District Court, opposition to Pulaski County Special School District's (PCSSD's) motion to approve modification to student assignment plan; District Court, notice of filing, Office of Desegregation Management report, ''Achievement Disparity between the Races in the North Little Rock School District (NLRSD)''; District Court, Pulaski County Special School District (PCSSD) motion for protective order; District Court, memorandum in support of Pulaski County Special School District (PCSSD) motion for protective order; District Court, first supplement to Pulaski County Special School District (PCSSD) motion for protective order; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. RECEIVED JUL 7 2000 IN THE UNITED STATES DISTRICT COURT JUL n 6 2000 OFFICE OF DESEGREGATION MONITORING EASTERN DISTRICT OF ARKANSAS JAMES W McCORMACK.,C LERK By .. WESTERN DIVISION DEP CCERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. OPPOSITION TO PCSSD'S MOTION TO APPROVE MODIFICATIONTO STUDENT ASSIGNMENT PLAN DEFENDANTS The Joshua Intervenors oppose the PCSSD's Motion to Approve Modification to Student Assignment Plan. The basis for the Joshua Motion is as follows: 1. The proposed Motion to Approve Modification to Student Assignment Plan was not presented to the Joshua Intervenors and the other parties until it was filed with the Court. This is a deviation from the desegregation plan requirement. It is important to note that the Office of Desegregation of the Pulaski County District has had no contact directly or indirectly with counsel regarding this matter and counsel is therefore left in the position of being uninvolved in the evolution of the modification. The Intervenors are also unaware that the district has shared its proposed modification proposal with the educational advisors to the district particularly, Dr. Steven Ross, which brings the Joshua Intervenors to point No. 2. 2. The proposal does not indicate how the modifications will strength the delivery of education to the affected children and how it will contribute to the remediation of preexisting and well-entrenched patterns of educational disparities between majority and minority students. In fact, the proposal is silent on tile educational benefits to the students. 3. The district indicates that it proposes to save money by making the modification to the student assignment plan. The purported business case does not delineate the amount of money ti-mt is involved in its proposal nor the amount of saving which would be effectuated. It suggests that by reduction of busing, it would reduce cost. But there is no demonstration that busing will actually be reduced. The map presented as Exhibit 1 to the motion is very general and does not set forth the geographical areas of any of the schools. Therefore, it is impossible to accurately ascertain the transportation impact upon students which brings us to the next point. 4. The text of the PCSSD brief shows (at 3) that the district proposes to implement option 3 set forth on Exhibit B. The Landmark school would be 75% white and the new Bates 70% black. Prior to the new construction, the three schools (Landmark, Old Bates, and Fuller) ranged from 42- 5 7% black. The district proposes a range of 25-70% black. Thus, new construction would promote segregation. That brings us to the next point. 5. The district argues in page 3 of its brief that these racial imbalances can be improved but its presents no plan for that improvement nor any date nor responsible authority for insuring that these schools will not become racially identifiable. 6. The proposal is patently racial because it proposes to shift white students from the majority African American school to the predominately white Landmark school and it proposes to shift African American students from predominately white Landmark school to the predominantly African American Bates school. The district simply cannot justify this racial assignment by noting that it will shift some programs from Landmark to Bates. Those shifts have not been documented nor discussed with Joshua nor have they been approved by the Court. Furthermore, shifting programs from one school to another cannot meet or satisfy the district's obligation to desegregate in full. The Joshua Intervenors again observe that there has been no educational program presented to the Court which would insure that the educational advantages available to children in the southeast quadrant of the school district will be equal to those in the north west quadrant. The schot>l district has not developed under the new administration any vision regarding improvement of educational opportunity for students in the southeast quadrant any of its schools. 