Court filings: District Court, order; District Court, notice of filing compliance report and request for scheduling order; District Court, motion for withdrawal of appearance; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, order

The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. - FILED .=,,A, _UE.S. DISTRICT COURT 1 RN DISTRICT ARKANSAS MAR,O f 200f IN 11IB UNITED STATES DISTRICT COURT '., \ EASTERN DISTRICT OF ARKANSAS ~A!"fE~jW- Mqe~RJ.f~K, CLERK WESTERN DMSION y -v 1 ~~ ~ bl'>]/\ LITTLE ROCK SCHOOL DISTRICT * * Plaintiff: * * vs. r * Case No. 4:82CV00866 SWW * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, ET AL. * * ECEIVED Defendants, * * MRS. LORENE JOSHUA, ET AL. * AR 2 200\ * Intervenors, * OffiCEOf * OESEGRE~1lotl KATHERINE W. KNIGHT, ET AL. * * Intervenors. * ORDER The Pu1aski County Special School District moves the Court for an Order authorizing a special election to be held May 8, 2001. See docket entry 3400. The District states the proposed election is for the purpose of placing before the voters for approval a millage increase sufficient to finance an ambitious program of school fucility enhancement. There have been no responses or objections to the motion, and the Court finds that the motion should be granted. TIIEREFORE, the Court hereby grants the motion and approves the special millage election to be held in the Pu1aski County Special School District on May 8, 2001. dt SO ORDERED this _j_ day of March 2001. ~.&-~ F JUDGE UNITED STATES DISTRICT COURT DEPCLERJ<'-.. ~ DOCUMENT ENTERED ON DOCKET SHEET IN ..,OMPUAN3_ C; WITH RULE 58 ANO'OR 79(~ FRCP )R_ . <X~CJf.. IV ::'!:?- -~-_;.--~,- 3409 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DNISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 . , Qff.!;R RECEI\.Y ~u PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL MAR 1 ~ 200\ OF.ICE OF DESEGREGATION MONITORING NOTICE OF FILING COMPLIANCE REPORT AND REQUEST FOR SCHEDULING ORDER PLAINTIFF DEFENDANTS INTERVENORS INTER VEN ORS The Little Rock School District ("LRSD" or "District") for its Notice of Filing Compliance Report and Request for Scheduling Order states: 1. LRSD hereby files the attached Compliance Report in accordance with Section 11 of its Revised Desegregation and Education Plan ("Revised Plan"). LRSD has substantially and in good faith complied with terms of the Revised Plan. A brief summary of each section of the Compliance Report is set forth below. 2. Good Faith. During the term of the Revised Plan, LRSD attempted to demonstrate its good faith by complying with its plan obligations. To manifest its good faith commitment for the future, the LRSD Board of Directors ("Board") on January 11, 2001, adopted a "Covenant for the Future," in which the Board promised to continue fighting discrimination, providing equity and improving the academic achievement of all students. A key component of the District's success under the Revised Plan was the establishment of Campus Leadership Teams ("CL Ts") at each school. The CLTs provide the horsepower driving the District's efforts to improve student achievement. The District invested heavily in providing training to the CLTs and school principals in Total Quality Management ("TQM"). - All principals received intensive TQM training through the Arkansas Leadership Academy. The District's focus on quality leadership has not gone without recognition. In the fall of 2000, the District received the Quality Commitment Award from the non-profit group Arkansas Quality Award. This award recognized the District as an organization that has a plan and commitment to quality management. The District's development ofleadership talent should pay substantial dividends in the future. 3. Faculty and Staff. LRSD had a strong record in the area of faculty and staff even before adopting the Revised Plan. Even so, the District worked hard to recruit, develop and promote increased numbers of qualified African-Americans. Under the Revised Plan, the District increased the percentage of African-American administrators and teachers, and it increased the number of African-American media specialists, counselors, secondary core subject teachers, early childhood teachers and primary grade teachers. The District also began tracking the distribution of the most experienced and educated teachers in an effort to better ensure an equitable distribution of these teachers. 4. Student Assignment. In accordance with the Revised Plan, the District revised student attendance zones to allow students to go to their neighborhood schools to the extent possible. While this resulted in an increase in the number of racially identifiable schools and schools more than 20 percentage points from the district-wide percentage of African-American students, the increases were not dramatic. Moreover, the large number of alternative assignment choices available to students helped minimize any adverse effect resulting from the neighborhood school zone plan. This year twenty-percent of the District's students chose to attend a school other than their zone school. 