Court filings concerning Joshua intervenors' interrogatories and requests for production of documents by Supt. Les Carnine regarding Joshua's objections to unitary status, requests for admissions to Superintendant James, and status report regarding Baker Elementary School

District Court, Joshua intervenors' requests for admissions propounded to Supt. Les Carnine; District Court, Joshua intervenors' interrogatories and requests for production of documents propounded to Supt. Les Carnine; District Court, order; District Court, motion for withdrawal as counsel; District Court, plaintiff's second set of interrogatories and requests for production to the Joshua intervenors regarding Joshua's objections to unitary status; District Court, order; District Court, entry of appearance; District Court, Joshua intervenors' revised requests for admissions propounded to Supt. Les Carnine; District Court, Joshua intervenors' requests for admissions to Superintendant James; District Court, status report regarding Baker Elementary School; District Court, Joshua intervenors' motion for definition and clarification of the issues and for other relief; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, order This transcript was create using Optical Character Recognition (OCR) and may contain some errors. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. 4: 82CV00866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNJGHT, ET AL. !,,.t ~ '\ ) RECEIVED SEP 2 8 2001 lJfflCE OF DESEGREGATION MONITORJNQ PLAINTIFF DEFENDANTS INTER VEN ORS INTER VEN ORS JOSHUA INTERVENORS REQUESTS FOR ADMISSIONS PROPOUNDED TO SUPT. LES CARNINE Come now the Joshua Intervenors, by and through undersigned counsel, for their Request for Admissions Propounded to Superintendent Les Carnine, as Chief Compliance Officer regarding Little Rock School District's compliance with the Revised Desegregation and Education Plan, state as follows: REQUEST FOR ADNfISSION NO. 1: You did not establish a committee of staff members to regularly meet with the Joshua Intervenors in order to discuss compliance issues. REQUEST FOR ADNfISSION NO. 2: You represented to the public meeting Little Rock School District Board of Directors and the Joshua"Intervenors that the commitments of Revised Desegregation and Education Plan. REQUEST FOR ADNfISSION NO. 3: You did not ask the Arkansas Department of Education to assist the Little Rock School District in meeting its obligations under the Revised Desegregation and Education Plan between March, 1998 and March, 2001. 1 REQUEST FOR ADl\lllSSION NO. 4: There is no writing from you which reflects that you requested the Arkansas Department of Education to monitor the Little Rock School District's compliance with the Revised Desegregation and Education Plan. REQUEST FOR ADl\lllSSION NO. 5: You and District counsel, Christopher Helle.c requested the Arkansas Department of Education to forgive the Little Rock School District's indebtedness to the Arkansas Department of Education of the 20 million dollar loan. REQUEST FOR ADl\lllSSION NO. 6: You and District counsel, Christopher Heller represented to the Department of Education Director, Ray Simon, that the Joshua Intervenors approved the District's efforts to obtain loan forgiveness. REQUEST FOR ADl\lllSSION NO. 7: You and District counsel, Christopher Heller represented during the negotiations with Arkansas Department of Education on loan forgiveness that you and counsel Heller were authorized to represent the interest of the Joshua Intervenors. REQUEST FOR ADl\lllSSION NO. 8: The subject ofloan forgiveness was inappropriate for the Little Rock School District Board of Direc!?rs to address in an executive session under the Arkansas Freedom oflnformation Act. REQUEST FOR ADl\lllSSION NO. 9: The Little Rock School District Board of Directors never passed a motion or resolution regarding the District 's requested loan forgiveness to Arkansas Department of Education. REQUEST FOR ADl\lllSSION NO. 10: Neither you nor the the Little Rock School District Board of Directors ever determined in a public meeting of the Board that the remediation . of achievement disparitiys as contemplated by the original Settlement Decree and the rulings of the Court of Appeals was impossible to achieve. 