Court filings concerning NLRSD July 1998 - June 1999 status report, ODM report, ''2000-01 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)'', motion of the PCSSD to approve middle school construction modification, and PCSSD motion to approve middle schools and revamped high schools

District Court, order; District Court, motion for extension of time to respond to Little Rock School District's (LRSD's) notice of filing and request for scheduling order; District Court, notice of filing, North Little Rock School District (NLRSD) July 1998 - June 1999 status report; District Court, notice of filing, Office of Desegregation Management report, ''2000-01 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)''; District Court, separate motion of the Pulaski County Special School District (PCSSD) to approve middle school construction modification; District Court, supplement to separate motion of the Pulaski County Special School District (PCSSD) to approve middle school construction modification; District Court, supplement to Pulaski County Special School District (PCSSD) motion to approve middle schools and revamped high schools; District Court, supplemental memorandum in support of Pulaski County Special School District (PCSSD) motion to approve middle schools and revamped high schools; District Court, notice of filing, Arkansas Department of Education (ADE) project managment tool The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. - RECEIVED APR 'J 2001 OfftCEOF 111116ATIONMONITORIN6 FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION APR 0 4 2001 JA~~sw. M~cc MACK, CLiRK .By. '5J- I ~k, ~ /\f\ 1!A DEPCLERK"" LITTLE ROCK SCHOOL DISTRICT * * Plaintiff, * * * VS. * No. 4:82CV00866 SWW * * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, ET AL. * * Defendants, * * MRS. LORENE JOSHUA, ET AL. * * Intervenors, * * KATHERINE W. KNIGHT, ET AL. * * Intervenors. * ORDER On March 15, 2001, the Little Rock School District ("LRSD") filed a Compliance Report and asked the Court to issue a Scheduling Order setting a date by which the parties must file any objections or challenges to the report.1 The LRSD suggests that the parties be given no more than twenty days within which to file their challenges and, in the event any party files a timely challenge, that the Court schedule a hearing before June 30, 2001. The Court has heard informally from one of the parties, who contends he needs more time to review the report and file challenges. See Attachment A 1See docket entry 3410. Having reviewed the Compliance Report, and considering the informal request for additional time, the Court finds that the parties need more than twenty days to review the many details set forth in the Report and prepar~ any challenges. After having consulted the Court's own calendar, the Court hereby establishes the following deadlines and hearing dates~ Any challenges to the LRSD's Compliance Report must be filed on or before May 18, 2001. If challenges to the report are filed, a hearing will be held on July 5 and July 6, 2001, beginning at 9:00 a.m. If necessary, the hearing will continue on August 1 and August 2, 2001. If the parties desire the Court to examine any documents pertaining to this hearing, those documents shall be submitted to the Court no later than June 29, 2001. Also before the Court is the motion of Tim C. Humphries to withdraw his appearance as counsel for separate defendant Arkansas Department of Education. The motion [ docket entry 3411] is granted.2 The Clerk is directed to remove Mr. Humphries as counsel for the Arkansas Department of Education. SO ORDERED this ~11\.__day of April 2001. a;z_&,,~ CHIEF JUDGE ' UNITED STATES DISTRICT COURT THIS DOCUMENT ENTERED ON . DOCKET SHEET IN COMPLIANCE 0~1~~8 A~~/m::a) FRCP 2On February 21, 2001, Sammye L. Taylor and Mark Hagemeier entered their appearances as counsel for the Arkansas Department of Education. See docket entries 3405 & 3406. 2 JOHN W. WALKER SHAWN CHILDS JOHN W. WALKER, P.A. ATIORNEY AT LAW 1723 BROADWAY LlTILE ROCK, .ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-418~ Via Facsimile March 26, 2001 Honorable Judge Susan Webber Wright Chief Judge United States District Court 600 West Capitol Avenue Little Rock, AR 72201 Re: LRSD v PCSSD Dear Judge Wright: OF COUNSEL ROBERT McHENRY, P.A. DONNAJ. McHENRY 8210 HENDERSON ROAD Li'ITLE RocK, ARKANSAS 72210 PHONE: (501) 372-3425 FAX (501) 372-3428 EMAIL: mchenryd@swbell.net Due to the fact that I was in trial before the Honorable George Howard Jr. in Pine Bluff, Arkansas from March 19-22, 2001 and in intense preparation for the days preceding the 191\ I am just getting in position to address the Little Rock filing, Notice of Filing Compliance Report and Request for Scheduling Order. I further note that Little Rock has indicated that it wishes to limit our time for filing challenges to twenty (20) days. This letter is being written to request that the Court set a time for a conference before addressing the issue of a scheduling order so that all parties, as well as the Office of Desegregation Monitoring, would have an opportunity to address the propriety of the scheduling order request. The compliance report is extensive. It appears to be more than two hundred (200) pages in length, is very detail oriented and it makes many claims which are unfamiliar to us and probably to the ODM as well. I am writing the Court this letter, rather than filing a motion, because Mr. Heller, who I am advised is away until Wednesday, expressed an interest in having some dialogue regarding this matter, and the State settlement as well, before this matter becomes, if it ever does, a public dispute which the Court must resolve. ! I understand that the Court .intends to schedule a hearing in the near future regarding the middle s~hool issues raised by the PCS SD. May I suggest that the matter of the hearing of the : scheduling order be set for the same day inasmuch as all parties-are expected to be in court for the PCSSD matter. Although I have been unable to speak with Mr. Heller and I have not attempted to reach his co-counsel, Mr. Clay Fendley who I intend to try and reach immediately, I have informed Ms. Ann Marshall regarding my concerns herein and will be having further conversations with the parties until such time I receive the Court's reply to this letter. With due respect to the court, I remain, JWW:js cc: Mr. Chris Heller Ms. Ann Brown Mr. Sam Jones Y...r. Steve Jones Mr. Richard Roachell Mr. Timothy Gauger Sincerely yours, ) i APR 12 2001 r:11 Glf.GEif u.!.o1s~fD EASTERN DISTAi r OURT l'Bn!atll!! C AFlKAMc:~c: lllillPII~ A PR O 4 2 IN THE UNITED STATES DISTRICT CO_MRT OOl EASTERN DISTRICT OF ARK.ANSAp)i~S W ..eggRMACK, CLERK WESTERN DIVISION I " ' .... DFP.'TJt[Af LITTLE ROCK SCHOOL DISTRICT PLAINTIFF VS. CASE NO. 4:82CV00866 SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL MOTION FOR EXTENSION OF Tll.VIE TO RESPON~ TO LRSD'S NOTICE OF FILING AND REQUEST FOR SCHEDULING ORDER DEFENDANTS Come now the Joshua Intervenors, through undersigned counsel, for their Motion for - Extension of Time to Respond to LRSD Notice of Filing Compliance Report and Request for Scheduling Order, state: 1. Due to undersigned counsel's trial schedule and other obligations, additional time is needed to review LRSD's Compliance Report. 2. In addition, undersigned adopts, by reference, his letter to the Court dated March 26, 2001. A copy is attached hereto as Exhibit 1. 3. This request is not for purposes of delay. WHEREFORE, for the reasons stated above, plaintiffs respectfully move the Court for an Order extending the time in which to file their Response LRSD's Notice of Filing Compliance Report and.Request for Scheduling Order for an additional thirty days including and up to May 4, 2001 Respectfully submitted, John W Walker, PA. 1723 Broadway Little Rock, AR 72206 501-374-3758 501-3 74-4187 (fax) CERTIFICATE O.F SERVICE I do hereby state that a copy of the foregoing motion has been sent to all counsel of record. <)L JI/ ~~ / ~ ,JOHN W. WALKER SHAWN CHlLDS JOHN W. WALKER, P.A. ATTORNEY AT LAW 1723 BROADWAY LITTLE ROCK, AR1<.,\.\S..\S 72206 T ELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile March 26, 200 I Honorable Judge Susan Webber Wright Chief Judge United States District Court 600 West Capitol Avenue Little Rock, AR 7220 l Re: LR.SD v PCSSD Dear Judge Wright : OF cou:--:SEL ROBERT McHENRY. P.A. DONNA .J. McHENRY 82 10 Ht::sOF.RSO~ ROAD LITTLE ROCK. :\.JlK,\:SS,IS i22 l 0 PHO:sf.: (501) 3i2-3-l25 F.-\X (50l) 3i2-3-128 E~l\lL: mchenryd'!!