7. The district makes reference to other matters under consideration such as moving schools in the southeast quadrant to the middle school concept. But those proposals have not been developed and are therefore are not being responded to by Joshua at this time. To respond to speculation would be an exercise in futility. WHEREFORE, the Joshualntervenors respectfully oppose the proposal of the school district to substantially change the racial identification of the Landmark and Bates schools. The Joshua Intervenors respectfully request a hearing on the subject, after reasonable opportunity to engage in discovery, and after such hearing, they respectfully request that the proposed modification be rejected. By: Respectfully submitted, JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 CERTIFlCATE OF SERVICE I hereby certify that a copy of the foreging has been mailed, postage prepaid to the following counsel or record, postage prepaid on this day of July, 2000. Mr. M. Samuel Jones, III Wright, Lindsey & Jennings 2000 NationsBank Plaza 200 W. Capitol Little Rock, Arkansas 7220 l Mr. Tim Humphries Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arknasas 72201 Mr. Richard Roachell 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Bldg. 400 W. Capitol Little Rock, Arkansas 7220 I Mr. Stephen W. Jones Jack, Lyon & Jones 3400 TCBY To,vers 425 W. Capitol Little Rock, Arkansas 7220 I Ms. Ann Brown 201 E. Markham, Ste. 510 Little Rock, Arkansas 72201 . Walker Ann S. Brown Federal Monitor ACHIEVEMENT DISPARITY BETWEEN THE RACES F I INTHE !L,E~ NORTH LITTLE ROCK SCHOOL DISTRICT EAsr~~N~1~1t'Mc~ A~R~~sAs July 12, 2000 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Norman W. Marshall Associate Monitor JUL 1 2 2000 ~~{AES W. McCORMACK. CL!::~K Dt:P C.::.~ Polly Ramer Office Manager I 1 1 I I I I I I I I I IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PCSSD MOTION FOR PROTECTIVE ORDER The PCSSD defendants, for their motion state: R ,HJl 3 1 2000 OrFICE Gr DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. Attached as serial Exhibit A are multiple FOIA requests received by the PCSSD and certain of its personnel during the past two weeks. Attached as serial Exhibit B are FOIA requests received from Joshua by the PCSSD generally dating from the Fall of 1999. 2. The PCSSD respectfully submits that Joshua is improperly utilizing the Arkansas FOIA as a substitute for the discovery specified by the Federal Rules of Civil Procedure. 3. Certain of the information sought pursuant to Joshua's FOi requests is irrelevant to the issues scheduled for hearing on August 9, 2000, or to any other issues which could reasonably arise in this litigation. 4. The current requests are often oppressive, burdensome and annoying. 193297-v1 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEIVED DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ~UL 31 2000 OFFICE OF DESEGREGATION MOfJITORING MEMORANDUM IN SUPPORT OF PCSSD MOTION FOR PROTECTIVE ORDER Rule 26(c) of the Federal Rules of Civil Procedure provides in pertinent part that: Upon motion by a party ... accompanied by a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action, and for good cause shown, the court in which the action is pending ... may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following: (1) that the disclosure or discovery not be had; (2) that the disclosure or discovery may be had only on specified terms and conditions, including a designation of the time or place; (3) that the discovery may be had only by a method of discovery other than that selected by the party seeking discovery; (4) that certain matters not be inquired into, or that the scope of the disclosure or discovery be limited to certain matters; Attached to the PCSSD motion, as serial Exhibit A, are copies of many of the FOi requests that have been served by Joshua since this Court entered its order scheduling 193040-v1 - this matter for hearing on August 9, 2000. Any perusal of the FOi requests makes it apparent that Joshua is seeking to utilize the Arkansas Freedom of Information Act in lieu of the discovery rules specified by the Federal Rules of Civil Procedure. The Arkansas Freedom of Information Act is codified beginning at ACA 25-19- 101. 