Compliance court orders

RECEIVED JUL - 8 2002 OFFICE OF IN THE UNITED STATES DISTRICT COURT ARKANSAS DESEGREGATION MONITORING EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION JUL 0 1 2002 JAMES 0y:^ LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER Pending is Plaintiffs Motion for a Protective Order and for Emergency Hearing. For the time being. Plaintiffs request for a protective Order against Joshua, or anyone acting on their behalf, is GRANTED. The deadline for exchanging exhibits and witnesses was set on May 15,2002, for June 21, 2002. At the request of lawyers for LRSD and Joshua, the deadline was orally extended until 5:00 p.m. on Monday, June 24, 2002. It appears, from the documents attached to Plaintiffs Motion, that Joshuas FOI request was submitted on June 26, two days after the deadline for exchanging exhibits and the names of witnesses. Even assuming the FOI can be used in addition to the Federal Rules of Civil Procedure by a party to litigation, it appears quite certain that this request was not timely. It is my impression, from a quick review of the law, that the great weight of authority precludes a party from using the FOI as a supplement to the discovery rules of the Federal Rules AO 72A (Rev.8/82)of Civil Procedure
but, be that as it may, this particular request appears to be manifestly out of time. I note in passing that many, if not most, of the documents requested in the FOI request are not pertinent to the three remaining issues in this case. Accordingly, the LRSD is relieved of any duty to respond to the FOI request by Joshua. If Joshua wants a hearing on this issue, it should file a response to Plaintiffs Motion forthwith. and request a hearingif such a request is made, a hearing will be set as soon as practicable. IT IS SO ORDERED. DATED this J day of July, 2002. UNITED STATES DISTRICT JUDGE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITHERULE 58 AND/OR 79>) FRCP BY. -2- AO72A (Rev.8/82)AO 72A (Rev.8/82) oJIaOilNaW N01iV33H03S3a 30301330 zooz 8 - inr cisAiaoau EASTeflN district nsac IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. RECEIVED MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. JUL 0 2 2002 JAMES w Ml By:. PLAINTIFF DEFENDANTS IX JUL -8 2002 INTERVENORS OmCEOF DESEGREGATION MONITORING INTERVENORS ORDER On July 1, 2002, I entered an Order (docket no. 3611) granting LRSDs request for a protective order to the extent that LRSD was relieved of its duty to respond to Joshuas FOI requests, which appeared to be untimely under the May 15, 2002 Scheduling Order (docket no. 3600). However, I permitted Joshuas counsel the opportunity to file a written response to LRSDs Motion for Protective Order and for Emergency Hearing and to request a hearing if he deemed it necessary. This morning, I received Joshuas counsels July 1, 2002 letter, a copy of which is attached to this Order. In that letter, Joshuas counsel requests me to rescind my July 1 Order, allow him an opportunity to file a written response to LRSDs Motion, and then allow either party to request a hearing. This Order responds to the various points raised by Joshuas counsel in his July 1 letter. First, my July 1 Order admittedly was entered in haste because LRSDs motion papers declared an emergency and made it clear that July 1, 2002, was the deadline for it to produce 6 1 2documents pursuant to Joshuas FOI requests. Furthermore, in LRSDs Brief in Support of Motion for Protective Order and Emergency Hearing, its counsel pointed out that Ark. Code Arm. 25-19-104 provides a potential criminal penalty (of thirty days in jail) which could flow from the LRSDs failure to respond within three days [to Joshuas FOI requests]. This time of year, jails in Arkansas are particularly uncomfortable. Therefore, I hastened to enter my Order before 5:00 p.m. on July 1, lest I place someone in jeopardy of being hauled off in chains. I want to assure counsel for Joshua that, in entering that Order, I was not vexed with counsel-somewhat or otherwise. I appreciate counsel for Joshua clarifying that the FOI requests were filed in connection with his ongoing monitoring of LRSD under the 1998 Revised Desegregation and Education Plan (the Revised Plan). This important point apparently was not communicated to LRSD, which understandably construed the FOI requests as seeking documents that Joshua intended to use in connection with the upcoming evidentiary hearing which commences on July 22, 2002. In LRSD V. PCSSD, 921 F.2d 1371,1386 (8* Cir. 1990), Judge Arnold made it clear that, in approving the 1989 global settlement of this case, the Court placed a great deal of weight on the fact that the parties have all agreed to continued monitoring, which the Court found to be essential. Likewise, Exhibit B to the Revised Plan makes it clear that Joshuas counsel will continue his monitoring of the LRSDs implementation of its desegregation obligations. By clarifying that Joshua is seeking the documents described in its FOI requests in connection with Its continuing monitoring duties, and not for use in the July 22 hearing, I believe counsel should be able to work out a satisfactory schedule for the production of the requested documents. As an aside, I believe that counsel for both sides have more than enough to do in preparing for the -2- AO72A (Rev.8/82)upcoming five days of evidentiary hearings beginning on July 22, and should not to have to concern themselves with the collection and production of a large volume of documents related to Joshuas ongoing monitoring function. It appears to me the production of those documents can and should be delayed until after the completion of the evidentiary hearings that begin in less than three weeks. In conclusion, my July 1 Order will remain in effect until after the evidentiary hearing unless counsel for Joshua can convince me that there is a need for the production of the documents described in the FOI requests before the July 22 hearing. Counsel for Joshua is allowed until and including July 8, 2002, to file a response to LRSDs Motion for Protective Order and for Emergency Hearing. LRSD can submit a short reply by 5:00 p.m. on Thursday, July 11, 2002. Thereafter, if either party requests a hearing on that Motion, the Court will likely conduct one. IT IS SO ORDER^ DATED this day of July, 2002. UNITED STATES DISTRICT JUDGE THIS DOCUMENT ENTERED ON docket sheet in compliance 58 and/or 79(a CP -3- AO72A (Rev.8/82)JUL. 1.2002 5:55PM JOHN M WALKER P A NO.521 P.2/3 JOHN W. WALKER, P.A. .'Attorney At Law 1723 Broadway LriTLB Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WAT.KP.ft SHAWN CHILDS Via Facsimile - 604-5149 July 1, 2002 OF COUNSEL ROBERT McHENKY, DONNAJ.McHENRY 8210 HxndbebonRoad Lmu Eock, Abkansas 72210 PHONE
(501) 372-3426 Fax (501) 372-3428 Email mehonrydSawbalLnat Honorable Judge William R, Wilson United States District Judge 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: Case Ne. 4
82CV0S66WRW/JTR LRSD V. PCSSD Dear Judge Wilson
I received your order dated July 1, 2002 after 5:30 p.m. when I returned to the office from trial before the Honorable George Howard, Jr., USA v. Dennis Williams and Joe Bryant. I am a surprised that the Court ruled on the matter before I had an opportunity to reply to it. I note, however, that the Court provides that opportunity to reply post hoc by the filing of a motion and requesting a hearing. The apparent premise of the Order is that the requested FOIA documents are intended for use at the trial on July 22, 2002. Moreover, the Court seems somewhat vexed with-ceunsel. I believe the Court would not be ygjtfid were I to have had a reasonable time in which to respond and to make the following explanation. Joshua has been monitoring the Districts record of compliance since the entry of the original Decree. In that role, we constantly receive concerns fiom class members about race related matters in each of the three Districts. We first seek to get the Districts information by letter. When that fails, we make a request under FOIA. The District usually responds to our letter requests unless a hearing like the one set for July 22 is approaching. Our monitoring was contemplated by the 8* Circuit and the Settlement A^eements herein. The Court has not been involved with respect to our monitoring unless the District claimed some prejudice in its trial preparation. Between 1998 and June 2001, there was not a single hearing before the Court on any matter involving LRSD that was initiated by Joshua, Furthermore, the Office of Desegregation Monitoring and Joshua have obtained information from the District in the same maimer for years. The Court has reacted in haste to a matter which is not, and will not be before it. The reaction is seen in the Courts conclusion that the requested information appears quite certain toJUL. 1.2002 5:55PM JOHN UI WALKER P A NO.521 P.3/3 be not timely. The Court seems persuaded that we did not meet the deadline for exchanging exhibits and names of witnesses. We each did so. Mr. Hellers office delivered his exhibits to us at the close of business on June 24,2002 and we returned our witness list and exhibits to Mr. Heller by his own courier. We agree with the Courts comments that the requests are not pertinent to the three remaining issues in this case as the case relates to the Districts compliance as of March 15,2001. That does not mean, however, that Joshuas monitoring ended upon the filing of the report by the District on March 15, 2001. For the foregoing reasons, I request the Court to simply rescind its Order, afford us a reasonable reply time and then allow either party an opportunity to request a hearing thereon. In that way, the burden of proof would be upon the moving party on the issue rather than having Joshua in the position of being the moving party. For the information of the Court and the other parties, a criminal jury trial in which I am counsel before Judge Howard is expected to last at least through July 8, 2002. Thank you for your attention to this matter. JWW
js cc: All Counsel of Record Cleric of the Court Si irely, ihn W. Walker Deceived JUL -8 2002 OFFICE OF ESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION :^NSAS JUL - 5 2002 JAMES W, Mc( By.----------J .RMACK, IRK EAST^R^N LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER On July 3, 2002, LRSD filed a Motion in Limine and Supporting Memorandum Brief arguing that
(1) because Joshuas witness list fails to comply with the Courts May 15, 2002 Order, Joshua should be required, on or before 5:30 p.m. on July 10,2002, to identify the date and time each of their witnesses will be called, to identify the issues on which each witness is expected to testify and to provide a detailed statement of the witnesses expected testimony on each issue
(2) certain Joshua exhibits should be excluded because they have not been provided to LRSD as required by the Courts May 15 Order
(3) Joshua should not be allowed to call Sadie Mitchell and Junious Babb, because, in earlier evidentiary hearings, Joshuas counsel has called and examined both of them on student achievement, guidance counseling, and advanced placement courses
(4) various Joshua exhibits should be excluded because, on their face, they do not directly relate to the three remaining issues of advanced placement courses, guidance counseling, and extracurricular activities
(5) any testimony from Jim Mosby and Jody Carter related to their recent removal as principals of Southwest Middle School and McClellan High AO 72A (Rev.8/82) 61 61 School should be excluded under Fed. R. Evid. 401,402, and 403
(6) Joshuas failure to identify any witnesses or exhibits for use in their thirty minutes of true rebuttal prevents them from presenting any rebuttal testimony at 8:30 a.m. on July 22,2002
and (7) Joshua Exhibits 767- 776 and 791 should be excluded under Fed. R. Evid. 801-804, 401-403, and 901. The schedule for LRSD and Joshua submitting their exhibits and witness lists to the Court on July 9 and the commencement of evidentiary hearings on July 22 necessitates an expedited response from Joshua to LRSDs Motion in Limine. Therefore, Joshua must file their response to LRSDs Motion in Limine no later than 2:00 p.m. on Monday, July 8, 2002, and serve other counsel by fax at or before that time. Thereafter, the Court will promptly decide the merits of LRSDs Motion in Limine. Since time is of the essence, this Order will be faxed to counsel of record as soon as it is entered. IT IS SO ORDERED. DATED this day of July, 2002. IITED STATES DISTRICT JUDG' UNITED DGE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE BY. WITH RULE 58 AND/OR79(a) FRCP OU 11 OTx -2- AO72A (Rev.8/82)RECEIVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION JUL "8 2002 OFFICE OF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS MEMORANDUM BRIEF IN SUPPORT OF PLAINTIFF'S MOTION IN LIMINE RELEVANCE GENERALLY The LRSD moves to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors pursuant to Fed. R. Evid. 401, 402 and 403. The ultimate issue before this Court is whether noncompliance with the Revised Plan casts doubt on the Board's intent to comply with the Constitution in the future absent court supervision. See Cody v. Hillard, 139 F.3d 1197, 1199 (8* Cir. 1998). Noncompliance that the Board knew nothing about has no bearing on this issue and is irrelevant. See Fed. R. Evid. 401. Section 1983 Liability Standard The issue before this Court is analogous to the issue of whether a governmental entity may be held liable under 42 U.S.C. 1983 for the unconstitutional conduct of its employees. Respondeat superior is not a permissible theory for holding a governmental entity liable for the unconstitutional acts of its employees. Monell v. Department of Social Services, 436 U.S. 658, 690, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978). Instead, a governmental entity is liable under 1983 when "a policy, statement, ordinance, regulation or decision officially adopted and promulgated by that body's officers" can be causally related to the allegedly unconstitutional conduct of itsemployees. Id. Liability may also be based on "constitutional deprivations visited pursuant to governmental custom even though such a custom has not received formal approval through the body's official decision-making channels." Id. at 690- 91, 98 S.Ct. 2018. See Ryan v. Board of Police Commissioners of the City of St. Louis. 96 F.3d 1076, 1084 (8th Cir.1996). In Ware v. Jackson County. 150 F.3d 873 (8th Cir.1998), the Eighth Circuit explained that: Official policy involves 'a deliberate choice to follow a course of action * * * made from among various alternatives' by an official who [is determined by state law to have] the final authority to establish governmental policy." Jane Doe A. 901 F.2d at 645. Alternatively, "custom or usage" is demonstrated by: (1) The existence of a continuing, widespread, persistent pattern of unconstitutional misconduct by the governmental entity's employees