-swbell.nct Due to the fact that I was in trial before the Honorable George Howard Jr. in Pine Bluff, Arkansas from March l 9-22, 2001 and in intense preparation for the days preceding the 191\ I am. just getting in position to address the Little Rock filing, Notice of Filing Compliance Report and Request for Scheduling Order. I further note that Little Rock has indicated that it wishes to limit our time for filing challenges to twenty (20) days. This letter is being written to request that the Court set a time for a conference before addressing the issue of a scheduling order so that all parties, as well as the Office of Desegregation Monitoring, would have an opportunity to address the propriety of the scheduling order request. The compliance report is extensive. It appears to be more t_han two hundred (200) pages in lengJh, is very detail oriented and it makes many claims which are unfamiliar to us and probably to the ODM as well. I am writing the Court this letter, rather than filing a motion, because Mr. Heller, who I am advised is away until Wednesday, expressed an interest in having some dialogue regarding this matter, and the State settlement as well, before this matter becomes, if it ever does, a public dispute which the Court must resolve. I understand that the Court intends to schedule a hearing in the near future regarding the middle school issues raised by the PCS SD. May I suggest that the matter of the hearing of the scheduling order be set for the same day inasmuch as all parties are expected to be in court for the PCSSD matter. Although I have been unable to speak with Mr. Heller and I have not attempted to reach his co-counsel, Mr. Clay Fendley who T intend to try and reach immediately, I have informed Ms. Ann Marshall regarding my concerns herein and will be having further conversations with the parties until such time I receive the Court's reply to this letter. ,../ I -r-, ---I With due res pect to the court, 1 remain, JWW:js cc: Mr. Chris Heller Ms. Ann Brown Mr. Sam Jones Mr. Steve Jones Mr. Richard Roachell Mr. Timothy Gauger 1 Sincerely yo~urs, . ' , ~~? r.. / 1 tA'r;Jf!-(!,c v fo'hn w. Walker l JACK, LYON & JONES, P.A. ATTORNEYS AT LAW .. Nashville Office #11 Music Circle South Suite 202 Nashville, Tennessee 37203 (615) 259-4664 Telecop;er (615) 259-4668 3400 TCBY TOWER REce,,,EDrk ~:;:~i~~:mplex 425WESTCAPITOLAVENUE Cf~, 400SalemRd .. Suite3 LITTLE ROCK, ARKANSAS 7220 1-3472 Conway,Arkansas72032 (501) 375-1 122 (501) 329-1133 TELECOPIER (50 1) 375- 1.027 ! APR 5 Telecopier (501) 336-9089 April 5, 2001 200/ VIA HAND DELIVERY OffiCE Of Christopher J. Heller, Esq. fBIREsAnoN MONITliRINS FRIDAY, ELDREDGE & CLARK 2000 Regions Bldg. 400 West Capitol Little Rock, Arkansas 72201 M. Samuel Jones, Ill, Esq. WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue 2200 Bank of America Bldg. Little Rock, Arkansas 72201 John W. Walker, Esquire JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 Sammye Taylor, Esq. Mark Hagemeier, Esq. Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Ann Brown OFFICE OF DESEGREGATION MONITORING 201 East Markham, Suite 510 Heritage West Building Little Rock, Arkansas 72201 Richard W. Roachell, Esq. Roachell Law Firm 401 W. Capitol Avenue, Suite 504 Little Rock, Arkansas 72201 Tim Gauger, Esq. Mitchell, Williams, Selig, Gates & Woodyard 425 W. Capitol, Suite 1800 Little Rock, Arkansas 72201-3525 RE: NLRSD Status Report/July 1998 - June 1999 Dear Ms. Brown and Counsel: Enclosed please find a copy of the above referenced Status Report. If you have any questions, please do not hesitate to contact me. SWJ:tl Enclosures yours, IN THE UNITED STA TES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION NORTH LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DEFENDANTS DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS RECEIVED APR 5 2001 OFFICE OF DESEGREGATION MONITORING NOTICE OF FILING PLAINTIFF North Little Rock School District hereby gives notice of the filing of the following document: 1. North Little Rock School District's July 1998 - June 1999 Status Report. Respectfully Submitted, JACK, LYON & JONES, P.A. 