5. Special Education. While African-American students remain disproportionately represented among special education students, a review of the District's programs, policies, and procedures revealed no vestiges of racial discrimination in the referral and placement of students in special education or other special needs programs. Furthermore, since 1998-99 the increase in the number of African-American students identified with disabilities has been in proportion to 2 their increase in the total student population. There has been only two percent growth in the number of identified students with disabilities since 1998-99, with the percentage of AfricanAmerican students remaining just about the same. The two percent growth correlates with the increase in total student enrollment over the same period, as well as an increase in the percentage of students qualifying for free/reduced lunch eligibility. 6. Discipline. The number of African-American students suspended decreased 20 percent from 1997-98 through 1999-2000. This was consistent with a 21 percent decrease in the total number of disciplinary sanctions. For the same time period, the number of students committing offenses decreased 16 percent. 1:hus, fewer student are committing offenses, and those that do commit offenses are less likely to commit a second offense. The behavior modification plans being implemented pursuant to the Revised Plan may account for this decrease. The decrease in discipline sanctions positively impacted parents' and teachers' perceptions of District schools. A survey of parents and teachers conducted during the 1999-2000 school year revealed that 93 percent of African-American parents and 95 percent of white/other parents who expressed an opinion agreed that their child was safe at school. Ninety-one percent of both African-American and white/other parents who expressed an opinion agreed that their child has a feeling of belonging at school. Ninety-seven percent of African-American teachers and 96 percent of white/other teachers who expressed an opinion indicated that they felt safe at school. 7. Extracurricular Activities. Extracurricular activities increased dramatically under the Revised Plan. The number of African-American students participating in extracurricular activities jumped from 2,335 to 5,203 from 1997-98 through 1999-2000. A large part of the increase in participation resulted from a "no-cut" policy in athletics for middle school six graders and the use of Supplemental Instructional Plans ("SIPs"). SIPs allow students who otherwise would be academically ineligible for athletics to continue participating in athletics while they attend tutoring to improve their grades. The District also organized an Activities Advisory Board to promote, support and enhance the activities available in the District. 3 The 1999-2000 survey of parents and teachers also reflected the District's success in the area of extracurricular activities. Ninety percent of African-American parents and 93 percent of white/other parents who expressed an opinion agreed that activities were open to students. Ninety-three percent of African-American teachers and 95 percent of white/other teachers who expressed an opinion agreed that students have opportunities for activities. 8. Advanced Placement Courses. New policies and procedures for placement of students in advanced courses greatly improved access and participation for all students, and especially African-American students. New programs have the potential of producing exponential growths in both participation and success in advanced courses in the next few years. The increasing number of African-American students participating and succeeding in advanced courses perhaps provides the best reason to be optimistic about the District's future. With regard to Advanced Placement ("AP") courses, the total enrollment of AfricanAmerican students increased from 471 in 1997-98 to 797 in 2000-01-an increase of 326 students or 69 percent. The total enrollment of white/other students in AP courses increased from 964 in 1997-98 to 1495 in 2000-01-an increase of 531 students or 55 percent. The total enrollment of all students in AP courses increased from 1435 in 1997-98 to 2292 in 2000-01-an increase of 857 students or 60 percent. The number of AP courses taught increased from 16 in 1997-98 to 20 in 2000-01; whereas, the average high school in the United States teaches only six AP courses. With regard to high school Pre-AP courses, the total number of high school students enrolled improved from 5065 in 1999-2000 to 5953 in 2000-01-an increase of 888 students or 15 percent. African-American student enrollment improved at a slightly higher rate-from 2341 in 1999-2000 to 2715 in 2000-01-an increase of 374 students or 16 percent. White/other student enrollment also improved-from 2724 in 1999-2000 to 3238 in 2000-01-an increase of 514 or 15 percent. With regard to middle school Pre-AP courses, African-American student enrollment grew 937 from 1999-2000 to 2000-01-an increase of 19 percent. White/other student enrollment in 4 middle school Pre-AP courses grew 1076 in one year-a 24 percent improvement. The total middle school Pre-AP enrollment grew by 2013 students-a 22 percent improvement. In contrast to the enrollment in the high school AP courses, where African-American enrollment was 35 percent of the total in 2000-01, the African-American enrollment in middle school Pre-AP courses was 51 percent of the total. In sixth grade Pre-AP/GT English courses there were 908 students enrolled in 2000-01 . At the high school level there were 