{"response":{"docs":[{"id":"bcas_bcmss0837_1728","title":"Court filings concerning NLRSD July 1998 - June 1999 status report, ODM report, ''2000-01 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)'', motion of the PCSSD to approve middle school construction modification, and PCSSD motion to approve middle schools and revamped high schools","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2001-04"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","North Little Rock School District","Office of Desegregation Monitoring (Little Rock, Ark.)","Pulaski County Special School District","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Education--Finance","Educational planning","Educational law and legislation","School buildings","School facilities","School improvement programs","School management and organization"],"dcterms_title":["Court filings concerning NLRSD July 1998 - June 1999 status report, ODM report, ''2000-01 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)'', motion of the PCSSD to approve middle school construction modification, and PCSSD motion to approve middle schools and revamped high schools"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1728"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["84 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"District Court, order; District Court, motion for extension of time to respond to Little Rock School District's (LRSD's) notice of filing and request for scheduling order; District Court, notice of filing, North Little Rock School District (NLRSD) July 1998 - June 1999 status report; District Court, notice of filing, Office of Desegregation Management report, ''2000-01 Enrollment and Racial Balance in the Little Rock School District (LRSD) and Pulaski County Special School District (PCSSD)''; District Court, separate motion of the Pulaski County Special School District (PCSSD) to approve middle school construction modification; District Court, supplement to separate motion of the Pulaski County Special School District (PCSSD) to approve middle school construction modification; District Court, supplement to Pulaski County Special School District (PCSSD) motion to approve middle schools and revamped high schools; District Court, supplemental memorandum in support of Pulaski County Special School District (PCSSD) motion to approve middle schools and revamped high schools; District Court, notice of filing, Arkansas Department of Education (ADE) project managment tool  The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  - RECEIVED APR 'J 2001 OfftCEOF 111116ATIONMONITORIN6 FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION APR 0 4 2001 JA~~sw. M~cc MACK, CLiRK .By. '5J- I ~k, ~ /\\f\\ 1!A DEPCLERK\"\" LITTLE ROCK SCHOOL DISTRICT * * Plaintiff, * * * VS. * No. 4:82CV00866 SWW * * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, ET AL. * * Defendants, * * MRS. LORENE JOSHUA, ET AL. * * Intervenors, * * KATHERINE W. KNIGHT, ET AL. * * Intervenors. * ORDER On March 15, 2001, the Little Rock School District (\"LRSD\") filed a Compliance Report and asked the Court to issue a Scheduling Order setting a date by which the parties must file any objections or challenges to the report.1 The LRSD suggests that the parties be given no more than twenty days within which to file their challenges and, in the event any party files a timely challenge, that the Court schedule a hearing before June 30, 2001. The Court has heard informally from one of the parties, who contends he needs more time to review the report and file challenges. See Attachment A 1See docket entry 3410. Having reviewed the Compliance Report, and considering the informal request for additional time, the Court finds that the parties need more than twenty days to review the many details set forth in the Report and prepar~ any challenges. After having consulted the Court's own calendar, the Court hereby establishes the following deadlines and hearing dates~ Any challenges to the LRSD's Compliance Report must be filed on or before May 18, 2001. If challenges to the report are filed, a hearing will be held on July 5 and July 6, 2001, beginning at 9:00 a.m. If necessary, the hearing will continue on August 1 and August 2, 2001. If the parties desire the Court to examine any documents pertaining to this hearing, those documents shall be submitted to the Court no later than June 29, 2001. Also before the Court is the motion of Tim C. Humphries to withdraw his appearance as counsel for separate defendant Arkansas Department of Education. The motion [ docket entry 3411] is granted.2 The Clerk is directed to remove Mr. Humphries as counsel for the Arkansas Department of Education. SO ORDERED this ~11\\.__day of April 2001. a;z_\u0026,,~ CHIEF JUDGE ' UNITED STATES DISTRICT COURT THIS DOCUMENT ENTERED ON . DOCKET SHEET IN COMPLIANCE 0~1~~8 A~~/m::a) FRCP 2On February 21, 2001, Sammye L. Taylor and Mark Hagemeier entered their appearances as counsel for the Arkansas Department of Education. See docket entries 3405 \u0026 3406. 2 JOHN W. WALKER SHAWN CHILDS JOHN W. WALKER, P.A. ATIORNEY AT LAW 1723 BROADWAY LlTILE ROCK, .ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-418~ Via Facsimile March 26, 2001 Honorable Judge Susan Webber Wright Chief Judge United States District Court 600 West Capitol Avenue Little Rock, AR 72201 Re: LRSD v PCSSD Dear Judge Wright: OF COUNSEL ROBERT McHENRY, P.A. DONNAJ. McHENRY 8210 HENDERSON ROAD Li'ITLE RocK, ARKANSAS 72210 PHONE: (501) 372-3425  FAX (501) 372-3428 EMAIL: mchenryd@swbell.net Due to the fact that I was in trial before the Honorable George Howard Jr. in Pine Bluff, Arkansas from March 19-22, 2001 and in intense preparation for the days preceding the 191\\ I am just getting in position to address the Little Rock filing, Notice of Filing Compliance Report and Request for Scheduling Order. I further note that Little Rock has indicated that it wishes to limit our time for filing challenges to twenty (20) days. This letter is being written to request that the Court set a time for a conference before addressing the issue of a scheduling order so that all parties, as well as the Office of Desegregation Monitoring, would have an opportunity to address the propriety of the scheduling order request. The compliance report is extensive. It appears to be more than two hundred (200) pages in length, is very detail oriented and it makes many claims which are unfamiliar to us and probably to the ODM as well. I am writing the Court this letter, rather than filing a motion, because Mr. Heller, who I am advised is away until Wednesday, expressed an interest in having some dialogue regarding this matter, and the State settlement as well, before this matter becomes, if it ever does, a public dispute which the Court must resolve. ! I understand that the Court .intends to schedule a hearing in the near future regarding the middle s~hool issues raised by the PCS SD. May I suggest that the matter of the hearing of the : scheduling order be set for the same day inasmuch as all parties-are expected to be in court for the PCSSD matter. Although I have been unable to speak with Mr. Heller and I have not attempted to reach his co-counsel, Mr. Clay Fendley who I intend to try and reach immediately, I have informed Ms. Ann Marshall regarding my concerns herein and will be having further conversations with the parties until such time I receive the Court's reply to this letter. With due respect to the court, I remain, JWW:js cc: Mr. Chris Heller Ms. Ann Brown Mr. Sam Jones  Y...r. Steve Jones Mr. Richard Roachell Mr. Timothy Gauger Sincerely yours, ) i APR 12 2001 r:11 Glf.GEif u.!.o1s~fD EASTERN DISTAi r OURT l'Bn!atll!! C AFlKAMc:~c: lllillPII~ A PR O 4 2 IN THE UNITED STATES DISTRICT CO_MRT OOl EASTERN DISTRICT OF ARK.ANSAp)i~S W ..eggRMACK, CLERK WESTERN DIVISION  I \" ' ....   DFP.'TJt[Af LITTLE ROCK SCHOOL DISTRICT PLAINTIFF VS. CASE NO. 4:82CV00866 SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL MOTION FOR EXTENSION OF Tll.VIE TO RESPON~ TO LRSD'S NOTICE OF FILING AND REQUEST FOR SCHEDULING ORDER DEFENDANTS Come now the Joshua Intervenors, through undersigned counsel, for their Motion for - Extension of Time to Respond to LRSD Notice of Filing Compliance Report and Request for Scheduling Order, state: 1. Due to undersigned counsel's trial schedule and other obligations, additional time is needed to review LRSD's Compliance Report. 2. In addition, undersigned adopts, by reference, his letter to the Court dated March 26, 2001. A copy is attached hereto as Exhibit 1. 