25-19-105 provides in pertinent part that: (a) Except as otherwise specifically provided by this section or by laws specifically enacted to provide otherwise, all public records shall be open to inspection and copying by any citizen of the State of Arkansas during the regular business hours of the custodian of the records. (b) It is the specific intent of this section that the following shall not be deemed to be made open to the public under the provisions of this chapter: (8) Documents which are protected from disclosure by order or rule of court. While the PCSSD is not seeking to protect certain records from disclosure, it is - seeking an order of this Court which harmonizes the provisions of the Federal Rules of Civil Procedure and the Arkansas FOIA for purposes of this litigation. While the public policy considerations underpinning the Arkansas FOi are sound and are not challenged by this motion, what is questioned is the propriety of substituting the FOi for traditional discovery. The public's right to know is one matter; however, the attempted conversion of a sunshine law into a truncated and oppressive discovery weapon is quite another. For the reasons that follow, this Court should enter an order consistent with the relief sought herein. 193040-v1 2 Certain of the information sought is irrelevant to the issues scheduled for. hearing on August 9, 2000, or to any other Issues which could reasonably arise in this litigation The August 9 issues The issues scheduled for hearing on August 9, 2000, are the PCSSD proposal to reorganize the assistant superintendentships for personnel and desegregation and a PCSSD proposal to modify some student assignments to the new Bates Elementary School. Although it will be obvious to the Court from examination of the FOi requests that Joshua has plans to bring Plan 2000 compliance issues to the Court's ultimate attention, those are not currently the subject of the August 9 hearing. Indeed, as the Court can see from examining Joshua's letter of July 19, 2000, Joshua has necessarily - elected to invoke the 30-day "complaint" procedure specified in Plan 2000. The PCSSD will respond to the complaint letter in the time allocated under Plan 2000. Thereafter, assuming that Joshua remains dissatisfied with the PCSSD response, Joshua will have the option to invoke the dispute resolution process specified with the Department of Justice. If, in fact, this dispute resolution process proves unsuccessful, then, but only then, may Joshua seek to invoke the jurisdiction of this Court. The foregoing is offered to illustrate the fact that even if Joshua is serious about ultimately raising compliance issues before this Court, the interim process will necessarily take some time and it is respectfully submitted that no hearing could be reasonably scheduled for such issues until some time this fall. Accordingly, the PCSSD believes it is reasonable to propose that Joshua's current FOi requests be reasonably limited to the discreet issues currently set for hearing, and that in respect of all other 193040-v1 3 - issues, that Joshua be ordered to utilize the traditional discovery techniques as specified in the Federal Rules of Civil Procedure. The current requests are oppressive, burdensome and annoying Any fair reading of the current FOi requests demonstrate that the requests are not all bottomed upon "the public's right to know" as envisioned by the Arkansas FOi. Neither can Joshua point to anything within the Arkansas FOIA which authorizes its use as a litigation tactic calculated to disrupt school district operations, seek information, such as thank you notes, get well cards, and anything "in writing" or "all writings" whatever they may be. Rather, the breadth and unbridled scope of the requests strongly suggests an ulterior motive; i.e. to keep administrators and staff from their regular jobs and to watch them jump through the hoops created by Joshua's requests. The Federal rules contain reasonable deadlines for discovery compliance