Little Rock Schools: King Interdistrict Magnet Elementary

United.States Court of Appeals FOR THE EIGHTH CIRCUIT Nos. 912640EA, 91-2648EA, 91-2655EA, 91-2683EA Little Rock School District, Pulaski County Special School District No. 1, North Little Rock School District, and Mrs. Lorene Joshua, Appellants. * * * * On Appeal from the United States District Court for the Eastern District of Arkansas. Submitted: September 4, 1991 Filed: November 14, 1991 Before ARNOLD, Circuit Judge, HEANEY, Senior Circuit Judge, and WOLLMAN, Circuit Judge. ARNOLD, Circuit Judge. On December 12, 1990, we approved a comprehensive settlement of the Pulaski County, Arkansas, school-desegregation case. Little Rock School District v. Pulaski County Special School District. 921 F.2d 1371 (Sth Cir. 1990). We recognized, however, that the approved plans, which we shall call the 1989 plan or plans, would need some modification because of the passage of time. We remanded the case to the District Court with directions to adopt the plans with any necessary transitional changes. We also stated that the parties are "free, by agreement, to modify the settlement plans by incorporating in them one or more provisions of the Tri-District Plan, subject, of course, to the approval of the District Court." 921 F.2d at 1393 n.l5.narrow, and that all of their proposed changes, being constitutional, workable, and fair, should have been approved. They ask us to reverse the orders of the District Court and remand the case with directions to approve all of modifications. the parties' I. There is much in the District Court's opinions with which we agree. The 1989 settlement which we approved last year should indeed be a benchmark for the future path of this parties are not authorized to modify it at will. case. The Further, we agree, for the most part, that any changes approved should be concerned only with the details of the plan, affecting it only at the margin, so to speak. We wish to dispel, in particular. any notion that an asserted lack of funds on the part of any of the three school districts would justify reduction in their commitment to desegregation represented in the 1989 plan, even if such a reduction were agreed to by the Joshua Intervenors, eventuality which, in any event, seems to us most unlikely. an The desegregation obligations undertaken in the 1989 plan are solemn and binding commitments, not be disturbed. The essence and core of that plan should On the other hand, we think the District Court was too strict with itself. We did not intend, for example, to limit changes in detail to matters that are merely transitional, or to the selection of certain provisions from the Tri-District Plan. (We accept responsibility for any lack of clarity in our December 1990 opinion on this point.) If a question is truly one only of detail, not affecting the major substantive commitments to desegregation, the District Court has the authority to consider it. Some such changes, for example, as the District Court noted, may have merit, either because they advance desegregation, or for other reasons. Even changes that go beyond the level of detail, moreover, could -4- abe approved, but only if the parties affirmatively establish good reasons (not including the lack of funds) for them. It may be helpful for us to state those elements of the 1989 plan that we consider crucial, and with respect to which no retreat should be approved. They are as follows: (1) double funding for students attending the incentive (virtually all-black) schools
(2) operation of the agreed number of magnet schools according to the agreed timetable
(3) operation of the agreed number interdistrict schools according to the agreed timetable
of (4) intradistrict desegregation of PCSSD according to the agreed timetable
(5) the agreed effort to eliminate achievement disparity between the races
(6) the agreed elements of early-childhood education, at least in the incentive schools
and (7) appropriate involvement of parents. For purposes of illustration, we will discuss a number of the proposed modifications. indicating which of them seem to us to concern mere details, and which of them, on the other hand, would require substantive justification. Items we consider to involve details include deciding whether Russian will be taught at Parkview
failing to include the 144-page appendix in the revised PCSSD May 1991 Plan
changing the plan's language with respect to a possible interdistrict school in Chenal Valley
changing the process to decide whether King Elementary School will be Montessori school
and eliminating Explorer memberships t a for 1 students at incentive schools. In contrast, changes we consider to be significant, requiring justification, include reducing the number of instructional aides in the incentive schools from one per classroom to two aides for every three classrooms
eliminating incentive-school themes
and eliminating a full-time nurse at each 1 Students at the incentive schools, which are all on the elementary level, are too young to be Explorer Scouts. Addendum (J.A.) 102. Joint -5-IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION - LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. ORDER FILED U.S DISTRICT COURT EASTERN DISTRICT ARKANSAS mar 17 1992 CARL R/ 5 By: r/ eWENTS, CLERK lEP CbgRK PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Before the Court is the Little Rock School District's request for approval to build the new King Interdistrict School at the site of a city park at Ninth and Pulaski Streets. A hearing on the site selection was held on March 9, 1992. The Court finds that the site should be approved. The parties originally were considering the renovation of or new construction on the old Westside Junior High School site at Fourteenth and Marshall Streets. However, after further consideration and court-ordered community input. the parties determined that the site at Ninth and Pulaski Streets is preferable for the new interdistrict school. The Court agrees that the proposed location is acceptable and consistent with the parties' court-approved desegregation plan. Additionally, it believes that a new. welldesigned school, which is highly visible and easily accessible from Interstate 630, will be attractive to parents and students.The Court is concerned, however, that members of the community , have expressed a perception that the Little Rock School District (LRSD) is not genuinely interested in citizen input into the school site selection process and that the school district deals with community participation in manner which is perceived as superficial and perfunctory. In recognition of this perception. which was expressed by witnesses at the hearing. the Court finds that the LRSD must strive in the future toward more meaningful involvement with parents and other citizens in determining the location of schools. The Court requires the parties to consider carefully the concerns and suggestions of community members in making decisions a such as the site of new schools. It cannot stress too strongly the wisdom of seeking community input early in the decision-making process. When members of the community can voice their concerns. opinions and suggestions and be heard by those in authority before final decisions are made. there is a greater likelihood that imaginative ideas. new alternatives. and creative solutions to problems will emerge from the broad perspective of our diverse community. There is also increased probability that the ultimate decisions will be more pleasing and acceptable to the community which has helped fashion them. Furthermore, sincerely inviting and utilizing community involvement in school district planning and operations builds a relationship of understanding and trust between citizens and education officials, ultimately fostering mutual confidence and long-term community support of the school district -2-and its education and desegregation goals. In the future, the Court expects the parties to consult with the Office of Desegregation Monitoring (ODM) in matters such as community involvement in school site selection to define a comprehensive but specific process that will ensure the timely and meaningful participation of parents and other citizens in the plans and actions that impact them. The school districts must approach decisions such as the placement of new schools according to a definitive community involvement action plan and schedule of implementation that is faithfully followed and results in citizens having ample opportunity to participate in making important decisions. The ODM will strictly monitor a school district's adherence to its plan and to its schedule of community involvement. The ODM will report the level of compliance to the Court. Concerning the King Interdistrict School, the Court directs the LRSD to work closely with the neighborhood residents, involving them early in decisions such as the design and orientation of the school building. location of parking lots and the playground. traffic patterns, and use of the school's playground facilities. The Court also requires the LRSD to investigate fully the feasibility of restoring. adapting. demolishing or otherwise properly disposing of vacant buildings in the Ninth Street Park area which detract from the general appeal of the proposed school site. The Court notes the distinctive and attractive architecture of the many significant historic and contemporary structures in the neighborhood and encourages the parties to design a school facility -3-that will aesthetically complement and reinforce the beauty of the area. The parties are reminded that the Settlement Plans caution against the duplication of school themes
therefore, the Court encourages the parties to join with parents, teachers, employers and employees in the Ninth and Pulaski area. and with other interested community members in creatively exploring fresh academic themes for King which capitalize upon the unique location of the new school and its proximate learning environments such as the nearby centers of government, law, medical technology and health care, for example. The Court advises the parties to begin working now to select a site for the proposed Stephens Interdistrict School, working diligently and in good faith with the community in the manner described herein. DATED this / ^*^^^ay of March, 1992. ) V, united states district JUDGE A f ey -4-IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V, LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS APR 2 31992 CARL R. BRENTS, CLERK By:---------------------------- DEP. CLERK PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS ) MOTION TO RESCHEDULE INTERDISTRICT SCHOOL CONSTRUCTION For its motion the Little Rock School District (LRSD) states: 1, LRSD notified the court on July 19, 1991 that the Westside School site at Fourteenth and Marshall Streets had been approved by all parties as the location for the King Interdistrict School. LRSD proceeded to develop plans for the new school at the Westside site, to secure options on adjacent property and to remove asbestos from the old Westside Junior High School building in preparation for demolition of the building to make way for the new school. After further consideration by the parties, community input, the presentation of evidence, and visits by the parties and the court to various potential school sites, LRSD requested approval to build the new King Interdistrict School on the site of a city park at Ninth and Pulaski Streets. Following a hearing on March 9, 1992, this court approved the site at Ninth and Pulaski Streets for the construction of King Interdistrict School. la(hy\C<B>tfucik)ii.9th) 2. Most of the land at the Ninth and Pulaski site is owned by the City of Little Rock and is presently being used as a city park. Additional land on the western portion of the site which fronts Dr. Martin Luther King, Jr. Drive, is privately owned. Additional land to the north of the proposed site is controlled by the Arkansas State Highway Commission. Since this court's approval of the Ninth and Pulaski site on March 17, 1992, LRSD has made a presentation about King Interdistrict School to the Board of Directors of the City of Little Rock, worked with city officials in an effort to devise a plan for the sale, lease, or joint use of the Ninth Street Park site which might be acceptable to the City Board of Directors, invited members of the community to meet concerning the development of the King Interdistrict School on the Ninth and Pulaski site. approached Arkansas Children's Hospital concerning possible acquisition and renovation of the Westside school building by the hospital, presented a proposal to the Chief Engineer of the Arkansas State Highway Commission for lease of the land north of the Ninth Street Park, contracted for appraisals of the various parcels of property west of Ninth Street Park, and reported to the Office of Desegregation Monitoring and the parties concerning these developments. 3. LRSD remains convinced that the Ninth and Pulaski site is a better site for the construction of the King Interdistrict School than the Westside site or any other site which the parties have thus far located. It is now clear, however, that LRSD will be unable to complete the following steps to construct the school in kihy\CowmjcuM.Wi 2time for the beginning of the 1993-94 school year: complete a sale lease or joint use agreement for the use of Ninth Street Park
finalize a lease for use of the land north of the park controlled by the Arkansas State Highway Commission
acquire any necessary property to the west of Ninth Street Park