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 (50 75-1122 CERTIFICATE OF SERVICE I, Stephen W. Jones, hereby certify that I have this 5th day of April, 2001, sent one copy of the foregoing via Hand Deliv~i;y, to the following: Christopher J. Heller, Esq. FRIDAY, ELDREDGE & CLARK 2000 Regions Center 400 West Capitol Little Rock, Arkansas 72201 M. Samuel Jones, Ill, Esq. WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue 2200 Bank of America Bldg. Little Rock, Arkansas 72201 John W. Walker, Esquire JOHN W. WALKER, P.A. 172;3 Broadway Little Rock, Arkansas 72206 Sammye Taylor, Esq. Mark Hagemeier, Esq. Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Ann Brown OFFIC.E OF DESEGREGATION MONITORING 201 East Markham, Suite 51 O Heritage West Building Little Rock, Arkansas 72201 Richard W. Roachell, Esq. Roachell Law Firm 401 W. Capitol Avenue, Suite 504 Little Roak, Arkansas 72201 Tim Gauger, Esq. Mitchell, Williams, Selig, Gates & Woodyard 425 W. Capitol, Suite 1800 Little Rock, Arkansas 72201-3525 1. I I I I I I I 1e I I I I I I ~ I I tT FILED 2000-01 ENROLLMENT AND RACIAL BALANCE IN 'Ufflt r/~;1i;:.~g9..i~~sAs LITTLE ROCK SCHOOL DISTRICT AND PULASKI COUNTY SPECIAL SCHOOL DISTRICT APR 1 1 2001 Melissa R. Guldin Associate Monitor April 11, 2001 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Ann S. Marshall Federal Monitor JAMES W. McCORMACK, CLERK .By: DEP CLERK Polly Ramer Office Manager !'.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. SEPARATE MOTION OF THE PCSSD TO APPROVE MIDDLE SCHOOL CONSTRUCTION MODIFICATION The PCSSD for its separate motion states: RECEIVED APR J 4 200:li illfflCEQf 1lESl!HfEGATION1MONITORINW PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. The PCSSD Board of Directors approved a conversion to middle schools on May 9, 2000. 2. On September 27, 2000 PCSSD submitted to this court, the ODM and the other parties its comprehensive Business Case which explains and justifies the overall middle school conversion. 3. On February 16, 2001 PCSSD filed its motion to approve middle schools and revamped high schools. A copy of the business case referred to in paragraph two was appended to that motion as was a comprehensive bound set of materials explaining the work and preparation that the District had done since May of 2000 to implement the middle school conversion. 4. As part of the conversion, physical modifications to Robinson High School and Mills University Studies High School were deemed necessary and were explained 248200-v1 - in the Business Case. The details of the modifications are set forth at page 57 of the booklet of materials filed February 16, 2001. For the convenience of the court and the parties, this page is re-appended to this motion as Exhibit"!('. 5. The renovations referred to Exhibit'~' are already in progress. Because of the general oversight which this court has pursuant to the PCSSD, the PCSSD requests that this court formally approve the renovations described in Exhibit'!A!'. WHEREFORE, the PCSSD respectfully requests an order of this court approving the renovation activities described in Exhibit'~' and for all proper relief. 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 ____ ,.-a-+-----~1-'-"'------ M. Ill (76060 Att ski Coun ial Sch On April 13, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Building Little Rock, Arkansas 72201 248200-v1 2 Ms. Ann Brown ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Brian Brooks 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 248200-v1 ~ ~ 3 EXHIBIT I A FACILITY NEEDS TO IMPLEMENT MIDDLE SCHOOL~OGRAM Robinson Hi'3h Item Amount Construct new 2 classroom addition ... ... . ..... .. .... . $160,000 Convert Ex. CR 11 into 2 classrooms . . . . . . . . . . . . . . . . . . . . . . $5,000 Convert Ex. CR 12 into 2 art labs . . . . . . . . . . . . . . . . . . . . . . . . . $5,000 Renovate Ex. Rm. 29 into a classroom . . . . . . . . . . . . . . . . . . . . $5,000 Renovate Ex. Rm. 30 into a classroom . . . . . . . . . . . . . . . . . . . . $5,000 Convert Ex. CR 27 ( choir room )into 2 classrooms . . . . . . . . $20.,.000 Sub-total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $200,000 Contingency, 10% ( +/-) . . .... . .... . ... '. . . . . . . . . . . . . . . . . . $10,000 Sub-total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $210,000 Architect fee, Misc. tests, etc., 8% ( +/-) ..... . ... . : . .... . . $15,000 Total ........ . . : . .. .. . ..... . ... .'. - : -: . . .. ... ..... .. .. $225,000 Mills University Studies High Convert existing Media Center into additional Cafeteria Space and teacher Amount work room ..... . ... . .. . . . ............. . ..... . . ....... . $85,000 Construct new Media Center . . ..... . ... .. ... . ..... .. .. $637,500 Sub-total .... . . . . . ...... . . .. ... . ... . .. .. .. . .... . ... . $722,500 Contingency, 10% ( +/-) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $72,300 Total . . ....... . ........ . . . .... . .... .. ... . .. _. ...... .. $794,800 .Total of Robinson High and Mills High .... . .......... . .... . ... .. ... $1,019,800 057 . . ' IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION R!C!JVa, APR 1 9 ZOOt ~~~OF --.vlll.1MIIUJJ IIJIJro- LITTLE ROCK SCHOOL DISTRICT PLAI NTI FF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS INTERVENORS I NTERVENORS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. SUPPLEMENT TO SEPARATE MOTION OF THE PCSSD TO APPROVE MIDDLE SCHOOL CONSTRUCTION MODIFICATION For its supplement to its renovation motion, the PCSSD states: 1. Attached as Exhibit "A" is a business case in support of the renovation motion which the PCSSD respectfully requests this Court to consider as part of its submissions in this matter. 249171-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 B -~,..::;...~----:-:-:-::::'='"::-:~-..;;;:....---Jones Ill (76 r Pulaski C Special rict CERTIFICATE OF SERVICE On April [1, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Ms. Sammye L. Taylor Mr. Mark A. Hagemeier Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 249171-v1 2 Executive Summary: Implementation of Middle Schools Construction Pulaski County Special School District April 2001 The Pulaski County Special School District (District) currently has 24 elementary schools, each encompassing grades kindergarten through six; one existing middle school, Jacksonville Middle School; and six junior high schools, each encompassing grades seven through nine. The six senior high schools currently contain students in grades ten through twelve. After discussions, workshops, and community meetings, the District's Board of Directors voted at its May 9, 2000, meeting to approve a district-wide conversion to middle schools, effective for the 2001-2002 school year. This decision to pursue middle school conversion included construction for the Mills University Studies High School campus and the Robinson High School campus. Staff estimated that costs for facility remodeling would total $983,734.00. Background: The implementation of the middle school concept will not change student assignments, only the configuration of the existing junior and senior high schools. Oak Grove Junior/Senior High School, Jacksonville Middle School, Jacksonville Junior High School and Jacksonville High School will be the exceptions to the proposed conversion. Toward this end, the District contracted a general evaluation of all of its schools. The facilities study provided the Board with a blueprint of construction needs. At this time, the District anticipates that the conversion to middle schools can be accomplished by converting the existing junior high facilities to middle school campuses and s ending ninth grade students to the senior high school facilities. Existing facilities have been examined for this movement of students. Two sites would need renovation to accomplish the conversion: Robinson High School will require classroom space conversion and renovation. Mills University Studies High School will need additional cafeteria space and a new media center. Problem Statement: Increasing the capacity at the Robinson and Mills sites is recommended for a successful conversion to 9-12 grade high schools. Without the proposed construction, student capacity would be severely limited. Recruitment within and to those areas would also be hampered. Failure to increase the student capacity at these two campuses would result in overcrowding, discipline problems and displacement of students. In turn, this would result in increased student displacement, busing and negative school-community relations. EXHIBIT 249145-v1 J II I I I I I I I I I Alternatives: The alternative to this recommendation for construction would be