3. This request is not for purposes of delay. WHEREFORE, for the reasons stated above, plaintiffs respectfully move the Court for an Order extending the time in which to file their Response LRSD's Notice of Filing Compliance Report and.Request for Scheduling Order for an additional thirty days including and up to May 4, 2001 Respectfully submitted, John W Walker, PA. 1723 Broadway Little Rock, AR 72206 501-374-3758 501-3 74-4187 (fax) CERTIFICATE O.F SERVICE I do hereby state that a copy of the foregoing motion has been sent to all counsel of record. \u003c)L JI/ ~~ / ~ ,JOHN W. WALKER SHAWN CHlLDS JOHN W. WALKER, P.A. ATTORNEY AT LAW 1723 BROADWAY LITTLE ROCK, AR1\u003c.,\\.\\S..\\S 72206 T ELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile March 26, 200 I Honorable Judge Susan Webber Wright Chief Judge United States District Court 600 West Capitol Avenue Little Rock, AR 7220 l Re: LR.SD v PCSSD Dear Judge Wright : OF cou:--:SEL ROBERT McHENRY. P.A. DONNA .J. McHENRY 82 10 Ht::sOF.RSO~ ROAD LITTLE ROCK. :\\.JlK,\\:SS,IS i22 l 0 PHO:sf.: (501) 3i2-3-l25  F.-\\X (50l) 3i2-3-128 E~l\\lL: mchenryd'!!-swbell.nct Due to the fact that I was in trial before the Honorable George Howard Jr. in Pine Bluff, Arkansas from March l 9-22, 2001 and in intense preparation for the days preceding the 191\\ I am. just getting in position to address the Little Rock filing, Notice of Filing Compliance Report and Request for Scheduling Order. I further note that Little Rock has indicated that it wishes to limit our time for filing challenges to twenty (20) days. This letter is being written to request that the Court set a time for a conference before addressing the issue of a scheduling order so that all parties, as well as the Office of Desegregation Monitoring, would have an opportunity to address the propriety of the scheduling order request. The compliance report is extensive. It appears to be more t_han two hundred (200) pages in lengJh, is very detail oriented and it makes many claims which are unfamiliar to us and probably to the ODM as well. I am writing the Court this letter, rather than filing a motion, because Mr. Heller, who I am advised is away until Wednesday, expressed an interest in having some dialogue regarding this matter, and the State settlement as well, before this matter becomes, if it ever does, a public dispute which the Court must resolve. I understand that the Court intends to schedule a hearing in the near future regarding the middle school issues raised by the PCS SD. May I suggest that the matter of the hearing of the scheduling order be set for the same day inasmuch as all parties are expected to be in court for the PCSSD matter. Although I have been unable to speak with Mr. Heller and I have not attempted to reach his co-counsel, Mr. Clay Fendley who T intend to try and reach immediately, I have informed Ms. Ann Marshall regarding my concerns herein and will be having further conversations with the parties until such time I receive the Court's reply to this letter. ,../ I -r-, ---I With due res pect to the court, 1 remain, JWW:js cc: Mr. Chris Heller Ms. Ann Brown Mr. Sam Jones Mr. Steve Jones Mr. Richard Roachell Mr. Timothy Gauger 1 Sincerely yo~urs, . ' , ~~? r.. / 1 tA'r;Jf!-(!,c v fo'hn w. Walker l JACK, LYON \u0026 JONES, P.A. ATTORNEYS AT LAW .. Nashville Office #11 Music Circle South Suite 202 Nashville, Tennessee 37203 (615) 259-4664 Telecop;er (615) 259-4668 3400 TCBY TOWER REce,,,EDrk ~:;:~i~~:mplex 425WESTCAPITOLAVENUE Cf~, 400SalemRd .. Suite3 LITTLE ROCK, ARKANSAS 7220 1-3472 Conway,Arkansas72032 (501) 375-1 122 (501) 329-1133 TELECOPIER (50 1) 375- 1.027 ! APR 5 Telecopier (501) 336-9089 April 5, 2001 200/ VIA HAND DELIVERY OffiCE Of Christopher J. Heller, Esq. fBIREsAnoN MONITliRINS FRIDAY, ELDREDGE \u0026 CLARK 2000 Regions Bldg. 400 West Capitol Little Rock, Arkansas 72201 M. Samuel Jones, Ill, Esq. WRIGHT, LINDSEY \u0026 JENNINGS 200 West Capitol Avenue 2200 Bank of America Bldg. Little Rock, Arkansas 72201 John W. Walker, Esquire JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 Sammye Taylor, Esq. Mark Hagemeier, Esq. Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Ann Brown OFFICE OF DESEGREGATION MONITORING 201 East Markham, Suite 510 Heritage West Building Little Rock, Arkansas 72201 Richard W. Roachell, Esq. Roachell Law Firm 401 W. Capitol Avenue, Suite 504 Little Rock, Arkansas 72201 Tim Gauger, Esq. Mitchell, Williams, Selig, Gates \u0026 Woodyard 425 W. Capitol, Suite 1800 Little Rock, Arkansas 72201-3525 RE: NLRSD Status Report/July 1998 - June 1999 Dear Ms. Brown and Counsel: Enclosed please find a copy of the above referenced Status Report. If you have any questions, please do not hesitate to contact me. SWJ:tl Enclosures yours, IN THE UNITED STA TES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION NORTH LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DEFENDANTS DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS RECEIVED APR 5 2001 OFFICE OF DESEGREGATION MONITORING NOTICE OF FILING PLAINTIFF North Little Rock School District hereby gives notice of the filing of the following document: 1. North Little Rock School District's July 1998 - June 1999 Status Report. Respectfully Submitted, JACK, LYON \u0026 JONES, P.A. 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 (50 75-1122 CERTIFICATE OF SERVICE I, Stephen W. Jones, hereby certify that I have this 5th day of April, 2001, sent one copy of the foregoing via Hand Deliv~i;y, to the following: Christopher J. Heller, Esq. FRIDAY, ELDREDGE \u0026 CLARK 2000 Regions Center 400 West Capitol Little Rock, Arkansas 72201 M. Samuel Jones, Ill, Esq. WRIGHT, LINDSEY \u0026 JENNINGS 200 West Capitol Avenue 2200 Bank of America Bldg. Little Rock, Arkansas 72201 John W. Walker, Esquire JOHN W. WALKER, P.A. 172;3 Broadway Little Rock, Arkansas 72206 Sammye Taylor, Esq. Mark Hagemeier, Esq. Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Ann Brown OFFIC.E OF DESEGREGATION MONITORING 201 East Markham, Suite 51 O Heritage West Building Little Rock, Arkansas 72201 Richard W. Roachell, Esq. Roachell Law Firm 401 W. Capitol Avenue, Suite 504 Little Roak, Arkansas 72201  Tim Gauger, Esq. Mitchell, Williams, Selig, Gates \u0026 Woodyard 425 W. Capitol, Suite 1800 Little Rock, Arkansas 72201-3525 1. I I I I I I I 1e I I I I I I ~ I I tT  FILED 2000-01 ENROLLMENT AND RACIAL BALANCE IN 'Ufflt r/~;1i;:.~g9..i~~sAs LITTLE ROCK SCHOOL DISTRICT AND PULASKI COUNTY SPECIAL SCHOOL DISTRICT APR 1 1 2001 Melissa R. Guldin Associate Monitor April 11, 2001 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Ann S. Marshall Federal Monitor  JAMES W. McCORMACK, CLERK .By: DEP CLERK Polly Ramer Office Manager !'.I I, 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 KNIGHT, ET AL. SEPARATE MOTION OF THE PCSSD TO APPROVE MIDDLE SCHOOL CONSTRUCTION MODIFICATION The PCSSD for its separate motion states: RECEIVED APR J 4 200:li illfflCEQf 1lESl!HfEGATION1MONITORINW PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. The PCSSD Board of Directors approved a conversion to middle schools on May 9, 2000. 2. On September 27, 2000 PCSSD submitted to this court, the ODM and the other parties its comprehensive Business Case which explains and justifies the overall middle school conversion. 3. On February 16, 2001 PCSSD filed its motion to approve middle schools and revamped high schools. A copy of the business case referred to in paragraph two was appended to that motion as was a comprehensive bound set of materials explaining the work and preparation that the District had done since May of 2000 to implement the middle school conversion. 4. As part of the conversion, physical modifications to Robinson High School and Mills University Studies High School were deemed necessary and were explained 248200-v1 - in the Business Case. The details of the modifications are set forth at page 57 of the booklet of materials filed February 16, 2001. For the convenience of the court and the parties, this page is re-appended to this motion as Exhibit\"!('. 5. The renovations referred to Exhibit'~' are already in progress. Because of the general oversight which this court has pursuant to the PCSSD, the PCSSD requests that this court formally approve the renovations described in Exhibit'!A!'. WHEREFORE, the PCSSD respectfully requests an order of this court approving the renovation activities described in Exhibit'~' and for all proper relief. Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 By ____ ,.