and plan the development of the King Interdistrict School with the help and support of the community surrounding the school site. LRSD believes that the desegregation plan will be better served in the long run if King Interdistrict School is constructed one year later at the larger, more accessible and more visible Ninth and Pulaski site than if a school is constructed immediately at the smaller Fourteenth and Marshall site. A further consideration is that the Fourteenth and Marshall site is presently occupied by an historic school building which could be renovated if the King school is built elsewhere but which must be demolished if the King school is constructed at that site. 4. The May 1, 1991 Proposed Desegregation Plan also requires LRSD to construct a second interdistrict school to be ready for operation the year following the opening of the King Interdistrict School. In order to avoid a competition for M to M transfer students between two new interdistrict schools which could work to the detriment of both schools, LRSD proposes that the construction of the second interdistrict school should be rescheduled if the construction of the King Interdistrict School is rescheduled. 5. The parties expected that interdistrict schools in both LRSD and PCSSD would be funded largely by state payments to the kjilhyVCoinKlk.9U 3districts for M to M transfer students. The granting of this motion will allow the parties to make any necessary adjustments to their desegregation planning which may be necessary following the PCSSD millage election scheduled for May 5, 1992. 6. PCSSD and NLRSD have authorized LRSD to say that they do not oppose this motion. WHEREFORE, for the reasons set out above, LRSD prays for an order rescheduling the construction of the King Interdistrict School to require that school to be open for the beginning of the 1994-95 school year and rescheduling the construction of the second LRSD interdistrict school to require that school to be open for the beginning of the 1995-96 school year. Respectfully submitted, FRIDAY, ELDREDGE & CLARK 2000 First Commercial Bldg. 400 West Capitol Street Little Rock, AR 72201 (501) 376-2011 B Bar No. 81083 kiihy\CoMiructkjn.9ih 4 CERTIFICATE OF SERVICE on I certify that a copy of the foregoing motion has been served the Office of Desegregation Monitoring and the following counsel of record by depositing copy of same in the United States mail on this 23rd day of April 1992. Mr. John Walker JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 Mr. Sam Jones WRIGHT, LINDSEY & JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 3400 Capitol Towers Capitol & Broadway Streets Little Rock, AR 72201 Mr. Richard Roachell #15 Hickory Creek Drive Little Rock, AR 72212 Ms. Ann Brown Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Christopher Hell ladiy^<xsUuctkn.9ih 5 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL FILED M U.S. DISTR ICT COURT EASTERN DISTRICT ARKANSAS APR 2 31992 CARL R. BRENTS, CLERK By:---------------------------- DEP. CLERK PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS I MOTION TO RESCHEDULE INTERDISTRICT SCHOOL CONSTRUCTION For its motion the Little Rock School District (LRSD) states: 1. LRSD notified the court on July 19, 1991 that the Westside School site at Fourteenth and Marshall Streets had been approved by all parties as the location for the King Interdistrict School. LRSD proceeded to develop plans for the new school at the Westside site, to secure options on adjacent property and to remove asbestos from the old Westside Junior High School building in preparation for demolition of the building to make way for the new school. After further consideration by the parties, community input, the presentation of evidence, and visits by the parties and the court to various potential school sites, LRSD requested approval to build the new King Interdistrict School on the site of a city park at Ninth and Pulaski Streets. Following a hearing on March 9, 1992, this court approved the site at Ninth and Pulaski Streets for the construction of King Interdistrict School. klhy\C(nuucl><n.9ihJ 2 . Most of the land at the Ninth and Pulaski site is owned by the City of Little Rock and is presently being used as a city park. Additional land on the western portion of the site which fronts Dr. Martin Luther King, Jr. Drive, is privately owned. Additional land to the north of the proposed site is controlled by the Arkansas State Highway Commission. Since this court's approval of the Ninth and Pulaski site on March 17, 1992, LRSD has made a presentation about King Interdistrict School to the Board of Directors of the City of Little Rock, worked with city officials in an effort to devise a plan for the sale, lease, or joint use of the Ninth Street Park site which might be acceptable to the City Board of Directors, M invited members of the community to meet concerning the development of the King Interdistrict School on the Ninth and Pulaski site. approached Arkansas Children's Hospital concerning possible acquisition and renovation of the Westside school building by the hospital, presented a proposal to the Chief Engineer of the Arkansas State Highway Commission for lease of the land north of the Ninth Street Park, contracted for appraisals of the various parcels of property west of Ninth Street Park, and reported to the Office of Desegregation Monitoring and the parties concerning these developments. 3. LRSD remains convinced that the Ninth and Pulaski site is a better site for the construction of the King Interdistrict School than the Westside site or any other site which the parties have thus far located. It is now clear, however, that LRSD will be unable to complete the following steps to construct the school in k>Qiy\Cooamicuco.9tb 2time for the beginning of the 1993-94 school year: complete a sale lease or joint use agreement for the use of Ninth Street Park
finalize a lease for use of the land north of the park controlled by the Arkansas State Highway Commission
acquire any necessary property to the west of Ninth Street Park
and plan the development of the King Interdistrict School with the help and support of the community surrounding the school site. LRSD believes that the desegregation plan will be better served in the long run if King Interdistrict School is constructed one year later at the larger, more accessible and more visible Ninth and Pulaski site than if a school is constructed immediately at the smaller Fourteenth and Marshall site. A further consideration is that the Fourteenth and Marshall site is presently occupied by an historic school building which could be renovated if the King school is built elsewhere but which must be demolished if the King school is constructed at that site. 4. The May 1, 1991 Proposed Desegregation Plan also requires LRSD to construct a second interdistrict school to be ready for operation the year following the opening of the King Interdistrict School. In order to avoid a competition for M to M transfer students between two new interdistrict schools which could work to the detriment of both schools, LRSD proposes that the construction of the second interdistrict school should be rescheduled if the construction of the King Interdistrict School is rescheduled. 5. The parties expected that interdistrict schools in both LRSD and PCSSD would be funded largely by state payments to the kjlhy\Con*inxnioa.9(h 3districts for M to M transfer students. The granting of this motion will allow the parties to make any necessary adjustments to their desegregation planning which may be necessary following the PCSSD millage election scheduled for May 5, 1992. 6. PCSSD and NLRSD have authorized LRSD to say that they do not oppose this motion. WHEREFORE, for the reasons set out above, LRSD prays for an order rescheduling the construction of the King Interdistrict School to require that school to be open for the beginning of the 1994-95 school year and rescheduling the construction of the second LRSD interdistrict school to require that school to be open for the beginning of the 1995-96 school year. Respectfully submitted. FRIDAY, ELDREDGE & CLARK 2000 First Commercial Bldg. 400 West Capitol Street Little Rock, AR 72201 (501) 376-2011 By: ThTistopher Helle: Bar No. 81083 lathy VCoDairuai on. 9th 4 CERTIFICATE OF SERVICE I certify that a copy of the foregoing motion has been served on the Office of Desegregation Monitoring and the following counsel of record by depositing copy of same in the United States mail on this 23rd day of April 1992. Mr. John Walker JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 Mr. Sam Jones WRIGHT, LINDSEY & JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 3400 Capitol Towers Capitol & Broadway Streets Little Rock, AR 72201 Mr. Richard Roachell #15 Hickory Creek Drive Little Rock, AR 72212 Ms. Ann Brown Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Christopher Helle^^^ io* ihy \CoQa irucii oo. 9Qi 5 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION CARL, By: LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-82866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. ORDER Before the Court is the motion of the FILED JUN - 5 1992 ERK t/ depTcl CLERK PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Little Rock School District [LRSD] to reschedule the construction of two interdistrict schools and the motion of the Pulaski County Special School District [PCSSD] to replace portable classroom buildings at Pinewood Elementary with permanent classrooms. The LRSD seeks to delay the construction of the King interdistrict school from the May Submission date of 1993-94 to a new date of 1994-95. It also asks the Court to approve a delay in construction of the Stephens interdistrict school from 1994-95 to 1995-96.^ The Court held a hearing on the motion on May 29, 1992. After careful consideration of the motion and the testimony presented at the hearing, the Court finds that the motion should be denied at this time. The Court is unconvinced that the LRSD cannot. if it acts diligently, meet the deadlines set forth in the May Submission for both the King and Stephens schools. Mr. Jim Ivey, manager of support services for the LRSD, testified that the money for both *The original 1989 plan construction dates were 1992-93 for King and 1990-91 for Stephens.schools is in the bank, with $3.85 million earmarked for King and $3.5 million earmarked for Stephens. The testimony of Mr. Doug Eaton, director of plant services for the LRSD, indicated that land acquisition for King is proceeding at an acceptable pace and that the additional year was needed mostly to get community input on the King school. There has been and will be sufficient time for community involvement on the design and use of the King school, provided the district acts expeditiously. There was no convincing argument that Stephens could not be constructed by 1994-95 as set forth in the May Submission. In order to ensure that the LRSD meets the 1994-95 opening date, the Court will require the district to develop and submit to the Court written plan for the construction of the new Stephens interdistrict school. The plan is to include dates of completion for each phase of development and the following: 1. A strategic plan for community involvement that includes neighborhood meetings with the community members living in the area surrounding the current Stephens Incentive School, formation of a biracial citizens site advisory committee, and the involvement of parents whose children are targeted for recruitment to the new school. a 2. The school's total capacity. the number of students to be assigned from LRSD schools, the number of PCSSD students to be recruited, and the number of early childhood classes anticipated with the ages of the students to be served. 3. A comprehensive description of projected attendance zone -2-changes and the effect these changes will have on the incentive school and/or area school enrollment, racial balance, and capacities. 4. A description of all anticipated costs. including site purchase, site preparation, design fees, construction, equipment. materials, furnishings, personnel. etc. must be included in complete budget of start-up and maintenance expenses. The portion of the costs to be funded by desegregation funds is to be clearly indicated in the budget. 5. Contingency plans for accommodating the current Stephens students while construction takes place, if the school is to he rebuilt on the current site. If the school is located elsewhere. a comprehensive reuse plan should be developed in conjunction with the community. 6. Description of the process that will be used to select and a purchase a site, if applicable. If a new site is selected, the description should include steps required to obtain any special zoning consideration required, status of options to purchase the property, and information regarding the neighborhood support for an interdistrict school. 7. Summary of the design and construction process including procedures for the selection of an architectural firm, preliminary designs, design input from citizens, teachers, and parents, design completion with adherence to federal requirements and ADE recommendations regarding new school construction. and a description of the construction schedule. -3-8. An outline of staff recruitment procedures for the school's administrative, teaching and support staff, including staff projections for each grade level and all support programs. If the recruitment and hiring practices planned differ from those outlined in the Professional Negotiations Agreement, a description of plans to negotiate the hiring modifications with the LRCTA must be included. The Court also orders the LRSD to refrain from spending the $3.85 million earmarked for King and the $3.5 million earmarked for Stephens, and the interest earned on the sums, for any pxirposes other than the construction of these interdistrict schools. In its motion. the PCSSD seeks authorization to replace portable classrooms at Pinewood Elementary School. One of the four double portable buildings recently was destroyed by fire. Because of this emergency and the district's assurance that capacity of the school will not be changed, the Court determines that the motion should be granted. In granting the motion, however, the Court notes that at the May 29th hearing, the PCSSD indicated that it intended to file a motion with the Court concerning the replacement of all portable classroom buildings with new construction. The Court prefers to consider the question of replacing portables in a comprehensive manner rather than piecemeal, and it is granting the motion as to Pinewood because of the particular circumstances involved. Further, on the topic of new construction in the PCSSD, at the May 29th hearing the Court also heard testimony on the PCSSD's -4-motion to delay construction of an interdistrict school on the Highway 67/167 corridor. The Court will delay ruling on the PCSSD motion until it receives and considers the anticipated comprehensive motion concerning replacing portable classrooms with new construction. IT IS THEREFORE ORDERED that the LRSD motion to delay interdistrict school construction [Doc. #1584] be and is hereby denied. The LRSD is ordered to submit to the Court within ninety (90) days from the date of entry of this Order a timetable for the construction of Stephens interdistrict school. IT IS FURTHER ORDERED that the PCSSD motion to replace portable classrooms at Pinewood Elementary School [Doc. #1607] be and is hereby granted. DATED this day of June, 1992. UNITED STATES DISTRICT JUDGE Also before the Court is the motion of the LRSD for phased implementation of the McClellan High School Business/Communication Magnet Plan [Doc. #1583]. Counsel for the LRSD orally withdrew the motion at the May 29th hearing