2 REQUEST FOR ADMISSION NO. 11 : The Ombudsperson did not have any role in the development of policies, programs or procedures with respect to the Revised Desegregation and Education Plan. Respectfully submitted, John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 (501) 374-3758 (501) 374-4187 (fax) By~nf-~ CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been mailed, postage prepaid to the following counsel of record, p~th is ~ day of September, 2001 . Mr. M. Samuel Jones, III "~ Mr. Christopher Heller Wright, Lindsey & Jennings Friday, Eldredge & Clark 200 West Capitol Avenue 400 W. Capitol, Suite 2200 Suite 2200 Little Rock, Arkansas 72201 Little Rock, Arkansas 72201-3699 Ms. Ann S. 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 72222-73 88 3 Mr. Stephen W. Jones Jones; Lyon & Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Mark Hagemeiemr Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 4 J IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. 4:82CV00866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. RECEIVED SEP 2 8 2001 OFFICE OF DESEGREGATION MONITORINQ JOSHUA INTERVENORS INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS PROPOUNDED TO SUPT. LES CARNINE ~t41.Ul.. RECEi E. SEP 2 8 200\ OFFICE OF DESEGREGATION MONITORIN~ PLAINTIFF DEFENDANTS INTER VENO RS INTERVENORS Come now the Joshua Intervenors, by and through undersigned counsel, for their Interrogatories and Requests for Production of Documents Propounded to Superintendent Les Carnine, as Chief Compliance Officer regarding Little Rock School District's compliance with the Revised Desegregation and Education Plan, state as follows: INTERROGATORY NO. 1: State the contemplated involvement of the Joshua Intervenors in the development of policies, programs and procedures with respect to the Revised Desegregation and Education Plan. INTERROGATORY NO. 2: Was the contemplated involvement referred to in_ Interrogatory No. 1 reduced to writing? If so, attach a copy of such writing and proof that such writing was delivered to Joshua Intervenors' counsel. INTERROGATORY NO. 3: If you contend that the identified writing, if any, is included 1 within the Revised Desegregation and Education Plan, please specify the pages and paragraphs thereof which reflect the contemplated involvement of the Joshua Intervenors. INTERROGATORY NO. 4: What was the contemplated involvement of Dr. Terrence Roberts and Dr. Steve Ross with respect to the development of policies, programs and procedures as contemplated by the Revised Desegregation and Education Plan. Was that contemplated involvement reduced to writing and shared with Joshua counsel or anyone else? INTERROGATORY NO. 5: Specify by number or letter, or both, each policy, program or procedure that was developed in fulfillment of the commitments of the Revised Desegregation and Education Plan. Please attach copies of each such policy, program or procedure in response to this interrogatory. INTERROGATORY NO. 6: Please state whether the Joshua Intervenors' counsel sought to be involved in the compliance committee activities. Do you have any writings which reflect such effort and your responses to same? Please attach copies of both. INTERROGATORY NO. 7: Did you create a written de_~egregation compliance program which included standards identified on pages 19 and 20 of the revised plan. If so, please state how the compliance program was implemented identifying the person or persons responsible for its implementation, the date they were appointed to the position and whether these persons were members of the District staff Also please identify all compliance standards that were adopted for student achievement, discipline, and evaluation of programs identified in the revised plan. Also identify the person or persons responsible for monitoring implementation of the compliance standards, the date he/she (or they) were appointed to the position and whether these persons were members of the District staff. 2 INTERROGATORY NO. 8: In your opinion, does the Compliance Plan contemplate periodic monitoring reports to be developed by LRSD staff regarding the implementation of the Revised Desegregation and Education Plan. If so, please state whether you and/or members of your staff produced any monitoring reports regarding the District's implementation of the Revised Desegregation and Education Plan. INTERROGATORY NO. 9: Were you made aware by Joshua Intervenors' counsel that Dr. Bonnie Lesley, Assistant Superintendent for Instruction, was constructing a plan which upon implementation would result in a set of in-school racially segregated class assignment programs? Please