to keep the campuses in their current configurations. This would cripple the ability to make the complete middle school conversion and conversion to 9-12 grade high schools. Action Recommended: By its vote on May 9, 2000, the Board of Directors approved a district-wide conversion to middle schools, to become effective for the 2001-2002 school year. The Board chose to delay the conversion of Oak Grove Junior/Senior High School to the middle school concept at this time. On March 13, 2001, the Board decided to delay the conversion of Jacksonville Middle School, Jacksonville Junior High School, and Jacksonville High School as well. Once the Board authorized the middle school concept, an examination of all secondary school facilities was conducted for student capacity. As a result of this examination, it was determined that addition construction would be needed at Mills and at Robinson High Schools. At Mills University Studies High School, a new media center is being built and the old media center would be converted into addition cafeteria space. These renovations will increase the capacity of the school media center and cafeteria. At Robinson High School, two additional classrooms will be constructed, the choir room would be divided and two dressing rooms will be converted into classroom space. This construction would increase the student capacity at Robinson High School by at least 250 students, both to accommodate the addition of the 9th grade and to provide for future desegregated growth. Objectives: The implementation of middle schools works to support the District's overall goals which includes the District's commitments to desegregation. Foremost, the creation of effective learning environments for all students support the District's goal of raising student achievement and successfully raising expectations. Students in sixth grade will have intensive use of technology and more opportunities to participate in co-curricular activities than is available in elementary schools. Ninth graders will enjoy increased opportunities for advanced academic pursuits and extra-curricular activities. Impact: Increased capacity will help to improve discipline, enhance recruitment efforts, and assist in maintaining racial balance at these campuses. It will also enhance student achievement and increase the opportunity for success of these students. Ninth grade students will benefit from the challenge of high school classes, increased curriculum opportunities and extra-curricular activities. 249145-v1 2 Student population at Mills for the current school year is 587 students for grades 10 through 12. Of that total, 343 students are white and 244 students are black. Present student capacity at Mills is 780. The projected student enrollment for 2001- 2002 school year, in grades 9 through 12, is 900. Of that projection, 483 students would be white, 417 students would be black. Student population at Robinson High School for the current school year is 435 students for grades 10 through 12. Of that total, 320 students are white and 115 students are black. Present student capacity at Robinson High School is 506. Robinson's projected enrollment for the 2001-2002 school year, in grades 9 through 12, is 638. Of that projection, 458 students would be white and 180 students would be black. Resources: The conversion to middle schools can be accomplished with few facility changes. Robinson High School and Mills University Studies High School have been identified as the only buildings needing immediate renovations. These costs are estimated to be $983,734. The construction at Mills will cost $766,680. Additional renovation at Robinson will cost $217,054 and will increase student capacity by about 250 students. Plan for Implementation: The Pulaski County Special School District will make the facility renovations required to accommodate a middle school conversion. At both Mills University Studies High School and Robinson High School construction started January 30, 2001. Estimated completion of construction is August 1, 2001. 