Court filings regarding motion of the Little Rock School District (LRSD) to be released from further supervision and monitoring of its desegregation efforts, Arkansas Department of Education (ADE) response to Court's order, Joshua intervenors' and LRSD's exhibit and witness list, and Arkansas Department of Education (ADE) project management tool.

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<dcterms_description>Court filings: District Court, the Joshua intervenors' opposition to the motion of the Little Rock School District (LRSD) to be released from further supervision and monitoring of its desegregation efforts; District Court, the Joshua intervenors' memorandum in support of their opposition to the motion of the Little Rock School District (LRSD) to be released from further supervision and monitoring of its desegregation efforts; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) response to Court's order of April 19, 2004; District Court, the Joshua intervenors' exhibit list and witness list; District Court, Little Rock School District (LRSD) witness list and exhibit list; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool This transcript was create using Optical Character Recognition (OCR) and may contain some errors. . ., . C,\ t,(A,~ - t: JWR... APR 15 200, IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAAMES W. McCORMACK. CLERK WESTSRN DIVISION By~ 5Epc(]Al( LITTLE ROCK SCHOOL DISTRICT V. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. LR-C-82-866 RECEIVED . APR 1 9 2004 OFFICE OF DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The Joshua Intervenors' Opposition to the Motion of the LRSD to Be Released from Further Supervision and Mon'i taring of Its Desegregation Efforts The "LRSD has [not] substantially complied with [Plan] Section 2. 7 .1, as specified in [the court's] Compliance Remedy." [Mem. Opiri., September 13, 2002, at 172] Therefore, the LRSD must continue to be subject to further supervision and monitoring of its implementation of the court-ordered remedy, until it demonstrates substantial compliance with that remedy. The LRSD motion should be denied apd supervision and monitoring should continue for a minimum of two additional years. 1 The Int.ervenors' Opposition is based upon record in the case, the accompanying memorandum, and evidence (including expert 1This two year period of time will afford the LRSD the minimum time it needs to achieve compliance with tne remedy; and, as well, give the Joshua Intervenors and the ODM the time to determine whether compliance is not merely transitory. 1 I i I l . i I I i l i testimony) and arguments to be submitted at the hearing scheduled - by the court. iRenvsr ~ ... Ro ert Pressman . 22 Locust Avenue Lexington, MA 02421 781-862-1955 Mass, 405900 Elaine R. Jones President &amp; Director-Counsel Norman Chachkin Theodore Shaw NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street New York, NY ,. 10013-28 97 212-965-2200 2 o Walker 'ckey Hicks ohn W. Walker, P.A . 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing has been served on all counsel of record on this 15th day of April, 2004 by placing a copy of same in the United States mail postage prepaid. 3 (J ' tr ~ - FILED ' c.ao-Jl;!_.,DISTRICT COURT ~ -. ..,..., s::rv11 DISTRICT ARKANSAS IN THE UNITED STATES DISTRICT COURT APR 15 2004 EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION JAMES W. McCORMACK, CLERK By . DEPCLERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. PULASKI COUN~Y SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. LR-C-82-866 RECEIVED APR 1 9 2004 OFFICE OF DESEGREGATION MONITORING DEFENDANTS INTERVENORS INTERVENORS The Joshua Intervenors' Memorandum in Support of Their Opposition to the Motion of the LRSD to Be Released from Further Supervision and Monitorina of Its Deseareaation Effo~ts The "LRSD has [not] substantially complied with [Plan] Section 2. 7. 1, as specified in [the court's] Compliance Remedy" [Memorandum Opinion, September 13,2002,at 172, para. F]. Therefore, the LRSD must continue to be subject to further supervision and monitoring of its implementation of the court-ordered remedy, until it demonstrates substantial compliance with that remedy. The retention of jurisdiction should be for a new period of two school years. This court's September, 2002 opinion identified the purpose of Section 2.7.1, the importance of substantial compliance with its terms, and the capacity which the LRSD must demonstrate as one element of its burden to justify the termination of the court's 1 / ,.. supervision. This court wrote: I find that the purpose of 2.7.1 was to make sure that the programs under 2. 7 actually worked to improve the academic achievement of African-American students. I further find that LRSD's substantial compliance with 2.7.1 was crucial to its commitment to improve the academic achievement of African American students; for, without performing a rigorous annual assessment of each of the many dozens of programs implemented under 2. 7, it would be impossible to determine which programs were working and should be continued and which programs were not working and should be discontinued, modified, or replaced with new programs [at 150; emphasis in original] . I conclude that the court should continue supervision and monitoring of LRSD's compliance with this crucially important section of the Revised Plan in order to ensure that LRSD has in place an effective assessment program that will allow it to identify and improve those programs that are most effective in rernediating the academic achievement of African American students. [at 168] These elements of the court's opinion help to frame the issues presented by the Joshua Intervenors' opposition to the LRSD motion. A. The Lack of the Capacity of the LRSD to Perform the Requisite Assessments and Evaluations (1.) For the reasons set forth in paragraphs 2 . through 14, the LRSD has failed to "[demonstrate] that a program assessment procedure is in place that can accurately measure the effectiveness of each program implemented under Section 2. 7 in improving the academic achievement of African-American students: . [ "Compliance Remedy," Mem. Opin., at 170; see also id. at 168) (2.) In its ruling of September 13, 2002, the court cited the recognition of the school board and upper echelon administrators that the LRSD had been without the capacity to . prepare what the court termed "in-depth and analytic program evaluations." [Mem. 2 / ,J' , 1' ' Opin. at 156; see id. at 153 (Dr. Lesley ) ; at 156-57 (school - board); at 157 (Superintendent Carnine)]; at 159 (Dr. Lesley)]. (3.) Subsequent to the court's entry of the Compliance Remedy, the LRSD has continued to have an inadequately staffed evaluation/assessment unit. [ODM report, March 30, 2004 at 2, 16] (4.) In its opinion of September 13, 2002, the court found that the LRSD had identified "many dozens of programs [as] implemented under Section 2. 