state the date you were so informed and what actions you took in response to those suggestions. INTERROGATORY NO. 10: Were you aware of the professional conflicts regarding - implementation of the revised plan, remediation of achievement disparities and program evaluation which existed between Dr. Bonnie Lesley and other staff members, notably, Dr. Kathy Lease, Ms. Sadie Mitchell, Mr. Junious Babbs and Dr. Marion I:.acy? If so, please describe in detail each of those conflicts and duration of each and what steps you took to remedy them. INTERROGATORY NO. 11: Was the District, in your opinion, obliged to maintain lower teacher pupil ratios in the former Incentive schools than in the more racially mixed schools. If so, please set forth any policies, programs and procedures which reflect that obligation. Also state whether the District was obliged to maintain greater resources of staff, materials, and programs in the former Incentive schools than in the other schools. INTERROGATORY NO. 12: In your opinion was the District obliged to develop policies, programs and procedures by which to remediate the academic achievement as that 3 existed between African American children in a class and other children. If so, please provide writings of each policy, program and procedure that was specifically developed to address remediation of African American students. INTERROGATORY NO. 13 : Were you aware of any racial disparities that existed in the LRSD during your tenure n the LRSD during your tenure? Please identify each disparity and what actions you specifically took to address each disparity by date, action taken, activities involved and any meetings which reflect that action. 1) INTERROGATORY NO. 14: Did you ever inform the ADE of any actions of the District which had a disparate impact upon African American students? Were you aware that the State of Arkansas was obliged to monitor the disparities referenced to above and to comply with the terms of what is known as the "Allen" letter. INTERROGATORY NO. 15: With respect to the loan forgiveness discussions with the ADE, please state in full detail who was involved in the negotiations, the dates, the positions that were taken by each participant. State whether Joshua counsel ~as involved with State counsel where negotiations took place with respect to loan forgiveness. Identify the Arkansas State Senators by name and residence and officials of the ADE who were involved in the loan forgiveness. INTERROGATORY NO. 16: Please state the involvement of Dr. Steven Ross and Dr. Terrence Roberts with respect to the subject ofloan forgiveness. Also state Drs. Ross and Robert's positions regarding loan forgiveness and how you obtained that knowledge. INTERROGATORY NO. 17: Did any LRSD board member request for you to seek loan forgiveness in a public meeting? If so, state the name of the board member and state the date of 4 such request. INTERROGATORY NO. 18: Did you have private meetings with board members in order to obtain authority for your negotiations with the ADE regarding the loan forgiveness. If so, identify the Board members, date of the private meetings, places where the meetings were held and attach any notes you made regarding those private meetings. INTERROGATORY NO. 19: Did you ever inform the Joshua Intervenors that you and the Board were going to address the subject of loan forgiveness with the ADE. If so, please j identify each writing that was exchanged between you and/or Mr. Chris Heller and each of the other parties to the private meetings which were held about the subject of the AD E's loan forgiveness regarding the LRSD. REQUEST FOR PRODUCTION NO. 1: Please attach a copy of each identified writing in response to each of the preceding interrogatories, numbered -I through 19. INTERROGATORY NO. 20: State how the District informed students of the Ombudsperson, his availability and role with respect to student ~iscipline and parent and student complaints of race based mistreatment. INTERROGATORY NO. 21 : Please explain whether the Ombudsperson was to have an ongoing relationship with the Joshua Intervenors with respect to investigating parent and student race based complaints in all areas of school operations? If the Ombudsperson was not the individual to investigate and address parent and student complaints of race based mistreatment, please identify the person or persons to whom these complaints were to be referred. INTERROGATORY NO. 22: State the