the motion is, therefore, moot. -5-ii D CENTRAL HIGH NEIGHBORHOOD ---------------r INC.'S---------------- 'We've Got Heritage," January 17, 1992 .c Ms. 0. G. Jacovelli President Little Rock School Board 6622 Gold Court 0e2^'^'laicH Little Rock, Arkansas 72209 \1 c^ Dear Ms. Jacovelli: The undersigned residents of the Central High neighborhood and patrons of the Little Rock School District hereby submit for consideration by the Little Rock School Board an alternative proposal for the development of an interdistrict school in the Central High neighorhood. We propose creation of a two-campus educational facilitythe Dr. Ms^tin Luther King, Jr. Educational Parkas the centerpiece of a neighborhood redevelopment initiative. Our proposal also would enable Ish Elementary School to remain in operation as an incentive school, an approach supported by patrons of' Ish. The School Board's response to this proposal should be directed Ethel Ambrose, president of the Central High Neighborhood Association, who can be reached during the day at 370-5950. to TEL: Feb 19.92 11:50 No.001 P.01 KING TNTERPXSTRICT SCHOOJ.. Site Selection Process T'lmel j.nc danuarv 11 - Phone survey of key community leaders Pulaski (Ninth .Htrect Park) arps.'i .in 91,11 cU'xi February A - Mailed specia.l PLil.aski StrewtiJ ai'ea survey to all LR.'^iO p-trcnl3 in Pt-lt mid February 10 - Host luncheon meet.!ng at Mt. with key community leaders Zion Paptiol Clnireh February 19 - Begin sending surveys to parents ot r.i.ndents in i.arget.ed areas of Little .Rock and Pulaski County Fe.bruary._19 - Form a site selection committee of parent.'? and teachers from both districts. February 20 - Di.stribute pr- publ.ic input nrinouiicinc period for February 20 - Mail survey? to selected Partner? in Education, bu.sinesses end cTiurchc in downtown Little Rock asking tliom to moke them available to l.he.ir employees and concrepations. those businesses to be ineJudHd are Arkansas Children' Amoiiij Hoppitnl, Arkansas State Capitol Mail, First. Cornmftrcia.l Hank, and Axkarnscis Powar and Light. Immanuel Baptist Church. Churches include Mt. Zion B.-aptist Chui-ch and February 23 ad in Arkansas Democrat-Gazette to announce publ.ic foruni.a and to inform public that surveys are nvailablo upon raquoot. survey. Include a phone number to call to requouL a February 24 - FUnT.l C FORUM Gi.bbs ScIkjoI , 6:00 p.m. 1115 W. 16th St. Fwbx-uary ..25. - PUBLIC FORUM Lawson School, 19901 Lawson Road 6:00 p.m. February 27 - PUBLIC FORUI4 Oak Grove Elementary Schoo.! , .5703 Oak Grove Road 6 : 0 n p. m. March 2 - Site Selection Committee Meeting LRSD Administration Building 6:00 p.m.I tL: Fee 19.92 11:50 No.001 P.02 ANNOUNCEMENT, February 19,1992 Dear Patron. elementary school in the area new school is scheduled to open in August 1993 Although c school will be built in the Little Rock School District, the Pulaski County Special School Distnet will be actively involved in recruiting students. We are very concerned about getting as much public opinion and input as possible in the selection of a site for this school. The new school will be an interdistrict school. Interdistrict schools serve black students from me Little Rock School District and white students from the Pulaski County Special School rjR'tnrt Tna ohl/4An*n TS..J_1 * . . - ------- < wAbMa-k Distner. The students from tlic Pulaski County Special School District are recruited on a volun- tary basis. The new elementary school, .which wiU be named after Martin Luther King, Jr., will have a capacity of 696 students. This includes two classes for four-year-old students. The' four-year-old classes will be free of charge. In addition, the new King School will have a . theme. minutes to complete the survey attached to this letter. As you can sec, we would like to have your input on the selection of a site and the selection of a theme for the new lung Interdistrict School. In addition to completing the survey, you are invited to attend one of the public forums listed on the survey form. These meetings will be held to give our community the opportunity to express any concerns/suggestions about the site and/or theme for the new Martin Luther King, Jr. Interrfishict School. Thanks in advance for taking the time to complete the site selection survev form. We hope to sec you at one of the public forums. Little Rock School District Pulaski County Special School DistrictTEL: Feb 19.92 11:50 No .001 P.03 Little Rock School District Pulaski County Special School District Community Survey Which of the following locations would you prefer for the new King Elementary Inteidistrict School? Rank (1 for first choice, 2 for second choice. Map is enclosed.) 9th and Pulaski Streets Westside Junior High School site (14th and Marshall Streets) Comments
Please check your choice for a theme for King Interdistrict School. Rank (1 for first choice, 2 for second choice, 3 for third choice, 4 for fourth choice, 5 for fifth choice, 6 for sixth choice, and 7 for seventh choice. Program descriptions ore enclo,) Basic Skills Computer Science Economic Education EnviTOnmcntal Science Medical Science and Health-related Occupations Visual and Performing Arts Other
__________________ Would you be interested in enrolling your child(ren) at the King Elementary Interdistrict School? Yes No Maybe You arc invited to give public comment about this school site selection at any of the following public forums
February 24,6 p.m. Gibbs Magnet Elementary School, Media Center, 1115 W. 16th, LRSD February 25,6 p.m. Lawson Elementary School, Cafeteria, 19901 Lawson Road, PCSSD February 27,6 p.m. Oak Grove Elementary School, Cafeteria, 5703 Oak Grove Road, NLR Name. Address Childs Current School Assignment Phone, ___Grade If apflicable, please return to your childs school by Monday, February 24, 1992.TEL: Fea 19.92 11:52 No .001 P.04 MARTIN LUTHER KING, JR. INTERDISTRICT SCHOOL SITE/THEME SELECTION SURVEY Theme Descriptions February 1992 Basic Skills This program places strong emphasis on mastery of basic skills at the student's instructional level in reading, math. Engli.sh, spelling, writing, science, social studies, health, penmanship, art, music, and physical education. This includes a highly structured, disciplined approach to academic and social behaviors. Computer Science Eac.h area of the basic skills curriculum will be supported by the use of computer technology. In addition, students will prepare for the twenty-first century with an introduction to programming, word processing, telecommunications, and interactive video. Economic Education This program will prepare students for the twenty-first century through e development of academic, technological and interpersonal skills. Each student's knowledge and awareness of business will be developed from both the consumer and career point of view. An enriched curriculum will be featured that includes in-class study(using varied Icaming/tcaching strategics), visiting speakers, and field trips. Environmental Sciences The environmental science program will be designed to offer challenging educational experiences with an emphasis on the scientific method, inquiry, methodologies, and experiences in environmental science. Challenging and meaningful activities will be geared to llic level of each student and his/her interest. Ecology and conservation will be the specific areas of concentration. Medical Science and Health-related Occupations This program will increase student awareness and understanding of content and careers in die health sciences. Students will have the opportunity to practice hands-on laboratory work in a controlled setting. Special emphasis will be placed on mastery in mathematics and science. Visual and Performing Arts This program will feature instruction in dance, vocal music, theater arts, and visual arts. Qualified professionals will instruct in the specialized areas and the opportunity for performance and/or exhibits will be an integral part of the program. An enriched basic skills program, using a variety of teaching strategies, will be provided to meet the needs of all students.I !L_ : Fes 19. 11 i No.001 P.05 MAP 921 S. Pulaski Little Rock, AR February 24, 1992 122^2 RECEIVED Mrs. Ann Brown Desegregation Monitor Office of Desegregation Monitoring 210 East Markham St. FEB ii 5 IW2 Office of Desegregation Monitoring Little Rock, AR 72201 Dear Mrs. Brown: Enclosed is a copy of signatures I collected in our neighborhood in opposiiton to the building of a school in the Ninth Street Park area. recent neighborhood meeting, our opposition. I felt concerned enough to do this after a We would appreciate consideration of Sincerely, H.W. Hall, Jr. Enclosures cc: Dr. Ruth Steele Mr. James Jennings Mrs. Arma Hart Mrs. Sharon Priest Mr. John Lewellen Mr. Jim LawsonWE, THE MEMBERS OF THE 9TH STREET PARK NEIGHBORHOOD, ARE OPPOSED TO THE SELLING OF THE 9TH STREET PARK AREA TO THE LITTLE WE ROCK SCHOOL DISTRICT FOR PURPOSES OF CONSTRUCTING A SCHOOL. NAME ADDRESS U/1^ .5- e'fa /rJ } 0 /< r)S <JG C5V& //)^i) V/^rA/2-y . a/0 f.J. fJ J i^t'} ______ n-Ai vxj'\o jr T21 '<//2- ^H'dasir/ Qd. ! JZ -------------,.--------------- \\)0U 11 .ul 'X, ^7'X ::><. A ^/ }'/6A A<^x\ /<6( 4. X6'~Z1 Q 4 Cd K ( I /J ,3/ U!. W l>./s-p^.lii.^k.'.x4(R J I ^1 K r /a>/>~/'^'A/cLS zf
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ZV> A/^rc f H-'/f^OAx if ///y/ 1*^6 I LOgj^'-t- ft) b(<v /k>-)-. .<?/. 1WE, THE MEMBERS OF THE 9TH STREET PARK NEIGHBORHOOD, ARE OPPOSED TO THE SELLING OF THE 9TH STREET PARK AREA TO THE LITTLE ROCK SCHOOL DISTRICT FOR PURPOSES OF CONSTRUCTING A SCHOOL. I, NAME Zz2 .ia- -ly/. ''t r ' <5 c ADDRESS ^rVXX-Z^ U / Q/i^^L^Z-JjmiLLih J /5I-) (^'e^ Iolcp i'i)\as y.'i /122. b /H-jS IJ7 , . cJ, 1^ Z) A t<n ^ \ArT A (0^1 if'.n o^-yrr-,^ \J 1 f Lyf^ 3 /} - (~Jy ( a/f swnitae B Sol V XB RECE5VED 1 LJ CENTRAL HIGH NEIGHBORHOOD ----------------r INC.3---------------- JUN 1 5 1592 Office of Desegregation Monitoring "Weve Got Heritage'. June 12, 1992 To: Little Rock Board of Directors From: Central High Neighborhood Association, Inc. Subj ect: Sale of the City Park at 9th and Pulaski Streets to the Little Rock School District for use as a site for the Martin Luther King Elementary School. We urge you to sell the park site at 9th and Pulaski Streets to the Little Rock School District for use as a site for the new Martin Luther King School which is mandated under the school desegragation plan. Both the preservation of the West Side Junior High School building and the development of a neighborhood elementary school are important to the stabilization of our neighborhood. If the LRSD acquires the block of land between Pulaski and MLK Blvd, and builds the school fronting on MLK Blvd, as they propose to do, it would be highly visible from 1-630 and in close proximity to Children's Hospital. from suburban neighborhoods. This would facilitate attracting white students Removal of structures in the block west of the park which at present create an eyesore would enhance the neighborhood aesthetically, increase property values and address the goal of the city to reduce crime by reducing blight. Children's Hospital has reaffirmed their desire to purchase the West Side Junior High School 0 As a corporate neighbor they have indicated a commitment to restoring the building and developing the property in a way that would enhance the neighborhood and increase pronerty values If the Little Rock School District can acquire the park site at 9th and Pulaski Streets plus the block of property west of the park and build the new inter-district school there and if Children's Hospital can purchase and renovate the West Side Junior High School, we feel the needs of the city, the neighborhood, the school district andLittle Rock Board of Directors, page 2 and Children's Hospital can be met. This could create a win-win compromise which would encourage families already living there to stay in the nieghborhood and would help to attract other stable families to move into the neighborhood. Again, we urge that the city sell the part site at 9th and Pulaski Streets to the Little Rock School District. cc: Dr. Mac Bernd Dr. Ruth Steele George Cannon Patricia Gee Willie D. Hamilton Dorsey Jackson 0. G. Jacovelli Katherine P. Mitchell John Moore Judge Wright Tom Dalton Dr. Randall O'Donnel Scott Gordone? IT FOR SPECI7VL MEETING FOLLOWING BOARD COMMITTEE MEETING LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, ARKANSAS '7 July 16, 1992 TO: Board of Directors JUL 6 Oiiice of Doseofesatof* FROM: SUBJECT: Mac Bernd, Superintendent of Schools ACQUISITION OF PROPERTY FOR NEW KING ELEMENTARY SCHOOL We are required by the desegregation plan to construct a new King School on the 1-630 corridor. The Federal District Court has approved the site at Ninth and Pulaski for the construction of the school. The District must acquire the property in the block bounded by Ninth Street, Martin Luther King Drive, Tenth Street, and the Ninth Street Park. We have obtained appraisals on the property that we need to acquire. I am recommending that the Board (1) act to declare the necessity to acquire the property within the boundary of Ninth Street, Martin Luther King Drive, Tenth Street and the Ninth Street Park
and (2) to authorize and direct the administration to proceed to acquire the privately owned property within the said boundary by purchase or, if necessary, condemnation. It will also be necessary to enter into lease agreements with the City and the State for some property outside the above described boundary, but these leases will be submitted to you at a later date for your approval.03/02x1993 15:00 FROM JOHN U.WALKER P.A. TO 3710100 P. 02 if .John w. walker, P.A. Attorney At Law J 72.3 Broadway Little Rock. Arka.nsas 72206 TEi.EIHONE (501) ^4-3758 FAX (501) 374-4187 J JOHN W. walker RALPH WASHINGTO.N MARK BURNETTE WILEY A. BRANTON. .JR. AUSTIN PORTER, .JR. A Ln wimittwl h. Pnirtiw i.i O.r,ia Ih. Wumhi,. March 2, 1993 pelivercd Vis Fax S U.S. Mail . I , ,i 'i ' i Honorable Susan Webber Wright United States District Judge United States District Court U.S. Post Office & Courthouse Little Rock, AR 72203 I" ,. I n T Re: LRSD V. PCSSD Dear Judge Wright: Today I had a visit with the Office of Desegregation Monitoring at which time I learned that principal interviews were being conducted by the Little Rock School District for the position of principal of ths new elementary school, In that we have participated in such interviews in the past, we believe that it is appropriate for us to participate in such interviews at present. Exclusion at this level will surely mean exclusion rather than inclusion at the next level. Moreover, the district did not involve us nor the ODM in a timely way in the site selection process for the school. This raises again the good faith of the administration in implementation of the desegregation program. Would you kindly include this matter on your list for the hearing on March 19, 1993. Thank you for your consideration on this matter. JWW
Ip cc