-a-+-----~1-'-\"'------ M. Ill (76060 Att ski Coun ial Sch On April 13, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 248200-v1 2 Ms. Ann Brown ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Brian Brooks Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 248200-v1 ~ ~ 3 EXHIBIT I A FACILITY NEEDS TO IMPLEMENT MIDDLE SCHOOL~OGRAM Robinson Hi'3h Item Amount  Construct new 2 classroom addition ... ... . ..... .. .... . $160,000  Convert Ex. CR 11 into 2 classrooms . . . . . . . . . . . . . . . . . . . . . . $5,000  Convert Ex. CR 12 into 2 art labs . . . . . . . . . . . . . . . . . . . . . . . . . $5,000  Renovate Ex. Rm. 29 into a classroom . . . . . . . . . . . . . . . . . . . . $5,000  Renovate Ex. Rm. 30 into a classroom . . . . . . . . . . . . . . . . . . . . $5,000  Convert Ex. CR 27 ( choir room )into 2 classrooms . . . . . . . . $20.,.000 Sub-total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $200,000 Contingency, 10% ( +/-) . . .... . .... . ... '. . . . . . . . . . . . . . . . . . $10,000 Sub-total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $210,000 Architect fee, Misc. tests, etc., 8% ( +/-) ..... . ... . : . .... . . $15,000 Total ........ . . : . .. .. . ..... . ... .'. - : -: . . .. ... ..... .. .. $225,000 Mills University Studies High  Convert existing Media Center into additional Cafeteria Space and teacher Amount work room ..... . ... . .. . . . ............. . ..... . . ....... . $85,000  Construct new Media Center  . . ..... . ... .. ... . ..... .. .. $637,500 Sub-total .... . . . . . ...... . . .. ... . ... . .. .. .. . .... . ... . $722,500 Contingency, 10% ( +/-) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $72,300 Total . . ....... . ........ . . . .... . .... .. ... . .. _. ...... .. $794,800 .Total of Robinson High and Mills High .... . .......... . .... . ... .. ... $1,019,800 057  . . ' IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION R!C!JVa, APR 1 9 ZOOt ~~~OF --.vlll.1MIIUJJ IIJIJro- LITTLE ROCK SCHOOL DISTRICT PLAI NTI FF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS INTERVENORS I NTERVENORS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. SUPPLEMENT TO SEPARATE MOTION OF THE PCSSD TO APPROVE MIDDLE SCHOOL CONSTRUCTION MODIFICATION For its supplement to its renovation motion, the PCSSD states: 1. Attached as Exhibit \"A\" is a business case in support of the renovation motion which the PCSSD respectfully requests this Court to consider as part of its submissions in this matter. 249171-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 B -~,..::;...~----:-:-:-::::'='\"::-:~-..;;;:....---Jones Ill (76 r Pulaski C Special rict CERTIFICATE OF SERVICE On April [1, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Ms. Sammye L. Taylor Mr. Mark A. Hagemeier Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 249171-v1 2 Executive Summary: Implementation of Middle Schools Construction Pulaski County Special School District April 2001 The Pulaski County Special School District (District) currently has 24 elementary schools, each encompassing grades kindergarten through six; one existing middle school, Jacksonville Middle School; and six junior high schools, each encompassing grades seven through nine. The six senior high schools currently contain students in grades ten through twelve. After discussions, workshops, and community meetings, the District's Board of Directors voted at its May 9, 2000, meeting to approve a district-wide conversion to middle schools, effective for the 2001-2002 school year. This decision to pursue middle school conversion included construction for the Mills University Studies High School campus and the Robinson High School campus. Staff estimated that costs for facility remodeling would total $983,734.00. Background: The implementation of the middle school concept will not change student assignments, only the configuration of the existing junior and senior high schools. Oak Grove Junior/Senior High School, Jacksonville Middle School, Jacksonville Junior High School and Jacksonville High School will be the exceptions to the proposed conversion. Toward this end, the District contracted a general evaluation of all of its schools. The facilities study provided the Board with a blueprint of construction needs. At this time, the District anticipates that the conversion to middle schools can be accomplished by converting the existing junior high facilities to middle school campuses and s ending ninth grade students to the senior high school facilities. Existing facilities have been examined for this movement of students. Two sites would need renovation to accomplish the conversion: Robinson High School will require classroom space conversion and renovation. Mills University Studies High School will need additional cafeteria space and a new media center. Problem Statement: Increasing the capacity at the Robinson and Mills sites is recommended for a successful conversion to 9-12 grade high schools. Without the proposed construction, student capacity would be severely limited. Recruitment within and to those areas would also be hampered. Failure to increase the student capacity at these two campuses would result in overcrowding, discipline problems and displacement of students. In turn, this would result in increased student displacement, busing and negative school-community relations. EXHIBIT 249145-v1 J II I I I I I I I I I Alternatives: The alternative to this recommendation for construction would be to keep the campuses in their current configurations. This would cripple the ability to make the complete middle school conversion and conversion to 9-12 grade high schools. Action Recommended: By its vote on May 9, 2000, the Board of Directors approved a district-wide conversion to middle schools, to become effective for the 2001-2002 school year. The Board chose to delay the conversion of Oak Grove Junior/Senior High School to the middle school concept at this time. On March 13, 2001, the Board decided to delay the conversion of Jacksonville Middle School, Jacksonville Junior High School, and Jacksonville High School as well. Once the Board authorized the middle school concept, an examination of all secondary school facilities was conducted for student capacity. As a result of this examination, it was determined that addition construction would be needed at Mills and at Robinson High Schools. At Mills University Studies High School, a new media center is being built and the old media center would be converted into addition cafeteria space. These renovations will increase the capacity of the school media center and cafeteria. At Robinson High School, two additional classrooms will be constructed, the choir room would be divided and two dressing rooms will be converted into classroom space. This construction would increase the student capacity at Robinson High School by at least 250 students, both to accommodate the addition of the 9th grade and to provide for future desegregated growth. Objectives: The implementation of middle schools works to support the District's overall goals which includes the District's commitments to desegregation. Foremost, the creation of effective learning environments for all students support the District's goal of raising student achievement and successfully raising expectations. Students in sixth grade will have intensive use of technology and more opportunities to participate in co-curricular activities than is available in elementary schools. Ninth graders will enjoy increased opportunities for advanced academic pursuits and extra-curricular activities. Impact: Increased capacity will help to improve discipline, enhance recruitment efforts, and assist in maintaining racial balance at these campuses. It will also enhance student achievement and increase the opportunity for success of these students. Ninth grade students will benefit from the challenge of high school classes, increased curriculum opportunities and extra-curricular activities. 249145-v1 2 Student population at Mills for the current school year is 587 students for grades 10 through 12. Of that total, 343 students are white and 244 students are black. Present student capacity at Mills is 780. The projected student enrollment for 2001- 2002 school year, in grades 9 through 12, is 900. Of that projection, 483 students would be white, 417 students would be black. Student population at Robinson High School for the current school year is 435 students for grades 10 through 12. Of that total, 320 students are white and 115 students are black. Present student capacity at Robinson High School is 506. Robinson's projected enrollment for the 2001-2002 school year, in grades 9 through 12, is 638. Of that projection, 458 students would be white and 180 students would be black. Resources: The conversion to middle schools can be accomplished with few facility changes. Robinson High School and Mills University Studies High School have been identified as the only buildings needing immediate renovations. These costs are estimated to be $983,734. The construction at Mills will cost $766,680. Additional renovation at Robinson will cost $217,054 and will increase student capacity by about 250 students. Plan for Implementation: The Pulaski County Special School District will make the facility renovations required to accommodate a middle school conversion. At both Mills University Studies High School and Robinson High School construction started January 30, 2001. Estimated completion of construction is August 1, 2001. 