261 students enrolled in English m AP in 2000-01 . If the current grade six students stay in the pipeline for advanced course enrollment, the English ill AP enrollment could improve 250 percent in a few years. The number of AP examinations taken increased from 422 in 1997-98 to 524 in 1999- 2000-an increase of24 percent. Although the percentage of students earning a "3" or higher on the AP examinations went down from 60 percent in 1997-98 to 52 percent in 1999-2000, the number of students earning a "3" or higher improved from 252 in 1997-98 to 268 in 1999-2000. With regard to the ACT, the most common college entrance exam taken by LRSD students, the number oftest-takers improved from 786 in 1997-98 to 1026 in 1999-2000 for an increase of240 or 31 percent. The number of African-American test takers improved from 410 to 570-an increase of 160 students or 39 percent. The number of white test takers also increased-from 268 in 1997-98 to 345 in 1999-2000-an improvement of77 students or 29 percent. African-American students improved their English scores from 17.2 in 1997-98 to 17.4 in 1999-2000, their Science Reasoning scores from 17.2 to 17.4, and their average composite scores from 17.2 to 17.3. While small increases, they represent a substantial accomplishment given that test scores usually decrease when the number of test-takers increases. African-American students' willingness to move into more rigorous academic courses may reflect their belief that they will get the support they need to succeed. In the 1999-2000 parent survey, 88 percent of African-American parents who expressed on opinion agreed that their child received academic support. Eighty-six percent of white/other parents who expressed an opinion agreed with this statement. 5 9. Academic Achievement. The District completely revised its policies, procedures, and programs to facilitate and enhance academic achievement of all students, especially AfricanAmerican students. The District implemented new standards-based curricula, effective teaching strategies, aligned materials, and a re-designed and a comprehensive professional development program in fall 1999 and expanded in fall 2000 in English language arts, mathematics, and science, K-9. School year 2001-02 will see expansions into grades 10-12, as well as K-12 social studies and the beginning of fine arts program planning. Efforts included the addition of several new student support programs, many of which were funded through federal, state, and foundation grants. This District set high expectations for its students by raising graduation standards. Beginning in 2002, seniors must have a minimum of24 units to graduate, and beginning in 2004, they must have 26 units. In addition, the District published a "Recommended Curriculum" for high school students that includes eight advanced courses in the 28 units that students are encouraged to complete. The District secured several major grants as a part of its efforts to improve academic achievement. They are as follows: A $3.4 million grant from the National Science Foundation to support improvements in mathematics and science; A $7.8 million Safe Schools/Healthy Students grant from the United States Department of Education to support implementation of new programs aligned with the District's transition of the junior highs to middle schools; Two multi-million dollar 21 st Century Learning Community grants from the United States Department of Education to develop and support after-school and summer programs to support student achievement; A $250,000 planning grant from the Carnegie Foundation to support a year of planning for high school reform and improvements in student achievement. 6 An $11 million grant proposal was submitted to the Department of Education in December 2000 to develop magnet curricula at four southwestern Little Rock schools. One challenge the District faces in its effort to improve academic achievement is students arriving for kindergarten without the necessary social or learning skills. To meet this challenge, the District went beyond the requirements of Revised Plan in funding (with no assistance from the State) an early childhood program. The District implemented new four-year-old classes in 1999- 2000 and again in 2000-01. In 2000-01 there were 954 four-year-olds enrolled-234 more than the 720 required by the Revised Plan. In addition, early childhood enrollment included 254 children served in the HIPPY program; 23 infants, toddlers, and three-year olds at Metropolitan; 63 infants, toddlers, and three-year-olds at Rockefeller; and 18 three-year-olds at Washington-for a total of 1058. The District implemented new procedures and programs for early childhood education designed to improve children's kindergarten "readiness" level. Specifically with regard to reading and language arts, the District developed its PreK-3 Literacy Plan to guide implementation of new standards-based curricula, instructional strategies, materials, and assessments across all schools. The District invested heavily in professional development for all teachers and in the purchase of classroom sets of materials for students. Consistent with the Revised Plan, the District established a two and one-half hour block of time for the teaching ofreading and language arts in grades K-3. To measure success of the PreK-3 