All Counsel of Record Dr. Mac Bernd Ms. Ann Brown Ve' truly yours, J^n W. Walker Counsel for the Joshua Intervenors 1 i I 03x02/1993 15!0 0 FROM JOHN U.URLKER P.fl. TO 3710100 P. 02 h. .1 JOHN W. WALKER. P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 TfxeIHONF. (501) 374-3758 FAX (501) 374-4187 I J i JOHN W. WALKER RALPH WA.SH1NGTON MARK BURN BITE WILEY A. BRANTON. JR. AUSTIN PORTER, JR. * Al?h (winiilUf.J Prntliw it thf IhMri'? Cyiliwhia. March 2, 1993 Delivered Via Fax & U.S. Mail . t J I Honorable Susan Webber Wright united States District Judge United States District Court U.S. Post Office & Courthouse Little Rock, AR 72203 I Re: LRSD V. PCSSD Dear Judge Wright: the Office of Desegregation i- I , .1 I I
I 5 I < 1 r f 1- Today I had a visit with Monitoring at which time I learned that principal interviews were being conducted by the Little Rock School District for the position of principal of the new elementary school. In that we have participated in such interviews in the past, we believe that it is appropriate for us to participate in such interviews at present. Exclusion at this level will surely mean exclusion rather than inclusion at the next level. Moreover, the district did not involve us nor the ODM in a timely way in the site selection process for the school. This raises again the good faith of the administration in implementation of the desegregation program. Would you kindly include this matter on your list for the hearing on March 19, 1993. Thank you for your consideration on this matter. JWW:Ip cc: All Counsel of Record Dr, Mac Bernd Ms. Ann Brown Ve Jl truly yours, ^n W. Walker Counsel for the Joshua Intervenors .'Z JOHN w. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 7220fi Telephone (501) 374-3758 FAX (501) 374-4187 RECEIVED MAR 1 9 1993 Office of Desegregation ^lonno.ing JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE WILEY A. BRANTON, JR, AUSTIN PORTER, JR. * ALw admillnl In Practice in Onrsia & the DLslrict of March 16, 1993 Dr. Mac Bernd Chris Heller, Esq. c/o Little Rock School District Little Rock, AR 72201 Dear Dr. Bernd and Mr. Heller: It has just been driven home to me that the interviews are now being conducted for the principalship of the new King School. understand that the other parties are participants in tl--- We those inteirviews. interests is Is there any reason why we are omitted? compelling and we. therefore. The Joshua request that the interviews be suspended until such time as we are included. Thank you for your cooperation. Sincerely, ijS. John W. Walker JWW:lp cc: All Counsel of Record Honorable Susan Webber WrightJOHN W. WALKER, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 722or> Telephone (501) 374-3758 FAX (501) 374-4187 RECEIVED MAR 3 I 1993 Office of Desegregation Monitoring JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE WILEY A. BRANTON, JR. AUSTIN PORTER, JR. Also admitlPd to Practice in Georgia & the District of Columbia. March 30, 1993 Honorable Susan Weber Wright United States District Judge United States District Court U.S. Post Office & Courthouse Little Rock, AR 72203 Re: LRSD V PCSSD Dear Judge Wright: I wish to raise the issue of the Little Rock School District's good faith once again regarding its plan to assign students who live in the Ish Incentive Elementary School attendance zone to the new Dr. Martin Luther King, Jr. Interdistrict School. This option would only discourage the parents of students in the Ish attendance zones from sending their students to Ish, thus forcing the closure of Ish Incentive School without proper court approval. On information and belief, the Little Rock School District has never discussed these plans with the patrons of the Ish Incentive School community. Moreover, the District has never discussed their position regarding the Intervenors. Ish attendance zones with the Joshua I would appreciate knowing, as soon as possible, whether we will be able to make our argument that Little Rock School District intends to close Ish Incentive Elementary School with or without court approval. Hopefully, the Court will allow this presentation on April 19th or 20th during the District's budget hearing. Thank you in advance for your response. Sincerely, /i Jbhn W. (j). Walker JWW/lp cc: All Counsel of Record Ms. Ann Brown Dr. Mac Bernd FRIDAY, ELDREDGE & CLARK HERSCHEL H. FRIDAY. P.A. ROBERT V. LIGHT, P.A. WILLIAM H. SUTTON. P.A. JAMES W. MOORE BYRON M. EISEMAN. JR.. P.A. JOE 0. BELL. P.A. JOHN C. ECHOLS. P.A. JAMES A. BUTTRV. P.A. FREDERICK S. URSERY. P.A. H.T. LARZELERE. P.A. OSCAR E. DAVIS. JR.. P.A. JAMES C. CLARK. JR.. P.A. THOMAS P. LEGGETT. P.A.* JOHN DEWEY WATSON. P.A. PAUL B. BENHAM III. P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EdWARO HARRIS. P.A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON, P.A. MEREDITH P. CATLETT, P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL UI. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A WALTER A. PAULSON II. P.A. BARRY E. COPLIN. P.A. RICHARD 0. TAYLOR. P.A. JOSEPH B. HURST. JR.. P.A. ELIZABETH J. ROBBEN. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A. ROBERT S. SHAFER. P.A. WILLIAM M. DRIFFIM HI. P.A, THOMAS N. ROSE, P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL III, P.A. A PARTNERSHIP OP INOIVIOUAUS ANO PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 FIRST COMMERCIAL BUILDING 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201*3493 TELEPHONE 601*379*2011 FAX NO. 501*379*2147 April 1, 1993 KEVIN A. CRASS, P.A. WILLIAM A. WADDELL. JR.. P.A CLYDE *TAB* TURNER. P.A. CALVIN J. HALL. P.A. SCOTT J. LANCASTER. P.A. JERRY L. MALONE. P.A. M. GAYLE CORLEY. P.A. ROBERT B. BEACH. JR.. P.A. J. LEE BROWN. P.A. JAMES C. BAKER. JR.. P.A. H. CHARLES OSCHWEND. JR.. P A HARRY A. LIGHT. P.A. SCOTT H. TUCKER. P.A. JOHN CLAYTON RANDOLPH. P.A GUV ALTON wade PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TONIA P. JONES OAVIO 0. WILSON JEFFREY H. MOORE T. WESLEY HOLMES ANDREW T. TURNER SARAH J. HEFFLEY JOHN RAY WHITE OAVIO M. GRAF PAMELA 0. PERCEFULL CARLA 6. SPAINHOUR JOHN C. FENOLEY. JR. COUNKl WILLIAM J. SMITH WILLIAM A. ELDREDGE, JR.. P.A B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON, JR., P.A. V HITCH'* OIHICT NO. (501) 370*1509 Honorable Susan Webber Wright United States District Judge United States District Court U.S. Post Office & Courthouse 600 West Capitol Little Rock, AR 72201 RECEIVED APR 2 1993 Re: LRSD V. PCSSD Office of Desegregation Monitoring Dear Judge Wright: I am writing in response to the March 30, 1993 letter to you from John Walker which I received today. Mr. Walker was sent a map and an explanation of the proposed King Interdistrict School attendance zone together with information concerning the impact of the creation of the King attendance zone upon other attendance zones. He was asked to comment on the proposed King attendance zone and was told that the proposal would be filed with the court after the Little Rock School District had the benefit of any comments by the other parties. The impact of the proposed King attendance zone upon Ish Incentive School has been and continues to be discussed in the Ish community. Mr. Walker has not given the Little Rock School District the benefit of any comments or concerns the Joshua Intervenors may have concerning the proposed King attendance zone. He will have the opportunity to foraally object when the proposal is presented to the district court in the near future. There is no reason to ignore the normal procedure and to take up this matter at a hearingscheduled for another purpose when there has been no motion filed by the Little Rock School District and no objection filed by the Joshua Intervenors. Thank you for your consideration. Yours very truly, Christopher Heller CJH/k cc
All Counsel of Record Ms. Ann Brown Dr. Mac Bernd f FRIDAY. ELDREDGE & CLARK HERSCHEL H. FRIDAY, P.A. ROBERT V. LIGHT, P.A. WILLIAM H. SUTTON, P.A. JAMES W. MOORE BYRON M. EISEMAN, JR., P.A. JOE D. BELL, P.A. JOHN C. ECHOLS. P.A. JAMES A. BUTTHY, P.A. FREDERICK S. URSERY, P.A. H T. LARZELERE, P.A. OSCAR E. DAVIS, JR., P.A. JAMES C. CLARK, JR.. P.A. THOMAS P. LEGGETT, P.A. JOHN DEWEY WATSON, P.A. PAUL B. BENHAM III, P.A. LARRY W. BURKS,P.A. A. WYCKLIFF NISBET, JR.. P.A. JAMES EDWARD HARRIS. P.A. J. PHILLIP MALCOM, P.A. JAMES M. SIMPSON, P.A. MEREDITH P. CATLETT, P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL III. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER, P.A. WALTER A. PAULSON II, P.A. BARRY E. COPLIN, P.A. RICHARD 0. TAYLOR, P.A. JOSEPH B. HURST, JR., P.A. ELIZABETH J. ROBBEN. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A. ROBERT S. SHAFER. P.A. WILLIAM M. GRIFFIN III. P.A. THOMAS N . ROSE, P. A . MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL III, P.A. A PARTNERSHIP OF INDIVIDUALS ANO PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 FIRST COMMERCIAL BUILDING 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 501-376-201 1 FAX NO. 601-376-2147 March 12, 1993 MW 1 7 '.iJ KEVIN A. CRASS, P.A. WILLIAM A. WADDELL, JR.. P.A. CLYDE 'TAB' TURNER. P.A. CALVIN J. HALL. P.A. SCOTT J. LANCASTER. P.A. JERRY L. MALONE. P.A. M. GAYLE CORLEY. P.A. ROBERT B. BEACH, JR., P.A. J. LEE BROWN, P.A. JAMES C. BAKER. JR., P.A. H. CHARLES GSCHWEND, JR.. P.A. HARRY A. LIGHT. P.A. SCOTT H. TUCKER. P.A. JOHN CLAYTON RANDOLPH. P.A. GUY ALTON WADE PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TONIA P. JONES DAVID 0. WILSON JEFFREY H. MOORE T. WESLEY HOLMES ANDREW T. TURNER SARAH J. HEFFLEY JOHN RAY WHITE DAVID M. GRAF PAMELA 0. PEACEFULL CARLA 0. SPAINHOUR JOHN C. FENOLEY. JR. Oli of Ce-jsgr on f/ionitonng COUNSEL WILLIAM J. SMITH WILLIAM A. ELDREDGE, JR.. P.A. B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR.. P.A. VRlTER'S OIHSCT NO. 1501 I 370-1506 g 'S lass w, -v- Ms. Ann Brown Office of Desegregation Monitoring Heritage West Building 201 East Markham, Suite 510 Little Rock, AR 72201 Mr. Sam Jones Mr. Steve Jones WRIGHT, LINDSEY & JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 JACK, LYON & JONES, P.A. 3400 Capitol Towers Capitol & Broadway Little Rock, AR 72201 Mr. John Walker Mr. Richard Roachell JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 MITCHELL & ROACHELL, P.A. 1014 West Third Little Rock, AR 72201 Re: LRSD V. PCSSD - King Attendant Zone Dear Ann and Gentlemen: I am providing for your review information concerning our proposed King Interdistrict school attendance zone and the impact of that zone upon several other assignment zones in the Little Rock School District. The number of students residing within the proposed zone constitutes roughly half of the expected student population of the school. The reason for this, of course, is that efforts will be made to recruit the remaining students from the Pulaski County Special School District and within the Little Rock School District. I have been advised that the creation of zones for the new Stephens school will not require an adjustment of the proposed King school zone or an adjustment of any of the zones which must now be adjusted to accommodate the creation of a King school zone.I would like to have your comments concerning the proposed King attendance zone as soon as possible. I have enclosed printed maps showing the proposed King zone and its impact upon other zones. Thank you for your consideration. Yours very truly, Christopher Heller CJH/k Enc cc: Mac BerndREPORT ON THE IMPACT OF THE KING ATTENDANCE ZONE Prepared By: Leonard Thalmueller Marie Parker The new Martin Luther King, Junior Elementary School is being constructed in an area near the satellite attendance zones for Jefferson, Forest Park and Terry and near the attendance zones of Rightsell and Mitchell Elementary Schools. The vast majority of the students who live in these attendance zones is black. The new Martin Luther King Elementary school will be an interdistrict school. The Little Rock School District will petition the Court to designate the school an interdistrict magnet school. PARAMETERS Listed below are the parameters which were considered in establishing the attendance zones for the new Martin Luther King, Junior (King) Elementary School: 1. The seating capacity of King will be 696. a. Thirty-six (36) of the 696 seats will be reserved for two four-year-old classes (18 students per class). 4. 5. b. Six hundred-sixty (660) of the seats will be reserved for students in grades kindergarten through sixth grade (k- 6) . The desegregation goal will be to achieve a racial balance of fifty percent black/white. a. b. kathy\King.A2 The range of acceptable racial balance will be from 40% to 60% of either race. The four-year-old classes will seek to obtain a racial balance of 50/50 of either race. King will have an attendance zone. The amount of busing will be minimized. The impact of changing attendance zones at other schools will be minimized. 2. 3.PROCEDURES After a careful analysis of the data and the study of various combinations of zone blocks, the areas indicated in Attachment 1 are the proposed attendance zones for King, Rightsell, Washington and the Jefferson satellite zone. The zone blocks which were reassigned are indicated below and shown in Attachment 2. A. Zone blocks 0432, 0433, and 0438 were transferred from the Jefferson satellite zone to King. B. Zone blocks 0473, 0476, 0477, 0479, 0480 and 0485 were transferred from Ish to King. C. Zone block 0439 was transferred from Rightsell to King. D. Zone block 0439 at Rightsell was replaced with zone block 0455 from Washington. E. Zone blocks 0432, 0433, and 9438 from the Jefferson satellite zone were replaced with 0111, 0112, 0121, 0122 and 0210 from Washington. F. The zone blocks from the Washington zone which were transferred to Jefferson and Rightsell were not replaced since the attendance zone for Washington contains more students than are needed at Washington. IMPACT ON SCHOOLS The school impacted most by the proposed attendance zone changes is Ish Elementary School. Ish is described below. The proposed relationship between King and 1. Students within the Ish attendance zone will be assigned to King but will have the option to remain at Ish. 2. Bus transportation will be provided for those students from the Ish attendance zone who go to the new King School. 3. Ish will remain open unless fewer than 100 students choose Ish, in which case all Ish students will be assigned to King, and Little Rock School District will work with the community to determine building. an appropriate use for the Ish Ish lathy UCing.AZ 2STUDENTS RESIDING IN ATTENDANCE ZONES The impact of the zone block assignments on the attendance zone of the schools involved are shown in the following table. Please note that these data indicate the number of students, other than magnet students, who reside in the attendance zone. Current Attendance Zone Black Nonblack Total Proposed Attendance Zone Black Nonblack Total Ish 186 187 Jefferson Satellite 182 291 473 208 289 497 King 342 349 Rightsell 311 313 294 302 Washington 738 25 763 573 15 588 1 * 0 0 0 0 0 0 7 2 8 *Assuming all students elect to go to King. BUSING The zone blocks shown in Attachment 2 are those whose current school assignments will be changed under this plan. The impact of changing these zone blocks on the transportation of students is indicated below. A. No Change in Transportation 1. The students in zone blocks 0439, 0455 are not B. transported this year and will not transportation under the plan. require The students in zone blocks 0111, 0112, 0121, 0122, 0210 are transported this year and will be transported next year under the plan. Change in Transportation 2. 1. The 110 students residing in zone blocks 0432, 0433 and 0438 are provided transportation this year to Jefferson but will not require transportation to King next year. 2. The 187 0476, 0477, students residing in zone blocks 0473, 0479, 0480 and 0485 are not provided kaihy\King.AZ 33. Attachment 1: Attachment 2: laifay\Kins.AZ transportation this year to transported to King next year. The above would indicate Ish an but will increase transportation for 77 students under this plan. 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y N Z E MPOMOPdOOMXO CMOO3 CMO^OICMOIP as 03 M e p w S.*: > m o z 4 p Z 4 4 c K Ji (n o O UI p . .- J a-i-3 -(EPzoSso o .4 w n E z z z - p o c. 2 3 ------------- -5cuj_j5p2Xq2 *>^cJmQmui-'< 4Ul5zPE?dX^MdUJx<3 4 _ uj u (A W o (I) W O X c > < i