amount-of the District's budget that was used for implementation of Sections 2.5 through 2.5.4 of the Revised Desegregation and Education Plan 5 identifying the amount for each section INTERROGATORY NO. 23 : Did you or some other person or persons designated by you specifically implement compliance standards in order to comply with Sections 2.5 through 2.5.4 of the Revised Desegregation and Education Plan. If so, what are those standards and where can they be found. INTERROGATORY NO. 24: State the amount of the District's budget that was used for implementation of Sections 2.7, 2.7.1 and Sections 5.1 through 5.5 of the Revised Desegregation and Education Plan identifying the amount for each section. INTERROGATORY NO. 25: Did you some other person or persons designated by you specifically implement compliance standards in order to substantially comply with Sections 2.7, 2. 7 .1 and Sections 5. I through 5. 5 of the Revised Desegregation and Education Plan. If so, what are those standards and where can they be found. INTERROGATORY NO. 26: Did you, any member of your compliance committee or any other person designated by you determine any area of noncompl~ance at any time during the term of the Revised Desegregation and Education Plan. If so, state the area of noncompliance, the date it was detected and all reasonable steps taken you, members of the compliance committee or any other person designated by you to correct the noncompliance and to prevent further noncompliance. Finally, jf you indicate that a compliance program was developed and implemented, please also advise whether modifications were ever made to the program. REQUEST FOR PRODUCTION NO. 2: Please attach a copy of each identified writing in response to each of the preceding interrogatories, numbered 20 through 26. Respectfully submitted, 6 ' I I~ .e John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 (501) 374-3758 (501) 374-4187 (fax) By:~'~-~ CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been mailed, postage prepaid to the following counsel of record, ~ t~ay of September, 2001. Mr. M. Samuel Jones, III ~ Mr. Christopher Heller Wright, Lindsey & Jennings ..., l Friday, Eldredge & Clark 200 West Capitol Avenue 400 W. Capitol, Suite 2200 Suite 2200 Little Rock, Arkansas 72201 Little Rock, Arkansas 72201-3699 Ms. Ann S. 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 7 Mr. Stephen W. Jones Jones, Lyon & Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Mark IJagemeiemr Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 u.frJJRl~QR EASTERN DISTRICT ARKA~SAS IN THE UNITED STATES DISTRICT COURT SEP 2 6 2001 EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION ~A_MES{/ ~RMACK, '7rERI y. l \ l [\ /\A A DEPCLERJ LITTLE ROCK SCHOOL DISTRICT PLAINTIFF vs. 4:82CV00866 SWW NORTH LITTLE ROCK SCHOOL DISTRICT, ET AL MRS. LORENE JOSHUA, ET AL MRS. KATHERINE KNIGHT, ET AL RECEIVED SEP 2 8 2001 UFFICE OF DESEGREGATION MONITORING 0 RD ER DEFENDANTS INTERVENORS INTERVENORS Before the Court is Little Rock School District's motion for contempt against John Walker . A hearing on this issue is hereby scheduled for Tuesday, October 16, 2001, at 9:00 a.m. The deadline for the mutual exchange of witness and exhibit lists shall be no 1ater than October 5, 2001. If the parties desire the Court to examine any documents pertaining to this hearing, those documents shall be submitted to the Court no 1ater than noon on October 12, 2001. The Court advises counsel that it will not be available to conduct this hearing beyond October 16, 2001. IT IS SO ORDERED this o4(;~day of September, 2001. SUSAN WE~GHT Chief United States District Judge :3 5 0 7 , . RECEIVED - SEP 2 7 2001 OFFICE OF \lESEGREGATION MONITORING STATE OF ARKANSAS OFFICE OF THE ATTORNEY GENERAL Mark Pryor Attorney General M. SamuelJones, IIl Wright, Lindsey & Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 72201 John W. Walker John Walker, P.A. 1 723 Broadway Little Rock, AR 72201 September 26, 2001 Ann Marshall Office of Desegregation Monitoring 124 W. Capitol, suite 1895 Little Rock, AR 72201 Richard Roachell P.O. Box 17388 Little Rock, AR 72222-7388 Sammye I. Taylor Assistant Attorney General Direct dial: (501) 682 -1320 Direct Facsimile: (501) 682-2591 E-mail: SarnmyeT@ag.state.ar.us 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 Re: LRSD v. PCSSD; USDC; 4:82CV866SWW Dear Counsel: I have transferred from the Civil Department to the Medicaid Fraud Unit of the