(2) Deliberate indifference to or tacit authorization of such conduct by the governmental entity's policymaking officials after notice to the officials of that misconduct
and (3) Th[e] plaintiff['s] injur[y] by acts pursuant to the governmental entity's custom, i.e., [proof] that the custom was the moving force behind the constitutional violation. Ware, 150 F.3d at 880 (citations omitted) (emphasis supplied). "[I]naction or laxness can constitute government custom if it is permanent and well settled." Tilson v. Forrest City Police Dept.. 28 F.3d 802, 807 (8th Cir.1994) (citation omitted). "Such a government custom of laxness or inaction must be the moving force behind the constitutional violation." Id. "To establish a city's liability based on its failure to prevent misconduct by employees, the plaintiff must show that city officials had knowledge of prior incidents of police misconduct and deliberately failed to take remedial action. Fowler. 98 F.3d 1069, 1075 (Sth Cir.1996) (emphasis supplied). Andrews v. In the context of the present case, the Board is the "final authority" in making District policy. During the term of the Revised Plan, the Board adopted and/or re-adopted clear, unambiguous policies indicating its intent to comply with the Revised Plan, federal civil rights statutes and the Constitution. See CX 719. Thus, to cast doubt on the Board's intent to comply with the Constitution in the future, Joshua must establish a "custom or practice" of failing to remedy noncompliance with the Revised Plan. This requires that Joshua show "that [the Board] had knowledge of prior incidents of [noncompliance] and deliberately failed to take remedial 2action." Andrews, 98 F.3d at 1075. Accordingly, incidents of noncompliance of which the Board did not have knowledge are irrelevant. See Fed. R. Evid. 401. Joshua may argue that the District failed to adequately train or supervise its employees who were violating the Revised Plan. It is true that a governmental body may also be held accountable under certain circumstances based on a failure to adequately train and supervise employees. City of Canton v. Harris, 489 U.S. 378, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989). In Andrews, the Eighth Circuit summarized these circumstances related to a city police force. The court stated: A city also may be liable for deficient policies regarding hiring and training police officers where (1) the city's hiring and training practices are inadequate
(2) the city was deliberately indifferent to the rights of others in adopting them, such that the failure to train reflects a deliberate or conscious choice by a municipality
and (3) an alleged deficiency in the city's hiring or training procedures actually caused the plaintiffs injury. It is necessary to show "that in light of the duties assigned to specific officers or employees the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, the policymakers of the city can reasonably be said to have been deliberately indifferent to the need." In other words, the plaintiff must demonstrate that the city "had notice that its procedures were inadequate and likely to result in a violation of constitutional rights. Andrews, 98 F.3d at 1076 (citations omitted) (emphasis supplied). In the context of the present case, Joshua must establish that the Board "had notice that its procedures were inadequate and likely to result in a violation of [the Revised Plan.]." Id. It is simple common sense that the Board cannot be on "notice that its procedures were inadequate" if the Board was unaware of the noncompliance resulting from the alleged procedural inadequacy. Therefore, Joshua must at a minimum show that the Board had knowledge of noncompliance with the Revised Plan in order to cast doubt on the Board's intent to comply with the Constitution in the future absent court supervision. The Revised Plan Requiring Joshua to show, at a minimum, that the Board had knowledge of noncompliance about which they complain is consistent with the Revised Plan. As a part of the 3Revised Plan, Joshua and the LRSD agreed to a process for raising and resolving compliance issues. Revised Plan 8 outlined a three step process for resolving compliance issues. First, the issue would be brought to the attention of the District. If the parties were unable to reach an agreement, the issue would be submitted to ODM for facilitation. Finally, the issue would be presented to the Court for resolution. During the term of the Revised Plan, all compliance issues raised by Joshua were resolved without the need for facilitation by ODM or resolution by the Court. See Final Report, p. 166. Consistent with Revised Plan 8, the Board expected Joshua to bring to its attention any substantial compliance issues. To facilitate Joshua's monitoring of the District's compliance, the Board agreed in advance to pay Joshua to monitor the LRSD's compliance with the Revised Plan, and Joshua billed the LRSD for monitoring the LRSD's Compliance. See Exhibits 7 and 8 to Plaintiffs Memorandum Brief in Support of Motion for an Immediate Declaration of Unitary Status. Therefore, Joshua cannot be heard to complain that requiring it to show that the Board had knowledge of noncompliance is inconsistent with the Revised Plan. Conclusion The parties knew there would be compliance issues, and for that reason, agreed to Revised Plan 8. Thus, real question before this Court is not whether there was noncompliance, but how the Board responded to noncompliance. The Board had no opportunity to respond to noncompliance of which it was unaware. Thus, noncompliance that was not brought to the Board's attention is irrelevant and should be excluded pursuant to Fed. R. Evid. 401, 402 and 403. 4t Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE & CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 / (501 S5011 Christopher Hell 81063) CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by mail on July 2, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 (via hand-delivery) 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 Mr. Sam Jones Wright, Lindsey & Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Christopher Hellei 5RECEIVED -/o 4^y JUL 1 0 2002 OmCEOF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT d^URT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION By. He 08 2082 LITTLE ROCK SCHOOL DISTRICT ^OTF V. NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. LET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS JOSHUA INTERVENORS RESPONSE TO THE LRSD I. Joshua Intervenors Witness List The Joshua Intervenors maintain that their witness list generally parallels the list submitted by the LRSD, by identifying the topics of witness testimony. For example, the LRSD can maintain that the summary of the testimony of Dr. Leslie (for 6 hours) provide [s] a detailed statement of the witnesses expected testimony on each issue only on a tongue in cheek basis. The Joshua Intervenors face two problems in preparing a witness list, which the LRSD does not face. The LRSD has ready access to all of its witnesses, who are its employees. In contrast, none of Intervenors witnesses are employees.' Moreover, at least 11 of Intervenors witnesses are subject to the direction of the LRSD. These are witnesses number 1-3, 5, 7, 14-15, 18-19, 23, and 26 on the Intervenors list. Nevertheless, the Joshua Intervenors will submit a supplemental witness list by 5:00 p.m. on Doctors Roberts and Ross are experts designated by Intervenors. -1-July 10, 2002. 2. Asserted Failure to Provide Exhibits The LRSD complains about the failure to provide exhibits identified by the numbers 793, 794, 799, 800 and 801. Each exhibit is an LRSD document(s). Some are voluminous. By this objection, the LRSD is simply seeking to frustrate the Joshua Intervenors effort to present the position of the class in a reasonable manner. Exhibit 801, LRSD Quarterly Status Reports, was the subject of testimony during the earlier hearings. These reports contain information regarding enrollment in advanced courses, as well as the extent to which students succeed. 3. Testimony by Sadie Mitchell and Junious Babbs These associate superintendents served on the LRSD compliance committee during the implementation of the revised plan and have had responsibility for the areas of guidance counseling and extracurricular activities. LRSD plans to offer lengthy testimony by Ms. Mitchell (two hours). The Joshua Intervenors, in contrast, propose to question each administrator for approximately 10 minutes. In this light, it is appropriate to allow Joshua Intervenors to proceed with the testimony. with the LRSD having the right to object to a question as repetitive. 4. Various Exhibits Assertedly Not Relevant to Issues to be Heard The exhibits deal with the following issues: advance placement: 754, 801-802 guidance and counseling: 780, 786-789 extracurricular activities: 746 (lumped statistics), 771, 773, 775 rebuttal: 743, 747, 749, 750, 755, 757, 758, 759, 760, 762, 763, 764, 779, 785 will not be offered: 752, 756, 761, 777, 778, 779, 782, 783, 784 -2-5. Testimony from Jim Mosby and Jody Carter The Joshua Intervenors do not plan to question Messrs. Mosby and Carter regarding their recent removal as principals. 55 6. Rebuttal The Joshua Intervenors will present rebuttal testimony by ODM Monitors Ann Marshall and Gene Jones. They will address the LRSDs testimony at the earlier hearing, which asserted compliance with Section 2.7.1 of the revised plan. 7. Joshua Exhibits 767-776. 791 These letters written by Ms. Springer are offered to show notice to the district of various problems. Counsel for Joshua Intervenors intends to explore at the hearing what if any investigation and other responsive actions were undertaken by the LRSD, after receipt of the letters. The LRSD pledged to implement programs, policies and procedures to insure non-discriminatory access to extracurricular activities. Its administrators responses to the letters is therefore relevant. The Joshua Intervenors should have the opportunity to seek the authentication of pages 2 and 3 of Exhibit 791, dealing with guidance, by the testimony of Junious Babbs and Sadie Mitchell. 8. Relevance Generally The LRSDs efforts to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors . . . [Motion in Limine at 3] and to rely on Section 1983 entity liability standards [Memorandum Brief in Support of Plaintiff s Motion in Limine] is flawed. These gambits ignore the law of the case, and, more particularly, multiple promises, throughout the plan, to implement various activities without regard to whether or not non-compliance was called to the attention of the Board. See, e.g.. Revised -J-Plan Sections 2.5, 2.7, 2.7.1, 2.12.1, 6, and 11. As emphasized in Joshua Intervenors response of May 30, 2002, the Court of Appeals has held and reiterated that the terms of settlement agreements in this case provide the standards for measuring the performance of the school districts, here the LRSD. [Memorandum at 47] The Revised Plan does not identify Section 1983 entity liability principles as the standard for evaluating compliance with its terms. Rather, it calls, inter alia, for adoption of various programs, policies, and procedures, their implementation, and monitoring to identify problems and provide a basis for remedial actions. School Board members are not LRSD employees, their commitment is for less than full-time. Manifestly, the plan envisions implementation activities by administrators and other elements of the work force, without qualification in terms of notice to the school board. Joshua Intervenors proof will be consistent with this framework. There will likely be questioning on the adoption of programs, policies, and procedures (largely the domain of the school board). There will be questioning of implementation, or the lack thereof (largely the domain of fulltime employees). The effort to exclude evidence, wholesale, is without merit. Respectfully submitted. / Robert Pressman, Mass Bar No. 405900 22 Locust Avenue Lexington, MA 02421 (781) 862-1955 4, // Lu John Walker, AR Bar No64046 JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501) 374-4187 (Fax) -4-CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has-been serit\by fax and U.S. Mail, postage prepaid to the following counsel of record, on this T" day of ,2002: Mr. Clay Fendley FRIDAY, ELDREDGE & CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Dennis !en Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Sam Jones WRIGHT, LINDSEY & JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Richard Roachell ROACHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 1 Jo^ W. Walker -5-RECEIVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION JUL ~8 2002 OmCEOF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V, LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS PLAINTIFF'S MOTION IN LIMINE Plaintiff Little Rock School District ("LRSD") for its Motion in Limine states: 1. May 15 Order: Joshua's Witness List. On May 15, 2002, the Court ordered the parties on or before June 21, 2002 to "identify the name of each of their witnesses, the date and time each witness will be called, and the anticipated time it will take for direct examination of each witness. A detailed statement must be included of each witnesses anticipated testimony on each issue the witness will address." Order filed May 15, 2002, p. 2 (emphasis in original). Joshua's witness list is attached hereto as Exhibit 1. As can be seen, Joshua failed to comply with the Court's order in every respect. Upon information and belief, Joshua has not even contacted many of the individuals identified to discuss their appearing at the hearing and testifying, and Joshua has no intention of calling all of the witnesses identified. The LRSD moves in limine that Joshua be ordered on or before 5:00 p.m. on July 10, 2002 to identify the date and time on which each witness will be called, to identify the issue(s) on which each witness is expected to testify and to provide a detailed statement of the witnesses' expected testimony on each issue. The LRSD further requests that Joshua be precluded from calling any witness for which it fails to provide this information on or before 5:00 p.m. on July 10, 2002. Finally, the LRSD asks that Joshua be instructed to only identify witnesses that it has interviewed and confirmed their availability for the hearing.2. May 15 Order: Joshua's Exhibits. On May 15, 2002, the Court also ordered the parties to exchange pre-marked exhibits on or before June 21, 2002. The Court further stated that "[a]ny exhibit not pre-marked and exchanged on or before June 21, 2002 will not be received into evidence during the July 22 hearing, absent highly imusual circumstances. A copy of Joshua's Exhibit list and the exhibits provided to the LRSD are attached hereto as Exhibit 2. Joshua failed to provide the LRSD with copies of Exhibits 793, 794, 799, 800 and 801 stating (t [rjequest is hereby made for those exhibits ..This request by Joshua is untimely. See Order filed July 1, 2002, p. 1. To the extent Joshua may be in possession of these documents, the LRSD moves in limine to exclude Joshua Exhibits 793, 794, 799, 800 and 801. 