<11 < UI 5 XMd_,5xz'd 5^3pOO4d -OpX4O-I--< E Z a ~ 4UIZZpEu^Z'mij^*X'* .__,.--.-.^^^Jo2Oz3e>5e52wZ ujO:*4>OO4e W4ZO<< < - 4^4 ZE5nffl-->-)u.zo->^->E_i4-,--2",'iOS>fflE->uJUPESi-2oS mui3idOZ'd Ea_i2euiz2 Q E E UII would like to have your comments concerning the proposed King attendance zone as soon as possible. I have enclosed printed maps showing the proposed King zone and its impact upon other zones. Thank you for your consideration. Yours very truly, Christopher Heller CJH/k Enc cc: Mac BerndREPORT ON THE IMPACT OF THE KING ATTENDANCE ZONE Prepared By: Leonard Thalmueller Marie Parker The new Martin Luther King, Junior Elementary School is being constructed in an area near the satellite attendance zones for Jefferson, Forest Park and Terry and near the attendance zones of Rightsell and Mitchell Elementary Schools. The vast majority of the students who live in these attendance zones is black. The new Martin Luther King Elementary school will be an interdistrict school. The Little Rock School District will petition the Court to designate the school an interdistrict magnet school. PARAMETERS Listed below are the parameters which were considered in establishing the attendance zones for the new Martin Luther King, Junior (King) Elementary School: 1. The seating capacity of King will be 696. a. Thirty-six (36) of the 696 seats will be reserved for two four-year-old classes (18 students per class). 4. 5. b. Six hundred-sixty (660) of the seats will be reserved for students in grades kindergarten through sixth grade (k- 6) . The desegregation goal will be to achieve a racial balance of fifty percent black/white. The range of acceptable racial balance will be from 40% to 60% of either race. b. The four-year-old classes will seek to obtain a racial balance of 50/50 of either race. King will have an attendance zone. The amount of busing will be minimized. The impact of changing attendance zones at other schools will be minimized. kalhy\Kin.AZ 2. 3. a. 1PROCEDURES After a careful analysis of the data and the study of various combinations of zone blocks, the areas indicated in Attachment 1 are the proposed attendance zones for King, Rightsell, Washington and the Jefferson satellite zone. The zone blocks which were reassigned are indicated below and shown in Attachment 2. A. Zone blocks 0432, 0433, and 0438 were transferred from the Jefferson satellite zone to King. B. Zone blocks 0473, 0476, 0477, 0479, 0480 and 0485 were transferred from Ish to King. C. Zone block 0439 was transferred from Rightsell to King. D. Zone block 0439 at Rightsell was replaced with zone block 0455 from Washington. E. Zone blocks 0432, 0433, and 9438 from the Jefferson satellite zone were replaced with 0111, 0112, 0121, 0122 and 0210 from Washington. F. The zone blocks from the Washington zone which were transferred to Jefferson and Rightsell were not replaced since the attendance zone for Washington contains more students than are needed at Washington. IMPACT ON SCHOOLS The school impacted most by the proposed attendance zone changes is Ish Elementary School. Ish is described below. The proposed relationship between King and 1. Students within the Ish attendance zone will be assigned to King but will have the option to remain at Ish. 2. Bus transportation will be provided for those students from the Ish attendance zone who go to the new King School. 3 . Ish will remain open unless fewer than 100 students choose Ish, in which case all Ish students will be assigned to King, and Little Rock School District will work with the Ish community to determine building. an appropriate use for the Ish kalhy\King.AZ 2STUDENTS RESIDING IN ATTENDANCE ZONES The impact of the zone block assignments on the attendance zone of the schools involved are shown in the following table. Please note that these data indicate the number of students, other than magnet students, who reside in the attendance zone. Current Attendance Zone Black Nonblack Total Proposed Attendance Zone Black Nonblack Total Ish 186 187 Jefferson Satellite 182 291 473 208 289 497 King 342 349 Rightsell 311 313 294 302 Washington 738 25 763 573 15 588 1 * 0 0 0 0 0 0 7 2 8 *Assuming all students elect to go to King. BUSING The zone blocks shown in Attachment 2 are those whose current school assignments will be changed under this plan. The impact of changing these zone blocks on the transportation of students is indicated below. A. No Change in Transportation 1. The students in zone blocks 0439, 0455 are not B. transported this year and will not transportation under the plan. require The students in zone blocks 0111, 0112, 0121, 0122, 0210 are transported this year and will be transported next year under the plan. Change in Transportation 2. 1. The 110 students residing in zone blocks 0432, 0433 and 0438 are provided transportation this year to Jefferson but will not require transportation to King next year. I 2. The 187 0476, 0477, students residing 0479, in zone blocks 0473, 0480 and 04 85 are not provided lcalhy\King.AZ 33. Attachment 1
Attachment 2: kathy\King. AZ transportation this year to transported to King next year. The above would indicate Ish an but will increase transportation for 77 students under this plan. School Attendance Zones Transferred Zone Blocks 4 be inJOHN W. WALKER, P.A. Attorney At Law 1723 Broadway Little Rock. Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 RECEIVED MAR 1 9 1993 Office of Desegregation fiyionnoiing JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE WILEY A. BRANTON. JR. AUSTIN PORTER. JR. * Also admiltPil to Prartice in (leorRia & Ilie District of Cohimbia. March 16, 1993 Dr. Mac Bernd Chris Heller, Esq. c/o Little Rock School District Little Rock, AR 72201 Dear Dr. Bernd and Mr. Heller: It has just been driven home to me that the interviews are now being conducted for the principalship of the new King School. We understand that the other parties are participants in those We those interviews, interests The Joshua Is there any reason why we are omitted? compelling and ve, request that the interviews be suspended until such time as we are included. is therefore, Thank you for your cooperation. Sincerely, John W. Walker JWW:Ip cc: All Counsel of Record Honorable Susan Webber WrightBOARD MEETING ON 3/25/93 LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, ARKANSAS 72201 received Z 6 TO: March 25, 1993 Olfice ot Desegregation Monitoring Board of Directors FROM: Mac Bernd, Superintendent of Schools SUBJECT: PERSONNEL RECOMMENDATION I recommend that Sadie Mitchell be appointed as the principal of the new Martin Luther King Elementary School for the 1993-94 school year at an annual salary of $42,881.14 plus a car allowance of $564.00.I /93 10:21 501 324 2032 L R School Dlst ODM Wie Need Your Ideas @002/002 Attention: NEIGHBORHOOD PUBLIC MEETINGS Martin Luther King Jr interdistrict School Opening for 1993-94 Community Meetings to gather information from porspective parents and patrons to be used in consideration of atten-jdance zones and theme selection for Martin Luther King Jr School opening at the onset of the 1993-94 school year. TUESDAY, March 30,7 p.m. Allison Presbyterian Church 922 Wright Street, Little Rock THURSDAY, April 1, 7 p.m. Ish Incentive Elementary School 3001 Pulaski Street, Little Rock The Little Rock School District will offer an innovative alternative to your neighborhood school with the opening of Martin Luther King Jr Interdistrict School in the fall of 1993. It will offer a strong, traditional basic skills curriculum woven into a special interest theme. Pulaski County School District students may attend through a majority-to-minority transfer. TEL: Mar 26.93 10 :25 No .001 P.01 UTTtB ROCK SCHOOL DieTRICT OVnCB OP DESBGRBGATION 01 iMnMa ^^**>4 *:. A* Tian TML (501) 324.2351 nan '3- J - 6 -d TO MONnt't nom 324-2271 mUBCT peeial laatnictions C*lico/KA-^ JOHN W. WALKER, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 RECESVED M4R 3 1 1993 Office of Desegregation Monitoring JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE WILEY A, BRANTON, JR. AUSTIN PORTER, JR. * Also admitted to Practice in (Jeorgia & the District of (olumbia. March 30, 1993 Honorable Susan Weber Wright United States District Judge United States District Court U.S. Post Office & Courthouse Little Rock, AR 72203 Re: LRSD V PCSSD Dear Judge Wright: I wish to raise the issue of the Little Rock School District's good faith once again regarding its plan to assign students who live in the Ish Incentive Elementary School attendance zone to the new Dr. Martin Luther King, Jr. Interdistrict School. This option would only discourage the parents of students in the Ish attendance zones from sending their students to Ish, thus forcing the closure of Ish Incentive School without proper court approval. On information and belief, the Little Rock School District has never discussed these plans with the patrons of the Ish Incentive School community. Moreover, the District has never discussed their position regarding the Intervenors. Ish attendance zones with the Joshua I would appreciate knowing, as soon as possible, whether we will be able to make our argument that Little Rock School District intends to close Ish Incentive Elementary School with or without court approval. Hopefully, the Court will allow this presentation on April 19th or 20th during the District's budget hearing. Thank you in advance for your response. Sincerely, (fiXn (1). Itlftfifc J n W. Walker JWW/lp cc: All Counsel of Record Ms. Ann Brown Dr. Mac BerndTO: FROM: RE: LITTLE ROCK SCHOOL DISTRICT 810 West Markham Little Rock, Arkansas March 30, 1993 Marie Parker, Associate Superintendent IJ HI 8 I T 1 I------- Jeanette Wagner, Acting Director of Communications Distribution of King Public Meeting Fliers The fliers for the King School public meetings were distributed as follows: 25 fliers - TCBY building for placement in employee lounges, etc. 20 fliers - Dept, of Education, Capitol Mall for placement in employee lounges 10 fliers - AlDC, Capitol Mall for placement in employee lounges and on bulletin boards. Janet van der Werff, director of communications, also agreed to place a notice on E-Mail for the next two days for all employees. no fliers - Arkansas Children's Hospital does not allow outside fliers to be placed in the building, Jessica Szehner, director of pubhc relations, agreed to put notice on E-Mail for their more than 3,000 employees for the next three days. Some very good groundwork has been laid by going through the proper channels. Onward!!( , I I C r' ( r f r r c (' f ( f '< \ ( ( i . !, i . p exhibit V 9 ------------ ' ** T^ztiztZ X'^/^n I. i .L Ml J Zi?. 13. I 1^2 ZT/X M / l(p >4.'-t <<, /.. 1 - , % I I9 i i 2. -J 7 iT f sa?r A' iiJr \i .. . ^-'k. L Wa:
.l-Tfe- >! 77V45 IL i^fi.------------------- J-3, 'r^ K> A: -.vA IS 33= X 'ir S 1 . 'v-hVL' " ' . ,, ..: -Vvt.l '? S' ! X l^ !, ^0 \11 Q! J (Iio r I - ! -o 'M ' I} , ? I f FRIDAY, ELDREDGE & CLARK if HERSCHEL H. FRIDAY. P.A. ROBERT V. LIGHT. P.A. WILLIAM H. SUTTON. P.A. JAMES W. MOORE BYRON M. EISEMAN, JR., P.A. JOE D. BELL, P.A. JOHN C. ECHOLS, P.A. JAMES A. BUTTRY, P.A. FREDERICK S. URSERY, P.A. H.T. LARZELERE, P.A. OSCAR E. DAVIS, JR., P.A. JAMES C. CLARK, JR., P.A. THOMAS P. LEGGETT. P.A.' JOHN DEWEY WATSON. P.A. PAUL B. BENHAM III. P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EbWARO HARRIS. P.A. J. PHILLIP MALCOM, P.A. JAMES M. SIMPSON, P.A. MEREDITH P. CATLETT. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL III. P.A. DONALD H. BACON, P.A. WILLIAM THOMAS BAXTER, P.A. WALTER A. PAULSON II, P.A. BARRY E. COPLIN, P.A. RICHARD 0. TAYLOR. P.A. JOSEPH B. HURST, JR.. P.A. ELIZABETH J. ROBBEN. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH, P.A. ROBERT S. SHAFER, P.A. william M. r.BicpiN )H p.4 THOMAS N. ROSE, P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY, P.A. WALTER M. EBEL III, P.A. A PARTNERSHIP OP INDIVIDUALS AND PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 FIRST COMMERCIAL BUILDING 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 TELEPHONE 601-376-201 1 FAX NO. 501-376-2147 April 1, 1993 KEVIN A. CRASS, P.A. WILLIAM A. WADDELL, JR., P.A. CLYDE *TA8 TURNER. P.A. CALVIN J. HALL, P.A. SCOTT J. LANCASTER, P.A. JERRY L. MALONE, P.A. M. GAYLE CORLEY, P.A. ROBERT B. BEACH, JR., P.A. J. LEE BROWN, P.A. JAMES C. BAKER, JR., P.A. H. CHARLES GSCHWEND, JR.. P.A. HARRY A. LIGHT, P.A. SCOTT H. TUCKER, P.A. JOHN CLAYTON RANDOLPH, P.A. GUY ALTON WADE PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TONIA P. JONES DAVID 0. WILSON JEFFREY H. MOORE T. WESLEY HOLMES ANDREW T. TURNER SARAH J. HEFFLEY JOHN RAY WHITE DAVID M. GRAF PAMELA 0. PERCEFULL CARLA G. SPAINHOUR JOHN C. FENDLEY, JR. COUNSEL WILLIAM J. SMITH WILLIAM A. ELDREDGE, JR., P.A. B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON, JR., P.A. WRITER'S DIRECT NO. (501) 370-1606 Honorable Susan Webber Wright United States District Judge United States District Court U.S. Post Office & Courthouse 600 West Capitol Little Rock, AR 72201 RECEIVED APR 2 I993 Re: LRSD V, PCSSD Office of Desegregation Monitoring Dear Judge Wright: I am writing in response to the March 30, from John Walker which I received today. 