which permit documents to be produced in a manner that is not disruptive to normal business and educational activities and responsibilities. The Arkansas FOIA, on the other hand, requires an almost instantaneous response which, when coupled with the volume of materials requested by Joshua, threatens chaos and disruption. The PCSSD suggests that this is an unwarranted perversion of the Arkansas FOi not calculated or contemplated by the Arkansas Legislature. Many of the FOi requests duplicate matters previously furnished to Joshua pursuant to FOi requests and duplicate requests for information routinely furnished to Joshua as part of PCSSD's desegregation philosophy Included as serial Exhibit B are FOi requests dated generally from 1999, to which the PCSSD then responded. At a minimum, the PCSSD should not be 193040-v1 4 put to the trouble of regurgitating again that which it has previously furnished Joshua within the last twelve months. Further, many of the requests implicate reports to the Board and the ODM which have been routinely generated during the last ten years and just as routinely, furnished to Joshua including, for instance, the annual PCSSD affirmative action reports, discipline reports, special education reports and other similar reports well know to the ODM and to this Court. It seems no great request that Joshua be ordered to discipline itself to the extent that it first ascertain whether or not it already has the information requested before blindly seeking it again and again from the PCSSD. Conclusion For the foregoing reasons, the PCSSD requests an order of this Court granting the relief sought herein. 193040-v1 Respectfully submitted, WRIGHT, LINDSEY & JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 - By \..- ;T-- ~ . ;-1--n- _,,, ' .._ . ( .______ M. Sa_!J)tlel ones Ill _(760,60) . . Attorneys f Pulaski C~ Special spt,ool Di ict '-_/ 5 CERTIFICATE OF SERVICE On July2:&ooo, a copy of the foregoing was served as follows on each of the following: Via Hand Delivery Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail: 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 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 193040-v1 6 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. FIRST SUPPLEMENT TO PCSSD MOTION FOR PROTECTIVE ORDER The PCSSD, for its first supplement to motion states: RECEIVED AUG 1 2000 i.HH10F OESE~OO-,mJ MmJITORIMG PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. Attached as Exhibit A-1 are FOi requests, received by Dr. Smith, all dated July 28, 2000. These requests were actually received on July 31, 2000. 2. These two requests supplement Exhibit A to the District's motion for protective order filed July 28, 2000. WHEREFORE, the PCSSD defendants renew the relief sought in theirmotion for protective order dated July 28, 2000, and for all proper relief. 193567-v1 Respectfully submitted, WRIGHT, LINDSEY & JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 CERTIFICATE OF SERVICE On July :3(, 2000, a copy of the foregoing was served as follows on each of the following: Via Facsimile on: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail on: Mr. Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown QOM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 193567-v1 2 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 193567-v1 3 i I i I I I i I ! JUL-31 -00 MON 07:36 AM FAX NO. t' , Uc'./Uli 5013744187 WALKER ~AW FIRM 909 P02 JU.. 28 100 17 : 15 JOHN W, WALXZll RALPH WASHINGTON MAllX BUllN!TTI SHAWN CHILDS Dr. Gary Smith Superintendent of Schools JOHN W. W~R, P.A. ATrOa.-.lY kr LAw 1723 BIOADWAY J.rrrLI R0CK, AilnNSAS 72206 TELEPHONE (i,01) s7,-S7118 FAX (~01) ~14-4187 Via Fac,imile - 490-0483 July 28, 2000 Pulaski County Special Sehool Dinrict 92S Dbcon :Read Little Rocle, AR 72206 Dear Dr. Smith: RECEIVED JUL 3 1 2000 This request is pursuant to the Arkansas Freedom 0lnfotmation Act. Would you please providl;l i!ll writings (lneoming and outaoins) thai ha-ve talcen pl~ between you, Dr. James Fox, ~ -Billy Bowles, Dr. Ruth Herta, Mr. Gary Miller, Mr. Eddie Collin11 Dr. Jerry Welch, Mr. Jim Johnson, Dr. Don Henderson. Ml. Beverly Williams, Ms. Manha Asti, M$. MttciJ Chapman, Mr. David Hendrix, Ms. Theresa Wallent and anyone else with desegregation responsibility since July 1, 1999, It