3. May 15 Order: Exhibit 803. The LRSD also moves to exclude any additional documents which Joshua may intend to introduce as Exhibit 803. Joshua identified as Exhibit 803, "The exhibits filed by the Little Rock School District for this hearing." This fails to comply with the Court's May 15, 2002 order, as the LRSD understood it. 4. May 9 Order: Good Faith. The Court stated in its order of May 9, 2002 that Joshua would be permitted to present additional evidence on the issue of the LRSD's good faith tr but only to the extent that: (a) it relates directly to the issues of advanced placement courses. guidance counseling, extracurricular activities and student achievement
and (b) it does not duplicate testimony already presented by Joshua on the issue of good faith." Order filed May 9, 2002, p. 14 (emphasis in original). Consistent with the Court's Order, the LRSD moves in limine as follows: a. Sadie Mitchell. Joshua called Mitchell to testify on August 1 and 2, 2001. S^ Tr. August 1, 2001, pp. 564-570 and August 2, 2001, pp. 848-896. Joshua specifically questioned Mitchell about student achievement (see. e,., Tr. August 1, 2001, p. 575) and advance placement courses (see, e^, Tr. August 1, 2001, p. 600), Additional testimony from Mitchell on these issues would be duplicative. Accordingly, the LRSD moves to prohibit Joshua from questioning Mitchell about student achievement and advanced placement courses. 2b. Junious Babbs. Joshua called Babbs to testify on July 5 and 6, 2001. See Tr. July 5, 2001 (all) and July 6, 2001, pp. 283-340. Joshua specifically questioned Babbs about advanced placement courses (s^, e^g., Tr. July 5, 2001, p. 219), guidance counseling (see, e^, Tr. July 5, 2001, p. 228), extracurricular activities (see, e.g.. Tr. July 5, 2001, p. 218) and student achievement (see, e^, Tr. July 5, 2001, p. 231). Accordingly, the LRSD moves to prohibit Joshua calling Babbs as a witness. c. Exhibits. The LRSD moves to exclude the following exhibits not directly related to the issues of advanced placement courses, guidance counseling, extracurricular activities and student achievement
743, 746, 747, 749, 750, 752, 754, 755, 756, 757, 758, 759, 760, 761, 762, 763,764,771, 773,775, 777, 778, 779, 780, 782, 783, 784, 785, 786, 787, 788,789 801 and 802. 5. Relevance Generally. The LRSD moves to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors pursuant to Fed. R. Evid. 401, 402 and 403. The LRSDs memorandum brief in support of this Motion is hereby incorporated by reference. The LRSD also incorporates by reference its Memorandum Brief in Support of Motion for an Immediate Declaration of Unitary Status and its Reply Brief in Support of Motion for an Immediate Declaration of Unitary Status. 6. Jim Mosby and Jodie Carter. The LRSD also moves to exclude evidence and testimony related to the removal of Jim Mosby and Jodie Carter as the principals of Southwest Middle School and McClellan High School, respectively, pursuant to Fed. R. Evid. 401,402 and 403. Both men are represented by counsel for Joshua, and filed Complaints against the LRSD on July 7, 2002 related to their removal which are now pending before this Court. The July 22 hearing on whether the LRSD should be declared unitary is not the appropriate forum to decide the merit of their Complaints, and this Court has a long-standing practice of not hearing individual claims as a part of this case. See, e.g.. Docket No. 1874, Order filed June 30, 1993. 37. Rebuttal Evidence. This Court's order of May 15, 2002 granted Joshua 30 minutes to present rebuttal evidence pertaining to the three issues tried virtually to conclusion during previous hearings before Judge Wright. Joshua failed to identify any witnesses or exhibits for this purpose. Moreover, none of the witnesses or exhibits would reasonably be construed as "true" rebuttal, as defined by Judge Wright. Judge Wright defined rebuttal evidence as evidence necessary to respond to evidence presented by the other side which could not have been anticipated. Tr. Nov. 20, 2001, 399. The LRSD submitted no evidence which could not have been anticipated by Joshua because it had all been previously outlined in the LRSD's Interim Report and/or Final Report. Therefore, the LRSD moves in limine that Joshua be prohibited from presenting any rebuttal evidence on July 22, 2002, at 8:30 a.m. 8. Letters from Joy Springer. Joy Springer is counsel for Joshua's paralegal, and she has not been identified as a witness. However, Joshua has identified as Exhibits 767- 776 a series of letters from her to District personnel related to individual student/parent complaints. The LRSD moves to exclude these letters for several reasons. First, the letters are hearsay reporting hearsay, and they fail to fall within any exception to the hearsay rule. See Fed. R. Evid. 801, 802 803 and 804. Second, the letters are irrelevant in that there is no evidence that these complaints were brought to the attention of the Board. See Fed. R. Evid. 401 and 402 and paragraph 5, supra. Third, any relevance is outweighed by the danger of unfair prejudice where no evidence will be presented that would allow this Court to assess the merit of the complaints made in the letters. See Fed. R. Evid. 403. 9. Joshua Exhibit 791. Joshua Exhibit 791 appears to be notes from a meeting with Ms. Jo Evelyn Elston, the LRSD's Director of Pupil Services. The LRSD assumes that the notes were prepared by Springer or another Joshua monitor. However, neither Springer nor any other Joshua monitor has been identified as a witness in this case. The LRSD moves to exclude Joshua Exhibit 791 for the same reasons set forth in paragraph 8 above. Joshua Exhibit 791 should also be excluded for an additional reason: the document, standing alone, cannot be 4authenticated, and Joshua has not identified any witness who will be able to authenticate the document. See Fed. R. Evid. 901. WHEREFORE, the LRSD prays that its Motion in Limine be granted
that it be awarded the relief sought herein
and that it be awarded all other just and proper relief to which it may be entitled. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE & CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376^Crn BY: 'hristopher Heller (#( '83) CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by U.S. mail on July 3, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 (VIA FAX and MAIL) Mr. Sam Jones 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 Wright, Lindsey & Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Ms. Ann Brown Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Christopher Heller F:\HOME\FENDLEY\LRSD 2001\dra-mot.limine-7.(l9-02 wpd 5 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANT MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE W KNIGHT, ET AL. INTERVENORS JOSHUA INTERVENORS WITNESS LIST REGARDING JULY 22-26. 2002 HEARINGS The Joshua Intervenors plan to call the following persons during the July 22-26, 2002 hearings: 1. Ms. Sadie Mitchell - Associate Superintendent for School Services Will disQuss guidance counseling and her oversight or lack of it within the schools. She will be called on July 23, 2002, and her testimony will be expected to take approximately ten minutes. 2. Mr. Junious Babbs - Associate Superintendent for Administrative Services Will address extracurricular activities and his oversight of those activities as Associate Superintendent for Administrative Services. His testimony will be approximately ten minutes and will occur on July 23, 2002. 3. Dr. Marian Lacey - Asst. Superintendent of Secondary Schools EXHIBIT 1 Will discuss her oversight of the secondary schools with respect to guidance counseling i S I 1advanced placement courses, and extracurricular activities. Her direct testimony will take approximately fifteen minutes. 4. Mr. Jodie Carter - Principal McClellan High School Will discuss special problems with advanced placement courses, guidance counseling, extracurricular activities and the Districts good faith. His testimony will take approximately two hours and will be presented on July 22, 2002. He will also discuss the support and involvement of school board members or the lack of. 5. Ms. Dorothy McDonald - Teacher Will discuss the Districts counseling program and problems which affect Afiican American students which have not been effectively addressed by the District. Her testimony will take approximately fifteen minutes. 6. Dr. Michael Faucette - Teacher Central High School Will discuss in detail the problems with the administration of advanced placement courses, the racial effect of the placements, the manner in which the placements are made, how the placements tend to favor one group of children over another, the problems with scheduling and how those scheduling decisions interact with other decisions of placement and counseling, participation in extracurricular activities, the favor given to white students at Central High School
the disparate effect of advanced placement courses with respect to teaching, awards, and other opportunities, and he will discuss the Districts good faith compliance. He testimony will presented on July 22"* and is expected to take approximately four hours on direct examination. 1. Ms. Pat Watson - Counselor at Hall High School 2Will address the Districts counseling program and how they are implemented. Her testimony will take approximately 15 minutes. 8. Mr. Kenneth Moore, Assistant Principal at Hall High School Will discuss extracurricular activities and good faith compliance. His testimony will take approximately ten minutes and will be presented July 23, 2002. 9. Ms. Pam Mercer - Parent of Former Student of Central High School Will discuss her efforts as a parent with respect to securing fair and equitable treatment for her children, Crystal and Justin, while they were at Central and how she was rebuffed along the way. She will also discuss the atmosphere at Central High School as it relates to privilege being extended to white children from middle class families. It will also cover counseling and extracurricular activities. Ms. Mercers testimony will take approximately twenty minutes on direct examination. 10. Mr. Justin Mercer - Former Student at Central High School Will address the problems he experienced of a racial nature while at Central High School and his efforts to obtain assistance and help from teachers, counselors and administrators. His testimony will take approximately ten minutes. 11. Crystal Mercer - Former Student at Central High School Will address the Districts counseling services from a African American students perspective. Her testimony will take approximately ten minutes. 12. Ms. Paulette Blevins - Former teacher at Central High School Will discuss how the grading system was manipulated so as to change grades and otherwise provide favor to white children at Central High School. Her testimony will take 3approximately fifteen minutes on direct examination. 13. Mr. Jimmy Mosby - Principal of Southwest Middle School Will discuss the efforts of the District to comply with the Plan with respect to good faith, guidance counseling and extracurricular activities while at Southwest Middle School and Hall High School. His testimony will take approximately twenty minutes on direct examination. 14. Ms. Sharon Brooks - Principal of Stephens Elementary School Will testify regarding good faith compliance and how she avoids it. The specific matter she will address will be unreported punishment without the involvement of a guidance counselor regarding the taking away of educational privileges for black boys for a period of two months while she was principal of Rightsell Elementary School. Her ' testimony will take ten minutes. 15. Ms. Susie Davis - LRSD Coordinator of English Will discuss the efforts of the Instruction Department to communicate Instruction Department standards to principals and teachers with respect English and Reading and other subjects which she supervises in her capacity as special assistant to Dr. Bonnie Lesley. Although this is not her title, she was regarded as the agent for Dr. Lesley within the schools. She will also discuss the extent of her and Dr. Lesleys association with respect to principals and counselors. Her testimony will take approximately ten minutes. 