1993 letter to you Mr. Walker was sent a map and an explanation of the proposed King Interdistrict School attendance zone together with information concerning the impact of the creation of the King attendance zone upon other attendance zones. He was asked to comment on the proposed King attendance zone and vzas told that the roposal would be filed with the court after the Little Rock School District had the benefit of any comments by the other parties. The impact of the proposed King attendance zone upon Ish Incentive School has been and continues to be discussed in the Ish community. Mr. Walker has not given the Little Rock School District the benefit of any comments or concerns the Joshua Intervenors may have concerning the proposed King attendance zone. He will have the opportunity to formally object when the proposal is presented to the district court in the near future. There is no reason to ignore the normal procedure and to take up this matter at a hearingscheduled for another purpose when there has been no motion filed by the Little Rock'School District and no objection filed by the Joshua Intervenors, Thank you for your consideration. Yours very truly, Christopher Heller CJH/k cc: All Counsel of Record Ms. Ann Brown Dr. Mac Bernd JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE WILEY A. BRANTON, JR. AUSTIN PORTER, JR. * Also admitted to Practice in CfOorRia & Iho District of Oilumbia. JOHN W. WALKER, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 received APR 6 1993 Office of Desegregation Monitoring April 5, 1993 Honorable Susan Webber Wright United States District Judge United States District Court U.S. Post Office & Courthouse Little Rock, AR 72203 Dear Judge Wright: This is in reply to the letter of April 1, to you. 1993 by Mr. Heller The Joshua concerns were presented to the Court on a timely basis when it became apparent that the District in fact intends to close an incentive school. Dr. Bernd's comments in the press about what will happen to Ish mirror your admonitions to the North Little Rock District with respect to the Rose City closing. Thus, to him at least, Ish's closing is already a fait accompli. That is not Moreover, it acceptable and represents a serious plan deviation. is an attempt to circumvent the double funding requirements of the plan for these children. We, therefore, seriously object to this dialogue. Furthermore, the new school construction contemplated by the plan was for the purpose of supplementing, than educational presence in the American rather supplanting, community. African Rather than work within the plan, Mr. Heller seems to relegate Joshua to litigation: "He will have the opportunity to formally object when the proposal is presented to the District Court in the near future." Par 2 The Joshua Intervenors do not wish to be, and by the settlement did not plan to be, in constant litigation regarding The district's approach unnecessarily basic tenets of the plan. involves the Court and counsel in the district's devious approach Surely, the Court can see that the district to modify the plan. plans to convert two schools to one by their plan. is to be continued other than by way of Joshua complaints regarding If litigationPage Two Honorable Susan Webber Wright April 5, 1993 implementation or LRSD change proposals after due consultation between the parties, then Joshua asserts that their counsel, like the school district counsel, should be paid for their time and effort. Time is of the essence because the African American community is again being left in s state of query and further divided by the School District's statements regarding Ish. Please set this for hearing on the 19th or 20th. Respectfully submitted, bhn W. Walker JWW:Ip cc: All Counsel of Record Ms. Ann Brown7. FRIDAY, ELDREDGE & CLARK HERSCHEL H, FRIDAY. P.A. ROBERT V. LIGHT, P.A. WILLIAM H. SUTTON, P.A. JAMES W. MOORE BYRON M. EISEMAN, JR., P.A. JOE 0. BELL. P.A. JOHN C. ECHOLS, P.A. JAMES A. BUTTRY, P.A. FREDERICK S. URSERY, P.A. H.T. LARZELERE, P.A. OSCAR E. DAVIS, JR., P.A. JAMES C. CLARK. JR., P.A. THOMAS P. LEGGETT, P.A. JOHN DEWEY WATSON, P.A. PAUL B. BENHAM III, P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET, JR.. P.A. JAMES EDWARD HARRIS, P.A. J. PHILLIP MALCOM, P.A. JAMES M. SIMPSON, P.A. MEREDITH P. CATLETT. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL III. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A. WALTER A. PAULSON II. P.A. BARRY E. COPLIN. P.A. RICHARD 0. TAYLOR. P.A. JOSEPH B. HURST. JR.. P.A. ELIZABETH J. ROBBEN. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A. ROBERT S. SHAFER. P.A. WILLIAM M. GRIFFIN III. P.A. THOMAS N . ROSE, P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL III. P.A. A PARTNERSHIP OF INDIVIDUALS ANO PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 FIRST COMMERCIAL BUILDING 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 601-376-2011 FAX NO. 601-378-2147 April 8, 1993 RECEIVED KEVIN A. CRASS. P.A. WILLIAM A. WADDELL. JR.. P.A CLYDE 'TAB* TURNER. P.A CALVIN J. HALL. P.A. SCOTT J. LANCASTER. P.A. JERRY L. MALONE. P.A. M. GAYLE CORLEY, P.A. ROBERT B. BEACH, JR., P.A. J. LEE BROWN. P.A. JAMES C. BAKER. JR.. P.A. H. CHARLES GSCHWENO. JR.. P.A. HARRY A. LIGHT, P.A. SCOTT H. TUCKER. P.A. JOHN CLAYTON RANDOLPH. P.A GUY ALTON WADE PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TONIA P. JONES OAVIO 0. WILSON JEFFREY H. MOORE T. WESLEY HOLMES ANDREW T. TURNER SARAH J. HEFFLEY JOHN RAY WHITE DAVID M. GRAF PAMELA D. PERCEFULL CARLA G. SPAINHOUR JOHN C. FENOLEY, JR. iPR 1 2 W3 Office of Dessgrj Monitonng COUNSCl WILLIAM J. SMITH WILLIAM A. ELDREDGE. JR.. P.A. B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON, JR.. P.A. WRITEK** OlfieCT NO. (50n 370-1606 Honorable Susan Webber Wright United States District Judge United States District Court U.S. Post Office & Courthouse 600 West Capitol Little Rock, AR 72201 Re: LRSD V. PCSSD - King Attendance Zone Dear Judge Wright: I must respond to Mr. Walker's letter of April 5, 1993. The assertions contained in that letter bear no relationship to the truth. 1993 . The The Little Rock School District has not "relegate[d] Joshua to litigation". The Little Rock School District has not tl unnecessarily involve[d] the Court and counsel in the district's devious approach to modify the plan". All the Little Rock School District has done is to provide the Joshua Intervenors through Mr. Walker information concerning the proposed King Interdistrict School attendance and to request Mr. Walker's conunents concerning the proposed attendance zone. We have received no zone Walker's response from Mr. Walker concerning the proposed King attendance zone. Mr. Walker contends that the Joshua Intervenors do not wish to be in constant litigation. statement. Joshua's recent actions belie that --------- First, Joshua's response was to the Court, not to LRSD, when LRSD simply sought to learn Joshua's position with respect to the King attendance zones so that the parties could discuss the not to LRSD, matter before anything was filed with the Court. Second, Mr. Walker sued the district concerning its election zones without any prior notice or discussion. Third, Joshua has filed numerous "motions for further relief" concerning matters which have nothing to do the desegregation plan. Finally, the Arkansas with Department of Education says in its recently filed brief that the Joshua Intervenors "did not even bother to contact the state" before filing litigation. a motion to bring the ADE brief, state back into this P- 5. That would be consistent with Joshua's recent efforts to avoid the negotiations and discussions required by the spirit of the desegregation plan and to resort first to litigation. If Joshua continues to refuse to provide its comments concerning the proposed King attendance zone to the Little Rock School District, the only reasonable way to proceed is to allow Joshua to respond appropriately in court at such time as the Little Rock School District attendance zone for King, before that time. seeks court approval to establish an There is no reason to call a hearing Respectfully submi CJH/k Enc cc: All Counsel of Record Ms. Ann Brown Dr. Mac Bernd Christopher^el r* EXHIBIT LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, AR 72201 s e LI April 22, 1993 TO: Board of Directors FROM: Marie Parker, Associate Superintendent, Organizational and Learning Equity THROUGH: Dr. C.M. Bernd, Superintendent of Schools SUBJECT: Approval of New Martin Luther King, Jr., Attendance Zone The new Martin Luther King, Jr. Interdistrict School located at 10th and Martin Luther King, Jr. Drive (King) is scheduled to open August, 1993. A map of the proposed attendance zone for King is attached. We have notified the parties, conducted neighborhood meetings with the community members and parents whose children are targeted for re- cruitment or assignment to the new school. We have also mailed surveys to all families that will be affected by the proposed zone, including Pulaski County Special School District. The receipt of this group of surveys will allow us to establish a theme for King. It is recommended that the Board approve the proposed attendance zone for the new Martin Luther King, Jr. Interdistrict School. I EXHIBIT "B"Little Rock School District fnv April 28, 1993 1J''1 A
1Y! 3 1993 O'tice of Do: igregatoii ^ion.io.ing Ms. Joy Springer 1723 Broadway Little Rock, AR 72206 Dear Ms. Springer: The information you requested in your letter dated April 20, 1993 regarding the Parent Recruitment Team is enclosed. The individuals on this team represents the first phase of our concerted effort to move beyond recruitment in isolation to a more comprehensive plan of recruitment. have someone from Joshua represented on this team. We would be pleased to Other teams to be directly involved in the recruitment process are LRSD Recruitment Coordinators representing each school, PTA representatives from each school and teams identified by categories of schools (incentive schools, area schools, magnet schools, etc.). Mrs. Becky Rather, Parent Recruitment Coordinator, will serve as the liaison person to each of these groups. She is housed in the Student Assignment Office and I am responsible for providing leadership to her in this endeavor. If there are questions or concerns please call. Sincerely, Marie A. Parker cc: Mac Bernd Ann Brown Chris Heller Becky Rather 810 West Markham Street Little Rock, Arkansas 72201 (501)324-2000 ti INTERDISTRICT PARENT RECRUITMENT TEAM I 1. Becky Rather, W/F, Parent Recruitment Coordinator (SAO) 2. Troy Cole, W/M, Parent Recruitment Coordinator (SAO) 3. Jeanette Wagner, W/F, Communications Director 4. Carla Bobo, B/F, PTA Council President 5. Debbie Milam, W/F, VIPS Coordinator 6. Roy Albert, B/M, Parent Council Chairperson 7 . Liz Parkhurst, W/F, Subcommittee Recruitment Chairperson, District Biracial Team 8. Catherine Gill, B/F, Parent Recruitment/Parent Involvementent, Coordinator for Incentive Schools 9. Sadie Mitchell, B/F, Principal, Martin Luther King, Jr. School 10. Marie Parker, B/F, Associate Superintendent for Organizational and Learning Equity 11. Pat Price, W/F, Early Childhood Education 12-15. Representative to be appointed from: A. B. C. D. Incentive Schools Area Schools Interdistrict Schools Magnet School 16. Representative to be appointed from LRSD Principals' Roundtable 17. Billy Bowles, B/M, Assistant Superintendent, PCSSD Separate working committees facilitated by the Recruitment Coordinator will be established to include: 1 a representative from each of the schools as described in the Plan PTA president from each school or their designeeJOHN W. WALKER, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 7220c Telephone (501) 374-3758 FAX (501) 374-4187 received aV 1 8 5 Office ot Desegregation Monitoring JOHN W, WALKER RALPH WASHINGTON MARK BURNETTE WILEY A. BRANTON, JR. AUSTIN PORTER. JR. Alwi arlniillcd to Practio* in (Iwrgia & the District of Columbia. May 17, 1993 Christopher Heller, Esq. Friday, Eldredge & Clark 2000 First Commercial Building Sam Jones, Esq. Wright, Lindsey & Jennings 2200 Worthen Bank Building Little Rock, AR 72201 Little Rock, AR 72201 Steve Jones, Esq. Jack, Lyon & Jones, P.A. 3400 Capitol Towers Capitol & Broadway Streets Richard Roachell, Esq. Roachell & Streett 401 West Capitol Ave. Little Rock, AR 72201 Suite 504 Little Rock, AR 72201 Ann Brown, Monitor Office of Desegregation Monitoring 210 East Markham Little Rock, AR 72201 Re: LRSD V. PCSSD
No. LR-C-82-866 Dear Sirs and Madam: Enclosed you will find the following pleadings which have been filed in the above matter: 1. Motion to Allow Discovery and for a Further Extension of Time in Which to Reply to the Motion to Dismiss
2 . The Response of the Joshua Intervenors to the Little Rock School District's Motion to Approval of Stephens Interdistrict School Site
and 3 . Opposition to Motion for Approval of King Interdistrict Attendance Zone. Sincerely, C J . A /tf John W. Walker JWW
Ip Enclosures JOHN W. WALKER RALPH WASHINCTON MARK BURNETTE WILEY A. BRANTON, JR. AUSTIN PORTER. JR. Also adinilUxl to Iraclico in (JoorKia & thn Bislrict of Columbia. JOHN W. WALKER, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 EAX (501) 374-4187 May 17, 1993 Honorable Susan Webber Wright United States District Judge 600 West Capitol Little Rock, AR 72203 Re: LRSD V. PCSSD No. LR-C-82-866 Dear Judge Wright: received may 1 8 Office of Desegregation Monitoring I am most disappointed with the site of the new King school. It meets none of your requirements for attractiveness or for being an attraction to pupils who are Someone apparently just decided to make possible by placing it right by King Drive. not required to attend there. it as unattractive as Also the plans for the construction of Stephens do not include placement for the youngsters who attend that school during the construction period. I am hand delivering this letter to you so that it can receive your immediate and urgent attention. The District seems to be planning or failure by its location of King and its silence upon the interim placement of the necessarily displaced students at Stephens. Would you please give these matters your urgent attention. iry truly yours, ohn W. Walker JWW/js cc: Ail Counsel of Record Dr. C.M. Bernd Ms. Ann Brown Mr. Bobby Lester Mr. James SmithPCSSD PULASKI COUNTY SPECIAL SCHOOL DISTRICT 925 East Dixon Road/P.O. Box 8601 Little Rock, Arkansas 72216-8601 (501) 490-2000 I DATE: May 17, 1993 TO: FROM: Ms. Peggy Bates, Lawson Elementary f^^Ruth Simmons Herts, Director of Desegregation SUBJECT: Student Recruitment for M. L. King Interdistrict Elementary School I have enclosed fliers which announce the opening of the M. L. King Interdistrict Elementary School. Please distribute to all K-6 students. Thank you very much for your cooperation. ch c Mr. Billy Bowles Mrs. Connie Hickman Tanner PCSSD PULASKI COUNTY SPECIAL SCHOOL DISTRICT 925 East Dixon Road/P.O. Box 8601 Little Rock, Arkansas 72216-8601 (501)490-2000 I DATE: May 20, 1993 TO: Affected Principals FROM: '^^r. Ruth Simmons Herts, Director of Desegregation, SUBJECT: Student Recruitment for M.L. King Interdistrict Elementary School As you are aware, we are recruiting students to attend the M.L. King Interdistrict Elementary School which will open in August 1993. White students from your school may attend on a majority-to-minority transfer. Ms, Becky Rather, Parent Recruiter Coordinator (LRSD), is available to make presentations to parents and share information about the new school. She can be contacted at 324-2272. Please inform your parent organization officers and other parents as well. Thank you very much for your cooperation. / c Mr. Billy Bowles Ms. Connie Hickman Tanner A copy of this memo was sent the following schools