also includes writing, (incoming and outgoins) of any kind whether they arc rcgardinn peraonnel, student assignment, educational initiative&, tranaporta~on. pay, proposals to the Coun. as well a.e any other mauers. ThiJ req1,mt also includH cmalla and ecmputer files. I would abo like to have access to the notet (incoming and outgoing) of yourself and those of Dr. Fox, Mr. Bowlea, Mt. Collins, Mr. Miller, Dr. Herts, Dr. Weloh, Dr. Henderson, Ms. Williams, Ms. Ast~ Ma, Chapman, Mr. Hendrix, Mr. Johnson and Ms. WaJJent, a.s they relate to the proposals that ha.ve been considered for presentation to the Court or to the school board in reference to the school desesreaation plan. I would ippreciato this infonnation not later than Wednesday, August 2, 2000. Would you also please provide the following: (l) list of applicants for the Director of Secondary Education position; (2) a. copy of the Elomentary/Seconduy School Civil Rights . Compliance Report/Individual School keport: I> 102 from the U.S. Department of :Education/Civil Rights; (3) Minutes of the Steering Committee meetings relli.tive to education plans of Dr. Steven Ross; (4) all numbered memorandums ofth.: above referenced lndividua1s from July J, 1999 to present; (5) e-mail addresses ofalt the abov~ referenced individuals; (6) responses from principal& to Eddie Collini regardina ms letter ofAl-lS\'st 2, t 999 regarding Disclplittary Management Plan; (7) Annual Disciplinary Summaey for all schools; (8) Incoming and outgoing type-written and hand-written writing& of all secret.uies of the above ~fcrenccd indrviduGJ1; (9) resportaes from all parties referenced to in your March 13, ZOOO letter relating to plan ZOOO; ( 1 O) copies of rriemo books from all lndlviduaJ.1 referenced to above; ( 11) a I.QPY of the written report of all annual reviews regarding speci&l ed~tion to Martha Asti; (12) copies of revised elementary and secondary student handbooks; and (12) list ofrecipi,nta (race and EXHIBIT I fi-1 ~ - - - ---- -- ---- -- JUL-31-00 MON 07:37 AM FAX NO. 5013?44187 ~LKER LAW FIRM 909 P03 t', U3/U4 Jl..1... 28 '00 17:1~ sender) who were honored durlOi the SAT lncentivc Award program duritli 1999-2000 school year. Caro CACI JUL-31-00 MON 07:37 AM rAX NU. 501374418? W~R LAW FIRM JOHN W, WALKER, P.~. '311 P02 r', U4/ U'i J\.L 29 '00 17:43 AT'l'ORNIY AT LAW 1,2s BitOADWAY R Ee E 1v ED L1TJ1,! RoCIC, AluwlsAS 72206 TELEPHONE (601) 874-3758 JOHN W, WALKiR JW..PH WABHlNOTON MARK BURNE'l'Tt SHAWN CHILDS FAX (501) 974-4187 JUL 3 1 2000 Via Facsimile - 490-0433 Dr. Gary Smith Superintendent of Schools Pulaski County Special Sr.boo[ District 91.5 Dixon Road Little Rock. AR 72206 Dear Dr. Smith: July 28. 2000 This request is pursuant to the Arkansas Freedom oflnformation Act. Would you please provide for review, inspection and oopyine the following: 1) a copy of the ADI! TAG Monitoring Repon dated February, 2000; 2) a copy otthe 2000-2001 Student Handbook approved by the Board of Education; 3) all writing, (incomina and outsoine) regar~ing pupil personnel (discipline and student assignments and enrollment) including notes, e-mails, computer files, numbered memorandums, ete. between yourself, Dr. Jam.es Fox, Mr. Bi~y Bowles, Dr, Ruth Herts, Mr. Gary Miller, Mr. Eddie Collins, Dr. Jerry Welch, Ms. Beverly Williams, Ms. Martha Ast~ Ms. Marcia Chapman, Mr. David Hendrix, ~. Theresa Wallent, Mr, Doug Lin.gton, Ms. Georgia Norris, Ms. Ann ____ (Bddie Collins Secretary) or any other person in Pupil Personnel with the responsibility of receiving and/or inputtina pupil persoMel data. Please make this information available by Thursday, Auewt 3, 2000. Sincerely, CACI IN THE UNITED STATES DISTRICT (;OURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION RECEIVED AUG I 2000 LITILE ROCK SCHOOL DISTRICT Off!CEOF 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 July, 2000. Respectfully Submitted, MARKPRYOR Attorney General Assistant Attom neral 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. IMPLEMENTATION PHASE ACTIVITY . I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of July 31, 2000 B. Include all Magnet students in the resident District's average daily membership for calculation. 1 . Projected Ending Date Last day of each month, August - June. This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.