249145-v1 3 EDWARD L. WRIGHT (1903-1977) ROBERT S. LINDSEY (1913-1991) ISAAC A. SCOTT, JR. JOHN G. LILE WRIGHT, LINDSEY & JENNINGS LLP ATTORNEYS AT LAW JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX, JR. TROY A. PRICE GORDON S. RATHER, JR. TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD, JR. PATRICK J. GOSS ALSTON JENNINGS, JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J . MULDROW N.M. NORTON CHARLES C. PRICE CHARLES T. COLEMAN JAMES J, GLOVER EDWIN L. LOWTHER, JR. CHARLES L. SCHLUMBERGER WALTER E. MAY GREGORY T. JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER McSPADDEN ROGER D. ROWE JOHN D. DAVIS Mr. John Walker John Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, Arkansas 72222-7388 RE: PCSSD Dear Counsel and Ms. Marshall: 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK, ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 376-9442 www.wlj .com OF COUNSEL ALSTON JENNINGS RONALD A. MAY M. TODD WOOD Writer's Direct Dial No. 501-212-1273 mjonesCwlJ.com April 27, 2001 Mr. Christopher Heller Friday, Eldredge & Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon & Jones 3400 TCBY Tower PATRICIA SIEVERS HARRIS JAMES M. MOODY, JR. KATHRYN A. PRYOR J . MARK DAVIS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J. SALLINGS WILLIAM STUART JACKSON MICHAEL D. BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON JENNlfER S. BROWN C. TAD BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J. CHARLES DOUGHERTY" M. SUN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE W. DUKE ROBERT W. GEORGE J . ANDREW VINES JUSTIN T. ALLEN CHRISTINE J. DAUGHERTY, Ph,O. LJcensad to practlca be/'orB the Unled Sla'9s Patent and Trademarl< Office RECEJ.\fED 425 West Capitol Avenue Little Rock, Arkansas 72201 APR 3 0 zom CIIIE81f -lllllQfflRIIS Ms. Sammye L. Taylor Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Enclosed are copies of supplement to PCSSD motion to approve middle schools and revamped high schools and supplemental memorandum in support which are being filed today. MSJ/ao Encls. 251317-v1 Cordially, WRIGHT, LINDSEY & JENNINGS LLP ~~ M. S muues, Ill IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION APR 3 0 20m Gffll(lf De~IIJIIDJRlli LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. 4:82CV00866SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL. KA THERINE KNIGHT, ET AL. SUPPLEMENT TO PCSSD MOTION TO APPROVE MIDDLE SCHOOLS AND REVAMPED HIGH SCHOOLS PCSSD, for its supplement to motion, states: 1. Contemporaneously with this supplement, the PCSSD is submitting for filing additional documents numbered 17 4 through 232 for the Court's review and consideration. 2. The numbering of this submission begins with the next number of the documents submitted February 16, 2001. In large measure, the documents are sequenced chronologically and several of them are discussed in the accompanying memorandum. 251097-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 '--- "' (7~ B ~ ---,, \::: ones Ill (76Q60) Pulaski'eounty Special ct CERTIFICATE OF SERVICE On April,ZJ, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge & Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, Arkansas 72222-7388 Ms. Sammye L. Taylor Mr. Mark A. Hagemeier Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 251097-v1 M. S~el Jo~es Ill ,. ) ~ u 2 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. 4:82CV00866SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. SUPPLEMENTAL MEMORANDUM IN SUPPORT PLAINTIFF DEFENDANTS INTERVENOR$ INTERVENORS OF PCSSD MOTION TO APPROVE MIDDLE SCHOOLS AND REVAMPED HIGH SCHOOLS Work on the implementation of middle schools has continued since the District's - original filing dated February 16, 2001. The supplemental document submission covers both documents generated since the first filing as well as supplies a handful of documents that were not available to counsel in February. Documents 174. and 175 represent the memorandum of understanding between PACT and PCSSD dealing with the placement of teachers in middle schools. Documents 176 through 181 represent a presentation made by Dr. Gloria Rousseau to administrators at the PCSSD which contains useful information concerning the process since January 2001. Documents 183 through 193 represent various committee reports and activities as do Documents 195 through 196. Documents 197 through 200 explain the formal Board policies which have been adopted and Documents 201 through 204 contain information regarding the middle school curri