7 [of the agreed upon Plan] II [Mem. Opin. at 150] The Compliance Remedy provides in part as follows: A. For the entire 2002-03 school year and the first semester of the 2003-04 school year, through December 31, 2003, LRSD must continue to assess each of the programs implemented under Section 2.7 to improve the academic achievement of AfricanAmerican students. [Mem. Opin. at 170; emphasis added] Nevertheless, despite inquiries from ODM , the LRSD has not even - identified, with clarity, the programs which it deems to be subject to this mandate (much less provided evidence of the assessment or evaluation of each program). [ODM report, March 30, 2004 at 23.] (5.) In the light of the court's opinion [Mem . Opin. at 151- 152; 153; 156-158], the LRSD properly concluded that it must each year, among other things, complete several compreh~nsive evaluations of key parts of the curriculum "designed to improve and remediate the academic achievement of African-American students . " [Plan Section 2. 7] 1 (6. ) On October 10, 2002, the LRSD school board adopted Regulation IL-Rl titled "Program Evaluation Agenda.". The regulation 1 . LRSD Compliance Plan, filed March 14, 2003, at 7. 3 / sets forth standards and procedures for program evaluations in the - LRSD. [See LRSD Submission of March 14, 2003, Appendix l] It provides in part (at 5) that "the first meetings [of the committee responsible for evaluating a particular program] will be devoted to the following tasks . D. Agree on any necessary research questions that need to be established in addition to the question, 'Has this curriculum\instruction program been effective i .n improving and remediating the academic achievement of African-American students?' (See Policy IL, 2.7.1 of the Revised Desegregation and Education Plan, and Judge Wilson's Compliance Remedy.)" (7.) The LRSD offers as one comprehensive evaluation the "Little Rock School District Literacy Program Evaluation" authored by Dr. Steven M. Ross and others of the Center for Research in Educational Policy, University of Memphis. The LRSD approved a list of research questions for this study not including the auestion quoted in para. 6 1 identified by the LRSD as a necessary element of any evaluation to be a part of the effort to satisfy the court's Compliance Remedy. 2 Indeed,the Literacy Evaluation states (at 4): "The primary purpose of research focus was to examine the achievement of Africa:n American students in reading and language arts in the Little Rock School District." (8.) Dr. Ross prepared for the LRSD a document regarding the "Page 148" evaluations. It is titled "Guidelines for Completing Eight Progr~m Evaluations in Little Rock School District.",[filed by LRSD on March 14~ 2003] The document articulates, among others, 2 See Literacy Evaluation at 1 (research questions), at 4 (indicating that question most relevant to the Compliance Remedy was given lesser emphasis). 4 the following premise [Plaintiffs' Notice ... , March 14, 2003, at - 1]: Program evaluations that focus predominately on student achievement outcomes while lacking sufficient implementation data have reduced value due to inability to determine the nature of the 'treatment.' The study will also fail to inform policymakers about the practicality of the program, now it was used and reacted to by stakeholders, or whether and\or how it needs to be improved to impact at-risk learners. (9 .) In 2000, Dr. Ross met with the LRSD Compliance Committee. A part of the discussion is described in the ODM report, March 30, 2004, as follows (at 3): (10.) . [Dr. Ross] also describ.ed the program evaluation process, which included a classroom observation plan developed at the University of Memphis. The observations were to ensure that programs were being consistently implemented in the classrooms throughout the district .. Respectfully, the O TTr'\-"':\ 1 1 V "-.&amp;..._.,..I.. ..L. text of the Literacy Evaluation shows, consistent with its stated purpose, that it "focused] predominately on student achievement outcomes while lacking sufficient implementation data ." The description of programs is exceedingly terse and, at grade levels 10-12, almost non-existent. [Literacy Evaluatton at 10-11] It reflects no observation of classrooms by outside observers to assess ~ctual program implementation. This is the case because the funding which the LRSD provided to Dr. Ross and his Center was not sufficient to pay for classroom observation. This study can provide little help to answer the question "whether and\or how [the literacy program] needs to be improved to impact at-risk learners." ,In this regard, it is noteworthy that LRSD Regulation IL-Rl includes, as one 5 / i -l criterion for identifying evaluation topics, the following question - [at 4] : "Can the results of the evaluation influence decisions about the prograrn?"3 ( 11.) Other elements of LRSD policy IL-Rl, as well as the professional standards on which the LRSD standards drew, buttress Joshua Intervenors' contention that the Literacy Evaluation falls short of the mark when judged in the light of the objectives of the court's Compliance Remedy (i.e., conducting PROGRAM evaluations for a particular purpose.) (a.) LRSD policy IL-Rl contains the following content: Program Documentation. The program being evaluated should be described and documented clearly and accurately so that it is identified clearly. [at 3) "Program Evaluation Procedures" G:C: Write a clear description .. of the curriculum\ in3truction program that is to be evaluated, with information about the schedule of its implementation. [at 4-5) (b.) LRSD Policy IL ("Evaluation of Instructional Programs") provides that "all program evaluations will follow standards established by the National Joint Cammi ttee on Standards for Education Evaluation." Policy IL-Rl further identifies these standards; they are The Program Evaluation Standards, 2nd Edition: How to Assess Evaluations of Educational Programs (Thousand Oaks, CA: Sage Publications) . These standards include the following content in the section on "accuracy standards" [at 127-28): 3 The Literacy Evaluation does inform the LR,SD that it must determine whther it has a literacy program at grades 6-12 and, as well, assess the need to communicate the content of the program to teachers. See Evaluation at 43 (first paragraph}. 