16. Ray Gillespie - Former Athletic Director Will discuss his role with respect to extracurricular activities and monitoring activities to ensure the absence of racial discrimination. His testimony will take approximately fifteen 4minutes. 17. Cassandra Norman - Principal at J. A. Fair High School Will discuss the Districts good faith compliance and her schools disparate treatment of black and white students. She will also discuss the support and involvement of school board members or the lack of. 18. Judith Pickering - Teacher - J.A. Fair High Schools Will discuss the racial atmosphere, advanced placement courses and extracurricular activities at J. A. Fair. Her testimony should take approximately fifteen minutes. 19. Foster Allen - Teacher at Central High Will discuss advance placement practices at Central High School and his relationship to those practices. His testimony will take five minutes. 20. Romona Horton and Bennie Horton - Parents of Former Central High Student Will discuss problems with AP placement of their child at Central High School. Their testimony will take five minutes a piece. 21. Alisha Allmon - Teacher Will discuss advanced placement practices at Central High School and his relationship to those practices. Her testimony will take five minutes. 22. Chris Payne- Former Student at J. A. High School Will discuss his efforts to participate in Quiz Bowl at J. A. Fair. His testimony will take ten minutes. 23. Ms. Sue Strickland, Dr. Katherine Mitchell, Dr. Michael Daugherty, Mr. Tony Rose Mr. Larry Berkley, Ms. Judy Magness and Mr. H. Baker Kurrus 5Will each give testimony regarding good faith compliance and their involvement in and knowledge of the development and implementation of guidance and counseling programs, advanced placement courses, regular courses, class sizes of regular courses, pupil teacher ratios between regular, advanced placement, honors and gifted and talented courses. Their testimony together is expected to take one hour on direct examination. 24. Jeanette Carter and Dr. Vertie Carter Will discuss problems which they experience with respect to the AP teachers and administrators and counselors regarding placement, retention and fair treatment in the AP program. Their testimony will take fifteen minutes. 25. Ms. Ethel Dunbar - Principal Franklin Elementary School Will discuss elementary good faith compliance, gifted and talented courses, guidance counseling and the assistance received with respect to these issues from the Division of Instruction. Her testimony will take approximately thirty minutes. 25. Mazie Phillips - Counselor at Fair High School Will address the Districts counseling program and how they are implemented. Her testimony will take approximately 15 minutes. 26. Leon Adams - Director of Federal programs Will discuss efforts to use Title I funds to promote the educational interests of all children rather than the children who were the intended beneficiaries of those funds
the correlation between counseling services, advanced placement courses and good faith compliance. His testimony will take approximately twenty minutes. 627. D.J. Thames and Avis Thames - Student and Parent - Fair High School Will discuss the Districts good faith compliance with respect to extracurricular activities. This testimony will take approximately ten minutes on direct examination. 28. Ann Marshall, Gene Jones, and Margie Powell - ODM Monitors Will discuss good faith compliance. Their testimony will take approximately thirty minutes. 29. Ray Simon Will discuss the Districts decision and the reason for it to retreat from the remediation requirement for loan forgiveness. His testimony will address the roles of Drs. Ross and Gamine with respect to discontinuing emphasis upon remediation of Black students relative achievement levels. It will take approximately twenty minutes. The exhibit which he will address is an agreement between the State of Arkansas and the Little Rock School District the description of about which I am not certain. 30. Dr. Terrence Roberts Will address the issue of good faith compliance, guidance counseling and relationship between regular and advanced courses. His testimony will take approximately twenty minutes and will be presented on July 23, 2002. 31. Dr. Stephen Ross Will testify about the Districts good faith compliance and advanced placement and honors courses. He will address the need for criteria for placement as will Dr. Roberts (see above). His testimony will take approximately thirty minutes. 7Respectfully submitted, John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 501-374-3758 501-374-4187 (fax) John W. Walker - Bar No. 64046 I CERTIFICATE OF SERVICE I hereby state that a copy of the foregoing witness list has been hand delivered to Counsel for the Little Rock School District on this 24* day of June, 2002. 8 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4
82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE W. KNIGHT, ET AL. INTERVENORS JOSHUA INTERVENORS EXHIBIT LIST REGARDING JULY 22-26. 2002 HEARINGS The Joshua Intervenors plan to use the following documents during the July 22-26, 2002 hearings: 743. E-mail dated July 2, 2001 from Virginia Johnson to Bonnie Lesley (page 182) 744. E-mail dated October 19, 2000 from Gary Smith to Bonnie Lesley (page 290) 745. E-mail dated June 29, 2001 from Sueellen Mann to Gail Hester and subsequent dated July 2, 2001 (page 167) 746. E-mail dated January 18, 2001 from Junious Babbs to Kathy Lease (page 12) 747. E-mail dated July 2, 2001 from Mona Briggs to Bonnie Lesley (page 191) 748. E-mail dated November 16, 2000 from Les Camine to Bonnie Lesley 749. E-mail dated November 21, 2000 from Ken Savage to Kathy Lease (page 38) 750. E-mail dated March 7, 2001 from Kathy Lease to T Rose and subsequent dated March 7, 2001 at 12:44 p.m. (page 7) 751. E-mail dated July 15, 2001 from Bonnie Lesley to Lionel Ward and subsequent 1 1 exhibit I I A.dated July 16, 2001 (page 88) 752. E-mail dated July 14, 2001, July 15, 2001 and July 16, 2001 from Bonnie Lesley to Ken James (page 96) 753. E-mail dated July 15, 2001 from Bonnie Lesley to Chris Heller (page 102) 754. E-mail dated April 18, 2001 from Bonnie Lesley to Kathy Lease and subsequent response (pages 708 and 709) 755. E-mails dated October 25, 2000 from Bonnie to Irma Truett and Kathy Lease re: Benchmark scores (pages 16 and 17) 756. E-mail dated June 28, 2001 8:00 p.m. from Mona Briggs to Bonnie Lesley (page 192 757. E-mail dated June 28, 2001 9:08 am. from Bonnie Lesley to members of her staff (Page 192 and 193) 758. E-mails dated September 29, 2000 between Bonnie Lesley and Kathy Lease re: Priorities 2000-01 (Page 51) 759. E-mail dated October 3, 2000 between Les Camine. Bonnie Lesley and Kathy Lease Re
ALT Check-in (Page 50) 760. E-mail dated June 20, 2001 from Bonnie Lesley to Beverly Griffin re: semester test Exemption (Page 351) 761. E-mail dated June 25, 2001 from Bonnie Lesley to Clay Fendley (page 297) 762. F-mails dated June 29, 2001 between Sadie Mitchell, Deanna Eggeston and Bonnie Lesley (pages 218-219) 763. E-mails dated February 12 and 13, 2001 Lesley, Ruffins, Lease and Camine (page 19) 764. Email dated February 13, 2001 from Kathy Lease to Les Camine (Pages 17 and 18) 765. Memo dated November 17, 2000 from Dr. Faucette to Mrs. Hargis re: exclusion of Regular English students fro Jennie Calder lecture 766. Email dated September 27, 2000 from Sadie Mitchell to Junious Babbs (Page 1) 27 767. Letter dated December 16, 1998 to Les Gamine from Joy Springer 768. Letter dated February 18, 1999 to Sadie Mitchell from Joy Springer 769. Letter dated March 17, 1999 to Rudolph Howard from Joy Springer 770. Letter dated October 14, 1999 to James Washington from Joy Springer 771. Letter dated February 28, 2000 to James Washington from Joy Springer 772. Letter dated February 28, 2000 to James Washington from Joy Springer re: Scouts 773. Letter dated August 28, 2000 to Ray Gillespie from Joy Springer 774. Letter dated September 12, 2000 to Les Gamine from Joy Springer 775. Letter dated October 10, 2000 to Les Gamine from Joy Springer 776. Letter dated September 13, 2000 to James Washington from Joy Springer 777. E-mail dated June 6, 2000 to Les Gamine from Don Stewart (Pages 100-0 1) 778. E-mail dated April 19, 2001 from Deanna Eggeston to Don Stewart (Page 37) 779. E-mail dated April 25, 2001 from Kathy Lease to Mark Millhollen 780. E-mail dated May 25, 2001 from Bonnie Lesley to Debbie Berry (Page 358) 781. E-mail dated June 7, 2000 from Glay Fendley to Bonnie Lesley 782. E-mail dated June 7, 2000 from Bonnie Lesley to Mary Paal (Page 136) 783. E-mail dated April 17-18, 2001 to Don Stewart from Bonnie Lesley 784. E-mail dated July 12, 2001 to Bonnie Lesley from Don Stewart (240) 785. E-mail dated February 28, 2001 to Bonnie Lesley from Don Stewart 786. Memo dated February 24, 1999 to Gayle Bradford from James Washington 787. Memo dated March 11, 1999 to Les Gamine from James Washington 788. Letter dated April 12, 1999 to Gayle Bradford from James Washington 3789. Letter dated March 22, 1999 to Gayle Bradford from James Washington 790. Letter dated April 26, 1999 to John Walker from Les Gamine 791. Memo dated May 3, 1999 regarding visit to Pupil Services & Administration buildings 792. Email dated 9/30/300 from Marian Lacey to Sadie Mitchell w/attachments 793. High School Master Schedule Audit, Little Rock School District 2001-2002 794. School Yearbooks for Central, Hall, McClellan, Fair, Hall and Parkview for school years 1998-99 through 2001-2002 795. Letter dated February 28, 2002 from Dr. Michael Faucette to Jane Welch regarding enrollment in Creative Writing course 796. Little Rock Central - Requests for Course - Creative Writing 797. Essay by Justin Mercer entitled: Black at Central: My 45 Years of Struggle 798. Memo dated August 4, 1999 from Bonnie Lesley to Ann Marshall 799. Academic awards reports for the period 1998 through 2002. 800. Rank Lists for Hall, Parkview, Central, McClellan and Fair for graduating senior classed for the period 1998 through 2002 801. LRSD Quarterly Status Reports - School Services - 1999 through 2002 802. Deposition of School Board Members - a. Sue Strickland b. Tony Rose c. Judy Magness d. Larry Berkley e. Katherine Mitchell 803. The exhibits filed by the Little Rock School District for this hearing Joshua notes that some of the foregoing exhibits are in the exclusive possession of the Plaintiff. Request is hereby made for those exhibits which include numbers 793, 794, 799, 800. 801. 4By: Respectfully submitted, JohnW. Walker,?. A. 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing exhibit list and exhibits have been hand carried to counsel for the Little Rock School District and the Office of Desegregation Monitoring on this day of June, 2002. 5 LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 2:24 PM 'heller^fec.nef Latest Fax 743' 1 had Anita fax over to you the latest-a bunch of stuff on our literacy plan. 1. He already has a copy of the PreK-3 Literacy Plan. Other information is in the Interim and Final Compliance Reports. 2. He also has the test results for SAT9, Grade 4 Benchmark, and DRA-so those are the results. 3. I don't know what he means by monitoring reports. 4. The assessment program is outlined in several pages in the Compliance Report. 5. I can copy those policies and regs for him. Want me to go ahead and send? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 1:44 PM JOHNSON, VIRGINIA RE: Needed Information-Important! Do you have dates for those three times? From: Sent: To: Subject: iriginal Message JOHNSON, VIRGINIA Monday, July 02, 2001 1:15 PM LESLEY, BONNIE RE: Needed Information-Important! Three times I sat in on sessions with Steve Ross along with other PRE staff. At no time did we review any NSF documents. The sessions focused on document review of the ESL and Pre-K Literacy reports. I have never "consulted" with him. I have never consulted with Dr. Roberts either. Original Message----- From: Sent: To: LESLEY, BONNIE Monday, July 02, 2001 12:07 PM ADAMS, LEON
ARNOLD, LAURA BETH
AUSTIN, LINDA
BRANDON, BARBARA
BRIGGS, MONA R.
BROADNAX, KAREN
BUSBEA, PAT
CARR, MARCELLINE
CARSON, RENE
CLEAVER, VANESSA
CLIFFORD, ELIZABETH
CRAWFORD, PAMELA: DAVIS, SUZI
DEBBIE MILAM
DILLINGHAM, YVETTE: DONALDSON, MABLE: FINNEY. ANTONETTE
FLETCHER. DANNY
FREEMAN. ANN
GILLIAM. ANITA
GLASGOW, DENNIS
HARDING, CASSANDRA: HUFFMAN, KRIS
JACKSON, MARION
JOHNSON, VIRGINIA
JONES, DOCIA
JONES, STEPHANIE
KIILSGAARD, SHARON
KILLINGSWORTH, PATRICIA
KOVACH, RENEE
LAJUANA RAINEY: LOYA, STELLA,: MARION BALDWIN: MARTIN, PAULETTE: McCOY, EDDIE
McNEAL, MARIE
MILAM, JUDY
NEAL, LUCY
PAAL, MARY M.
PAUL, ANNITA
PERRITT, YORIKO U.
PRICE, PATRICIA: RYNDERS, PAULA: SMITH, GARY
SMITH, PAULA
TEETER, JUDY
WALLS, COLLEEN
WARD, LIONEL
WILLIAMS, BARBARA
WILLIAMS, ED
WILSON, LEVANNA
WOODS, MARION Subject: Needed Information-Important! 182snimitci@lrsdadm.lrsd.kl2.ar.us Original Message----- From: Sent To: Cc: Subject: CARNINE, LESLIE V. Thursday, October 19, 2000 1:59 PM MITCHELL, SADIE NEAL, LUCY
LESLEY, BONNIE
LEASE, KATHY R.
SMITH, GARY RE: Will we have the software available by 2nd Semester? What system(s) are being looked at? Original Message From: Sent To: Subject: MITCHELL, SADIE Thursday, October 19. 2000 10:33 AM CARNINE, LESLIE V. FW: Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us Original Message From: Sent To: Cc: Subject 7^^ SMITH, GARY Thursday, October 19, 2000 10
25 AM LESLEY. BONNIE WARD. LIONEL
GADBERRY. BRADY L.
NEAL. LUCY
MITCHELL. SADIE
CAWTHON. FRANCES H.
LACEY. MARIAN G.
ADAMS. LEON
AUSTIN. LINDA
BRADFORD. GAYLE: BRIGGS. MONA
BROADNAX. KAREN
CLEAVER. VANESSA: COLFORD. SUSAN
DAVIS. SUZI
DONALDSON. MABLE
Eddie McCov
ELSTON, JO
FULLERTON, JAMES
GLASGOW, DENNIS: HAWKS, EVERETT
KEOWN, ADA
MARION BALDWIN
NORMAN, CASSANDRA R.
