Court filings concerning ODM report, ''2001-02 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)'', LRSD motion for an immediate declaration of unitary status, and statement of material facts not in dispute

District Court, three orders; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, order; District Court, notice of filing, Office of Desegregation Management report, ''2001-02 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)''; District Court, motion for an immediate declaration of unitary status; District Court, statement of material facts not in dispute submitted in support of motion for an immediate declaration of unitary status; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, motion for extension of time to respond to Little Rock School District's (LRSD's) motion for an immediate declaration of unitary status This transcript was create using Optical Character Recognition (OCR) and may contain some errors. FILED U.S. DISTRICT COURT IN THE UNITED STATES DISTRICT COURfSTf:fW ';'STR'~T /\ 0 """" 1SAS EASTERN DISTRICT OF ARKANSAS FEB 1/ 2002 WESTERN DIVISION JAMES W, fvicCLl 1 ' K, CLERK LITTLE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * MRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors. * * * * * * ORDER Bv:=-- ......... ~~-- 01:P.CLERK No. 4:82CV00866 WRW ;Y There will be a telephone conference at 10:30 a.m. on Tuesday, February U , 2002. Lawyers for all parties should be available to participate. DATED this 10th day of February, 2002. THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITH ~LE 58 AND/OR ~yep ON ~fJ.l/0 ~ BY_..!.-~~4:---~~-- 5 7 02/13/2002 14:26 5016045137 USDC IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, * vs. PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * MRS. LORENE JOSHUA, et al., * Intervenors, * KATHERINE KNIGHT, et al., lntervenors. * * ORDER No. 4:82CV00866 WRW PAGE 01/02 The Little Rock School District (LRSD) and the Joshua Intervenors (Joshua) asked to mediate the issue of unitary status of the LRSD. I granted that request. During a telephone conference held on February 12, 2002, the State of Arkansas (State) and the Knight Intervenors (Knight) asked to be included in those mediation discussions. In response to this request, the Joshua lntervenors suggested that initial discussions take place between LRSD and Joshua, and that other parties be brought in only ifLRSD and Joshua come to a tentative agreement. Lawyers for all parties understand, of course, that any agreement between LRSD and Joshua would be binding only on those two parties, and that any agreement is subject to Court approval. 02/1 3/ 2002 14:26 50160451 37 USDC PAGE 02/02 With those limits in mind, I will permit LRSD and Joshua to pursue settlement discussions between themselves. If those two parties reach agreement, and if that agreement materially affects any other party in the case, then that party would then be brought in to the settlement talks. For the present, however, LRSD and Joshua may proceed with settlement talks without the presence of lawyers for other parties in the case. Counsel for Knight orally asked that the Knight Motion to Compel PCS SD Compliance with Plan 2000, Section F (Discipline) (docket entry# 3526) be held in abeyance. That oral motion is GRANTED. I will decide Pulaski County Special School District's Motion for Approval of Middle School Site (docket entry # 3562) on or before Friday, February 22, 2002. Any additional briefs or information on this motion should be fil~/tore 2:00 p.m,, Wednesday, February 12, 2002. IT IS SO ORDERED this } '},} day of February, 2002. 2 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION UTILE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * MRS. LORENE JOSHUA, et al., Intervenors, KATIIERINE KNIGHT, et al., Intervenors. * * ORDER No. 4:82CV00866 WRW t-'AGE 02 The Pulaski County Special School District (PCSSD) has moved for approval of a middle school site (docket entry# 3562). Specifically PCSSD, "seeks a determination by this Court that Plan 200 authorizes the construction of a new middle school within the city limits of the Town of Maumelle." The Joshua Intervenors oppose the motion on two grounds: first, that there is no justification for a new school anywhere in Pulaski County at this time; and second, that PCS SD is, in truth, requesting an advisory opinion from the Court. Of course, advisory opinions are not permissible in these circumstances. (They are rarely, if ever, proper in federal litigation.) It is undeTstatem.ent to say that this Court is not writing on a blank slate in this case. The case was filed almost twenty years ago, and the opinions of the Court of Appeals, as well as the - - -------- - - - U.J.LI\.,, various agreements of the parties are binding, not only the parties, but upon this Court. PCSSD's - current desegregation plan, Pulaski County Special School District Plan 2000 (Plan 2000), was approved March 20, 2000. It is, thus, Plan 2000 which not only guides, but controls. Plan 2000 states, in pertinent part: "An elementary school, located around 145th Street, and a middle school or junior high school in the Crystal Hill/Maumelle area will be built. The Board will address the development of a plan for new school construction during the term of this Plan if funds are sufficient, including its funding, and report its conclusions not later than 150 days after the court's approval of this Plan. Moreover, the PCSSD shall not close schools which are located in predominantly African-American areas absent reasons of compelling necessity (which does not include the opposition of white patrons to attending such schools)." PCSSD Plan 2000H(2). PCSSD concedes that it has not done required planning for a Maumelle school, but rather is waiting to "[obtain] the Court's views upon the matter [of whether Plan 2000 pennits construction of a new school within Maumelle town limits) .. .. " PCS SD directly asks this Court: "May (the PCSSD] explore and ultimately propose to this Court a middle school site located within the city limits of Maumelle'?" I am inclined to agree with the Joshua Intervenors that what PCSSD seeks is an advisory opinion on the suitability of a yet-to-be-selected site for a new middle school. The PCS SD is, of course, free to "explore" and "propose" construction of a new school in Maumelle, or anywhere else. I fmd nothing in Plan 2000 which categorically rules out a school within Maumelle town limits. On the other hand, court approval of a specific site at this stage would be inappropriate. The query posed is theoretical, and does not go to an actual controversy before this Court. I will consider a t 2 r-1-\Ut:. t:Jq motion for approval of a new school site when the issue is ripe; that is, after the PCS SD has done - the study, consultation, and analysis required by Plan 2000 and prior court orders. 1 Accordingly, the Motion for Approval of a Middle School Site is denied without prejudice; it is not yet ripe for decision. DATED this ___,r-''--- day of February, 2002. UNITED STATES DISTRICT JUDGE 1PCSSD's memorandum in support of its motion specifically notes that as of December 13, 2001 , "[the] PCSSD has not yet consulted the administrations of the Little Rock and North Little Rock School Districts, the PCSSD has not yet submitted a proposed site to its bi-racial committee for consideration, no specific site has been finalized and no recent public meetings have been held in the Maumelle and Oak Grove Communities, the District has yet to form a site selection bi-racial committee which include(sJ representative of the LRSD, the NLRSD and the Joshua Intervenors, and the [Office of Desegregation Monitoring] has not yet been specifically consulted concerning a specific site." On Wednesday, February 13, 2002, cowisel for the PCSSD notified the Court that since the Motion for Approval was filed, the PCSSD has conducted community forums in Maumelle and in the Crystal Hill area. 3 Fax 3 f- J - 01 07) lo ; HrVJJ ~ , u/)/41 fri ; )~ ~ ~ -- a J:JuJv ~ ~ {),,,___~ 3/tq /o-z- . PAGE 01 RECEIVED MAR 1 - 2002 - OFACEOF DESEGREGATION MONITORING 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. NOTICE OF FILING DEFENDANTS r~ ~ 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 February, 2002. Respectfully Submitted, MARK.PRYOR Attorney General Assistant Attorney Genera 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 February 28, 2002, 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. SamuelJones,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 One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 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 KA THERINE 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 February 28, 2002 ~~~~~1~7i~i~~ffi~~~~~~~~~~\~g~j~;~~t~~~~~g~~~hJ.$f~~t~icip't~t~aiiM~ 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. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS FILED WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS MAR - t 2002 JA~ES W. McCO~~K .By. ~K vs. * * * * No. 4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * 1vfRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors. * * * * * * ORDER RECEIVED MAR - 4 2002 OFACE OF DESEGREGATION MONITORING In preparing for hearings in this case, it would help me - and perhaps the parties as well - to have copies of all agreements related to this case which any party believes to be binding ( either on that party or on another party). I have studied the desegregation plans of the school districts, and previous court orders, but there may be other agreements or understandings between or among various parties which affect the