarten, kindergarten and first grade learning readiness experiences for students who come to schools without such experiences; 16 j. Train teachers to manage successful learning for all students in diverse, mainstreamed classrooms; k. Use the third and/or fourth grade as a transition year from focused reading/language arts and mathematics instruction to a more traditional school day; and, 1. Provide opportunities for students to perform and display their academic training in a public setting. 7.2.2. Intermediate Grades. PCSSD intends to implement at least the following strategies to improve the academic achievement of students in grades four through six: a. Adopt as a goal that by completion of the sixth grade all students will master and use daily higher level reading comprehension skills for learning in all subject areas, for making meaning in real life experiences and for personal growth and enjoyment; b. Promote thematic instruction; c. Establish, where feasible, uninterrupted blocks of time for reading/language arts, mathematics, science and social studies instruction; d. Monitor the appropriateness of teaching/learning materials to achieving curricular objectives and the availability of such materials in all classrooms; e. Monitor student performance using appropriate assessment devices; 17 ---- - - f. Provide parents/guardians with comprehensive information about their child's academic achievement in order to help facilitate the academic development of the students; g. Provide ongoing annual staff development for all teachers, train teachers to manage successful learning for all students in diverse, mainstreamed classroom; and h. Provide opportunities for students to perform and display their academic training in a public setting. 7.2.3. Secondary Schools. PCSSD intends to implement the following strategies to improve the academic achievement of students in grades seven through twelve: a. Adopt as a goal that upon graduation all students will read independently with comprehension in all subjects areas and be proficient in language arts, as necessary to be successful workers, citizens and life-long learners; b. Establish specific reading comprehension learning objectives for the language arts, mathematics, science and social studies curricula; c. Revise the language arts curriculum to include greater emphasis on reading for meaning and on expressing comprehension of reading through writing and speaking; d. Provide appropriate training to secondary teachers for implementation of these strategies; 18 - ----- - e. Monitor student progress and achievement using appropriate assessment devices. . 7.3. Mathematics. PCSSD shall implement the following strategies to improve mathematics instruction; 7. 3 .1. Revise the mathematics curriculum to include a smaller number of concepts at each level, the use of manipulatives and problem solving and critical thinking and train teachers on its implementation; 7.3.2. Develop appropriate assessment devices for measuring individual student achievement and the success of the revised curriculum;