Office of Attorney General, and am therefore filing a motion to withdraw as counsel ofrecord in the captioned case. The file remains with Assistant Attorney General Mark Hagemeier for further handling. Thank you. SLT/ale Enclosure Cordially yours, Chief Barrister 323 Center Street Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 FAX (501) 682-2591 Internet Website http ://www.ag.state.ar.us/ 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. MOTION FOR WITHDRAW AS COUNSEL RECEIVED SEP 2 7 2001 OFFICE Of DESEGREGATION MONITORING PLAINTIFF DEFENDANTS I, Sammye L. Taylor, hereby move to withdraw my appearance as counsel on behalf of separate defendant Arkansas Department of Education in the above-captioned matter. Please allow Assistant Attorney General Mark A. Hagemeier of the Office of the Attorney General to serve a counsel ofrecord. WHEREFORE, I, -Sammye L. Taylor, 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. Respectfully Submitted, / BMys.ia:mm&yeLay1.cr~#831~ Chief Barrister 323 Center Street, Suite 200 Little Rock, AR 72201-2610 (501) 682-1320 CERTIFICATE OF SERVICE I, Sammye L. Taylor, certify that on ~of September, 2001 , I caused a copy of the foregoing document to be served by U.S. mail, postage 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 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Richard Roachell P.O. Box 17388 Little Rock, AR 72222-7388 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 Marshall Office of Desegregation Monitoring 1 Union National Plaza 124 W. Capitol, suite 1895 Little Rock, AR 72201 ~-~ sammyeL.Tay 2 IN THE UNJTED 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 RECEIVED OCT 1 2001 OFflCr: Or DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTER VEN ORS INTERVENORS PLAINTIFF'S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION TO THE JOSHUA INTERVENORS REGARDING JOSHUA'S OBJECTIONS TO UNITARY STATUS > Comes the Plaintiff, Little Rock School District ("LRSD"), and submits the following Interrogatories and Requests for Production to be answered within thirty days in accord with Rules 33 and 34 of the Federal Rules of Civil Procedure. GENERAL DEFINITIONS AND INSTRUCTIONS (A) "you" or "your" Shall mean the Joshua Intervenors' LRSD class representative and counsel for the Joshua Intervenors and any person (as defined below) acting on their behalf; (B) "person" Shall mean any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, and other such entities; (C) "communicate" or "communication" Shall mean every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of information whether orally or by document or whether face to face, by telephone, mail, personal delivery, or otherwise; (D) "document" Shall mean any original written, typewritten, handwritten, printed or recorded - material, as well as all tapes, disks, non-duplicate copies and transcripts thereof, now or at any time in your possession, custody or control; and, without limiting the generality of the foregoing definition, but for the purposes of illustration only, "document" includes notes, correspondence, memoranda, business records, diaries, calendars, address and telephone records, photographs, tape recordings, videotapes and financial statements. Without limitation of the term "control" as used in the preceding sentence, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person or a public or private entity having actual possession thereof. If a document that is responsive to a request for identification or production is in your control, but is not in your possession or custody, identify the person with possession or custody. If any document that is responsive to a request for identification or production was, but is no longer, in your possession or subject to your control, state what disposition was made of it, by whom, and the date or dates or approximate date or dates on which disposition was made, and why; (E) "identify" (i) As to a person (as defined), shall mean the person's name, business and residence address( es), occupation, job title; and, if not an individual, state the type of entity and the address of its principal place of business; (ii) As to a document, shall mean the type of document (letter, memo, etc.) the identity of the author or originator, the date authored or originated, the identity of each person to whom the original or copy was addressed or delivered, the identity of such person known or reasonably believed by you to have present