PRICE, PATRICIA
TATUM, KATHY: WYATT-ROSS, JANICE Dr. Lesley, The consensus recommendation of the SAIP committee is for a SAIP be created for students at all grade levels who are not proficient based state mandated benchmark tests and/or District mandated Achievement Level Tests (ALT) - Our specific recommendations to implement this are
obtain/create the software necessary to identify students not proficient on state benchmarks/district assessment that will also generate/print the adopted SAIP form with student information and test scores printed on the SAIP form obtain/create the software that will generate/print specific strategies (along with and printed checklists for those who wish not to use computer) developed by a committee made up of teachers and curriculum specialists as a resource available for teachers to use (especially secondary teachers) - this can be attached to the SAIP form as needed develop an "instructional" sheet for the SAIP form that will explain in more detail the information to documented and procedures to follow provide training on the use of SAIP form directly to teachers (the exact training may have to be determined at a future date based on the development of software noted above) - delivery of training would need to be coordinated with staff development for most effective and comprehensive presentation to all teachers to ail of you in Cyber Land - is there anything else I forgot? - thanks Gary 290LESLEY, BONNIE From: Sent: To: Cc: Subject: BABBS, JUNIOUS Monday, July 02, 2001 8:08 AM ELSTON, JO NEWBURN, LINDA
LESLEY, BONNIE RE
Counseling Program Kit 745- Message Flag: Due By
Flag Status
Follow up Monday, July 09, 2001 5:00 PM Flagged It is positive to see that things are moving forward on this "01 - 02 priority. Prior to coming to closure, I ask that your look to set up a time to fill me in on the "buy in" of players called upon (committee members) to develop districtwide literature to be distributed. The connection to Curriculum and Instruction is a biggee that should be run through Dr. Lesley. I will look to give you a call a bit later regarding B/W high school scholarship information and the 3 - 4 year comparisons. To date, this information has not been provided. Junious C. Babbs, Jr jcDabbs@stuasn.lrsd.kl2.ar,us Little Rock Schoo! District -----Original Message From: Sent: To: Cc: Subject: VANN, SUELLEN Friday, June 29, 2001 11:08 AM HESTER, GAIL ELSTON, JO
BABBS, JUNIOUS Counseling Program Kit Jo Evelyn Elston is in my office, and we're working on a counseling program kit with insert sheets. Mr. Babbs will pay for this out of his budget. I'm going to talk with Kristy Black about the design of the kit and sheets, but I figured we'd better give you the info for the quote since it looks like a pretty good-sized job. The kit will be one-pocket on right side with a business card slot
the kit will print front and back with one pocket. There won't be a separate "wing" like the recruitment kit had. Quantity: 25,000 Jo Evelyn likes the paper we used for the recruitment kit and insert sheets, so we could just go with those. The insert sheets: 1. JOBBS sheet - print front only
quantity 30,000 2. Early college planning sheet - print front only
quantity 20,000 3. PCEP sheet - print front only
quantity 20,000 4. What Does Counselor Do? sheet - print front only
quantity 30,000 5. Counseling program sheet - print front and back
quantity 30,000 6. Couseling fact sheet - print front only
quantity 30,000 The kit and insert sheets would print 4-color. Have I forgotten anything? No bleeds. THANKS! (Mr. Babbs, you might want to set up a lemonade stand on Sherman to pay for this!!!!!) Suelle.n S. Vann,- APR Director of Communications Little Rock School District (501)324-2020 167LESLEY, BONNIE 7^6 From: Sent
To: Subject: LEASE, KATHY R. Thursday, January 18, 2001 6:06 PM BABBS, JUNIOUS RE
Section 2 Thanks for the input! We have been with the program evaluation consultant all cay, so I just finished editing the report to send to Bonnie. I will incorporate your changes and suggestions, and send it to her again. Do you want the Power Point as an Appendix or the outline for it incorporated into the body of the report? I'm so sorry I am just getting around to my email, but I'll take the heat for sending another correction. Not enough hours in the day!! Kathy PS--Thanks for the encouragement! Original Message From: Sent: To: Cc: Subject: BABBS, JUNIOUS Thursday, January 18, 2001 10:53 AM LEASE, KATHY R. GADBERRY, BRADY L. FW/: Section 2 Good information. Working with timelines and specific report information submissions for this division, I have not been able to dissect in great detail but my original thinking touches upon 2 - 3 items that may warrant some review. You will note that Brady is also being forwarded who can provide his thinking as well. Future compliance sessions will toss this about for further revision. 1. Inclusion of the power point presentation. 2. When touching upon Dr. Ross - It may be advantageous to refer to "looks to build or acknowledges" specific district efforts as opposed to "praising". 3. It would be appropriate to list current data that is available. Be reminded that when writing materials for our report submission, we will include "districtwide" numbers We may not be thprp yet but this will help to serve as an indicator of established basSTihe Fnformation from which we will jump off of. Keep your chin up. . --------------------------- Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message----- From: Sent: To: Cc: Subject: LEASE, KATHY R. Wednesday, January 17, 2001 6:14 PM LESLEY, BONNIE BABBS. JUNIOUS
DILLINGHAM, YVETTE
HUFFMAN, MAC
JOHNSON, VIRGINIA
McCOY, EDDIE
SUMMERVILLE, ROSALYN P.
TRUETT, IRMA
WILLIAMS, ED Section 2 File
Deseg Report (2.7.1).doc Bonnie, Here is the first draft of Section 2.7.1. Please let me know what additions or revisions you want made. Thanks, Kathy PS-PRE folks-Look to see what I left out, what typos 1 have, and what needs to be edited. Thanks 12747 Chris, I am in LR this week-end and you can reach me at 868-4289, I can come to your office to help, or I can work from my office. Call if you need me. Are we having fun yet? Dr, Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 8:16 AM BRIGGS, MONA R, RE
Thank you, my friend, I "vegged" all week-end, seriously "vegged," I know this will be a HARD week. Yes, I hear Kathy is on his witness list. It'll be interesting. -----Original Message----- From: Sent: To
Subject: BRIGGS, MONA R. Monday, July 02, 2001 6:53 AM LESLEY, BONNIE RE: I have been thinking a lot about you. You can't let this bring on a stroke or something. You don't need this kind of pressure all by your self!! It is not worth it-no job is worth it. And you can't take on the woes of a district that has been screwing up for a decade or more. I hope Kathy does get called to testify. She needs to have to answer to John Walker and if it bodes ill for the district so be it! She and Camine just waltzes out of here and leaves everyone else holding the rope. You make time for sleep and food!! Mona R, Briggs Middle Level Specialist Little Rock School District 501-324-2412 " Seek First to Understand
then to be understood" (Covey) Original Message From: Sent: To: LESLEY. BONNIE Friday, June 29, 2001 7:55 AM BRICSS, MONA R, 191STEWART, DONALD M. From: Sent: To: Cc: Subject: CARNINE, LESLIE V. Thursday, November 16, 2000 12:23 PM LESLEY, BONNIE BABBS, JUNIOUS
Mitchell, Sadie
GADBERRY, BRADY L.
STEWART, DONALD M. Upper Division Classes and African Americans 74^ Were you able to pull together the numbers-last year and this year's enrollment? John Walker also has called and is questioning his non involvement in the policy development(IKF). I told him I thought the evidence was so strong for Black kids and that I would send him the information. When was the first time he would have received the policy for comment? He is raising much the same issue-impact on black kids as Katherine...IKF\ \ Cc: Subject LESLEY. BONNIE: CARNINE. LESLIE V. RE: Chart Revisions Ken, _ Thanks so much for this explanation of what happened, i he important thing about making a mistake is finding a way not to make it again. I think you have done this, and we will all profit from it. I know you feel really badly about this, but the most important thing is to correct the process. We all make mistakes. We are committed to quality in PRE and that includes continuous improvement and continuous learning. This experience has provided us with both. What a bonus!! Thanks for helping with the corrections. I will take care of getting them to the appropriate Cabinet people and getting them redistributed to the Board. -----Original Message----- From: Sent: To: Subject: Dr Lease, SAVAGE. KEN Tuesday. November 21, 2000 10:31 AM LEASE. KATHY R. Chart Revisions I have reviewed the charts that I created from the benchmark data. When I created the charts originally I had encountered a problem similar to the one described by Dr. Lesley, but I specifically remember correcting the error prior to sending the charts to you. Needless to say, I was more than a little alanned that the charts you received contained errors because the charts I have appear to coincide with the data I have. I went on further to investigate by looking at the email I sent you. And there, big as day, the error had reappeared. So the charts I had sent you were incorrect because they were never updated in the manner that I expected. Here is what I believe happened based on what I remember and what I learned this morning: I created the charts in an Excel document that contained the data. 1 copied the charts only out into another document, creating what is called a linked object. I printed and reviewed the charts and this is when I found the error. I corrected the error and reopened the "linked charts. They appear to have accepted the corrections. I emailed the file with the linked charts to you rather than the file containing the charts and data. Heres where the problem arose and information that I have just become aware of this morning. First, when using linked objects, each time you open the file you are given a choice to update the information. Unfortunately, 1 only sent you the charts and not the data that drives them. So regardless, you could not have updated the charts. Second, and more importantly, even though a chart has been updated previously, it will always revert back to the original chart that was corrected no matter how many times the data has been updated. Third, if the file with the original data is already open, when the linked item is opened it automatically updates without intervention. I believe that the second option above is what occurred. The charts were created, an error was encountered and corrected, the link was updated but the chart reverted back to its original when the file was closed. What 1 propose to do to prevent this kind of fiasco in the future is: 1. Only send charts embedded in files which contain the data--no linking. 2. Only create the linked charts after ALL data has been proofed and corrected. The erroneous data was only last year's data for black students in the comparison between this year and last'year for both Math and Literacy. I am printing and will send ten revised copies of the charts. Ken. 38 LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Wednesday, March 07, 2001 12:44 PM BABBS, JUNIOUS- RE: Research Committee Meeting 7JO Bonnie said that the evaluations weren't part of the court submission. Is that still correct? If so, then it looks like we should slow down a bit and do it rignt. are you in agreement? - ' KL ----------------------------- -------------- Original Message From: Sent: To: Subject: BASES, JUNIOUS Wednesday, March 07, 2001 12:36 PM LEASE, KATHY R. RE
Research Committee Meeting Orioinai thinking was to get another date scheduled prior to the March 15th court submission but with information you have noted, consideration of a later date is necessary. I don't see major conflict. Junious C Babbs, Jr )Cbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District -Original Message----- From
Sent: To: Subject: Importance: High LEASE, KATHY R. Wednesday. March 07, 2001 12:27 PM 'trrose@ualr.edu'
BABBS, JUNIOUS Research Committee Meeting We have had another committee member who will not be able to come to the meeting on the 13th. We now have agenda meeting at 5:00, and Steve can only be with us by phone. What do you all think about postponing the meeting until after spring break? That would give John plenty of time to make revisions, and we can schedule a meeting when Steve can be w'ith us. I hope to have the template/program evaluation guidelines completed by then as well. Let me know what you think! Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 7LESLEY, BONNIE From: Sent: To: Subject
LESLEY, BONNIE Monday, July 16, 2001 z
24 PM MITCHELL, SADIE RE
Documents yes, thanks. I need asap. -----Original Message----- From: Sent: To: Cc: Subject: MITCHELL, SADIE Monday, July 16, 2001 5:51 PM LESLEY, BONNIE WASHINGTON, CHARLOTTE Documents We got the list of documents on file done but I forgot to remind Charlotte to send it to you. She is gone for the day and it is on her computer. You will have it first thing in the morning. Sadie Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 16, 2001 7:24 PM WARD, LIONEL RE
SAIP He requested info from me. I told him I had given him all I had but that you are the administrator on this issue. I was following up to see if he had contacted you. -----Original Message----- From: Sent To: Subject: WARD, LIONEL Monday, July 16, 2001 4:29 PM LESLEY, BONNIE RE: SAIP Are you trying to tell me something? I have not received any such request from Mr. Walker. If he talks with me, I will talk to you about a proper response first. One basic problem with implementation is in the thought some might harbor which explains why their efforts started late in the game. I am sure some folks faced more struggles than others. Clearly, schools must satisfy the requirements v/ith wise, careful and timely deliberations this year. Original Message From: Sent: To: LESLEY, BONNIE Sunday, July 15, 2001 3:49 PM WARD, LIONEL Subject: SAIP Lionel, has Mr. Walker requested anything from you about the implementation of SAIPs? If so, what did you send to him? Thanks. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 88501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE. Monday, July 16, 2001 8
16 AM JAMES, KENNETH RE: Work in Progress Absolutely! Original Message From: Sent To
Subject: JAMES, KENNETH Monday, July 16, 2001 7:54 AM LESLEY, BONNIE RE
Work in Progress Bonnie: I agree. The work and time that you have invested in this will indeed pay off. as the testimony unfolds. It will be interesting to see how the judge handles all of this information and to observe her thought process. Ken Original Message From: Sent: To: LESLEY, BONNIE Sunday, July IS, 2001 9:42 PM JAMES, KENNETH Subject: RE
Work in Progress When I left today, I left a lot still un-done, but I left feeling more and more certain that we have strong evidence that we did the plan. This is going to be helpful to me in remembering all the effortseven if Chris decides not to use some of it as evidence. I think it will particularly be strong when we combine what Sadie has with ours in this Division. -----Original Message----- From
Sent
To: LESLEY, BONNIE JAMES, KENNETH Sunday, July 15, 2001 9:34 PM Subject: RE: Work in Progress Bonnie
I have reviewed both documents and they are excellent at showing what has been accomplished in the areas of evaluation and assessment Great job! We will touch base tomorrow. Ken Original Message----- From: Sent: To: Subject: LESLEY, BONNIE Saturday, July 14, 2001 6:24 PM 'helle.r@fec.net
JAMES, KENNETH
MITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback. File: 1 Program cvaluation.doc File: 1 Assessment Grid.doc 96Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject
LESLEY, BONNIE Sunday, July 15, 2001 3:41 PM 'heller@fec.net' JAMES, KENNETH SAIPs Mr. Walker requested on June 20 the follow: "Please advise whether you have information regarding the District's implementation of STudent Academic Improvement Plan (SAIP) as required by the State. If so, please share with this this office." 1 replied: "You will find that information in the March 2001 Compliance Report in Section 2.7. I do not have any information beyond what you will rind there since the implementation is done at the school level. Leonel Ward is in charge of implementation." When I searched everything for the documents I needed from you, I found several memos in Learning Links that I had forgotten about-about the philosophy in implementing SAIP, sample SAIPs done by Price, Glasgow, and Davis, the memo establishing the committee to develop the program, the memo to the board, etc. Should I forward those to Mr, Walker as well?. Dr, Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From
Sent
To: Subject: LESLEY, BONNIE Saturday, July 14, 2001 6:24 PM 'heller@fec.net'
JAMES, KENNETH
MITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback. s 1 Program Evaluation.Qoc 1 Assessment Grid.doc Dr. Bonnie A. Lesley, Associate Supe.hntendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 102LESLEY, BONNIE From: Sent: To: Cc: Subject: Don Crary [dcrary@newfuturesforyouth.org] Wednesday, April 18, 2001 1:33 PM LESLEY, BONNIE mopierce@newfuturesforyouth.org Re: Computer with Access Great. We can pay for it. I'm sure it will be cheaper if it is purchased through the district contract. The district can invoice us and we will reimburse them for the cost. Don -----Original Message From: LESLEY, BONNIE <BALESLE@IRC.LRSD.K12.AR.US> > To: 'dcrary@newfuturesforyouth.org' <dcrary@newfuturesforyouth.org Cc: BRIGGS, MONA R. <MRBRIGG@ANNEX.LRSD.K12.AR.US>
PAAL, MARY M. <MrVIPAAL@ANNEX.LRSD.K12.AR.US> Date: 04/18/2001 12:50 PM Subject: Computer with Access >l talked with Mona about your need for a dedicated computer somewhere in the >district so that your evaluator can come work on direct access to the data >base. She is arranging for an additional computer drop in the office that >Mary Paal will have at Garland. Can you all purchase the computer out of >your budget? > >Dr. Bonnie A. Lesley, Associate Superintendent for Instruction >Little Rock School District >3001 S. Pulaski >Little Rock, Arkansas 72206 >501/324-2131 >501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject: LEASE, KATHY R. Wednesday, April 18, 2001 12:32 PM LESLEY, BONNIE MITCHELL, SADIE
CAWTHON, FRANCES H.