6 / STANDARD The program being evaluated should be described and documented clearly and accurately, so that the program is clearly defined. Overview It is necessary for the evaluator to gain a solid understanding of the program being evaluated, including both the way it was intended to be and the way it actually was implemented, and to convey this description to others. Failure to gain such understanding will lead to an evaluation that, when completed, is likely to be of questionable use. A valid characterization of a program as it actually was implemented will describe its unique features and component parts in order to facilitate comparisons of the program with similar programs. A good description of the program will also facilitate attempts to associate components of the program with its effects. * GUIDELINES A. Ask the client and the other stakeholders to describe orally, and, if possible, in wri ting--the intended and actual program with reference to such characteristics .as personnel, cost, procedures, location, facilities, setting, activities, objectives, natrire of participation, and potential side effects ... C. Engage independ~nt observers to describe the program if time and budget permit. D. Set aside time at the beginning of the evaluation to observe the program and the staff and participants who are involved ... (1 2 .) The LRSD provides as one comprehensive evaluation "An Evaluation of Mathematics and Science Programs in the Little Rock School District from 1998 to 2003" (December 2003 ) . The dos:;ument provides only a brief general description of the math and science programs evaluated. [at 9-10] It notes the phasing in of the program in the period 1998-1999 to 2002-03 [at 7-~], with grades 10-12 reached in the school year 200 ?. -03. [i3t. 9] The evaluation recognizes the importance of actual implemen~ation in the classroom. [at 11, 106, 107] It identifies three methods utilized 7 / to secure data on this matter, but does not report any results. [at - 11] With regard to the description of the program evaluated and its implementation, this evaluation falls short of the LRSD and professional standards cited above. Consequently, one can not determine whether the program or any component of it is responsible for any of the outcomes cited in the report. ( 13.) The weakness of the "Page 148" evaluations also evidences the lack of capacity of the LRSD to fulfill paragraphs (a) and (A) of the Compliance Remedy. [Mem. Opin. at 170-171] See infra, para. 15 and (14.) The ODM Report of March 30, 2no4, states: "Contrary to the spirit of the regulation for program evaluation, the [LRSD] literacy evaluation team's involvement was limited to tacit approval of . the evaluation plan and assisting with data - collection . " [at 16] This is a negative factor in terms of the system's developing internal capacity for conducting evaluations and assessments . B. The Preparation of the Page 148 Evaluations (15.) The LRSD did not comply in substance with the requirement of the court-ordered remedy that it [prepare] the program evaluations identified on page 148 of the Final Compliance Report . [Compliance Remedy, Mem. Opin. at 170] The evaluations filed by the LRSD on March 14, 2003 do not satisfy the sLandards for evaluations set forth in Regulation ~LRl, o~ the professional standards on which they are ~ased. See "The Joshua Intervenors' Comments on the Submission of Page 148 8 'Evaluations,'" filed April 14, 2003; ODM Report, March 30, 2004, - at 21 (citing views of Dr. Ross "that, for the most part, the evaluations of the subject programs 'were worthless'" and "that the evaluations were of little or no use to the district.") C. The Use of Evaluation and Assessment Results (16.) The LRSD provides no discussion of any use made of the results of evaluation/assessment in the science area . [ODM report, March 30, 2004 at 15] (17.) The LRSD did not use the "page 148 [evaluations]" "as part of the program assessment process, to determine the effectiveness of those programs in improving African American achievement and whether, based on the evaluations, any changes or modifications should be made in those programs." [Compliance Remedy, Mem.Opin . . Qt 171-7-2] Th:e1.-e is no suggestion of such use in either the March 14, 2003 submission or the March 12, 2004 submission of the LRSD; see also ODM report, March 30, 2004 at 22. D. The Failure of the LRSD to Provide Information ( 18.) Subsequent to the court's entry of the Compliance Remedy, the LRSD has acted in a manner to limit the availability of information about its compliance activities . (a) LRSD Policy IL-Rl ("Program Evaluation Agenda") adopted by the LRSD on October 10, 2002, provides in part (at 5) that the "team leader" for each evaluation shall G. Plan wa vs to Provide reaular oroaress reports {e.g., dissemination of meeting minutes, written progress reports, oral reoorts to the Superintendent's Cabinet an.d\or Compliance team) to stakeholders, including the Associate ' Superintendent for Instruction, the Superintendent of Schools, _the Office of Desegregation Monitoring (until Unitary Status is achieved), 9 / and the Joshua Intervenors (until Unitary Status is achieved). - Thereafter , the LRSD did not implement this provision . (b) On April 8, 2003, as part of the Section 8 process, counsel for the Joshua Intervenors directed a letter to the LRSD concerning the plan for carrying out evaluations and the provision to Joshua of information on observation of the educational program within several schools . The LRSD ignored this letter, Attachment A hereto. (c) The Joshua also discussed their concerns regarding the LRSD's implementation of the Compliance Remedy in a letter to Ms. Ann Marshall, ODM on March 10, 2004, a copy of which was provided to counsel for the school district. hereto. E . Other Factors This letter is Attachment B LRSD submissions subsequent to the court's entry of the Compliance Remedy do not show that in that period the district worked with the Arkansas Department of Education to remediate the racial academic achievement disparities which continue to exist in the LRSD. See, for example, the test data in the math-science evaluation. The LRSD did not comply with the requirements of the Pulaski . County School District Desegregation Case Settlement Agreement, March 1989 (as Revised September 28 , 1989), Section IIIF( a,c), III-G . CONCLUSTON The LRSD has neither completed adequately the products which this court required, nor demonstrated the capacity to carry on 10 adequately in the evaluation/assessment sphere without court - supervision and