possession, custody, or control thereof, 2 and a brief description of the subject matter thereof, all with sufficient particularity to request - its production under Rule 34 of the Federal Rules of Civil Procedure; (iii) As to a communication, shall mean the date of the communication, the type of communication (telephone conversation, meeting, etc.), the place where the communication took place, the identity of the person who made the communication, the identity of each person who received the communication, and of each person present when it was made and the subject matter discussed; (F) "Pertaining to" Shall mean constituting, embodying, ansmg out of, incident to, referring to, mentioned, bearing upon, reflecting, evidencing, affecting, concerning, providing evidence for, or relating to the transaction, individual, entity, act, object, conference, contention, communication, allegation or activity identified; (G) To "describe in detail" Shall mean to provide with respect to any act, occurrence, transaction, event, statement, communication or conduct (hereinafter collectively, "act") all facts concerning any such act known to Plaintiffs after due inquiry, including but not limited to a description of each act, the date, the location, and the identify of each person involved; (H) "or" shall be construed either conjunctively or disjunctively to bring within the scope of these Interrogatories any information which might otherwise be construed to be outside their scope; The singular includes the plural number, and vice versa. The masculine includes the feminine and neuter genders. The past tense includes the present tense where the clear meaning is not distorted by change of tense. 3 If you do not answer any Interrogatory or Request for Production because of a claim - of privilege, set forth the privilege claimed, the facts upon which you rely to support the claim of privilege, and identify all documents for which such privilege is claimed. INTERROGATORY NO. 1: Please identify all persons who participated in the preparation of the responses hereto. INTERROGATORY NO. 2: Please identify all persons you intend to call as a witness at the hearing set for November 19 and 20, 2001. INTERROGATORY NO. 3: Please identify all documents you intend to introduce as an exhibit at the hearing set for November 19 and 20, 2001. REQUEST FOR PRODUCTION NO. 1: Please produce all documents identified in the preceding interrogatory. INTERROGATORY NO. 4: Please identify and describe in detail all communications between you and persons in any way cC>nnected to the National Science Foundation pertaining to LRSD's National Science Foundation Grant. REQUEST FOR PRODUCTION NO. 2: Please produce all documents pertaining to communications between you and persons in any way connected to the National Science Foundation pertaining to LRSD's National Science Foundation Grant. INTERROGATORY NO. 5: Please identify and describe m detail all communications between you and Dr. Terrence Roberts pertaining to LRSD's compliance with its Revised Desegregation and Education Plan. REQUEST FOR PRODUCTION NO. 3: Please produce all documents pertaining to communications between you and Dr. Terrence Roberts pertaining to LRSD's Revised Desegregation and Education Plan. 4 INTERROGATORY NO. 6: Please identify and describe in detail all 9 communications between you and Dr. Steven Ross pertaining to LRSD's compliance with its Revised Desegregation and Education Plan. REQUEST FOR PRODUCTION NO. 4: Please produce all documents pertaining to communications between you and Dr. Steven Ross pertaining to LRSD's Revised Desegregation and Education Plan. INTERROGATORY NO. 7: For each expert witness that you may call as a witness at the hearing set for November 19 and 20, 2001, please provide a complete statement of all opinions and the basis and reasons therefor; identify and describe in detail the documents, communications, data or other information considered by the witness in forming the opinions; provide the qualifications of the witness, including a list of all publications authored by the witness withing the preceding ten (10) years; provide the compensation to be paid for investigation and testimony; and provide a listing of all other cases in which the witness has testified as an expert at trial or by deposition within the preceding four ( 4) years. REQUEST FOR PRODUCTION NO. 5: Please produce all documents identified in the preceding