249145-v1 3 EDWARD L. WRIGHT (1903-1977) ROBERT S. LINDSEY (1913-1991) ISAAC A. SCOTT, JR. JOHN G. LILE WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX, JR. TROY A. PRICE GORDON S. RATHER, JR. TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD, JR. PATRICK J. GOSS ALSTON JENNINGS, JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J . MULDROW N.M. NORTON CHARLES C. PRICE CHARLES T. COLEMAN JAMES J, GLOVER EDWIN L. LOWTHER, JR. CHARLES L. SCHLUMBERGER WALTER E. MAY GREGORY T. JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER McSPADDEN ROGER D. ROWE JOHN D. DAVIS Mr. John Walker John Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, Arkansas 72222-7388 RE: PCSSD Dear Counsel and Ms. Marshall: 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK, ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 376-9442 www.wlj .com OF COUNSEL ALSTON JENNINGS RONALD A. MAY M. TODD WOOD Writer's Direct Dial No. 501-212-1273 mjonesCwlJ.com April 27, 2001 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower PATRICIA SIEVERS HARRIS JAMES M. MOODY, JR. KATHRYN A. PRYOR J . MARK DAVIS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J. SALLINGS WILLIAM STUART JACKSON MICHAEL D. BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON JENNlfER S. BROWN C. TAD BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J. CHARLES DOUGHERTY\" M. SUN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE W. DUKE ROBERT W. GEORGE J . ANDREW VINES JUSTIN T. ALLEN CHRISTINE J. DAUGHERTY, Ph,O. LJcensad to practlca be/'orB the Unled Sla'9s Patent and Trademarl\u003c Office RECEJ.\\fED 425 West Capitol Avenue Little Rock, Arkansas 72201 APR 3 0 zom CIIIE81f -lllllQfflRIIS Ms. Sammye L. Taylor Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Enclosed are copies of supplement to PCSSD motion to approve middle schools and revamped high schools and supplemental memorandum in support which are being filed today. MSJ/ao Encls. 251317-v1 Cordially, WRIGHT, LINDSEY \u0026 JENNINGS LLP ~~ M. S muues, Ill IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION APR 3 0 20m Gffll(lf De~IIJIIDJRlli LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. 4:82CV00866SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL. KA THERINE KNIGHT, ET AL. SUPPLEMENT TO PCSSD MOTION TO APPROVE MIDDLE SCHOOLS AND REVAMPED HIGH SCHOOLS PCSSD, for its supplement to motion, states: 1. Contemporaneously with this supplement, the PCSSD is submitting for filing additional documents numbered 17 4 through 232 for the Court's review and consideration. 2. The numbering of this submission begins with the next number of the documents submitted February 16, 2001. In large measure, the documents are sequenced chronologically and several of them are discussed in the accompanying memorandum. 251097-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 '---  \"'  (7~ B ~ ---,, \\:::  ones Ill (76Q60) Pulaski'eounty Special ct CERTIFICATE OF SERVICE On April,ZJ, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, Arkansas 72222-7388 Ms. Sammye L. Taylor Mr. Mark A. Hagemeier Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 251097-v1 M. S~el Jo~es Ill ,.  ) ~ u 2 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. 4:82CV00866SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. SUPPLEMENTAL MEMORANDUM IN SUPPORT PLAINTIFF DEFENDANTS INTERVENOR$ INTERVENORS OF PCSSD MOTION TO APPROVE MIDDLE SCHOOLS AND REVAMPED HIGH SCHOOLS Work on the implementation of middle schools has continued since the District's - original filing dated February 16, 2001. The supplemental document submission covers both documents generated since the first filing as well as supplies a handful of documents that were not available to counsel in February. Documents 174. and 175 represent the memorandum of understanding between PACT and PCSSD dealing with the placement of teachers in middle schools. Documents 176 through 181 represent a presentation made by Dr. Gloria Rousseau to administrators at the PCSSD which contains useful information concerning the process since January 2001. Documents 183 through 193 represent various committee reports and activities as do Documents 195 through 196. Documents 197 through 200 explain the formal Board policies which have been adopted and Documents 201 through 204 contain information regarding the middle school curri "},{"id":"bcas_bcmss0837_1703","title":"Court filings: District Court, order; District Court, notice of filing compliance report and request for scheduling order; District Court, motion for withdrawal of appearance; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, order","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2001-03"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Arkansas. Department of Education","Pulaski County Special School District","Education--Arkansas","Education--Evaluation","Education--Finance","Educational law and legislation","Educational planning","Little Rock School District","School management and organization","School improvement programs","School employees","School integration","Student assistance programs"],"dcterms_title":["Court filings: District Court, order; District Court, notice of filing compliance report and request for scheduling order; District Court, motion for withdrawal of appearance; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, order"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1703"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["22 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  - FILED .=,,A, _UE.S. DISTRICT COURT 1 RN DISTRICT ARKANSAS MAR,O f 200f IN 11IB UNITED STATES DISTRICT COURT '., \\ EASTERN DISTRICT OF ARKANSAS ~A!\"fE~jW- Mqe~RJ.f~K, CLERK WESTERN DMSION  y -v 1 ~~ ~ bl'\u003e]/\\ LITTLE ROCK SCHOOL DISTRICT * * Plaintiff: * * vs. r * Case No. 4:82CV00866 SWW * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, ET AL. * * ECEIVED Defendants, * * MRS. LORENE JOSHUA, ET AL. * AR 2 200\\ * Intervenors, * OffiCEOf * OESEGRE~1lotl  KATHERINE W. KNIGHT, ET AL. * * Intervenors. * ORDER The Pu1aski County Special School District moves the Court for an Order authorizing a special election to be held May 8, 2001. See docket entry 3400. The District states the proposed election is for the purpose of placing before the voters for approval a millage increase sufficient to finance an ambitious program of school fucility enhancement. There have been no responses or objections to the motion, and the Court finds that the motion should be granted. TIIEREFORE, the Court hereby grants the motion and approves the special millage election to be held in the Pu1aski County Special School District on May 8, 2001. dt SO ORDERED this _j_ day of March 2001. ~.\u0026-~ F JUDGE  UNITED STATES DISTRICT COURT DEPCLERJ\u003c'-.. ~ DOCUMENT ENTERED ON DOCKET SHEET IN ..,OMPUAN3_ C; WITH RULE 58 ANO'OR 79(~ FRCP )R_ .  \u003cX~CJf.. IV ::'!:?- -~-_;.--~,- 3409 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DNISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 . , Qff.!;R RECEI\\.Y ~u PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL MAR 1 ~ 200\\ OF.ICE OF DESEGREGATION MONITORING NOTICE OF FILING COMPLIANCE REPORT AND REQUEST FOR SCHEDULING ORDER PLAINTIFF DEFENDANTS INTERVENORS INTER VEN ORS The Little Rock School District (\"LRSD\" or \"District\") for its Notice of Filing Compliance Report and Request for Scheduling Order states: 1. LRSD hereby files the attached Compliance Report in accordance with Section 11 of its Revised Desegregation and Education Plan (\"Revised Plan\"). LRSD has substantially and in good faith complied with terms of the Revised Plan. A brief summary of each section of the Compliance Report is set forth below. 2. Good Faith. During the term of the Revised Plan, LRSD attempted to demonstrate its good faith by complying with its plan obligations. To manifest its good faith commitment for the future, the LRSD Board of Directors (\"Board\") on January 11, 2001, adopted a \"Covenant for the Future,\" in which the Board promised to continue fighting discrimination, providing equity and improving the academic achievement of all students. A key component of the District's success under the Revised Plan was the establishment of Campus Leadership Teams (\"CL Ts\") at each school. The CLTs provide the horsepower driving the District's efforts to improve student achievement. The District invested heavily in providing training to the CLTs and school principals in Total Quality Management (\"TQM\"). - All principals received intensive TQM training through the Arkansas Leadership Academy. The District's focus on quality leadership has not gone without recognition. In the fall of 2000, the District received the Quality Commitment Award from the non-profit group Arkansas Quality Award. This award recognized the District as an organization that has a plan and commitment to quality management. The District's development ofleadership talent should pay substantial dividends in the future. 