Literacy Plan, the District administers the Observation Survey and the Developmental Reading Assessment in kindergarten through grade two. Both are informal reading inventories that are administered one-on-one. They are administered both in the fall and spring so growth can be measured. The results from the 1999 fall pre-test showed that white kindergarten students began with a score of more than two ( a score of two indicates readiness for the next grade level), as compared to African-American students whose fall pre-test score was less than one. Thus, white students began kindergarten with a higher level of readiness. On the spring post-test, the kindergarten class had the highest percentage of students scoring at or 7 above readiness (72.2 percent) of any of the three grades tested, perhaps as a result of the new Animated Literacy program in phonemic awareness that was introduced in fall 1999, along with the new ELLA strategies and materials. Both African-American and white students improved significantly from the pre-test to the post-test. On average, African-American kindergarten students' post-test scores were 43 percent of that of their white counterparts. First graders performed the poorest of the three grades tested in terms of the percentage of students scoring at or above readiness at the end of the school year ( 53. 6 percent), perhaps indicating the need for the Animated Literacy program for these students. All first graders improved, but white students improved the most, probably because the reading skills that they began the year with enabled them to progress faster. However, the average score for AfricanAmerican first graders was 65 percent of that of their white peers, suggesting a narrowing of the achievement gap that existed when the students entered the District. All second graders' scores improved significantly over the course of the year, just as they did in kindergarten and first grade, with 67.5 percent at or above the readiness level on the spring post-test. On average, African-American student's scores were 77 percent of that of their white peers, an increase from 43 percent in kindergarten and 65 percent in first grade. This again suggests that the District may be having success in narrowing the achievement gap which exists when students enter the District. With regard to reading and language arts in the intermediate grades, the District implemented new standards-based curricula, instructional strategies, materials, and assessments across the District in fall 1999, just as with the primary grades. The District emphasized Effective Literacy in professional development for intermediate grade teachers. While the District is still not where it would like to be, the results from the State Benchmark Exam taken by fourth graders showed substantial improvement. Scores improved from 32 percent at the proficient/advanced levels in 1998-99 to 42 percent in 1999-2000-an improvement of 31 percent. African-American students improved almost 10 points on the exam, 8 a 50 percent improvement, and white students improved four points, a seven percent improvement. The gap between the scores of African-American and white students narrowed six points in 1999-2000, from 42 points to 36 points. The rate of improvement of African-American students was 43 points higher than for white students. The District had many fewer grade four students performing at the lowest level in 1999-2000 than in 1998-99-a reduction of 13 percentage points or a 32 percent decrease. Additionally, fewer African-American students performed at the Below Basic level-a reduction of 16 percentage points or a 31 percent decrease. White students in the lowest level were reduced by seven percentage points for a 41 percent decrease. The gap between white and African-American students in the Below Basic level was 35 points in 1998-99 and was reduced to 26 points in 1999-2000. Reading scores also improved for fifth graders on the Stanford Achievement Test (91h Edition) ("SAT9") from 1999-2000. The average percentile score for all students improved five points, for African-American students improved five points, and for white students improved one point. Compared to the SAT9 scores from the fall of 1997, the average percentile score for all students improved five points, for African-American students improved seven points, and for white students improved four points. The achievement gap in reading narrowed from 46 percentile points in 1997-98 to 43 percentile points in 2000-01. Fifth graders' language scores on the SAT9 also improved from 1999-2000. The average percentile score for all students improved four points and for African-American students improved six points. Compared to the SAT9 scores from the fall of 1997, the average percentile score for all students improved four points, for African-American student improved seven points, and for white students improved one point. The achievement gap in language narrowed from 36 percentile points in fall 1997 to 30 percentile points in fall 2000. With regard to math and science, the District implemented new standards-based curricula, instructional strategies, and materials in K-9. The District funded these efforts in large part with 9 the grant from the National Science Foundation. Major investments occurred in professional development and