LACEY, MARIAN G. RE: ALT Results Bonnie, did you meet with yesterday? Do I need to contact them? I explained to all of them when we What group of principals ot tnem wnen did the testing calendar that we could get results back to everyone before school was out, if they followed the schedule. If there are some that we need to follow up with, please let me know who they are. We are returning ALT results as quickly as schools get them in. The whole purpose of setting up the schedule like it is centers around being able to get the results back to everyone before school is out. District results can't be calculated until all schools are in. That is why it is imperative that everyone stay on schedule. Both teachers and parents will get their results unless someone doesn't follow the schedule. Second grade results have all been returned to the schools, along with two copies of the parent report. High school preliminary results have been returned to Parkview and Fair. McClellan's results are here and are being scored. Central and Hall have not turned in their answer sheets yet. All make-ups were to have been completed by this past Monday. Retests for high schools are due back on Friday. The first page of the parent report can be printed, but we can't print the longitudinal report for parents unless all high schools are in. 70875^ Our elementary schools did a great job during 2nd grade testing
so if they keep that up, we will sail right through their scoring and printino. They have all of their results. We're still missina two of the middle schools' Algebra I / geometry results as of this morning. We are having a scoring problem with the high school science tests, but NWEA is working on it. The subject specific math and science tests require no retests, so that shouldn't hold things up. . . . Also, we have provided data on request any school who wants to know last fall's ALT scores for their rising grade students. If you have any other questions, please let me know. Kathy Original Message From: Sent: To: Subject: LESLEY, BONNIE Wednesday, April 18, 2001 10:37 AM LEASE, KATHY R. ALT Results I met with a group of principals yesterday who suggested to me that if they can't receive their ALT results before school is out that there is no use in sending them at all. Kids and parents need them quickly, and the school needs them quickly in order to plan for next school year. What our your chances of being able to do that? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: Paulette Mabry [pmabry(gnewfuturesforyouth.org] Wednesday, April 18, 2001 10:59 AM Bonnie Lesley
Brady Gadberry
Junious Babbs
Linda Austin
Marian G. Lacey
Sadie Mitchell Words to encourage us Rosedoc Thought you might enjoy this today as a way to jumpstart the afternoon when things seem impossible. Paulette LESLEY, BONNIE From: Sent: To: Subject: BRIGGS. MONA R. Wednesday, April 18, 2001 10:10 AM LESLEY, BONNIE Cost of Tools for Learning (Fred Jones)
Parent Component Importance: High The discounted costs of books is: 500 books @ $18.00 (regularly priced at 29.95) 300-499 @ $18.50 200-299 @ $18.95 100-199 @ $19.95 Shipping for 500 is S546.75
it may be slightly less for fewer numbers but not significantly. RE
Parent involvement with training 709GADBERRY, BRADY L. 735 From: Sent: To: Subject: LEASE, KATHY R. Tuesday, November 28, 2000 4:31 PM BABBS, JUNIOUS: FRANCES CAWTHON
Gadberry, Brady L
Hurley, Richard: LESLEY, BONNIE: Leslie Camine: LINDA WATSON: MARIAN LACEY: Milhollen, Mark: Sadie Mitchell: STEWART, DONALD M.: Vann, Suellen Steve Ross-Program Evaluation.ppt Steve Ross-Program Evaluation__ KL FYI--Here is a copy of Steve's presentation to the Board. GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Thursday, November 16, 2000 8:32 AM GADBERRY, BRADY L. RE
PRE List Requested I shared with Babbs that I thought we could provide some assistance in PRE to make the surveying process a little easier We've got the equipment and the software! I just talked with Gene Jones to confirm his schedule, and he said that he was invited to the compliance meeting tomorrow morning. I told him, "Great! See you then!" KL Original Message From: Sent: To: Cc: Subject: GADBERRY, BRADY L. Thursday, November 16, 2000 8:17 AM BABBS, JUNIOUS LEASE, KATHY R. RE: PRE List Requested We were told early in the year by Dr. Camine that all surveys would be done through PRE. -----Original Message----- From: BABBS, JUNIOUS Sent: Tuesday, November 14, 2000 7:15 PM To: GADBERRY, BRADY L. Cc: LEASE, KATHY R. Subject: FW
PRE List Requested To my knowledge Vic and I both allowed department "Quality of Service Surveys" that went to appropriate building staff to be returned and worked through our own division shops. What is your thinking to continue with this format or consideration through PRE ? Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message From: Sent: To: Cc: Subject: LEASE, KATHY R. Friday, November 10, 2000 12:18 AM Clay Fendley"
LESLEY, BONNIE
BABBS, JUNIOUS
MITCHELL, SADIE
GADBERRY, BRADY L.
STEWART, DONALD M. CARNINE, LESLIE V. List Requested Dear Folks, Attached is the list of programs or strategies that have either received some evaluation services or have requested evaluation services. If you need additional information, please let me know. 15 Thanks, Kathy File
Additional Programs and Strategies Requesting Evaluation.doc GADBERRY, BRADY L. From
Sent: To: Subject: LEASE, KATHY R. Friday, October 27, 2000 2:52 PM MITCHELL, SADIE
LESLEY, BONNIE
BABBS, JUNIOUS
GADBERRY, BRADY L
STEWART, DONALD M. Memo to Gene Jones 0 logo memo.doc know ASAP. KL Here is what I am having Irma send on Monday. If you see anything that needs to be changed, let her GADBERRY, BRADY L. From: Sent: To
Subject
LEASE, KATHY R. Wednesday, October 25, 2000 8:37 PM CARNINE, LESLIE V.
MITCHELL, SADIE
BABBS, JUNIOUS
GADBERRY, BRADY L. FW
Benchmark Scores Dear Folks. If Bonnie wants to continually harass me that is one thing, but I would appreciate it if she didn't pick on my assistant. Please read the exchanges below. She also left Irma a voice message that was very curt. Irma has been working like a dog in room 16 to finish up the answer documents for the CRTs, so she wasn't immediately available to read email or answer the telephone. No one came down here looking for her, so she didn't know that there was an urgent message. I emailed a reply message to Bonnie and sent you all a blind copy
so I'm sure I'll be in trouble again. However, there has to be an end to this. We are working as hard as we can to produce these test reports, implement the assessment program, and produce program evaluations. I don't know how much more I can stand. She also continues to work behind my back through Eddie McCoy. This is ridiculous!! Who could be successful in such an environment? I'm sorry for ranting, but I am exhausted mentally, physically, and emotionally. Kathy Original Message From: Sent: To: Subject: TRUETT, IRMA Wednesday, October 25, 2000 8:21 PM LEASE, KATHY R. FW: Benchmark Scores Original Message From: Sent: To: Subject: LESLEY, BONNIE Wednesday, October 25, 2000 5:05 PM TRUETT, IRMA RE: Benchmark Scores I'm sorry, Irma, but I can't accept that response. -----Original Message From: Sent: To: Subject: TRUETT, IRMA Wednesday. October 25. 2000 2:08 PM LESLEY, BONNIE RE: Benchmark Scores Sorry, I'm just now getting your e-mail, but Ive been working in room 16. I don't have this information and from what I understand Dr. Lease has it with her to give to the principals this afternoon. Sorry! Original Message 16 From: Sent: To: LESLEY. BONNIE Wednesday. October 25. 2000 9:44 AM TRUETT. IRMA 7^3 Subject: Benchmark Scores I need copies of the state test results by school in my office asap. Board members and others are calling for information. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Wednesday, October 25, 2000 8:17 PM LESLEY, BONNIE Benchmark Scores ?rma forwarded your messages to her about the test scores. As I told you when we met with Suellen, I would have your curriculum copies ready by Friday. They are ready now. After learning that you were insistent on having the scores immediately I stayed late tonight and finished them up. Irma came back down here from home to help me. I am iust waiting on your initials on the memos. I will bring them to the Institute tomorrow. Irma can come pick them up and make copies I understood Dr. Carnine to say that the Board reports could be sent in the Friday report. I had them readv at the Board meeting but he didn't want them distributed until we had more time to confirm the data. Since you have asked for them I printed what we have at this time in draft copy. I will give the copies to you that are printed for the Board. If you think they need to be sent by special courier rather than in the Friday report, that will be your choice. I was only trying to follow the directions I was given. ..... , u If you needed the scores so guickly. why didn't you call me out of the meeting today? Irma didn t even know where we had secured the copies of the reports. It was very unfair of you to keep harassing her and making her feel badly because ~ 1 > ir.____ J f-i-iz-. tkrt oAi iHocu Mt ck'inn mo tnr it i nau becuieu iHti cuuic:> UI uic
icpwiio. It w. ,.r
--------\l -t c jt i she couldn't oroduce the reports instantly for you. If you need something, please do me the courtesy of asking me for it. I r .. . . < ________L'.-C_____________:tU . . U /z>t I okzM ilrl Izif ma Ln/^VA/ understood that the Friday timeline was satisfactory with you. If it wasnt, you should have let me know. Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 17Subject: RE: This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Friday! Original Message From: Sent: To: Subject: BRIGGS, MONA R. Thursday, June 28, 2001 8:00 PM LESLEY, BONNIE RE: Bonnie, I hate all this, don't you? I guess you will have your day in court." Too bad Kathy didn't get in on it...I understand from Eddie that she took all her files with her. What a deal. Surelv, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 "Seek First to Understand
then to be understood^ (Covey) -----Original Message------ From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN
SLENN, RANDALL
WATSON, LINDA
ELSTON, JO
WIEDOWER, JULIE
ESSLESTON, DEANA
ADAMS, LEON
ARNOLD, LAURA BETH
AUSTIN, LINDA
BRANDON, BARBARA
BRIGGS, MONA R.
BROADNAX, KAREN
BUSBEA, PAT
CARR, MARCELLINE
CARSON, RENE'
CLEAVER, VANESSA
CLIFFORD, ELIZABETH
CRAWFORD, PAMELA
DAVIS, SUZI
DEBBIE MILAM
DILLINGHAM, YVETTE
DONALDSON, MABLE
FINNEY, ANTONETTE
FLETCHER, DANNY
FREEMAN, ANN
GILLIAM, ANITA
GLASGOW, DENNIS
HARDING, CASSANDRA
HUFFMAN, KRIS
JACKSON, MARION
JOHNSON, VIRGINIA
JONES, DOCIA
JONES, STEPHANIE
. 192Subject: RE: 751 This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Friday! Original Message From
Sent: To: Subject: BRIGGS, MONA R. Thursday, June 28, 2001 8:00 PM LESLEY, BONNIE RE: Bonnie, I hate all this, don't you? I guess you will have your "day in court." Too bad Kathy didn't get in on it...I understand from Eddie that she took all her files with her. What a deal. Surely, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 "Seek First to Understand: then to be understood!' -----Original Message------ From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN
CLENN, RANDALL
WATSON, LINDA
ELSTON, JO
WIEDOWER, JULIE
ECSLESTON, DEANA
ADAMS, LEON
ARNOLD, LAURA BETH
AUSTIN, LINDA
BRANDON, BARBARA
BRieOS, MONA R.
BROADNAX, KAREN
BUSBEA, PAT
CARR, MARCELLINE
CARSON, RENE'
CLEAVER, VANESSA
CLIFFORD, ELIZABETH
CRAWFORD, PAMELA
DAVIS, SUZI
DEBBIE MILAM
DILLINGHAM, YVETTE
DONALDSON, MABLE
FINNEY, ANTONETTE
FLETCHER, DANNY
FREEMAN, ANN
GILLIAM, ANITA
GLASGOW, DENNIS
HARDING, CASSANDRA
HUFFMAN, KRIS
JACKSON, MARION
JOHNSON, VIRGINIA
JONES, DOCIA
JONES, STEPHANIE
192Cc: KIILSSAARD, SHARObJ
KILLINSSWORTH, PATRICIA
KOVACH, RENEE
LA JUAN A RAINEY
LOYA, STELLA
MARION BALDWIN
MARTEN, PAULETTE
McCOY, EDDIE
McNEAL, MARIE
MILAM, JUDY
NEAL, LUCY
PAAL, MARY M.: PAUL, ANNITA
PERRITT, YORIKO U.