monitoring. Therefore, the LRSD motion should be denied and supervision and monitoring should continue for a minimum of two additional school years. Respectfully submitted, ~-tG 1"2-~~v- Robert Pressman 22 Locust Avenue Lexington, MA 02421 781-862-1955 Mass Bar 405900 Elaine R. Jones President &amp; Director-Counsel Norman Chachkin Theodore Shaw NAACP Legal . Defense- and- . Educational Fund, Inc. 99 Hudson Street New York, NY 10013-2897 212-965-2200 11 J hn W. Walk:er (./Rickey Hicks John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 / I on all a copy CERTIFICATE OF SERVICE do hereby state that a copy of the foregoing has been served counsel of record on this 15th day of April, 2004 by placing of same in the United States mail postage prepaid. f}L7l2 l&lt;)vJiw-, LI- 12 / JOHN W. WALKER, P.A. ATTORNEY AT LAW 1723 BROADWAY LITn.E ROCK, AB.KANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER OF COUNSEL. SHAWNCIDLDS ROBERT McHENRY. PA DONNA J. McHENRY 8210 HENDERSON ROAD Lrrru RocK, ARKANSAS 12210 PHONE: 1501) 372-3425 F.4.X (501) 372-3428 EMAIL: mchenryd@swbellnec Mr. Clay Fendley Friday, Eldredge.&amp; Clark 2000 Regions Center Little Rock, AR 72201 Re: LRSD Dear Clay: April 8, 2003 This letter is a follow up to the issues raised by Joshua Intervenors regarding implementation of the evaluation remedy. As you will recall, Ann Marshall has chaired two meetings on this matter. Joshua lntervenors requested that the LRSD a.dd to the matters to be the subject of full evaluation the providing of interventions for students failing to meet standards. We took the position that this area is of particular importance to the class which. we represent. We also requested that the evaluation standards be.modified to guarantee that the outside -consultant is in charge of the evaluation product for the area for which he or she is hired. We have had no respoo:')e as to whether the LRSD school board has adopted our two suggestions. Please inform us of the school board's decision on each of these matters and the date of action by the Board. At each of the meeting chaired by Ms. Marshall, we were informed by Dr Lesley about detailed reviews of teaching practices and other factors within several schools. We were.twice told that we would receive copies of the reports for these schools. We have yet to receive the reports and ask that they be provided promptly. At the second meeting, Dr. Lesley indicated that she had in mind ex~erts to recommend to work on each of the comprehensive evaluations. However, she declined at that time to identify those persons. Please inform us of the experts who have been selected to work on each of the evaluations and provide us with a copy of the curriculum vitae if we have not already been provided a copy. ff the schedule for producing the comprehensive evaluations has been changed, please provide us a copy of the revised schedule. As we are in need of deciding whether to raise any of these matters before the court, . we / Attachment A Page 2 - Letter dated April 8, 2003 would appreciate a prompt response to this letter. Sincerely, Robert Pressman cc: Ms. Ann Marshall / JOHN W. WALKER, P.A. JOHNW. WALKER SHAWN CHILDS lvis. Ann S. 1:vfarshaJl, Monitor Office ofDesegregati.on monitoring 124 West Capital, Suite 1895 Little Rock, AR 72201 A."'l'ORNEY .Af! LAW 1723 BROADWAY 1rrrLE RoCK, .ARKANsAs 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile - 371-0100 March 10, 2004 Re: Little Rock School District Dear Ms. Marshall: OF COUNSEL ROBERT McHEN-:RY, P.A.: DONNAJ. McHENRY 8210 liF.NDERSON RaAJl L1Trr.E ROCK, AElw!SAS 72210 PHONE: (501) 372-3425 F.AX (501) 372-3428 EMAIL: mchenryd@swbell.net . Now that we have the 8th Circuit Court of Appeals decision, it is very clear that the ~ourt is c.011ceri-1ed, a s ;;,.re are, about impr.uving the acadernic .achit:vement OI ...~ _Jiica!I~l...m.erica:r1 students. o.ur belief is th.at ~11 of the components oftheJ?lan were intended to work :hand in glove' to that end. When we last met with your office after having invoked the .process set forth in the Plan regarding compliance issues, there were numerous areas of disagreement with respect to the D_i.strict's obligations. Those areas have not been resolved. Moreover, we did not reach agreements on whether all pro grams as set forth in the March 15, 2001 Compliance Rep0rt were to be evaluated or which ones indeed were to be evaluated. Little Rock took the position that it would only evaluate literacy and math. We resisted that position then and we do so now because such limitation does not address the very pur_poses of the evaluations in the first place. Dr. Bonnie Lesley and Chris Heller were the District's representatives at the conference with you. Joy Springer, Bob Pressman and I (for a short while) represented Joshua. Since Dr. Lesley has left the District we have had no :further contact with anyone from the District for the purpose offollowup discussions regarding the subject. On or about January 15, 2004, I received two lengthy reports from the District entitled: 1) Little Rock Literacy Prow.am Evaluation; and 2) An Evaluation.of Mathematics &amp; Science Programs in the Little Rock Sahool District from 1998 to 2003. They were sent without explanation or an invitation for discussion. 1:vJr. Heller was aware that we had invoked the process o.utlined in the Plan and that apparently your office was awaiting more responses from LRSD before having more followup meeting between Joshua and Lit'-J.e Rock. We have received the updates you have sent the parties as, you have monitored LRSD's program evaluation. 1 1 / Attachment B We have now completed our initial review and discussion regarding those evaluations and find not only do they fail to address all of the programs that.we negotiated to be evaluated but, that inter alia, the evaluations are keyed to "No Child Left Behind" mandates or State accountability mandates. They appear to be less keyed to the explicrt outcome objectives of the plan or to the evaluation processes the district adopted in its cqmpliance plan and regulations. While Mr. Heller has contended that there are no outcome requirements of the plan, it was certainly a promised expectation that programswould be altered, modified, and improved upon their inadequacies and then nonworking programs which failed to remediate achievement disparity would be eliminated and replaced. The objective we expect is that achievement of black school children will be not less than 90% of the achievement of white school children. I believe that the program evaluations that have been presented miss their mark on many counts, some of which I now bring to your,attention as the process facilitator with a notation that these comments are also being delivered to Mr. Heller for the District's :use. These evaluations address only literacy, math and science which certainly are not all the programs that are related to improving and remediati.ng the academic achievement of African American students. I call your attention to the Court's Order of September 13, 2002, pag~ 168. I am also informing Judge Wilson of our serious concerns regarding the deficiencies of the program evaluations. Our list is not comprehensive because we need to 1) thoroughly review the evaluations, 2) have discussions via the process and the study itself and 3) have more information regarding the District's intentions. 