in the purchase of new materials. The scores of fourth graders on the State Benchmark Exam provide a reason for optimism. The State administered the grade four State Benchmark Exam in mathematics for the second time in spring 2000. The District's scores showed significant improvements for all students (eight points), for African-American students (seven points), and white students (eight points). Although the gap widened one point between African-American and white students in 1999-2000 (from 45 to 46 points), the percentage improvement for African-American students was much greater than that of white students, 88 percent compared to 15 percent. The District's grade four as a whole saw fewer students performing at the lowest level in 1999-2000 as compared to 1998-99-a reduction of four percentage points or a seven percent decrease. Additionally, fewer African-American students performed at the lowest level-a reduction of five percentage points or a seven percent decrease. The gap between white and African-American students in the Below Basic level shrank from 50 points in 1998-99 to 45 points in 1999-2000. Fifth graders' mathematics scores improved slightly on the fall 2000 SAT9, with all students' scores up one percentile point and African-American students' scores up two percentile points. Compared to fall 1997 SAT9, the average percentile scores for all students improved one point and for African-American students improved four points. The achievement gap narrowed slightly from 1997-98 to 2000-01, from 36 to 32 percentile points. Tenth graders' SAT9 mathematics scores also improved. Their teachers had had initial training in a standards-based curriculum, and the students were the first required to take physics in the ninth grade. From 1999-2000 to 2000-01, the average percentile scores for all students improved four points, for African American students improved one point, and for white students improved six points. 10. Parental Involvement. The District already had a plethora of parent and community involvement policies, procedures, and programs when the Revised Plan was approved in 1998. Accordingly, the District directed it efforts to widening the outreach, focusing on the school level, and creating a more coherent leadership structure at the district level. The District began including parents and community representatives on CLTs, and the Board approved a Parent Program Restructuring Plan which consolidated all parent programs under the direction of one Collaborative Action Team. 11. Equitable Allocation of Resources. The District developed a unique method of reviewing equity in the allocation of resources. Each year the resource allocation review revealed no correlation between resources allocated to a school and the school's racial composition. Moreover, the District used the results of the review in making resource allocation decisions, such as allocating grant and Title I funding. 12. Guidance and Counseling. The 1999-2000 survey of parents revealed that 94 percent of all parents, both African-American and white/other, who expressed an opinion agreed that help and guidance was available to their child. This perception has proven a reality at least with regard to scholarship money received by African-Americans. Of the 301 scholarships awarded in the 1998-99 school year, 147 or 49 percent went to African-American students totaling $3,256,207 or 47 percent of the total dollar amount of scholarships awarded. For 1999- 2000 school year, African-American students received a total of 185 scholarships valued at $3,716,358. African-American students represented 56 percent of the scholarship recipients and received 58 percent of the total dollar amount of scholarships awarded. African-American females outpaced all other groups in the number received (105) and the dollar value of scholarships awarded ($1,967,654). 13. Cultural Sensitivity. Since the 1999-2000 school year, the District has been providing cultural sensitivity training through Dr. Terrence Roberts, one of the "Little Rock Nine" and a desegregation consultant for the District approved by the Joshua lntervenors. His workshop, entitled "Learning to Cope with Differences," provides strategies for dealing with differences in race, ethnicity, gender, economics, disabilities, religion and other characteristics that 11 I can divide people and create unhealthy tension. The 1999-2000 survey of teachers suggests that the District has done well in this regard. Ninety-four percent of African-American teachers and 93 percent of white/other teachers who expressed an opinion agreed that District administrators value diversity. Eighty-eight percent of African-American teachers and 92 percent of white/other teachers who expressed an opinion agreed that personnel respond to cultural differences. 14. Compliance. Section 8 of the Revised Plan included a procedure for parties to raise issues related to the District's compliance. This procedure was invoked on only five occasions, with the last being in December of 1999. All of those issues were resolved without the necessity of court intervention. 15. The Revised Plan obligated LRSD to implement programs, policies and/or procedures designed to achieve certain outcomes, and it has done so. Although the Revised Plan did not obligate LRSD to achieve any particular outcomes, the Compliance Report includes information on outcomes which was used by LRSD to evaluate the programs, policies and procedures being implemented. 