PRICE, PATRICIA
RYNDERS, PAULA
SMITH, CARY
SMITH, PAULA
TEETER, JUDY
WALLS, COLLEEN
WARD, LIONEL
WILLIAMS, BARBARA
WILLIAMS, ED
WILSON, LEVANNA
WOODS, MARION 'heller@fec.net' Subject: I just spoke with Chris Heller, our attorney. He asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Please make sure the staff not named in this e-mail also understand this directive. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To
Subject
LESLEY, BONNIE Friday, June 29, 2001 2:47 PM ADAMS, LEON
ARNOLD, LAURA BETH
AUSTIN, LINDA
BRANDON, BARBARA
BRIGGS, MONA R.
BROADNAX, KAREN
BUSBEA, PAT
CARR, MARCELLINE
CARSON, RENE'
CLEAVER, VANESSA
CLIFFORD, ELIZABETH
CRAWFORD, PAMELA
DAVIS, SUZI
DEBBIE MILAM
DILLINGHAM, YVETTE
DONALDSON, MABLE
FINNEY, ANTONETTE
FLETCHER, DANNY
FREEMAN, ANN
GILLIAM, ANITA
GLASGOW, DENNIS
HARDING, CASSANDRA
HUFFMAN, KRIS
JACKSON, MARION
JOHNSON, VIRGINIA
JONES, DOCIA
JONES, STEPHANIE
KIILSG/V\RD, SHARON
KILLINGSWORTH, PATRICIA
KOVACH, RENEE
LAJUANA RAINEY
LOYA, STELLA
MARION BALDWIN
MARTIN, PAULETTE
McCOY, EDDIE
McNEAL, MARIE
MILAM, JUDY
NEAL, LUCY
PAAL, MARY M.
PAUL, ANNITA
PERRITT, YORIKO U.
PRICE, PATRICIA
RYNDERS, PAULA
SMITH, GARY
SMITH, PAULA
TEETER, JUDY
WALLS, COLLEEN
WARD, LIONEL
WILLIAMS, BARBARA
WILLIAMS, ED
WILSON, LEVANNA
WOODS, MARION
BABBS, JUNIOUS
FRANCES CAWTHON
GADBERRY, BRADY L
HURLEY, RICHARD
JAMES, KENNETH
LINDA WATSON
MARIAN LACEY
MILHOLLEN, MARK
Sadie Mitchell
STEWART, DONALD M.
VANN, SUELLEN
WATSON, LINDA
ANDERSON, BARBARA
ASHLEY, VIRGINIA
BRANCH, SAMUEL
BROOKS, SHARON
CARSON, CHERYL
CARTER, LILLIE
COURTNEY, THERESA
COX, ELEANOR
DARIAN SMITH
DEBORAH MITCHELL
ETHEL DUNBAR
Faith Donovan
FIELDS, FREDERICK
GOLSTON, MARY
HALL, DONNA
HARKEY, JANE
HOBBS, FELICIA L
JONES, BEVERLY
KEOWN, ADA
Lillie Scull
MANGAN, ANN
MANNO, ROBERTA
MARY BARKSDALE
MENKING, MARY
MORGAN, SCOTT
NANCY ACRE
OLIVER, MICHAEL
PHILLIPS, TABITHA
SHARON BROOKS
SMITH, MARY
TAYLOR, LESLIE
TUCKER, JANIS A.
WILSON, JANICE M.
WORM, JERRY
ZEIGLER, GWEN S.
BERRY, DEBORAH
BLAYLOCK, ANN
FULLERTON, JAMES
HUDSON, ELOUISE
Larry Buck
MOSBY, JIMMY
PATTERSON, DAVID
ROUSSEAU, NANCY
SAIN, LLOYD DRA Results by Middle School Feeder Pattern 193 the ALTS, and so they were down there yesterday and again today just kind of picking it up, but they do not necessarily know' what they are supposed to be doing. They need direction, and I don't feel that I should provide it. How do you want to handle this? LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Monday, October 02, 2000 6:48 PM CARNINE, LESLIE V. FW: Priorities 2000-2001 Dr. C., I'm sorry. I guess I don't quite know what to do with the plan I sent to Bonnie. I guess I missed the mark. I thought we were to develop what we were doing in our department to meet the areas you outlined in your critical priorities processes. Do you want me to send the parts to the people Bonnie mentioned below? Or are you going to put it all together using what you want out of what we sent? Let me know what you want me to do. KL Original Message----- From: Sent
To
Subject: LESLEY, BONNIE Friday, September 29, 2000 3:04 PM LEASE, KATHY R. RE: Priorities 2000-2001 You need to send the technology stuff to Lucy Neal. You need to send the Campus Leadership stuff to Sadie Mitchell. I suggest that you forward the other two pieces directly to Dr. Carnine. They are much more detailed than the other items in the Division of Instruction Work Plan and therefore don't "fit" with what we have, /^si^ I know nothing about the_Quality Initiative Plan, so that makes no sense, to. me. Perhaps he can just include your items separately. .......... ~ -----Original Message From
Sent: To: Subject: LEASE, KATHY R. Friday, September 29, 2000 2:50 PM LESLEY, BONNIE Priorities 2000-2001 Importance: High I had massive computer failures today. It took Ed, Ken, Virginia, and Irma to help me get it all back. Here are the priorities from PRE. Call me, if you want me to go over them with you. Thanks, Kathy File: Priority II Technology 2000-2001.doc File: Priority lll-2000.doc Assessmentdoc File: Priority IV lnstruction-evaluation.doc File: Priority IV instruction- Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 51sounds like the our data is available. LESLEY, BONNIE From
Sent
To
Subject
LEASE, KATHY R. Tuesday, October 03, 2000 6:09 PM CARNINE. LESLIE V. CTA issues 75^1 Did Clementine come in today to discuss assessment issues with you? I invited her in last spring to talk with me, but she never came. If she has some specific issues that you think we need to address in the questionnaire, let me know. I started drafting some ideas about questions, but I think 1 need some input from you. It looks like from one of the emails you sent that folks have been communicating with you about their concerns. They may have shared some things we haven't thought about. Let me know if you have any time tomorrow afternoon to visit with me (phone or in person) about the survey. Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To
Subject: LEASE, KATHY R. Tuesday, October 03, 2000 5:45 PM CARNINE, LESLIE V. RE: ALT Check-In, Etc. This is pure fabrication. This is not the situation here in PRE. We have a fox in the hen house. 1 thought this kind of thing was supposed to be over. The digs have continued. The ALT process has to have someone who shepherds it. I said originally that I would need Gayle at least six weeks to two months. I fully understand the strain that Sadie is under because she has come to depend on Gayle as well. If Gayle cannot fulfill her commitment with ALT, then I think she would let me know. She had to go over to the administration building to get some work done to be ready for the Bi-Racial committee report that she is scheduled to give tonight. Roz told her that she could take care of anyone who checked in things today. I guess the real question is that if my staff thinks they are having a problem "handling" the ALT today, why didn't they contact me? We had Ed here scanning and scoring, and Irma received no calls that she couldn't handle. I'm afraid 1 am left with no other conclusion but that this is continued harassment by the person that I thought had agreed to quit harassing. Can you help me with any other explanation? KL Original Message----- From
Sent To: Cc: Subject: CARNINE. LESLIE V. Tuesday, October 03, 2000 11:10 AM LEASE, KATHY R. Mitchell, Sadie FW: ALT Check-In, Etc. I know you know how assumptions can get you in trouble. Obviously, there appears to be a communication problem and I would hope you and Sadie could work it out. Original Message From: Sent
To: Subject: LESLEY, BONNIE Tuesday, October 03, 2000 10:55 AM CARNINE, LESLIE V. ALT Check-In, Etc. I have had three complaints already today-two from IRC staff and one from building-level. Gayle has returned to downtown, and Kathy is sitting in the school improvement meetings. Neither of them organized the staff for the return of 50LESLEY, BONNIE From
Sent: To: Subject
LESLEY, BONNIE Wednesday, June 20, 2001 1:13 PM GRIFFIN, BEVERLY RE: Semester Test Exemption Thanks, Bev. -----Original Message----- From: Sent: To: Subject: GRIFFIN, BEVERLY Wednesday, June 20, 2001 1:15 PM LESLEY, BONNIE RE: Semester Test Exemption I gave a copy of the minutes from the February Board meeting to Mrs. Lacey earlier this week. I don't think I have a copy of the kids proposal, but I will check. I was under the impression that this action was for this year's seniors only. I might be wrong . . . but, it might be worth
checking with Board members to see if they intended for it to be a permanent change to the policy. I will fax you the minutes in just a minute. Original Message----- From: Sent: To: LESLEY, BONNIE Wednesday, June 20, 2001 12:51 PM GRIFFIN, BEVERLY Subject: Semester Test Exemption Bev, there is wide disagreement about what people remember as the motion the board made regarding the exemption of seniors from their spring semester tests. I don't remember the month they did thatprobably February or March? Will you send to me the text of the motion, as well as the text of the language used by the , kids in their proposal. I don't have that and will need it to update those regulations/poiicies. i Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock,.Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Wednesday, June 20, 2001 1:12 PM TRUETT, IRMA Compliance The compliance report lists several "program evaluations" that PRE reported that they had completed, but which I have never seen. Please provide me with three copies each of the following reports. They have been requested by Mr. Walker. Extended Year Schools Summer School HIPPY Program Charter School Campus Leadership Teams English as a Second Language Lyceum Scholars Program at Philander Smith College Southwest Middle School's SEDL Program Onward to Excellence (Watson Elementary) Collaborative Action Tearn (CAT) 3S1LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, June 25, 2001 12:37 PM 'Clay Fendley'
'heller@fec.net' RE: Meeting schedule Yea! Thanks you! I can't tell you how important this is! I just talked with Ann Brown. She wanted all the test scores. I put her off until the end of the week. We need to talk about what to give her. -----Original Message From: Sent: To: Cc: Subject: Clay Fendley [SMTP:FENDLEY@fec.net] Monday, June 25, 2001 12:42 PM BALESLE@IRC.LRSD.K12.AR.US Chris Heller RE: Meeting schedule Leaving at 1:05 on the 6th is fine. We will tell Walker that if he wants to call you as a witness, he will need to call you on the 5th. Thanks. > "LESLEY, BONNIE" <BALESLE@IRC.LRSD.K12.AR.US> 06/25/01 11:49AM > I just called the airlines. I would need to catch a plane at 1:05 on the 6th to get to Amarillo in time for the rehearsal dinner for this big wedding. If I can't do that, then the latest I could leave to get there at all on Friday is at 5:35. Then I would come home on Sunday. What do you advise? >-----Original Message----- > From: Clay Fendley [SMTP:FENDLEY@fec.net] > Sent: Monday, June 25, 2001 9:41 AM > To: BALESLE@IRC.LRSD.K12.AR.US
blgadbe@lrsdadm.lrsd.k12.ar.us
DMSTEWA@lrsdadm.lrsd.k12.ar.us
Ivcarni@lrsdadm.lrsd.k12.ar.us
SMMitch@lrsdadm.lrsd.k12.ar.us
JCBABBS@STUASN.LRSD.K12.AR.US > Cc: Chris Heller
KJAMES@lrsdadm.lrsd.k12.ar.us Subject: Meeting schedule > > > Here's the meeting schedule so far Mr. Gadberry - Wednesday at 2:00 at our office. Dr. Lesley - Thursday at 1:00 at our office. Ms. Mitchell - Friday at 9:00 at our office. > > We should get Joshua's objections today and have requested a witness list > by Wednesday. > We are leaving Monday (July 2) open until we get Joshua's witness list. > Everybody plan on meeting Tuesday (July 3) all day at our office. Let me > know if that presents a problem for you, and we can try to work around > your schedule. > > Remember, the most important thing in preparation for the hearing is for > you to know what's in the Revised Plan and the interim and final > compliance reports. > > We will provide copies of Joshua's objections as soon as they are > received. > Let me know if you have any questions. 297 76 Z selected to receive Merit Scholarship*' awards. The info in italics is from the National Merit web site. So, of the 1.2 million entrants, only 7,900 are named Finahsts for National Merit scholarships and corporate-sponsored scholarships. That amounts to 6/10 of 1 % of the entrants. Mr. Walker's statement on page 22 is: "We note here that the district is yet to have a single Black national merit scholar in the nineteen years of this active litigation." THIS IS INCORRECT. Without reviewing 19 years of data (and we don't have all of the data for those years), as recently as 4 years ago Salonica Gray, an Afiican American female senior at Central, was a National Merit Finalist. Hope this helps! Suellen S. Vann, APR Director of Communications Little Rock School District (501) 324-2020 LESLEY, BONNIE From: Sent
To: Subject: LESLEY, BONNIE Thursday, June 28, 200T 11:36 AM MITCHELL, SADIE RE
I am wondering how he is feeling as well. This is baptism by fire. -----Original Message From: Sent: To: Subject: MITCHELL, SADIE Thursday, June 28, 2001 9:29 AM LESLEY, BONNIE RE: I panicked when I got here and saw all of the stuff from John. I am worried about Dr. James. I hope he will be able to handle all of this. Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us Original Message----- From
Sent To: Subject
LESLEY, BONNIE Thursday, June 28, 2001 9:09 AM MITCHELL, SADIE RE: He was kind of angry that we are even attempting to respond to this stuff. He asked me what he needed to do to make sure everyone understands that we are not to play Mr. Walker's game. How ya doing today? Original Message----- From: Sent: To: LESLEY, BONNIE MITCHELL. SADIE Thursday, June 28, 2001 9:18 AM Subject: RE
:) Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 218762. Original Message From: Sent: To: Cc: Subject: LESLEY, BONNIE Thursday, June 28, 2001 9:04 AM MITCHELL, SADIE
EGGLESTON, DEANA: GADBERRY, BRADY L
STEWART. DONALD M BABBS JUNIOUS
JAMES, KENNETH 'heller@fec.net' RE: I just spoke with Chris Heller, and he asked me to tell all of you that we are not going to make this information (copies of our invitations and documents sent to Mr.Walker or Ms. Springer) available to Mr. Walker. It is without exception stuff we have already sent to him. He also asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Original Message From: Sent: To: Cc: Subject: MITCHELL, SADIE Thursday, June 28, 2001 9:03 AM EGGLESTON, DEANA LESLEY, BONNIE
GADBERRY, BRADY L.