interrogatory. REQUEST FOR PRODUCTION NO. 6: Please produce all contemporaneous time records maintained by you pertaining to your monitoring ofLRSD's implementation of the Revised Desegregation and Education Plan. INTERROGATORY NO. 8: Please identify and describe in detail all information provided to you by LRSD employees either anonymously or without the knowledge or 5 consent of counsel for LRSD pertaining to LRSD's compliance with the Revised 9 Desegregation and Education Plan. REQUEST FOR PRODUCTION NO. 7: Please produce all documents provided to you by LRSD employees either anonymously or without the knowledge or consent of counsel for LRSD pertaining to LRSD's compliance with the Revised Desegregation and Education Plan. INTERROGATORY NO. 9: Please identify all LRSD employees who have provided you information or documents without the knowledge or consent of counsel for LRSD pertaining to LRSD's compliance with the Revised Desegregation and Education Plan. INTERROGATORY NO. 10: Please identify and describe in detail all oral communications between you and LRSD employees since August 17, 2001 , pertaining to LRSD's Revised Desegregation and Education Plan which took place outside the presence of counsel for LRSD. INTERROGATORY NO. 11: For each Joshua monitor identified in response to Interrogatory No. 3 of Plaintiffs First Set oflnterrogatories and Requests for Production of Documents, please: (a) describe in detail all education, training and experience that you believe qualifies them to serve as monitors; (b) describe in detail all monitoring activities undertaken by them, including the dates, times and locations where monitoring occurred and the subject matter of the monitoring; and ( c) describe in detail each and every instance where the monitoring revealed what you contend was noncompliance or bad faith implementation of LRSD's Revised Desegregation and Education Plan. 6 REQUEST FOR PRODUCTION NO. 8: Please produce all documents pertaining to 9 your monitoring of LRSD's Revised Desegregation and Education Plan, including but not limited to any notes or summaries of monitoring activities. INTERROGATORY NO. 12: You allege in your response to Request for Production No. 1 of Plaintiffs First Set oflnterrogatories and Requests for Production ofDocuments that Dr. Les Carnine and Chris Heller requested that you not publish any monitoring reports. Please identify and describe in detail all communications between you and Dr. Carnine and/or Mr. Heller pertaining to your monitoring reports. REQUEST FOR PRODUCTION NO. 9: Please produce all documents pertaining to communications between you and Dr. Carnine and/or Mr. Heller pertaining to your monitoring reports. INTERROGATORY NO. 13: In your response to Interrogatory No. 8 of Plaintiffs First Set oflnterrogatories and Requests for Production of Documents, you allege that the Compliance Committee refused to share quarterly reports produced by the School Services Division, please identify and describe in detail all communications between you and any Compliance Committee member pertaining to these quarterly reports. REQUEST FOR PRODUCTION NO. 10: Please produce all documents pertaining to communications between you and any Compliance Committee member pertaining to these quarterly reports. INTERROGATORY NO. 14: In your response to Interrogatory No. 8 of Plaintiffs First Set of Interrogatories and Requests for Production of Documents, you allege that "Joshua's counsel was continually misled and misinformed by LRSD school officials including Carnine and Hellerregarding desegregation accomplishments." Please identify and describe in detail all communications between you and any LRSD official in which you were 7 misled or misinformed about LRSD's implementation of the Revised Desegregation and 9 Education Plan. REQUEST FOR PRODUCTION NO. 11: Please produce all documents pertaining to communications between you and any LRSD official in which you were misled or misinformed about LRSD's implementation of the Revised Desegregation and Education Plan. REQUEST FOR PRODUCTION NO. 12: Please produce all documents pertaining to communications between you and any LRSD employee pertaining to the semester by semester discipline statistics referred to in your response to Interrogatory No. 8 of Plaintiffs First Set oflnterrogatories and Requests for Production of Documents. INTERROGATORY NO. 15: In your response to Interrogatory No. 8 of Plaintiffs First Set oflnterrogatori