1) Joshua remains concerned about the lack of achievement for African American students at virtually all grade levels. 2) The literacy report does not identify any significant relationship or correlation between the literacy programs implemented by LRSD and the achievement of Afiican American students. 3) Neither the literacy report nor the math/science report addressed African American student achievement by grade level, achievement by school or specific remediation mastery by student, grade level or school. None of the curricular programs in the study had a significant impact on student achievement in 5th grade, for exampie. 4) The literacy report (page 45) makes the 'surprising' notation that substantial differences exist in the overall achievement of African American students and other students in the Little Rock School District. This conclusion ii; in large part, what this action is intended to correct. Joshua interprets that notation to mean that the programs that have been utilized have :o.ot successfully addressed African American student achievement nor have they been modified or replaced by others which promise greater success. It surely cannot mean that the objective is impossiqle to attain. 2 / I 5) The control groups utilized for the literacy report raise another concern. In this report, a significant number of the students, almost half of them, in the District appear to be eliminated from the study. 6) The literacy report contains formative information through a few teacher focus groups, however, this data is not inclusive of the total teacher population responsible for remediation of African American student achievement. Therefore, Joshua must conclude that such information is skewed at best. 7) Joshua recalls the representations of Dr. Bonnie Lesley during her court testimony that the achievement gap in grades K-2 had been eliminated according to her DRA assessments during the 2001-2002 school year. The 2003 literacy evaluation submitted by the District now contradicts her :findings in that approximately half of the African American students during 2002-2003 in 4th. grade were performing Below Basic. Those second grade students would appear to be the 4th. graders now performing below basic. Surely there are sufficient data to prepare an evaluation of literacy in these grades (K-2) and for the District to be able to track their individual performances through Dr. Lesley's data. I read that the Court's Order, Page i 70, paragraph A , contemplates the use of this data, i.e., "LRSD now has over three years of testing data ..... " 8) Joshua remains concerned regarding the District's ability to accurately record, collect, retain and retrieve student achievement data. 9) There is no discussion regarding-the participation .of African.American students in Pre-AP and AP courses :which were allegedly instituted to address African American achievement. Nor is there any evaluation of the District's tutoring programs or other pro grams aimed at improving African American performance. 10) The report indicates that African American students had substantially lower absolute performance than did other students. The academic gains on literary tests were lower for African American students than for other students. The evaluations do not compare the achievement ofBencbmark exams of 4th or 8th grade students for 2001 or 2002 scoring Below Basic .in successive years. Moreover, the SAT 9 test results for higher grade students reflect a need for more information. 11) The District was inconsistent in providing the necessary support for teachers to attend necessary literacy training (Reading Recovery, Effective Literary and ELLA). . -~ 12) The evaluation reports discussed prnfessional development in literacy and mathematics while ignoring the three major professional development commitments in the March 15, 2001 compliance report. .., .J The foregoing list is merely suggestive; it is not exhaustive. Because ofyqur designated role, I am requesting that Judge Wtlson involve your office in preparing a comprehensive monitoring report of the District's compliance with its student achievement commitments by use of the evaluation process. That I believe was a role envisioned for OD.M by both the Court Of Appeals and by the District Court as well. I will be filing the necessary papers to that end, but in the meantime would you kindly advise me as to the status of our having already invoked the process set forth by the plan. TWW:js cc: Honorable Judge William R. Wilson N.fr. Chris Reller Nk Robert Pressman All Other Counsel 4 / IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS JAM FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS K LITTLE ROCK DIVISION Br,.:-t-,:......!.,J.,:.....-L.l,,.~:::::..=:~::::-== LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEIVED DEFENDANTS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. APR 21 2004 INTERVENORS OFFICE OF INTERVENORS DESEGREGATION MONITORING ORDER Please file a list of your expected witnesses and exhibits by noon, day after tomorrow, April 21, 2004. For each witness you expect to call, please set forth the amount of time you expect to spend on direct examination. If you want a conference call regarding the presentation of evidence at the hearing next week please call Ms. Mary Johnson at 501-604-5144 forthwith. IT IS SO ORDERED this / f;{ty of April, 2004. WM. R. WILSON, JR. 8 5 8 THE ATTORNEY GENERAL STATE OF ARKANSAS MIKE BEEBE RECEIVED APR 21 2004 OFFICE OF DESEGREGATION MONITORING Mark A Hagemeier Assistant Attorney General Direct dial: (501) 682-3643 E-mail: mark.hagemeier@ag.state.ar.us M. Samuel Jones, III Wright, Lindsey &amp; Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 April 20, 2004 Christopher Heller Friday, Eldredge &amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 Stephen W. Jones Jack, Lyon &amp; Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Marshall Office of Desegregation Monitoring I Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Re: Little Rock School District v. Pulaski County Special School District, et al. USDC No. LR-C-82-866 Dear Counselors and Ms. Marshall: Please find enclosed ADE's Response to the Court's Order of April 19, 2004 that we filed today. 