STEWART, DONALD M.
BABBS, JUNIOUS RE: Thank you Sadie Mitchell srnmitch@lrsdadm.lrsd.kl2.ar.us -----Original Message From: Sent: To: Cc: Subject: EGGLESTON.DEANA Thursday, June 28, 2001 8:38 AM MITCHELL, SADIE BABBS, JUNIOUS RE: Everyone sent the information when it was requested, however. I'm not sure if they have sent recent documents since his original request. I just spoke with Clay and he said to make the folders we have available to Joy on Monday as per her request, but for me to not to put the documents in any particular order (ie. date, subject, etc.) Deana Original Message From: Sent: To: Cc: Subject: MITCHELL, SADIE Thursday, June 28, 2001 8:41 AM LESLEY, BONNIE
STEWART, DONALD M.
GADBERRY, BRADY L
BABBS, JUNIOUS
JAMES, KENNETH EGGLESTON, DEANA Mr. Walker sent a fax requesting "all invitations to Ms. Springer or Mr. Walker to meetings of any kind, as well as copies of any documents you have sent to them over the past three years. Also any document of whether Mr. Walker or Ms. Springer actually attended the meetings to which you invited them." I think we already sent this information to Mr. Babbs and he compiled it. Is this correct? Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 219LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:54 PM CARNINE, LESLIE V. FW: Test Pack Importance: High Dr. Camine, What is the purpose of this? Am I missing something? Is Bonnie trying to eliminate her need to work with this department? We have some software that is licensed to this department. Eddie has been trying to get it loaded on her computer. My guess is that she needs it to work on her dissertation. She has not spoken to me about what her data needs are for her dissertation. Most doctoral candidates come in and visit with us about their data needs. We work with them, but they get data in an aggregate form, not individual students' information. I wish you would please tell me what role you want this department to play. I know the game that is being played. I am about to my wit's end with it. Kathy -----Original Message----- From: Sent To: Subject: JOHNSON, VIRGINIA Tuesday, February 13, 2001 12:43 PM LEASE, KATHY R. FW: Test Pack Original Message From: Sent To
Cc: Subject LESLEY, BONNIE Monday, February 12, 2001 5:31 PM RUFFINS, JOHN JOHNSON, VIRGINIA
McCOY, EDDIE
CLEAVER, VANESSA RE: Test Pack Thanks so much, JOhn. -Original Message From
Sent To
Subject RUFFINS, JOHN Monday, February 12, 2001 4:46 PM LESLEY, BONNIE RE: Test Pack I will come over and personally visit with Virginia and Eddie to access their data and program needs. From: Sent: To: Original Message- LESLEY, BONNIE Monday, February 12, 2001 2:40 PM RUFFINS, JOHN Subject: Test Pack John, 1 am moving Eddie McCoy and Virginia Johnson out of the rooms designated for PRE and into the room where Vanessa Cleaver is. Both of them will have some program evaluation responsibilities and need to be able to access the SAT9 data, as well as other student data. How do I get those programs loaded onto their machines? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 SOl/324-2131 S01/324-0S67 (fax) 19 " LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 5:36 PM CARNINE, LESLIE V. RE: Another thought Here's one more thought, then I'm burying this frustration. I wouldn't have known about what she is doing at all if Virginia hadn't forwarded me a copy of the message. I'm trapped in junior high!!! Can't somebody save me??? Kathy Original Message From: Sent: To: Subject: CARNINE, LESLIE V. Tuesday, February 13, 2001 4:05 PM LEASE, KATHY R. RE
Another thought I can support but you do not want to hold the data... You want free access. Give her ail the access she wants or needs... and then give her more. -----Original Message From
Sent
To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in ail my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 4:10 PM CARNINE, LESLIE V. RE: Another thought I totally agree with that. I want everyone to have access to the data at his or her fingertips. I just continue to be frustrated with the way she refuses to work with me. Kathy Original Message From: Sent: To: Subject: CARNINE, LESLIE V. Tuesday, February 13, 2001 4:05 PM LEASE, KATHY R. RE
Another thought I can support but you do not want to hold the data... You want free access. Give her all the access she wants or needs... and then give her more. -----Original Message From: Sent
To: Subject
LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought 177^^ is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject LEASE, KATHY R. Tuesday, February 13, 2001 12:59 PM CARNINE, LESLIE V. Positions After Don's comment in Cabinet about not hiring people, I visited with him about the positions that I currently have advertised. He suggested that I visit with you about whether or not I can hire the people I need to do the assessment program. I am currently down to three employees. I don't think we can do assessment for 20,000 kids with that number. I want to set up interviews this week, but I want your blessing! Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE. LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski UttleRock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 18From: Dr. Faucette To: Mrs. Hargis Date: 17 November 2000 76 S Subject: Exclusion of regular English students from Jennie Calder lecture I write to request a bit of information concerning the recent visit of Jennie Calder, a Robert Louis Stevenson scholar from Scotland, to Central as a part of the conference celebrating this great writer. It was my understanding, after our conversations last spring, that the event was in recognition of the universal appeal of a revered writer. Known and loved the world over, Stevenson is one of a select group whose works attract readers from widely varying backgrounds, uniting people of all classes and condition in the appreciation of a gifted artist. I was excited about the opportunity Central studentsincluding my own students would have to be^exposed to a world of exciting and enthusiastic research that would be especially significant for seniors, (Traditionally, the last year of high school English is dedicated to the exploration of the rich legacy of British literature.) I was disappointed beyond belief to learn that nonenot oneof my regular English students would be allowed to benefit from the singular experience of having the chance to see and hear the visiting scholar. Only AP and pre-AP students were allowed to attend the presentation. In fact, most teachers of regular English classes only learned of the event when students began to ask why they were not allowed to attend the assembly that students in other classes were discussing at lunch. Limiting the experience to students in AP and pre-AP English classes meant that very few black students were allowed to attend. I am shocked and outraged that yet another singular educational opportunity has been reserved for the children of privilege. Because many of the privileged AP English students took advantage of the event to slip out of the building and skip the assembly, and because you wanted to supplement their numbers, you solicited the attendance of students from AP science and history classes, still denying access to students from regular English classes. If you really wanted to impress Ms. Calder, having the Creative Writing Club presented would have done just that. The knowledge that, at 287 members, the Creative Writing Club is the most active club at Central would impress any true scholar or teacher. One can only wonder why you, Mr. Howard, and the third floor English department all miss the significance of the fact that the club that most fully represents the student diversity in our building is a club centered around an academic endeavor, the study and practice of literature. Yes, this is quite an example you set for our students. Central, Mr. Howard, the English department, and you all had a chance to shine as this scholar brought her enthusiasm to our large and diverse student body. Central, Mr. Howard, the English department, and you dropped the ball disastrously on this one. Rather than seizing the opportunity to be shining beacons by providing this opportunity for learning outside the traditional limitations of the classroom to all of our students, you have shown your true stripe. I thank you for the demonstration once again that, instead of a single unified English department. Central actually has two
the second floor containing primarily regular English classes, and the privileged third-floor home of AP English. I would now ask an additional bit of information. Please inform me in writing of your reasons for this latest instance of educational snobbery so that I might explain more accurately to my classes your dismissal of them as second-class students. I 1 I i ! I i j I i i i j iVia Facsimile - 324-2146 December 16, 1998 7^7 Dr. Leslie Gamine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Dr. Carnine: Would you please ask Mr. James Washington, the Districts ombudperson, to look into the complaint of Mr. & Mrs. Deodis Fleming regarding their concerns at Carver Magnet. You are probably not aware that this office has had several complaints from other parents regarding the unfair treatment of black students at Carver. You should have received a letter from the Flemings outlining their concerns along with a response from Ms. Barksdale. Copies of both are enclosed for your convenience. The Flemings believe that Ms. Barksdale is trying to excuse the reason for Ms. Ransoms exclusion of their son from participation by stating that he had behavior problems. In todays society, persons who discriminate usually attempt to establish legitimate reasons for their discriminatory actions. The reason given by Ms. Ransom, we believe, is pretextual. In other words, the reason that she has given is not legitimate. The Flemings were not previously advised that their son had behavior problems regarding his participation in Odyssey of the Mind. Moreover, they are not aware that their son has a behavior problem. Ms. Barksdales commitment to establish an OM Guideline booklet is a step, I believe, in the right direction. However, I do not believe that she should wait until next year. That process should start immediately. Opportunity for discrimination evolves when there are no written guidelines or rules for participation in a particular activity. The person overseeing or administering the activity usually has the discretion to make rules as they go along. These rules usually favor their own personal interests. Moreover, these rules or guidelines usually change daily to fit a particular interest or situation. I am not sure why the Flemings chose not assist in the coaching of Odysseys students as indicated by Ms. Barksdale
however, many of our childrens parents are unable to participate in many of the schools activities because often they occur when they are obliged to work and other commitments to meet the overall needs of their families. 76 7 Page 2 - Letter to Dr. Carnine December 17, 1998 I have indicated to Mr. & iVIrs. Fleming that I would be happy to sit down with Mr. Washington, Ms. Mitchell, Ms. Barksdale, and any other persons that they believe can help brini ig this matter to an amicable resolution. In fact, Mr. Washington may assume the role as the parent advocate, if the Flemings agree. I would, however, like to receive a report of his findings and resolution. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors JCS/ Enclosures cc: Mr. & Mrs. Deodis Fleming Ms. Diane Barksdale Ms Sadie Mitchell Mr. James WashingtonVia Facsimile - 324-2146 February 18, 1999 Ms. Sadie Mitchell Associate Superintendent for Student Services Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Ms. Mitchell: This office has received several calls regarding the selection process for the new football coach at J. A. Fair High School. It is our information that the selection process has been changed to favor the selection of a particular coach for the position. In order to address the concerns that have been raised, would you please provide to me a copy of process being utilized by District officials for the selection of coaching positions including the selection criteria. If this information has changed from prior years, also please provide the process and criteria that was utilized in previous years. I have spoken with Mr. Gillespie regarding this matter and he has assured me that the only change in the process was that the selection committee did not meet on the school campus as it has done in previous years. I was, however, a bit concerned about the gender makeup of the selection committee for the Fair position. I voiced my concern to Mr. Gillespie that the committee was all males. I am available to discuss this matter with you and Mr. Gillespie at a mutually convenient time. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Mr. Ray GillespieVia Facsimile - 324-2308 March 17, 1999 Rudolph Howard Principal, Central High School 1400 Park Street Little Rock, AR 72202 Dear Mr. Howard: I am writing on behalf of Rev. & Ms. Bennie Horton and their son, Tarick, to request a conference regarding his grades. As I review the revised desegregation plan, I can point to a number of areas including equal treatment, participation in honors and gifted classes, academic achievement, parental involvement etc. that are involved in these parents concern. By copy of this letter to the Districts Ombudsperson, Mr. James L. Washington, I am also putting him on notice of this concern and invite him to participate in the conference. I have spoken with Ms. Horton and she is available during her lunch hour to discuss this matter. Please let me hear from you. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Rev. & Mrs. Bennie Horton Mr. James L. WashingtonJohn W. Walker, P.A. Attorney At Law 1723 Broadway Dttle Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 . 377(. ./7 JOHN W. WALKER RALPH WASHINGTON N-LARK BURNETTE AUSTIN PORTER, JR. Via Facsimile - 324-2213 October 14, 1999 Mr. James Washington Little Rock School District Office of Ombudsman 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: I am writing to request that you look into the selection process for students participating on mock trial teams at Central High School. We request that you obtain some background information regarding past composition by grade, race and gender and the current composition by grade, race and gender. This office has received a complaint that these teams are generally one race and favor white students because their parents or other relatives are business professionals such as lawyers, judges, etc. Thank you for your attention to this matter. We further request a report of your findings with respect to this inquiry. By copy of this letter to Mr. Howard, Nir. Babbs and Dr. Camine, I am also advising them of these allegations. On Behalf of Joshua JCS/ cc: Mr. Ruduloph Howard Nir. Junious Babbs Dr. Leslie Camine y?/ Via Facsimile February
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