3. Faculty and Staff. LRSD had a strong record in the area of faculty and staff even before adopting the Revised Plan. Even so, the District worked hard to recruit, develop and promote increased numbers of qualified African-Americans. Under the Revised Plan, the District increased the percentage of African-American administrators and teachers, and it increased the number of African-American media specialists, counselors, secondary core subject teachers, early childhood teachers and primary grade teachers. The District also began tracking the distribution of the most experienced and educated teachers in an effort to better ensure an equitable distribution of these teachers. 4. Student Assignment. In accordance with the Revised Plan, the District revised student attendance zones to allow students to go to their neighborhood schools to the extent possible. While this resulted in an increase in the number of racially identifiable schools and schools more than 20 percentage points from the district-wide percentage of African-American students, the increases were not dramatic. Moreover, the large number of alternative assignment choices available to students helped minimize any adverse effect resulting from the neighborhood school zone plan. This year twenty-percent of the District's students chose to attend a school other than their zone school. 5. Special Education. While African-American students remain disproportionately represented among special education students, a review of the District's programs, policies, and procedures revealed no vestiges of racial discrimination in the referral and placement of students in special education or other special needs programs. Furthermore, since 1998-99 the increase in the number of African-American students identified with disabilities has been in proportion to 2 their increase in the total student population. There has been only two percent growth in the number of identified students with disabilities since 1998-99, with the percentage of AfricanAmerican students remaining just about the same. The two percent growth correlates with the increase in total student enrollment over the same period, as well as an increase in the percentage of students qualifying for free/reduced lunch eligibility. 6. Discipline. The number of African-American students suspended decreased 20 percent from 1997-98 through 1999-2000. This was consistent with a 21 percent decrease in the total number of disciplinary sanctions. For the same time period, the number of students committing offenses decreased 16 percent. 1:hus, fewer student are committing offenses, and those that do commit offenses are less likely to commit a second offense. The behavior modification plans being implemented pursuant to the Revised Plan may account for this decrease. The decrease in discipline sanctions positively impacted parents' and teachers' perceptions of District schools. A survey of parents and teachers conducted during the 1999-2000 school year revealed that 93 percent of African-American parents and 95 percent of white/other parents who expressed an opinion agreed that their child was safe at school. Ninety-one percent of both African-American and white/other parents who expressed an opinion agreed that their child has a feeling of belonging at school. Ninety-seven percent of African-American teachers and 96 percent of white/other teachers who expressed an opinion indicated that they felt safe at school. 7. Extracurricular Activities. Extracurricular activities increased dramatically under the Revised Plan. The number of African-American students participating in extracurricular activities jumped from 2,335 to 5,203 from 1997-98 through 1999-2000. A large part of the increase in participation resulted from a \"no-cut\" policy in athletics for middle school six graders and the use of Supplemental Instructional Plans (\"SIPs\"). SIPs allow students who otherwise would be academically ineligible for athletics to continue participating in athletics while they attend tutoring to improve their grades. The District also organized an Activities Advisory Board to promote, support and enhance the activities available in the District. 3 The 1999-2000 survey of parents and teachers also reflected the District's success in the area of extracurricular activities. Ninety percent of African-American parents and 93 percent of white/other parents who expressed an opinion agreed that activities were open to students. Ninety-three percent of African-American teachers and 95 percent of white/other teachers who expressed an opinion agreed that students have opportunities for activities. 8. Advanced Placement Courses. New policies and procedures for placement of students in advanced courses greatly improved access and participation for all students, and especially African-American students. New programs have the potential of producing exponential growths in both participation and success in advanced courses in the next few years. The increasing number of African-American students participating and succeeding in advanced courses perhaps provides the best reason to be optimistic about the District's future. With regard to Advanced Placement (\"AP\") courses, the total enrollment of AfricanAmerican students increased from 471 in 1997-98 to 797 in 2000-01-an increase of 326 students or 69 percent. The total enrollment of white/other students in AP courses increased from 964 in 1997-98 to 1495 in 2000-01-an increase of 531 students or 55 percent. The total enrollment of all students in AP courses increased from 1435 in 1997-98 to 2292 in 2000-01-an increase of 857 students or 60 percent. The number of AP courses taught increased from 16 in 1997-98 to 20 in 2000-01; whereas, the average high school in the United States teaches only six AP courses. With regard to high school Pre-AP courses, the total number of high school students enrolled improved from 5065 in 1999-2000 to 5953 in 2000-01-an increase of 888 students or 15 percent. African-American student enrollment improved at a slightly higher rate-from 2341 in 1999-2000 to 2715 in 2000-01-an increase of 374 students or 16 percent. White/other student enrollment also improved-from 2724 in 1999-2000 to 3238 in 2000-01-an increase of 514 or 15 percent. With regard to middle school Pre-AP courses, African-American student enrollment grew 937 from 1999-2000 to 2000-01-an increase of 19 percent. White/other student enrollment in 4 middle school Pre-AP courses grew 1076 in one year-a 24 percent improvement. The total middle school Pre-AP enrollment grew by 2013 students-a 22 percent improvement. In contrast to the enrollment in the high school AP courses, where African-American enrollment was 35 percent of the total in 2000-01, the African-American enrollment in middle school Pre-AP courses was 51 percent of the total. In sixth grade Pre-AP/GT English courses there were 908 students enrolled in 2000-01 . At the high school level there were 261 students enrolled in English m AP in 2000-01 . If the current grade six students stay in the pipeline for advanced course enrollment, the English ill AP enrollment could improve 250 percent in a few years. The number of AP examinations taken increased from 422 in 1997-98 to 524 in 1999- 2000-an increase of24 percent. Although the percentage of students earning a \"3\" or higher on the AP examinations went down from 60 percent in 1997-98 to 52 percent in 1999-2000, the number of students earning a \"3\" or higher improved from 252 in 1997-98 to 268 in 1999-2000. With regard to the ACT, the most common college entrance exam taken by LRSD students, the number oftest-takers improved from 786 in 1997-98 to 1026 in 1999-2000 for an increase of240 or 31 percent. The number of African-American test takers improved from 410 to 570-an increase of 160 students or 39 percent. The number of white test takers also increased-from 268 in 1997-98 to 345 in 1999-2000-an improvement of77 students or 29 percent. African-American students improved their English scores from 17.2 in 1997-98 to 17.4 in 1999-2000, their Science Reasoning scores from 17.2 to 17.4, and their average composite scores from 17.2 to 17.3. While small increases, they represent a substantial accomplishment given that test scores usually decrease when the number of test-takers increases. African-American students' willingness to move into more rigorous academic courses may reflect their belief that they will get the support they need to succeed. In the 1999-2000 parent survey, 88 percent of African-American parents who expressed on opinion agreed that their child received academic support. Eighty-six percent of white/other parents who expressed an opinion agreed with this statement. 