323 Center Street Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 FAX (501) 682-2591 Internet Website http://www.ag.state.ar.us/ Page 2 of2 April 20, 2004 MAH Enclosure cc: Scott Smith (w/enclosure) Very truly yours, ~r Assistant Attorney General IN THE UNITED STATES DISTRICT COURT FILED U.S. DISTRICT COURT EASTERN OISTRICi ARKANSAS EASTERN DISTRICT OF ARKANSAS JAMi:....n11.__, K LITTLE ROCK DIVISION .B-,~~~w.:::..c....=~~= LITTLE ROCK SCHOOL DISTRICT v. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. RECEIVED APR 1 g 2004 D OFF/Cf OF ESEGREGAT/ON MONITORING ORDER DEFENDANTS INTERVENORS INTERVENORS Please file a list of your expected witnesses and exhibits by nrnn, day after tomorrow, April 21, 2004. For each witness you expect to call, please set forth the amount of time you expect to spend on direct examination. If you want a conference call regarding the presentation of evidence at the hearing next week please call Ms. Mary Johnson at 501-604-5144 forthwith. ~tf IT IS SO ORDERED this Jj!_ day of April, 2004. DNlHOllNOW NOllVD3HD3S3a ~033~~0 eAs,kG(4,~D s,R,c, xouR, RKANsAs ~DOZ 8 Z ~dV APR 2 f 1AnL JAMts ,uu, By: W. MccoRMA C3Al3~3H IN THE UNITED STATES DISTRJCT C CK, CLE Rk EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. 4:82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ET AL . . MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. THE JOSHUA INTERVENORS' EXIIlBIT LIST PLAINTIFF DEFENDANT INTER VEN ORS INTER VEN ORS The )6shua&lt;Interverio:rs rriay use tliefoliowing exmbits~dunng the hearing scheduled for ,. ':. :: ~- ...... .:.~!' ; .. :,, : - -:- ~-;::~.i.;~1: -.~::~;. ,',!-~ . . ;1~~ : . . ~:...:::, :1 r ... r . . : April 26 and 27, 2004: ,.!. : 1 1) LR.Sb Policy IL ("Evaluati&lt;?n of Instructional Programs,,J; CX 575 - 2) LRSD :Regulation IL-Rl ("Program Evaluation Agenda) 3) Text of Plan, Sections 2.7 and 2.7.1 4) Review of Ye~ Two Evaluations, Steven M. Ross, Ph.D. (Provided to Intervenors by Counsel for the LRSD, October 25, 2002) 5) Memoranda from Superintendent James to LRSD Board of Education (Prepared by Assoicate Superintendent for Instruction Bonnie A. Lesley): a) Approval of the Charter School Program Evaluation, October 24, 2002 b) Approval ofthe SEDL's Program Evaluation for the Collaborative Action Team Project, November 21, 2002 : i".,f)] ; ; ,ri : c) Approval of Program Evaluation for Southwest Middle School's Partnership with Southwest Edtic"atiori'D'evelopment Lab (SEDL\ November 21, 2002 - - " d) Campus Leadership Team Program Evaluation, February 13, 2003 e) HIPPY Program Evaluation, February 13, 2002 f) Onward to Excellence Program Evaluation, February 13, 2003 g) Campus Leadership Team Program Evaluation, February 13, 2003 h) Vital Link program Evaluation, February 13, 2003 i) Middle School Transition Program Evaluation, February 27, 2003 j) Lyceum Scholars Program Evaluation, February 27, 2003 k) Extended Year Education (EYE) Program Evaluation, February 27, 2003 1) Elementary Summer School Program Evaluation, February 27, 2003 6) Guidelines for Completing Eights Program Evaluations in LRSD, Steven M. Ross, Ph.D. (Filed by LRSD March 14, 2003) 7) Letter from Chris Heller to Ann Marshall and John W. Walker, October 27, 2003 8) Letter from Chris Heller to John W. Walker, January 12, 2004 9). LRSD Literacy Program Evaluation 10) An Evaluation of Mathematics and Science Programs in the Little Rock School District from 1998 to 2003 11) The LRSD's Implementation of the Court's Compliance Remedy, March 30, 2004 12) Resume, Walter M. Haney, Ed.D. (Professor, Lynch School of Education, Seriior Research Associate, Center for the Study of Testing, Evaluation and Educational Policy, Boston College) 13) Grade .to Grade Progression Data for LRSD and Arkansas, By Race 14) Vita, Richard C. Hunter, Ed. D. (Professor of Educational Administration and Head of the Educational Organizatien and Leadership Organization and Leadership Department. Joshua reserves the right to utilize the exhibits as listed by the defendants. Respectfully submitted, 0J 9 I 0 (kv~ t/~ f 1~ ,i1}rYVJfi'"' .. ; . , Robert Pressman i hA 22 Locust Avenue g(v Lexington , MA 02421 781 - 862 - 1955 Mass Bar 405900 Elaine R. Jones President &amp; Director-Counsel Norman Chachk.in Theodore Shaw NAACP Legal Defense and Educational Fund, Inc . 99 Hudson Str eet New York, NY 10013-2897 212 - 965-2200 ~n w( Walker /~ickey Hicks / John W. Walker, 1723 Broadway Little Rock , AR 501-374-3758 Ark . 64046 CERTIFICATE OF SERVICE P .A. 72206 I do hereby state that a copy of the foregoing has been served on all counsel of record on this 21st day of April, 2004 by placing a copy of same in the United States mail postage ' ,') I' / prepaid . .,, ~ ,, , ti~ :;f utb r,, RECEIVED uflLEO EASTERN \s\tfwcr COURT ICT ARKANSAS - APR 2 8 2004 APR 2 12004 '\MfSW OFRCEOF : McCORMACK CL DESEGREGATION MON!i0RlNG --- , ERK IN THE UNITED STATES DISTRJCT COURT EASTERN DISTRJCT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRJCT V. CASE NO. 4:82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ET AL. MRS. LORENE JOSHUA, ET AL. KATHERJNE KNIGHT, ET AL. THE JOSHUA INTERVENORS' WITNESS LIST DEPCLERK - PLAINTIFF DEFENDANT INTERVENORS INTER VEN ORS The Joshua Intervenors may call thefollowing persons as witnesses du.....:...ng the hearing scheduled for April 26 and 27, 2004: 1. Gene Jones, Office of Desegregation Monitoring - 1 hour 2. Walt Haney, Ed. D., Expert - 1 1/4 hours 3. Richard Hunter, Ed. D., Expert - 45 minutes 4. Margie Powell, Office of Desegregation Monitoring - 1 hour 5. Dennis Glasgow, Little Rock School District - 20 minutes 6. Ann Marshall, Office of Desegregation Monitoring - 20 minutes 7. Willie Morris, Arkansas Department of Education - 20 minutes 8. Morris Holmes, Interim Superintendent, Little Rock School District - 1/4 hour 9. Junious Babbs, Associate Superintendent, Little Rock School District - 15 minutes 10. Ethel Dunbar, Principal at Franklin Elementary School, L~SD - 10 minutes 11. David Smith, Principal at Southwest Middle School, LRSD - 10 minutes 12. Cassandra Norman, Principal at McClellan High School, LRSD - 10 minutes 13. Karl Brown, Assistant Superintendent, PCS SD - 5 minutes 14. Bobby Acklin, Assistant Superintendent, NLRSD - 5 minutes Joshua reserves the right to call witnesses listed by the Little Rock School District. Respectfully submitted, Pr ssman 22 Locust Avenue Lexington, MA 02421 781-862-1955 [/Rickey Hicks Mass Bar 405900 Elaine R. Jones - ..... President &amp; Director-Counsel Norman Chachkin Theodore Shaw NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street New York, NY 10013-2897 212-965-2200 John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing has been served on all counsel of record on this 21st day of April, 2004 by placing a copy of saG in the United 1hStates mail postage prepaid. _ j ~ \ I i r\l._ 1 1 \ / /\ . \.. /, (V ,V\./\J ~ ( V ; fl/jlJ ( ( t l~V . IOIO&lt;I t--'. 