Lawson Elem. Oak Grove Elem. Pine Forest Elem. Sherwood Elem. to Sylvan Hills Arnold Drive Cato Elem. Dupree Elem. Jacksonville Elem. Elem. Elem. Taylor Elem. Tolleson Elem. A PCSSD PULASKI COUNTY SPECIAL SCHOOL DISTRICT 925 East Dixon Road/P.O. Box 8601 Little Rock, Arkansas 72216-8601 (501) 490-2000 DATE: May 11. 1993 TO: Affected Principals FROM- Ruth Simmons Herts, Director of Desegregation SUBJECT: M. L. King Informational Fliers I have enclosed fliers for the meetings which are scheduled next week regarding the M. L. King Elementary Interdistrict School. Please distribute to K-5 students. contact me. Thank you very much. If you have questions, feel free to ch This memo was sent to the following: Sherwood Elem. Sylvan Hills Elem. Pine Forest Elem. Oak Grove Elem. PCSSD PULASKI COUNTY SPECIAL SCHOOL DISTRICT 925 East Dixon Road/P.O. Box 8601 Little Rock, Arkansas 72216-8601 (501) 490-2000 DATE: May 11. 1993 TO: Affected Principals FROM: . Ruth Simmons Herts, Director of Desegregation SUBJECT: Recruitment for M.L. King Elementary Interdistrict I have enclosed fliers which outline information about the M. L. King Elementary Interdistrict School which is opening this fall. Please distribute to K-5 students. me. Thank you very much. If you have questions, feel free to contact ch This memo was went to the following schools: Arnold Drive Cato Elem. Dupree Jacksonville Elem. Taylor Elem. Tolleson Elem. PCSSD PULASKI COUNTY SPECIAL SCHOOL DISTRICT 925 East Dixon Road/P.O. Box 8601 Little Rock, Arkansas 72216-8601 (501) 490-2000 I June 3, 1993 Dear Counselor: Thank you for agreeing to attend an informational meeting regarding the new Dr. Martin Luther King Elementary Interdistrict School. The meeting will be held , Monday, June 7, 1993, 9 a.m. at the Little Rock School District Administrative Office Building located at 810 West Markham. The meeting will end around 11:00 - 11:30 a.m. Parking is available at the side and back of the building, on the street and in the fenced area across the street. I have been informed by Little Rock School District officials that it is fine to park at either one of these areas. As you are aware, the new school is scheduled to open in August. The Pulaski County Special School District is presently recruiting students to attend the school on majority-to-minority transfers. I certainly look forward to seeing you there on June 7. Please feel free to call me at 490-2000, ext. 205 if you have any questions. Sincerely, Ruth Simmons Herts, Ed.D. Director of Desegregation ps 0 Mr. Bobby Lester Mr. Billy Bowles PCSSD PULASKI COUNTY SPECIAL SCHOOL DISTRICT 925 East Dixon Road/P.O. Box 8601 Little Rock, Arkansas 72216-8601 (501) 490-2000 June 3, 1993 Dear Parents/Guardians: Thank you for agreeing to attend an informational meeting regarding the new Dr. Martin Luther King Elementary Interdistrict School. The meeting will be held Monday, June 7, 1993, 9 a.m. at the Little Rock School District Administrative Office Building located at 810 West Markham. The meeting will end around 11:00 - 11:30 a.m. Parking is available at the side and back of the building, on the street and in the fenced area across the street. I have been informed by Little Rock School District officials that it is fine to park at either one of these areas. As you are aware, the new school is scheduled to open in August. The Pulaski County Special School District is presently recruiting students to attend the school on majority-to-minority transfers. I certainly look forward to seeing you there on June 7. Please feel free to call me at 490-2000, ext. 205 if you have any questions. Sincerely, Ruth Simmons Herts, Ed.D. Director of Desegregation ps c Mr. Bobby Lester Mr. Billy Bowles The following people were sent information about a meeting regarding the new King Elementary Interdistrict School, Monday, June 7, 1993 held at the Little Rock School District Administrative Office Building located at 810 West Markham. Arnold Drive, Elementary Tanna Pitts, Parent Route 1 Box 525 Ward, AR 72176 Penny Davenport, Parent Cato Elementary Jennifer Drew, Counselor P.O. Box 21297 Little Rock, AR 72221 Patricia Losack, Parent 120 Gravel Lane North Little Rock, AR 72120 835-7830 Dupree Elementary Vickie Wordworth, Parent 112 Marilyn Lane Jacksonville, AR 72099 988-5514 Vivien McCullough, Counselor 2005 Millwood Conway, AR 72032 Denise Smith 1008 McArthur Drive Jacksonville, AR 72076 982--6553 Jacksonville Elementary Linda Remele, Counselor #2 Foxhunt Cove Jacksonville, AR 72076Sandy Blasingame, Parent 1113 Grazing Lane Jacksonville, AR 72076 Julia Evans 809 Braden Cove Jacksonville, AR I Lawson Elementary Ellen Stanber, Parent 7911 Johnston Little Rock, AR 72210 445-5307 Cathy Swaty, Parent 17124 Lawson Road Little Rock, AR 72210 Lois Craig, Counselor 3600 Rocky Lane Little Rock, AR 72210 Oak Grove Elementary Mickey Kendrick, Parent 13007 Katherine Drive North Little Rock, AR 72118 Susan Haynes, Parent Julia Rauton, Parent 1700 West Park #40 Little Rock, AR 72204 Oakbrooke Elementary Bridget Riedie, Parent 387 East Marilyn Sherwood, AR 72120 Lisa Rogers, Parent 103 Summer Shade Sherwood, AR 72120 Nancy Eddy, CounselorPine Forest Elementary Rebecca Stanley, Parent 51 Kingsbridge Way Little Rock, AR 72212 Pinewood Elementary Sara Shinn, Counselor 10 Satterfield Mayflower, AR 72106 I Sherwood Elementary Marilyn Berry, Parent 1406 Coolhurst Sherwood, AR 72116 835-6817 Jane Luckey, Counselor 5 Brooklawn Drive Little Rock, AR 72205 Sylvan Hills Elementary Peggy O'Sullivan, Parent 310 Kelso Road Jacksonville, AR 72076 Angie Scott, Parent 43 Stanwood Loop North Little Rock, AR 72118 Jacquelyn Briley, Counselor 12133 Southridge Little Rock, AR 72212 Taylor Elementary Anita Knife, Parent Route 1 Box 181-13 Jacksonville, AR 72076 Bobbi Young, Parent Route 1 Box 177 Military Road Jacksonville, AR 72076Cindy Williams, Counselor #6 Pineridge Place Jacksonville, AR 72076 Tolleson Elementary Lisa Peeples, Counselor Route 1 Box 8062 Jacksonville, AR 72076 982-2572 ( Sue Pillow, Parent 702 Jefferson Jacksonville, AR 72076 835-6556 Charles Ellison, Parent 125 Arkansas Jacksonville, AR 72099 988-2802FRIDAY, ELDREDGE & CLARK ee HERSCHEL H. FRIDAY. P.A. ROBERT V. LIGHT. P.A. WILLIAM H. SUTTON. P.A. JAMES W MOORE BYRON M. EISEMAN, JR.. P.A. JOE 0. SELL. P.A. JOHN C. ECHOLS. P.A. JAMES A. BUTTRY. P.A. FREDERICK S. URSERY. P.A. H.T. LARZELERE. P.A. OSCAR . DAVIS. JR.. P.A. JAMES C. CLARK. JR.. P.A. THOMAS P. LEGGETT. P.A. JOHN DEWEY WATSON, P.A. PAUL S. BENHAM III. P.A. LARRY W. BURKS, P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EDWARD HARRIS, P.A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON. P.A. MEREDITH P. CATLETT. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL III. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A. WALTER A. PAULSON II. P.A. BARRY E. COPLIN. P.A. RICHARD 0. TAYLOR. P.A. JOSEPH B. HURST. JR.. P.A. ELIZABETH J. ROBBEN. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A. ROBERT S. SHAFER. P.A. WILLIAM M. GRIFFIN III, P.A. THOMAS N . ROSE. P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL III. P.A. A PARTNERSHIP OF INOIVIOUALS ANO PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 FIRST COMMERCIAL BUILDING 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 TELEPHONE 501-376-201 1 FAX NO. 501-378-2147 May 24, 1993 received mat 2 8 W5 OHIce of Desegregation Monitoring Honorable Susan Webber Wright United States District Judge United States District Court U.S. Post Office & Courthouse 600 West Capitol Little Rock, AR 72201 Re: LRSD V. PCSSD Case No. LR-C-82-866 Dear Judge Wright: to you. KEVIN A. CRASS. P.A. WILLIAM A. WAOOCLL, JR.. P.A. CLYDE *TAB* TURNER. P.A. CALVIN J. HALL. P.A. SCOTT J. LANCASTER. P.A. JERRY L. MALONE. P.A. M. GAYLE CORLEY. P.A ROBERT B. BEACH. JR.. P.A. J. LEE BROWN. P.A. JAMES C. BAKER. JR.. P.A. H. CHARLES GSCHWEND. JR.. P.A. HARRY A. LIGHT. P.A. SCOTT M, TUCKER. P.A. JOHN CLAYTON RANDOLPH. P.A GUV ALTON WADE PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TONIA P. JONES DAVID 0. WILSON JEFFREY H. MOORE T. WESLEY HOLMES ANDREW T. TURNER SARAH J. HEFFLEY JOHN RAY WHITE DAVID M. GRAF PAMELA 0. PERCEFULL CARLA G. SPAINHOUR JOHN C. FEN OLEY, JR. COUNtCi WILLIAM J. SMITH WILLIAM A. ELDREDGE. JR.. P.A. B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON, JR., P.A. VNITCN't OINECT NO. (501) 370-1606 I am writing in response to Mr. Walker's May 17, 1993 letter Mr. Walker contends that judicial action is required because the King Interdistrict School is "unattractive" and "the plans for the construction of Stephens do not include placement for the youngsters who attend that school during the construction period." He is wrong. The King Interdistrict School is being constructed in compliance with the applicable desegregation plans and the orders of this Court. find the school to be There is no requirement that Mr. Walker personally tl attractive". The plans for relocating Stephens students during the construction of the Stephens Interdistrict School are contained in the "Stephens Elementary School Strategic Plan" which was filed and served upon Mr. Walker on September 8, 1992. That plan, at page 6, says that Stephens students "will be moved to the Oakhurst/King school site during the construction period".Since these issues were raised in a letter to the Court, and not in a pleading, we do not believe that any further response from LRSD is required. Thank you for your consideration. Yo ery Christopher Heller CJH/k Enc cc: All Counsel of Record Dr. Mac Bernd Ms. Ann Brown Mr. Bobby Lester Mr. James Smith IqC. ' K * II C Fiin 1
- ! C IN THE UNITED STATES STRICT COURT EASTERN DISTRICT O^J\RKANSAS f. WESTERN DIVISION '' c
. , I n A LITTLE ROCK SCHOOL DISTRICT BY. PLAINTIFFS NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL DEFENDANTS KATHERINE KNIGHT, ET AL INTERVENORS 1. MOTION FOR APPROVAL OF KING INTERDISTRICT SCHOOL ATTENDANCE ZONE The Dr. Martin Luther King, Jr. Interdistrict School is presently under construction at a site approved by the Court. King Interdistrict School is scheduled to be open for the 1993-94 school year. The Interdistrict Desegregation Plan states that II Interdistrict Schools shall be populated primarily by black L
V. 2. students from LRSD and by white students from PCSSD or beyond Pulaski County". Interdistrict Desegregation Plan, p. 4. The Plan also notes that tl [a]s new Interdistrict Schools are established those seats attributable to LRSD will be available for those students who otherwise would or could have been assigned to an Incentive School". 3. LRSD developed a proposed attendance zone for King Interdistrict School and submitted the proposed zone to all of the parties to this case and to the Office of Desegregation Monitoring < * on March 17, 1993 . The proposed King Interdistrict School attendance zone was approved by the LRSD Board of Directors at its regular meeting on April 22, 1993. A map of the proposed zone is attached as Exhibit "A". A Memorandum from Marie Parker to the LRSD Board of Directors in support of the attendance zone is attached as Exhibit "B" . A report on the impact of the King attendance zone prepared by Marie Parker and Leonard Thalmueller is attached as Exhibit "C" . A list of the steps which have been taken in preparation for the opening of King school is attached as Exhibit "D". A draft recruitment plan for King Interdistrict School is attached as Exhibit "E" . The results of the survery conducted to select a theme for King Interdistrict School are attached as Exhibit Information concerning the public meetings which were conducted to gather information from "F". prospective parents and patrons to be used in consideration of attendance zones and theme selection for King Interdistrict School is attached as Exhibit "G". 4 . The King attendance zone proposed by the Little Rock School District has been submitted to all the parties to this case and to the Office of Desegregation Monitoring, discussed at community meetings and approved by the LRSD Board of Directors. LRSD asks this court to approve the proposed zone. WHEREFORE, for the reasons set out above, LRSD prays for an order approving the attendance zone for King Interdistrict School I shown on the map attached to this motion. Respectfully submitted. 2LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE & CLARK 2000 First Commercial Bldg. 400 West Capitol Street Little Rock, AR 72201 (501) 376-2011 Christopher Hell?6f Bar No. 81083 CERTIFICATE OF SERVICE I certify that a copy of the foregoing Motion for Approval of King Interdistrict School Attendance Zone has been served on the following by depositing copy of same in the United States mail on this , day of April, 1993: Mr. John Walker JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 Mr. Sam Jones WRIGHT, LINDSEY & JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 3400 Capitol Towers Capitol & Broadway Streets Little Rock, AR 72201 Mr. Richard Roachell #15 Hickory Creek Drive Little Rock, AR 72212 3Ms. Ann Brown Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 istopher 4 LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, AR 72201 April 22, 1993 TO: Board of Directors FROM: Marie Parker, Associate Superintendent, Organizational and Learning Equity THROUGH: Dr. C.M. Bernd, Superintendent of Schools SUBJECT: Approval of New Martin Luther King, Jr., Attendance Zone The new Martin Luther King, Jr. Interdistrict School located at 10th and Martin Luther King, Jr. Drive (King) is scheduled to open August, 1993. A map of the proposed attendance zone for King is attached. We have notified the parties, conducted neighborhood meetings, with the community members and parents whose children are targeted for re- cruitment or assignment to the new school. We have also mailed surveys to all families that will be affected by the proposed zone. including Pulaski County Special School District. The receipt of this group of surveys will allow us to establish a theme for King. It is recommended that the Board approve the proposed attendance zone for the new Martin Luther King, Jr. Interdistrict School. EXHIBIT "B n( REPORT ON THE IMPACT OF THE KING ATTENDANCE ZONE Prepared By: Leonard Thalmueller Marie Parker The new Martin Luther King, Junior Elementary School is being constructed in an area near the satellite attendance zones for Jefferson, Forest Park and Terry and near the attendance zones of Rightsell and Mitchell Elementary Schools. The vast majority of the students who live in these attendance zones is black. The new Martin Luther King Elementary school will be an interdistrict school. The Little Rock School District will petition the Court to designate the school an interdistrict magnet school. PARAMETERS Listed below are the parameters which were considered in establishing the attendance zones for the new Martin Luther King, Junior (King) Elearntary School: 1. The seating capacity of King will be 696. Thirty-six (36) of the 696 seats will be reserved for two four-year-old classes (11 students per class). 