5 9. Academic Achievement. The District completely revised its policies, procedures, and programs to facilitate and enhance academic achievement of all students, especially AfricanAmerican students. The District implemented new standards-based curricula, effective teaching strategies, aligned materials, and a re-designed and a comprehensive professional development program in fall 1999 and expanded in fall 2000 in English language arts, mathematics, and science, K-9. School year 2001-02 will see expansions into grades 10-12, as well as K-12 social studies and the beginning of fine arts program planning. Efforts included the addition of several new student support programs, many of which were funded through federal, state, and foundation grants. This District set high expectations for its students by raising graduation standards. Beginning in 2002, seniors must have a minimum of24 units to graduate, and beginning in 2004, they must have 26 units. In addition, the District published a \"Recommended Curriculum\" for high school students that includes eight advanced courses in the 28 units that students are encouraged to complete. The District secured several major grants as a part of its efforts to improve academic achievement. They are as follows:  A $3.4 million grant from the National Science Foundation to support improvements in mathematics and science;  A $7.8 million Safe Schools/Healthy Students grant from the United States Department of Education to support implementation of new programs aligned with the District's transition of the junior highs to middle schools;  Two multi-million dollar 21 st Century Learning Community grants from the United States Department of Education to develop and support after-school and summer programs to support student achievement;  A $250,000 planning grant from the Carnegie Foundation to support a year of planning for high school reform and improvements in student achievement. 6 An $11 million grant proposal was submitted to the Department of Education in December 2000 to develop magnet curricula at four southwestern Little Rock schools. One challenge the District faces in its effort to improve academic achievement is students arriving for kindergarten without the necessary social or learning skills. To meet this challenge, the District went beyond the requirements of Revised Plan in funding (with no assistance from the State) an early childhood program. The District implemented new four-year-old classes in 1999- 2000 and again in 2000-01. In 2000-01 there were 954 four-year-olds enrolled-234 more than the 720 required by the Revised Plan. In addition, early childhood enrollment included 254 children served in the HIPPY program; 23 infants, toddlers, and three-year olds at Metropolitan; 63 infants, toddlers, and three-year-olds at Rockefeller; and 18 three-year-olds at Washington-for a total of 1058. The District implemented new procedures and programs for early childhood education designed to improve children's kindergarten \"readiness\" level. Specifically with regard to reading and language arts, the District developed its PreK-3 Literacy Plan to guide implementation of new standards-based curricula, instructional strategies, materials, and assessments across all schools. The District invested heavily in professional development for all teachers and in the purchase of classroom sets of materials for students. Consistent with the Revised Plan, the District established a two and one-half hour block of time for the teaching ofreading and language arts in grades K-3. To measure success of the PreK-3 Literacy Plan, the District administers the Observation Survey and the Developmental Reading Assessment in kindergarten through grade two. Both are informal reading inventories that are administered one-on-one. They are administered both in the fall and spring so growth can be measured. The results from the 1999 fall pre-test showed that white kindergarten students began with a score of more than two ( a score of two indicates readiness for the next grade level), as compared to African-American students whose fall pre-test score was less than one. Thus, white students began kindergarten with a higher level of readiness. On the spring post-test, the kindergarten class had the highest percentage of students scoring at or 7 above readiness (72.2 percent) of any of the three grades tested, perhaps as a result of the new Animated Literacy program in phonemic awareness that was introduced in fall 1999, along with the new ELLA strategies and materials. Both African-American and white students improved significantly from the pre-test to the post-test. On average, African-American kindergarten students' post-test scores were 43 percent of that of their white counterparts. First graders performed the poorest of the three grades tested in terms of the percentage of students scoring at or above readiness at the end of the school year ( 53. 6 percent), perhaps indicating the need for the Animated Literacy program for these students. All first graders improved, but white students improved the most, probably because the reading skills that they began the year with enabled them to progress faster. However, the average score for AfricanAmerican first graders was 65 percent of that of their white peers, suggesting a narrowing of the achievement gap that existed when the students entered the District. All second graders' scores improved significantly over the course of the year, just as they did in kindergarten and first grade, with 67.5 percent at or above the readiness level on the spring post-test. On average, African-American student's scores were 77 percent of that of their white peers, an increase from 43 percent in kindergarten and 65 percent in first grade. This again suggests that the District may be having success in narrowing the achievement gap which exists when students enter the District. With regard to reading and language arts in the intermediate grades, the District implemented new standards-based curricula, instructional strategies, materials, and assessments across the District in fall 1999, just as with the primary grades. The District emphasized Effective Literacy in professional development for intermediate grade teachers. While the District is still not where it would like to be, the results from the State Benchmark Exam taken by fourth graders showed substantial improvement. Scores improved from 32 percent at the proficient/advanced levels in 1998-99 to 42 percent in 1999-2000-an improvement of 31 percent. African-American students improved almost 10 points on the exam, 8 a 50 percent improvement, and white students improved four points, a seven percent improvement. The gap between the scores of African-American and white students narrowed six points in 1999-2000, from 42 points to 36 points. The rate of improvement of African-American students was 43 points higher than for white students. The District had many fewer grade four students performing at the lowest level in 1999-2000 than in 1998-99-a reduction of 13 percentage points or a 32 percent decrease. Additionally, fewer African-American students performed at the Below Basic level-a reduction of 16 percentage points or a 31 percent decrease. White students in the lowest level were reduced by seven percentage points for a 41 percent decrease. The gap between white and African-American students in the Below Basic level was 35 points in 1998-99 and was reduced to 26 points in 1999-2000. Reading scores also improved for fifth graders on the Stanford Achievement Test (91h Edition) (\"SAT9\") from 1999-2000. The average percentile score for all students improved five points, for African-American students improved five points, and for white students improved one point. Compared to the SAT9 scores from the fall of 1997, the average percentile score for all students improved five points, for African-American students improved seven points, and for white students improved four points. The achievement gap in reading narrowed from 46 percentile points in 1997-98 to 43 percentile points in 2000-01. Fifth graders' language scores on the SAT9 also improved from 1999-2000. The average percentile score for all students improved four points and for African-American students improved six points. Compared to the SAT9 scores from the fall of 1997, the average percentile score for all students improved four points, for African-American student improved seven points, and for white students improved one point. The achievement