4 As,}!kt,('m,f D Ots-,-Rtc-,- COI.Jttr AR~'-'Si\s . APR 2 1 ,n,.L JA.MEs c.w, Sy: w. MccoRMA. IN THE UNITED STATES DISTRICT C Cl(, CLER}( EASTERN DISTRJCT OF ARKANSAS Dt:pC(ERK WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. CASE NO. 4:82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ET AL. MRS. LORENE J,?SHUA, ET AL. KATHERINE KNIGHT, ET AL. THE JOSHUA INTERVENORS' EXHIBIT LIST DEFENDANT INTER VEN ORS Thl'TERVENORS Toe Joshua Intervenors may use the following exhibits during the hearing scheduled for April 26 and 27, 2004: 1) LRSD Policy IL ("Evaluation of Instructional Programs"), CX 575 2) LR.SD Regulation IL-Rl (''Program Evaluation Agenda) 3) Text of Plan, Sections 2.7 and 2.7.1 4) Review of Year Two Evaluations, Steven M. Ross, Ph.D. (Provided to Imervenors by Counsel for the LRSD, October 25. 2002) 5) Memoranda from Superintendent James to LRSD Board of Education (Prepared by Assoicate Superintendent for Instruction Bom:rie A. Lesley): v~ i 1 a) Approval of the Charter School Program Evaluation, October 24, 2002 V,1 ~=-b) Approval oft:he SEDL's Program Evaluation for the Collaborative Action Team Project, November 21 , 2002 v ~ / ., c) Approval of Program Evaluation for Southwest Middle School's Partnership with Southwest Education Development Lab (SEDL), November 21, 2002 '- ,/ VtJ l. m d) Campus Leadership Team Program Evaluation, February 13, 2003 .,, ;9 v ~, 1. t:: e) HIPPY Program Evaluation, February 13, 2002 v~I-!!1- ) Onward to E.'Ccellence Program Evaluation, February 13, 2003 v g) Campus Leadership Team Program Evaluation, February 13, 2003 l s ~ e ,. / ) \/4 1.-u:r h) Vital Link program Evaluation. February 13, 2003 / Vo . IY- i) Middle School Transition Program Evaluation, February 27, 2003 I-fV j) Lyceum Scholars Program Evaluation, February 27, 2003 --- \/4,/ ~ k) Extended Year Education (EYE) Program Evaluation, February 27, 2003 / Vt} l. fY 1) Elementary Summer School Program Evaluation, February 27, 2003 / 6) Guidelines for Completing Eights Program Evaluations in LRSD, Steven M. Ross, Ph.D. (Filed by LRSD March 14, 2003) 7) Letter from Chris Heller to Aon Marshall and John W. Walker, October 27, 2003 / 8) Letter from Chris Heller to John W. Walker, January 12, 2004 / 9) LRSD Literacy Program Evaluation C. 1~ 6,, ,_, 10) An Evaluation of Mathematics and Science Programs in the Little Rock School District from 1998 to 2003 ( i: ,., D 11) Toe LRSD's Implementation of the Court's Compliance Remedy, March 30, 2004 f .t\D~l~"f) 12) Resume, Walter M. Haney, Ed.D. (Professor, Lynch School of Education, Senior ~ Research Associate, Center for the Study of Testing, Evaluation and Educational Policy, Boston College) 13) Grade to Grade Progression Data for LRSD and Arkansas, By Race .' 14) Vita. Richard C. Hunter, Ed. D. (Professor of Educational Administration and Head of the Educational Organization and Leadership Organization and Leadership Department. ? Joshua reserves the right to utilize the exhibits as listed by the defendants. Respectfully submitted, l ! , ! ~ST#~G'sstfo . '"''er OIJF(r ;\.q ~S,\,s APR 2 IN THE UNITED STATES DISTRICT ~~W. I /$f EASTERN DISTRICT OF ARKANSAs&gt;'~ Mccol?M-4cK. WESTERN DMSION ' CLf:Rk DepCWfRK LITI'LE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ET AL. MRS. LORENE JOSffiJA. ET AL. KATHERINE KNIGHT, ET AL. THE .JOSHUA INTERVENORS' WITNESS LIST DEFENDANT INTERVENORS INTERVENORS The Joshua Intervenors may call the following persons as v.:itncsscs d~...ng the henring scheduled for April 26 and 27, 2004: 1. Gene Jones, Office of Desegregation Monitoring - l hour 2. Walt Haney, Ed. D., Expert - 11/4 hours 3. Richard Hunter, Ed. D., Expert - 45 minutes 4. Margie Powell, Office of Desegregation Monitoring - I hour 5. Dennis Glasgow, Little Rock School District - 20 minutes 6. Ann Marshall, Office of Desegregation Monitoring - 20 minutes 7. Willie Morris, Arkansas Department of Education - 20 minutes 8. Morris Holmes, Interim Superintendent, Little Rock School District - 1/4 hour 9. Junious Babbs, Associate Superintendent, Little Rock School District - 15 minutes 10. Ethel Dunbar, Principal at Franklin Elementary School, LRSD - 10 minmes 11. David Smith, Principal at Southwest Middle School, lRSD - 1 0 minutes 12. Cassandra Norman, Principal at McClellan High School, LRSD - 10 minutes 13. Karl Brown, Assistant Superintendent, PCS SD - 5 minutes 14. Bobby Acklin, Assistant Superintendent, NLRSD - 5 minutes Joshua reserves the right to call witnesses listed by the Little Rocle School District. f . J [} . ~-J;, f&amp;~,J . irs rt ressman ry}ri"n 22 Locust. Avenue Lexington, MA 02421 781-862-1955 Mass Bar 405900 Elaine R. Jones President &amp; Directer-Counsel Norman Chachkin Theodore Shaw NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street New York, NY 10013-2897 212-965-2200 Respectfully submitted, '.__ - c:1Lrh - ;1- ohn W. Walker ~' ickey Hicks John W. Walker, P.A . 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 CERTIFICATE OF SERVICE I do hereby state that a copy cf the foregoing has been served on all counsel of record on this 21 st day of April, 2004 ;~e~!f~ing a copy of 5T\ int Ut;f:~; mail postage \ I . 1 t . r+ 0 ,__,. .-. '..!.-1 \., \..,,I) t ' V d V ;,., - - - - - - -------- ---------- THE ATTORNEY GENERAL STATE OF ARKANSAS MIKE BEEBE RECEIVED APR 21 2004 OFFICE OF DESEGREGATION MONITORING Mark A. Hagemeier Assistant Attorney General Direct dial: (501) 682-3643 E-mail: mark.hagemeier@ag.state.ar.us M. Samuel Jones, III Wright, Lindsey &amp; Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 April 20, 2004 Christopher Heller Friday, Eldredge &amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 Stephen W. Jones Jack, Lyon &amp; 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 Re: Little Rock School District v. Pulaski County Special School District, et al. USDC No. LR-C-82-866 Dear Counselors and Ms. Marshall: Please find enclosed ADE's Response to the Court's Order of April 19, 2004 that we filed today. 