16. Section 11 of the Revised Plan provides: At the conclusion of the 2000-01 school year, the district court shall enter an order releasing LRSD from court supervision and finding LRSD unitary with regard to all aspects of school operations provided that LRSD has substantially complied with its obligations set forth in this Revised Plan. In anticipation of release, LRSD shall issue a report on March 15, 2001, indicating the state ofLRSD's compliance with the Revised Plan. Any party challenging LRSD's compliance bears the burden of proof If no party challenges LRSD's compliance, the above-described order shall be entered without further proceedings. LRSD has substantially complied with its obligations set forth in the Revised Plan. If no party challenges LRSD's compliance, an order should be entered finding LRSD unitary with regard to all aspects of school operations. 17. LRSD respectfully requests that the Court issue a scheduling order establishing a period not exceeding 20 days for parties to file challenges to LRSD's compliance pursuant to Section 11 of the Revised Plan. This should be sufficient time given that the parties have known when this report would be filed since April 10, 1998, and that Section 8 of the Revised Plan 12 required parties to raise compliance issues "as soon as reasonably practicable." See Revised Plan, Section 8.2.1. If any party files a challenge on or before the deadline established by the Court, LRSD respectfully requests that a hearing on the challenge be held before June 30, 2001, the end of the 2000-2001 school year. WHEREFORE, LRSD prays that this Court immediately issue a scheduling order establishing a period not exceeding 20 days for parties to file challenges pursuant to Section 11 of the Revised Plan; that should a challenge be filed by a party, a hearing be held on the challenge before June 30, 2001; and that should no party file a challenge on or before the deadline established by the Court, that on June 30, 2001, this Court enter an order finding LRSD unitary with regard to all aspects of school operations. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE & CLARK First Commercial Bldg., Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376-~-i--- 13 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by handdelivery on March 15, 2001 : . Mr. John W. Walker JOHNW. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey & Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-73 88 Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Timothy G. Gauger Mitchell, Williams, Selig, Gates & Woodward 425 West Capitol Avenue, Suite 1800 Little Rock, AR 72201-3525 14 RECEIVED MAR 1 s 2001 Little Rock School District Revised Desegregation and Education Plan Compliance Report March 15, 2001 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. RECEIVED MAR 2 s zam lllll&EJ~ WfMONllURINQJ PLAINTIFF DEFENDANTS MOTION FOR WITHDRAWAL OF APPEARANCE I, Tim C. Humphries, hereby move to withdraw my appearance as counsel on behalf of separate defendant Arkansas Department of Education in the above-captioned matter. I, Tim C. Humphries, am no longer employed with the Office of the Attorney General, and separate defendant - Arkansas Department of Education is now represented in this matter by Chief Barrister Sammye L. Taylor and Assistant Attorney General Mark A. Hagemeier of the Office of the Attorney General. WHEREFORE, I, Tim C. Humphries, respectfully request that this motion be granted and that the Court direct the clerk of the court to remove me as counsel for separate defendant Arkansas Department of Education. By: Respectfully Submitted, TIM C. HUMPHRIES1. Secretary of State's Office State Capitol, Room 256 Little Rock, AR 72201 (501) 682-3016 CERTIFICATE OF SERVICE I, Tim C. Humphries, certify that on l_k of March, 2001, I caused a copy of the foregoing document to be served by U.S. mail, postige prepaid, on the following person( s) at the address( es) indicated: M. Samuel Jones, III Wright, Lindsey & Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 7220 I John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 7220 I Richard Roachell 401 W. Capitol, Suite 504 Little Rock, AR 7220 I Timothy Gauger Mitchell, Williams, Selig, Gates & Woodyard 425 West Capitol Ave. Suite 1800 Little Rock, AR 72201-3525 Christopher Heller Friday, Eldredge & Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 Stephen W. Jones Jack, Lyon & Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Brown 201 E. Markham, Ste. 510 Little Rock, AR 72201 Tim c:Humphries 2 I I I , ' . I i II J IN THE UNITED STA TES DISTRICT COURT EASTERN DJSTRICT OF ARKANSAS WESTERN DMSION RECEIVED APR 12 2001 LITTLE ROCK SCHOOL DISTRICT OFFiCEOF DESEGREGATION MONITORING PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's Order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE's Project Management Tool for March, 2001 . Respectfully Submitted, MARK PRYOR Attorney General Assistant Attorney Ge 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-3643 Attorney for Arkansas Department of Education CERTIFICATE OF SERVICE I, Mark A. Hagemeier, certify that on March 28, 200 l, I caused a copy of the foregoing doc