2. 5. b. Six hundred-sixty (660) of the seats will be reserved for students in grades kindergarten through sixth grade (k- 6) . '"he desegregation goal will be to achieve a racial balance of ifty percent black/white. a. b. The range of acceptable racial balance will be from 40% to 60% of either race. The four-year-.old classes will ^-jek to obtain a racial balance of 50/50 of either race. King will have an attendance zone. The amount of busing will e minimized. The impact of changing attendance zones at other schools will be minimized. EXHIBIT "C" 3. 4.PROgEPVEES After a careful analysis of the data and the study of various combinations of zone blocks, the areas indicated in Attachment 1 are the proposed attendance zones for King, Rightsell, Washington and the Jefferson satellite zone. --- .LllL. ---- Th* zone blocks which were reassigned are indicated below and shown in Attachment 2. A. Zone blocks 0432, 0433, and 0438 were transferred from the Jefferson satellite zone to King. B. Zone blocks-0473, 0476, 0477, 0479, 0480 and 0485 were transferred from Ish to King. C. Zon* block 0439 was transferred from Rightsell to King. D. Zone block 0439 at Rightsell wee replaced with zone block 0455 from Washington. E. Zone blocks 0432, 0433, and 9438 from the Jefferson satellite zone were replaced with 0111, 0112, 0121, 0122 and 0210 from Washington. r. The zone blocks from the Washington zone which were transferred to Jefferson and Rightsell were not replaced since the attendance zone for Washington contains more students than are needed at Washington. IMPACT ON SCHOOLS The school impacted most by the proposed attendance zone changes is Ish Elementary School. Ish is described below. The proposed relationship between King and 1. Students within the Ish attendance zone will be assigned to King but will have the option to remain at Ish. 2. Bus transportation will be provided for those students from the Ish attendance zone who go to the new King School. 3. Ish will remain open unless fewer than 100 students choose Ish, in which case all Ish students will be assigned to King, and Little community to determine building. Rock School District will work with the Ish an appropriate use for the Ish 2f STUDENTS RESIDING IN ATTENDANCE ZONES The impact of the zone block assignments on the attendance zone of the schools involved are shown in the following table. Please note that these data indicate the number of students, other than magnet students, who reside in the attendance zone. Current Attendance Zone Proposed Attendance Zone Nonblack Total Ish 186 187 Jefferson Satellite 182 291 473 208 289 497 King 342 349 Rightsell 311 313 294 302 Washington 738 25 763 573 15 588 jLL&sk 1 0 0 0 0 0 0 7 2 8 *Assuming all students elect to go to King. The zone blocks shown in Attachment 2 are those whose current school assignments will be changed under this plan. The impact of changing these zone blocks on the transportation of students is indicated below. A. No Change in Transportation 1. The students in zone blocks 0439, 0455 are not 2. B. transported this year and transportation under the plan. will not require The students in zone blocks 0111, 0112, 0121, 0122, 0210 are transported this year and will be transported next year under the plan. Change in Transportation 1. The 110 students residing in zone blocks 0432, 0433 and 0438 are provided transportation this year to Jefferson but will not require transportation to King next year. 2 . The : 0476, 187 0477 , students residing 0479, in zone blocks 0473, 0430 and 0485 are not provided 33 . Attachment 1: Attachment 2: transportation this year to transported to King next year. The above would indicate Ish an but will increase transportation for 77 students under this plan. School Attendance Zones Transferred Zone Blocks be in I 4MARTIN LUTHER KING, JR. INTERDISTRICT SCHOOL We have completed the following steps regarding the Martin Luther King, Jr. Interdistrict Elementary School. ..Developed maps for proposed attendance zone ..A Principal has been selected ..A theme has been proposed to the Superintendent ..Four community meetings were held - March 7, April 1, April 21, and May 4. ..Marie Parker has spoken several times via telephone and visited in her office with Sarah Facen, Ish community leader ..Proposed attendance zone presented and approved by the Board ..Sent survey letters to all students in the proposed .attendance zone ..Two community meetings have been scheduled for PCSSD on May 17 and May 18, 1993. ..Draft of King recruitment plan ..Surveyed PCSSD, LRSD, and Governmental agencies near school site exhibit "D nSUPPORT DATA 1. List of signatures 2. 3 . Recruitment Plan for King Theme selection survey results 4. Report of the impact of the King attendance zone 5. Copy of attendance zone maps 6. Copy of letter submitted to Board 7 . Neighbor meetingsEXHIBIT "E RECRUITMENT PLAN FOR MARTIN LUTHER KING JR, SCHOOL March 20, 1993 SITUATION ANALYSIS The Desegregation Plan places great importance on the Inter-District Schools in enabling the LRSD to be in full compliance. In order to draw a school population from the surrounding area, this plan was designed to enroll black children from the immediate area and white children from Pulaski Counts- as well as Little Rock. TARGET AUDIENCES The major target audiences include: The neighborhood surrounding the school Additional zoned areas PCSSD Magnet Schools (non-placements) Children of employees at
Arkansas Children's Hospital The State Capitol Comple.x (Big Mac, Dept, of Ed., State Capitol, etc.) West Dttle Rock Areas of Chenal Valley, Taylor Loop, etc. The major goal of this recruitment plan is to dese^r-egate. MLKJ according to the Desegregation Plan by using the neighborhood to draw black students and draw white students from PCSSD first and them from Magnet School nonplacements, employees of the medical and government comple.x, and counts' residents in West Little Rock. This plan will rely heavily on the cooperation of PCSSD to assist in the recruitment of white parents from their district. ACTION P^J\N It is understood that this recruitment process cannot begin until the school theme and curriculum are chosen, the principal has bcm named and some promotion
: materials have been printed. The theory behind this -- parents want to km - what they are getting. Parents want to know the academic 1 theme and nvw their child will relate to the curriculum, thes- want to meet and talk wi
L the person who will be in charge, and they 'v.ant to walk awas- with information in hand. The act -m plan will begin with group presentations in hope.s that rhe school will be filled bs- using the parent recruitment team manpower in a more- frugal was'. Howeser if this cannot be accomplished, one-on-one recruitment will take place. In each meeting there will be an esaluation component or surses- for parents to ill out. T his will be used later to es-aluate '
e process ai.tl to pros ide iniormation for ODM and the Court about the recruitment process. 'This will also he used to document PCSSD'.s ins-ols ement.King Recruitment Plan Page 2 GROUP PRESENTATIONS - May, June The Parent Recruitment Team will begin as soon as possible (mid-late April) in organizing and implementing the following: Meeting with PCSSD to discuss the recruitment of their white students beginning with those who were unhappy because they could not get into Crystal Hill. Organize a meeting at Crystal Hill to meet with these parents. Meeting with Magnet Review Committee to obtain a list of students who could not get into magnets. Organize a meeting with those parents at a central location. Recruitment meetings in churches in the school neighborhood. Recruitment meetings in churches in West Little Rock. Special presentations to Realtors Association, Rotary, Optimist Club, etc. Working with the Public Relations Offices of Children's Hospital, State Capitol, Big Mac, Dept, of Ed. and other government offices, decide the best time to present a program to the employees about the school. (Group presentations may be timed to catch staff arriving/leaving their work schedule and may need to include donuts and coffee or refreshments of some kind). Work with local corporation relocation staff (AP&L, Arkla, Systematics) to reach people as soon as they enter the area. Follow-up meetings with area employees may be necessary. ONE-ON-ONE PRESENTATIONS - July, August If the group presentations have not filled the school with the appropriate racial balance, the enrollment will be reviewed for racial composition and the following will be done: If more students of each race are needed: Individual letters followed by phone calls will be made by Parent Recruitment Team in the neighborhood area , PCSSD lists. West Little Rock. (This will require that PCSSD provide a list to LRSD). I A Phone-a-thon organized to call after hours to insure parents are reached. If more black students are needed: Same as above and possibb' home visits to parents.King Recruitment Page 3 If more white students are needed: Same as above and possibly home visits to parents. School visits and meetings held at the school should begin as soon as the school is ready. Group tours will be a must! PUBLIC RELATIONS/COMMUNICATIONS SUPPORT FOR RECRUITMENT Write a special, catchy promotional theme (just a few words) to be used and identified with MLKJ school. This will be used on all promotions so that the community will quickly indentify it with the school. Assist in writing and producing literature for recruitment. Use Dr. Bernd's weekly radio show to promote recruitment. Produce PSAs - radio and T.V. Use KLRE/KUAR heavily to promote the school Plan a recruitment campaign with the Chamber of Commerce to promote the school to newcomers. Order the Daily Record to receive all new residents addresses to mail information. Ask SWB, Arkla, or AP&L to include an ad in their billing to promote the school. Ask the same corporations as well as others to place a story about the new school in their corporate newsletter. Work with T.V. stations to do a feature spot about the school. Ask local radio D.J's to do their morning shows from the school in order to talk about how great it is. Ask D.J.'s to bring their mobile units to the school to promote -- have T- shirt give aways and other goodies to draw people.MARTIN LUTHER KING, JR. INTERDISTRICT SCHOOL THEME SELECTION SURVEY RESULTS LITTLE ROCK SCHOOL DISTRICT MARCH-APRIL 1993 Suggested Theme Choices Theme Rankings 1st 2nd 3rd 4 th The Martin Luther King, Jr. Interdistrict School for Economic Education The Martin Luther King, Jr. Interdistrict Academy for Communication Arts The Martin Luther King, Jr. Interdistrict School for High Intensity Learning The Martin Luther King, Jr. Interdistrict School for Health Sciences 11 19 26 20 47 30 16 19 22 27 w X a H oa H Tl 9 5 3 9 5 3 Other Suggestions: l.Kids ride the bus from Ish to King. 2-Martin Luther King, Jr. Interdistrict School - Dreams Come True_____ Where 3.No. Ish teachers be hired at this new school. l.EistorY_jnagnet with strong emphasis on African culture. S.Martin Luther King, Jr. .Interdistrict School for Music 0.Martin Luther King, Jr._Interdistrict School for Econo- mics, Center Communication, Intensity, and Overall Learning_____ IMARTIN LUTHER KING, JR. INTERDISTRICT SCHOOL COMMUNITY SURVEY RESULTS LITTLE ROCK SCHOOL DISTRICT PULASKI COUNTY SPECIAL SCHOOL DISTRICT FEBRUARY 1992 r Site Rankings Suggested Site Choices 1st 2nd 9th and Pulaski Streets Westside Jr. High site (14th & Marshall) 174 135 134 159 Theme Rankings Basic Skills Suggested Theme Choices 1st 2nd 3rd 4th 5th 6t! 185 41 33 26 18 Computer Science 73 121 70 37 21 13 Economic Education 13 53 68 66 73 30 Environmental Science 16 40 36 80 86 Medical Science and Health-related Occupations Visual and Performing Arts 53 17 Would you be interested in enrolling your child(ren) at King? 40 69 53 Yes 73 32 226 No 57 34 63 42 98 Maybe 30 14- 7 Other Theme Suggestions: Foreign/Sign Language Physical Education Cooking Science/Social Studies Job Preparation Communication Math/Science Special Education Aviation Black History theme Multicultural Education Education Athletics/PE Aeronautics Self-Esteem & Interpersonal Skills AerospaceMartin Luther King, Jr. Interdistrict School Community Survey Results Little Rock/Pulaski County Special School Districts February 1992 Page 2 Comments: - 1. All schools should have the same themes, equal opportunities for all students. 2. Neither site is in a safe location. 3. Those attending should choose their own site. 4. What about Granite Mountain as a site? 5. No additional schools are needed - Little Rock should maintain the present ones - do not bus. 6. Securitv/transportation - need more information on this. 7. Blacks need basic skills first before any of these other things. 8. Martin Luther King, Jr. was not deserving of this honor - he was nothing but a trouble maker - perhaps name in the honor of Alex Haley. 9. Wrong side of the river - need school like this in North Little Rock or Jacksonville. 10. School too far for some North Little Rock and Jacksonville children to be bussed - they prefer their neighborhood schools.MARTIN LUTHER KING, JR. INTERDISTRICT SCHOOL THEME SELECTION SURVEY RESULTS PULASKI COUNTY SPECIAL SCHOOL DISTRICT MARCH-APRIL 1993 Suggested Theme Choices Theme Rankings 1st 2nd 3rd 4th The Martin Luther King, Jr. Interdistrict School for Economic Education The Martin Luther King, Jr. Interdistrict Academy for Communication Arts The Martin Luther King, Jr. Interdistrict School for High Intensity Learning The Martin Luther King, Jr. Interdistrict School for Health Sciences Interested in enrolling child at King? 40 69 160 18 Yes 43 50 56 41 No 182 75 50 29 57 Maybe 67 55 37 13 102 7 7 ther Suggestions: Math/Science with emphasis on hands on learning using computers. "Mr. Rogers type science labs. Combination of all four. Math/Scie
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