323 Center Street Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 FAX (501) 682-2591 Internet Website http://www.ag.state.ar.us/ Page 2 of2 April20, 2004 MAH Enclosure cc: Scott Smith (w/enclosure) Very truly yours, ~T Assistant Attorney General FIL IN THE UNITED STATES DISTRICTE.&amp;s~sTR1~'2RT EASTERN DISTRICT OF ARKANSAS N DISTRICT ARKANSAS WESTERN DIVISION APR 2 f 20()/f LITTLE ROCK SCHOOL DISTRICT ~~MES W. McCORMACK, CLERK -----~=,:JP~J~AilluNT~F DEPCU::RK V. LR-C-82-866 PULASKJ COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL RECEIVED DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL APR 2 ,' 2004 OFFICE OF DESEGREGATION MONITOfflNG LITTLE ROCK SCHOOL DISTRICT WITNESS LIST AND EXHIBIT LIST The Little Rock School District expects to call the following witnesses and present the following exhibits at the hearing scheduled to being on April 26, 2004, except Dr. Lesley, whose testimony will be presented by deposition. 1. 2. 3. 4. 5. WITNESS LIST Dr. Steven M. Ross, Director, Center for Research in Education Policy, University of Memphis - expected direct examination time - 1 hour; Dr. Bonnie Lesley, former LRSD Associate Superintendent for Curriculum and Instruction - expected direct examination time - 1 hour; Dennis Glasgow, Interim Associate Superintendent for Curriculum and Instruction - expected direct examination time - 1 hour; Dr. Ed Williams, LRSD Research Specialist - expected direct examination time -30 minutes; Krista Underwood, Director of Early Childhood and Elementary Literacy - expected direct examination time - 30 minutes; Page 1 of 4 6. 7. Suzi Davis, Director of Secondary English - expected direct examination time - 30 minutes; Vanessa Cleaver, Director of National Science Foundation Grant - expected direct examination time - 30 minutes. EXHIBIT LIST 1. Program Evaluations and Accompanying Memoranda submitted to the LRSD Board of Directors for approval on October 24, 2002, November 21 , 2002, December 19, 2002, February 13, 2003 and February 27, 2003 (These were attached to our Notice of Filing on March 14, 2003 in Volumes I - IV); 2. September 26, 2002 Program Evaluation Agenda, 2002-03; 3. October 4, 2002 letter from Clay Fendley transmitting Compliance Plan to counsel and Ms. Marshall; 4. October 10, 2002 memo to Dr. Ken James from Ann Marshall re LRSD 's Compliance Plan 5. October 10, 2002 Memo to LRSD Board from Dr. Bonnie Lesley; 6. 7. 8. 9. 10. 11. 12. 13. 14. October 11 , 2002 letter from Clay Fendley to Counsel and Ann Marshall regarding Compliance Remedy; October 17, 2002 Request for Qualifications of Revised Desegregation and Education Plan Program Evaluation Consultant; October 25, 2002 letter from Clay Fendley to Counsel and Ann Marshall; November 4, 2002 letter to John Walker and Ann Marshall from Bonnie Lesley; Guidelines for Completing Eight Program Evaluations in LRSD prepared by Dr. Ross; December 3, 2002 letter to Ann Marshall from Bonnie Lesley; December 3, 2002 letter to John Walker from Bonnie Lesley; January 27, 2003 Memo to Dr. Ken James from Dr. Bonnie Lesley regarding contracted Services - Dr.Ross; February 13, 2003 Memo to LRSD Board from Dr. Lesley regarding Information on Completion of Eight Program Evaluations for Submission to Federal Court Page 2 of 4 15. April 8, 2003 letter from John Walker to Clay Fendley; 16. Response to ODM and Joshua Objections, by Dr. Steven M. Ross; 17. Changes in Science Curriculum, by Dennis Glasgow; Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE &amp; CLARK Christopher Heller (#81083) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) 376~~9.lL- ---- -~::~~:-. -....... , -----.. &gt; B ~,,.,---q..=:&amp;4,1~2J~~:_;_f,,,c:..4+~........,,.,... Page 3 of 4 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 April 21, 2004: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey &amp; Jennings 2200 Nations Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON &amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Judge J. Thomas Ray U. S. District Courthouse 600 West Capitol Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Mark A. Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Page 4 of 4 TOM COURTWAY Interim Director State Board of Education JoNell Caldwell, Chair Lillie Rock Shelby Hillman, Vice Chair Carlisle Sherry Burrow Jonesboro Luke Gordy Van Buren Calvin King Marianna Randy Lawson B-ille MaryJane Rf."bick Lillie Rock Diane Tatum Pine Bluff Jeanna Westmoreland Arkadelphia Arkansas April 30, 2004 OFFICE Of DESEGREGATION MONITORING Mr. M. Samuel Jones, III Wright, Lindsey &amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers &amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge &amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon &amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Ms. Ann Marshall One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 RE: Little Rock School District v. Pulaski County Special School District, et al. US. District Court No. 4:82-CV-866 . Dear Gentlemen and Ms. Marshall: Per an agreement with the Attorney General's Office, I am filing the Arkansas Department of Education's Project Management Tool for the month of April 2004 in the above-referenced case. If you have any questions, please feel free to contact me at your convenience. Sincerely, :ti- m1t General Counsel Arkansas Department of Education SS:law cc: Mark Hagemeier - - ------ ---------- --- 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 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 the ADE's Project Management Tool for April 2004. Respectfully Submitted, Scott Smith, Attorney, Arkansas Department of Education #4 Capitol Mall, Room 404-A Little Rock, AR 72201 501-682-4227 CERTIFICATE OF SERVICE I, Scott Smith, certify that on April 30, 2004, I caused the foregoing document to be served by depositing a copy in the United States mail, postage prepaid, addressed to each of the following: Mr. M. Samuel Jones, III Wright, Lindsey &amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes Wagoner, Ivers &amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge &amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon &amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Ms. 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 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 April 30, 2004 Based on the information available at March 31, 2004, the ADE calculated the Equalization Funding for FY 03/04, subject to periodic adjustments. 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.</dcterms_description>

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