resolution of this case. It is important that we all proceed on the same premises, and that all parties understand the obligations and promises of all other parties in the case. Within thirty days of the date of this order, each party must submit to me complete copies of all its agreements with any other party to the case, - whether previously filed or not, which touch on matters relating to the desegregation plans of any 577 - of the three school districts in this case. This is required regardless of the number of parties to an agreement. By "parties," I mean: Little Rock School District, Pulaski County Special School District, North Little Rock School District, State of Arkansas, Joshua Intervenors, and Knight Intervenors. "Relating to desegregation plans" includes, but is not limited to, issues surrounding unitary status. If an agreement or understanding relating to desegregation plans has not yet been reduced to writing, but a party believes that it is ( or may be) binding on another party, then all material terms of that agreement or understanding must be summarized in writing and submitted to me. This Order pertains to agreements between or among the parties (and not, for example, a contract with a bus company). Obviously, I already have copies of court-approved desegregation plans, so it is not necessary to include the plans themselves in your submissions. Collective bargaining agreements (and individual contracts between teachers and school districts) are exempt - from this Order, at least for the time being. If there are agreements that a party or parties believe are not covered by this Order, a fair, accurate, and brief summary of those agreements must be submitted along with the copies of the agreements which are produced. I s~ DA TED this ~-___ day of March, 2002. THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITH RULE 58 AND/O~P ON 311\0~ BY-~------ 2 ' le ' I ' I ' ' I ,e I I --I I .. I I :- ~-.- :-::.- -- -~ ;::;: u.fJLEo ' EASTERN ol~r~;gT COURT - T ARKANSAS MARO 1 2002 ~::MES W. McCORMACK . , CLERK 2001-02 ENROLLMENT AND RACIAL BALANCE IN THE LITTLE ROCK SCHOOL DISTRICT AND PULASKI COUNTY SPECIAL SCHOOL DISTRICT Melissa R. Guldin Associate Monitor March 1, 2002 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Ann S. Marshall Federal Monitor Polly Ramer Office Manager ' 1 - IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DNISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL RECEIVED MAR 1 5 2002 OFACEOF DESEGREGATION MONITORING DEFENDANTS INTERVENORS ; INTERVENORS MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL MOTION FOR AN IMMEDIATE DECLARATION OF UNITARY STATUS Plaintiff Little Rock School District ("LRSD") for its Motion for an Immediate Declaration of Unitary Status states: 1. The LRSD moves for an immediate declaration of unitary status and an end to court supervision based on its substantial compliance with the Revised Plan in accordance with Revised Plan 11, which 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 abovedescribed order shall be entered without further proceedings. 2. The LRSD reported on March 15, 2001, that it had substantially complied with the Revised Plan. See Docket No. 3410. 3. The Joshua Intervenors ("Joshua") challenged the LRSD's compliance with a limited number of Revised Plan sections. See Docket No. 3447. 4. In proceedings before the Honorable Susan Webber Wright, the Court heard five and one-half days of testimony and received 201 exhibits on the Revised Plan sections covering academic ~-~-l;rievement ( 2.7), program assessment( 2.7.1) and student discipline( 2.5 - 2.5.4). The LRSD should be granted unitary status with regard to these Revised Plan sections based on the record of those proceedings. Joshua failed to come forward with any evidence that the LRSD failed to comply with those sections or that would cast doubt on the LRSD's intent to comply with the Constitution in the future absent court supervision. 5. Additionally, the LRSD should be granted summary judgment as to all remaining Revised Plan sections with which Joshua challenged the LRSD's compliance. The discovery process revealed that Joshua has no evidence that would cast doubt on the LRSD's intent to comply with the Constitution in the future absent court supervision. As a result, there are no material factual disputes, and additional hearings are unnecessary. 6. Finally, the LRSD should be granted unitary status with regard to those Revised Plan sections to which no party filed a timely challenge to the LRSD's compliance. See Revised Plan 11. 7. The accompanying brief and the attached exhibits are hereby incorporated by reference. - WHEREFORE, the LRSD prays that an Order be entered without further evidentiary hearings granting the LRSD unitary status and releasing the LRSD from court supervision and that it be awarded all other just and proper relief to which it may be entitled. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE & CLARK Christopher Heller (#81083) John C. Fendley, Jr. (#92182) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) B ===~~~~~~~~~ Christopher 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on March 15, 2002: 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 Finn 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Ms. Ann Marshall (hand-delivered) Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Mark Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 3 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL RECEIVED MAR 1 5 2002 OFFICE OF DESEGREGATION MONITORING STATEMENT OF MATERIAL FACTS NOT IN DISPUTE SUBMITTED IN SUPPORT OF PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS MOTION FOR AN IMMEDIATE DECLARATION OF UNITARY STATUS Plaintiff Little Rock School District ("LRSD") for its Statement of Material Facts Not In Dispute Submitted in Support of Motion for an Immediate Declaration of Unitary Status states: 1. The LRSD substantially complied with its Revised Desegregation and Education Plan. 2. There is no reason to doubt the LRSD Board of Directors' intent to comply with the Constitution in the future absent court supervision. WHEREFORE, the LRSD prays that an Order be entered without further evidentiary hearings granting the LRSD unitary status and releasing the LRSD from court supervision and that it be awarded all other just and proper relief to which it may be entitled. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE & CLARK Christopher Heller (#81083) John C. Fendley, Jr. (#92182) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) 37 ..L..---::--:- B Y: t:::::;;~~~~~~~~~ 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on March 15, 2002: Mr. John W. Walker JOHNW. WALKER,P.A. 1 723 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 72222-7388 Little Rock, AR 72201 Ms. Ann Marshall (hand-delivered) Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Mark Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 ~ 3 --- IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION RECEIVED MAR 2 8 2002 OFRCEOF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT 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, 2002. Respectfully Submitted, MARK.PRYOR Attorney General Assistant Attorney Gen r 1 323 Center Street, Suite 0 Little Rock, Arkansas 72201 (501) 682-3643 Attorney for Arkansas Department of Education CERTIFICATE OF SERVICE I, Mark A. Hagemeier, certify that on March 26, 2002, I caused a copy of the foregoing document to be served by U.S. mail, postage prepaid, on the followingperson(s) at the address( es) indicated: M. SamuelJones,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 One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 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 KA THERINE 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 March 29, 2002 ll&IJ.il1f.illf illl1l~ll$.if.llii;1;,1~?jrlli;111~~\f ,9 rnt~tf;JfiJ 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. RECEIVED MAR 2 8 2002 OFACE OF , DESEGREGATION MONITORING ~- ,_,,<~ ., - - . IN THE UNITED STATES DISTRICT C'Ol:JR'L - - ,,. EASTERN DISTRICT OF ARKANSAS --------.. WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. 4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. Jv.lRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PLAINTIFF DEFENDANTS INTERVENORS 4r:~= INTER VENO RS MOTION FOR EXTENSION OF TIME TO RESPOND TO LRSD'S MOTION FOR AN IMMEDIATE DECLARATION OF UNITARY STATUS Come the Joshua Intervenors, by and through undersigned counsel, John W. Walker, P.A., and respectfully move the court for an extension of time for thirty days in which to respond to Plaintiff's Motion for An Immediate Declaration of Unitary Status. Joshua respectfully states: 1. Due to counsel's previous commitments, the unexpected filing of the Plaintiff, the pending requirements imposed upon the parties by the Court and the length and substance of said motion, Joshua needs the requested time in order to prepare a response thereto. 2. Counsel for the Little Rock School District, Mr. Chris Heller, has authorized undersigned counsel to indicate to the Court that the Plaintiff, LRSD, does not object to the requested extension. WHEREFORE, the Joshua Intervenors respectfully pray that the Court enter an order extending the time which to respond up and including April 18, 2002. Respectfully submitted, John W. Wallcer, P.A. 1723 Broadway Little R9i::k, AR 72206 501-374-3758 501-374-4187 (fax) CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing Motion has been sent to all counsel of record via Ullited States mail poitage prepai~~ 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.