gap in language narrowed from 36 percentile points in fall 1997 to 30 percentile points in fall 2000. With regard to math and science, the District implemented new standards-based curricula, instructional strategies, and materials in K-9. The District funded these efforts in large part with 9 the grant from the National Science Foundation. Major investments occurred in professional development and in the purchase of new materials. The scores of fourth graders on the State Benchmark Exam provide a reason for optimism. The State administered the grade four State Benchmark Exam in mathematics for the second time in spring 2000. The District's scores showed significant improvements for all students (eight points), for African-American students (seven points), and white students (eight points). Although the gap widened one point between African-American and white students in 1999-2000 (from 45 to 46 points), the percentage improvement for African-American students was much greater than that of white students, 88 percent compared to 15 percent. The District's grade four as a whole saw fewer students performing at the lowest level in 1999-2000 as compared to 1998-99-a reduction of four percentage points or a seven percent decrease. Additionally, fewer African-American students performed at the lowest level-a reduction of five percentage points or a seven percent decrease. The gap between white and African-American students in the Below Basic level shrank from 50 points in 1998-99 to 45 points in 1999-2000. Fifth graders' mathematics scores improved slightly on the fall 2000 SAT9, with all students' scores up one percentile point and African-American students' scores up two percentile points. Compared to fall 1997 SAT9, the average percentile scores for all students improved one point and for African-American students improved four points. The achievement gap narrowed slightly from 1997-98 to 2000-01, from 36 to 32 percentile points. Tenth graders' SAT9 mathematics scores also improved. Their teachers had had initial training in a standards-based curriculum, and the students were the first required to take physics in the ninth grade. From 1999-2000 to 2000-01, the average percentile scores for all students improved four points, for African American students improved one point, and for white students improved six points. 10. Parental Involvement. The District already had a plethora of parent and community involvement policies, procedures, and programs when the Revised Plan was approved in 1998. Accordingly, the District directed it efforts to widening the outreach, focusing on the school level, and creating a more coherent leadership structure at the district level. The District began including parents and community representatives on CLTs, and the Board approved a Parent Program Restructuring Plan which consolidated all parent programs under the direction of one Collaborative Action Team. 11. Equitable Allocation of Resources. The District developed a unique method of reviewing equity in the allocation of resources. Each year the resource allocation review revealed no correlation between resources allocated to a school and the school's racial composition. Moreover, the District used the results of the review in making resource allocation decisions, such as allocating grant and Title I funding. 12. Guidance and Counseling. The 1999-2000 survey of parents revealed that 94 percent of all parents, both African-American and white/other, who expressed an opinion agreed that help and guidance was available to their child. This perception has proven a reality at least with regard to scholarship money received by African-Americans. Of the 301 scholarships awarded in the 1998-99 school year, 147 or 49 percent went to African-American students totaling $3,256,207 or 47 percent of the total dollar amount of scholarships awarded. For 1999- 2000 school year, African-American students received a total of 185 scholarships valued at $3,716,358. African-American students represented 56 percent of the scholarship recipients and received 58 percent of the total dollar amount of scholarships awarded. African-American females outpaced all other groups in the number received (105) and the dollar value of scholarships awarded ($1,967,654). 13. Cultural Sensitivity. Since the 1999-2000 school year, the District has been providing cultural sensitivity training through Dr. Terrence Roberts, one of the \"Little Rock Nine\" and a desegregation consultant for the District approved by the Joshua lntervenors. His workshop, entitled \"Learning to Cope with Differences,\" provides strategies for dealing with differences in race, ethnicity, gender, economics, disabilities, religion and other characteristics that 11 I can divide people and create unhealthy tension. The 1999-2000 survey of teachers suggests that the District has done well in this regard. Ninety-four percent of African-American teachers and 93 percent of white/other teachers who expressed an opinion agreed that District administrators value diversity. Eighty-eight percent of African-American teachers and 92 percent of white/other teachers who expressed an opinion agreed that personnel respond to cultural differences. 14. Compliance. Section 8 of the Revised Plan included a procedure for parties to raise issues related to the District's compliance. This procedure was invoked on only five occasions, with the last being in December of 1999. All of those issues were resolved without the necessity of court intervention. 15. The Revised Plan obligated LRSD to implement programs, policies and/or procedures designed to achieve certain outcomes, and it has done so. Although the Revised Plan did not obligate LRSD to achieve any particular outcomes, the Compliance Report includes information on outcomes which was used by LRSD to evaluate the programs, policies and procedures being implemented. 16. Section 11 of the Revised Plan provides: At the conclusion of the 2000-01 school year, the district court shall enter an order releasing LRSD from court supervision and finding LRSD unitary with regard to all aspects of school operations provided that LRSD has substantially complied with its obligations set forth in this Revised Plan. In anticipation of release, LRSD shall issue a report on March 15, 2001, indicating the state ofLRSD's compliance with the Revised Plan. Any party challenging LRSD's compliance bears the burden of proof If no party challenges LRSD's compliance, the above-described order shall be entered without further proceedings. LRSD has substantially complied with its obligations set forth in the Revised Plan. If no party challenges LRSD's compliance, an order should be entered finding LRSD unitary with regard to all aspects of school operations. 17. LRSD respectfully requests that the Court issue a scheduling order establishing a period not exceeding 20 days for parties to file challenges to LRSD's compliance pursuant to Section 11 of the Revised Plan. This should be sufficient time given that the parties have known when this report would be filed since April 10, 1998, and that Section 8 of the Revised Plan 12 required parties to raise compliance issues \"as soon as reasonably practicable.\" See Revised Plan, Section 8.2.1. If any party files a challenge on or before the deadline established by the Court, LRSD respectfully requests that a hearing on the challenge be held before June 30, 2001, the end of the 2000-2001 school year. WHEREFORE, LRSD prays that this Court immediately issue a scheduling order establishing a period not exceeding 20 days for parties to file challenges pursuant to Section 11 of the Revised Plan; that should a challenge be filed by a party, a hearing be held on the challenge before June 30, 2001; and that should no party file a challenge on or before the deadline established by the Court, that on June 30, 2001, this Court enter an order finding LRSD unitary with regard to all aspects of school operations. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026 CLARK First Commercial Bldg., Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376-~-i--- 13 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by handdelivery on March 15, 2001 : . Mr. John W. Walker JOHNW. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026 Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026 JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-73 88 Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Timothy G. Gauger Mitchell, Williams, Selig, Gates \u0026 Woodward 425 West Capitol Avenue, Suite 1800 Little Rock, AR 72201-3525 14 RECEIVED MAR 1 s 2001 Little Rock School District Revised Desegregation and Education Plan Compliance Report March 15, 2001 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. RECEIVED MAR 2 s zam lllll\u0026EJ~ WfMONllURINQJ PLAINTIFF DEFENDANTS MOTION FOR WITHDRAWAL OF APPEARANCE I, Tim C. Humphries, hereby move to withdraw my appearance as counsel on behalf of separate defendant Arkansas Department of Education in the above-captioned matter. I, Tim C. Humphries, am no longer employed with the Office of the Attorney General, and separate defendant - Arkansas Department of Education is now represented in this matter by Chief Barrister Sammye L. Taylor and Assistant Attorney General Mark A. Hagemeier of the Office of the Attorney General. WHEREFORE, I, Tim C. Humphries, respectfully request that this motion be granted and that the Court direct the clerk of the court to remove me as counsel for separate defendant Arkansas Department of Education. By: Respectfully Submitted, TIM C. HUMPHRIES1. Secretary of State's Office State Capitol, Room 256 Little Rock, AR 72201 (501) 682-3016 CERTIFICATE OF SERVICE I, Tim C. Humphries, certify that on l_k of March, 2001, I caused a copy of the foregoing document to be served by U.S. mail, postige prepaid, on the following person( s) at the address( es) indicated: M. Samuel Jones, III Wright, Lindsey \u0026 Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 7220 I John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 7220 I Richard Roachell 401 W. Capitol, Suite 504 Little Rock, AR 7220 I Timothy Gauger Mitchell, Williams, Selig, Gates \u0026 Woodyard 425 West Capitol Ave. Suite 1800 Little Rock, AR 72201-3525 Christopher Heller Friday, Eldredge \u0026 Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Brown 201 E. Markham, Ste. 510 Little Rock, AR 72201 Tim c:Humphries 2 I I I , ' . I i II J IN THE UNITED STA TES DISTRICT COURT EASTERN DJSTRICT OF ARKANSAS WESTERN DMSION RECEIVED APR 12 2001 LITTLE ROCK SCHOOL DISTRICT OFFiCEOF DESEGREGATION MONITORING PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's Order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE's Project Management Tool for March, 2001 . Respectfully Submitted, MARK PRYOR Attorney General Assistant Attorney Ge 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-3643 Attorney for Arkansas Department of Education CERTIFICATE OF SERVICE I, Mark A. Hagemeier, certify that on March 28, 200 l, I caused a copy of the foregoing doc "},{"id":"bcas_bcmss0837_1733","title":"Court filings concerning ODM report, ''Student Participation in Extracurricular Activities in the Pulaski County Special School District (PCSSD)'', motion for approval of special election, PCSSD Middle School Project, and PCSSD motion to approve middle schools and revamped high schools","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2001-02"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Office of Desegregation Monitoring (Little Rock, Ark.)","Pulaski County Special School District","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Education--Finance","Education--Standards","Education, Secondary","Educational law and legislation","Educational planning","School buildings","School management and organization","School employees","School facilities","Student activities"],"dcterms_title":["Court filings concerning ODM report, ''Student Participation in Extracurricular Activities in the Pulaski County Special School District (PCSSD)'', motion for approval of special election, PCSSD Middle School Project, and PCSSD motion to approve middle schools and revamped high schools"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1733"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["24 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"District Court, notice of filing, Office of Desegregation Management report, ''Student Participation in Extracurricular Activities in the Pulaski County Special School District (PCSSD)''; District Court, motion for approval of special election; District Court, memorandum in support of motion to approve special election; District Court, supporting materials for forthcoming motion and brief on Pulaski County Special School District (PCSSD) Middle School Project; District Court, Pulaski County Special School District (PCSSD) motion to approve middle schools and revamped high schools; District Court, memorandum in support of Pulaski County Special School District (PCSSD) motion to approve middle schools and revamped high schools; District Court, two entries of appearance; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, notice of change of address and telephone number  The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  I 1. i -I I I I I -I Iii I I I I FILED U.S. DISTRICT COURT .EASTERN DISTRICT ARKANSAS FEB O 2 2001 STUDENT PARTICIPATION IN EXTRACURRicu4~~1;~~ACK, CLERK . IN THE PULASKI COUNTY SPECIAL SCHOOL DISTRICT DEP CLERK Ann S. Marshall Federal Monitor February 2, 2001 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Horace R. Smith Associate Monitor Polly Ramer Office Manager EDWARD L . WRIGHT (1003 - 1977) ROBERTS . LINDSEY (1013 1001) ISAAC A. SCOTT, JR . JOHN G. LILE GORDON S. RATHER, JR . TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD, JR. PATRICK J . GOSS ALSTON JENNINGS, JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J. MULDROW N.M. NORTON WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW aO WEST CAPITOL AVENUE SUITE 2200 RECEIVE ROCK, ARKANSAS 72201-3699 (501) 371 - 0808 FAX (501) 376-9442 fE6 15 10m www . wlJ .com CHARLES C. PRICE OF COUNSEL CHARLES T. COLEMAN oct:lf'C.QC. ALSTON JENNINGS JAMES J, GLOVER rnu1. r RONALD A . MAY EDWIN L. LOWTHER, JR. II \u0026lf\\U'\\lODI\\IQ M. TOCO WOOD CHARLES L. SCHLUMBERGER ... ~~l11f\\ll 11\\\\111 1\\111 WALTER E. MAY ~IV GREGORY T. JONES Writer's Direct Dial No. 501-212-1273 H. KEITH MORRISON mjones@wlj .com BETTINA E. BROWNSTEIN WALTER McSPAODEN ROGER 0. ROWE JOHN O. DAVIS Mr. John Walker John Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 Ms. Ann Brown ODM February 14, 2001 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX, JR. 00 TROY A. PRICE PATRICIA SIEVERS HARRIS JAMES M. MOODY, JR. KATHRYN A. PRYOR J. MARK DAVIS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J. SALLINGS WILLIAM STUART JACKSON MICHAEL D. BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON JENNIFER S. BROWN\" C. TAD BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J . CHARLES DOUGHERTY\"\" M. SEAN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE W. DUKE ROBERT W. GEORGE J . ANDREW VINES JUSTIN T. ALLEN CHRISTINE J. DAUGHER'l'.Y, Ph .D.  Licensed only In Florida and Texas  Licensed to prac/ice before the UnNed States Patent and Trademark Office Heritage West Building, Suite 510 201 East Markham Little Rock, Arkansas 72201 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 RE: PCSSD Dear Counsel and Ms. Brown: Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Enclosed are copies of motion for approval of special election and memorandum in support which are being filed today. MSJ/ao Encls. 234632-v1 Cordially, ~T, LINDSEY \u0026 JENNINGS LLP ~a~u CELEBRATING 100 YEARS 1900-2000 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 KNIGHT, ET AL. MOTION FOR APPROVAL OF SPECIAL ELECTION The PCSSD for its motion, states: fEB 1 ~ no1 OffUJ:.]f lBIREGATiorunmm,11 PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. The PCSSD desires to conduct a special election on May 8, 2001. 2. The proposed election is for the purpose of placing before the voters for approval a millage increase sufficient to finance an ambitious program of school facility enhancement. 3. Exhibit \"A\" describes certain projects proposed for Phase I of this plan. - The proposed program is a result of the formal facilities study conducted by the District last year. 4. State law offers no impediment to the calling of this election as more fully explained in the accompanying memorandum. 5. This motion is presented to the Court for approval because of this Court's monitoring role regarding the financial affairs of the PCSSD. 232191-v1 WHEREFORE, the PCSSD prays for an order of this court approving the special election to be held on May 8, 2001. Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 CERTIFICATE OF SERVICE On February ~2001, a copy of the foregoing was served via U.S. mail on each r - of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 232191-v1 2 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 232191-v1 3 J FEB-01-0J THU 04:36 PM FAX NO. l'lWPOSED BOND REFERENDUM SCOPE (PHASE 1) PULASKI COUNTY SCHOOLS ZON: I 0~1cs 1:lcmcnrary College S1olion l~kmcnr~ry Fuller Junior High (m~jor rcnov:ilion) Mills Univcrsi1y Studies High (major rcnovntion) ZONJ,;l NEW ELEMENTARY SCIIOOL (500) 13akcr l111e,,fatric1 Elcmcni:uy L:lndmark Elcmcnl.lry (major rcnnvnlir.,n) L:iw,011 Elcmcu!.lry (11uj,1r rcnova.lion) ItEPLACE ROil!NSON MIDDLE SCHOOL (SOO) Rnbu\\SOII IIif:ll ZON~J C1ys1al I lill E.lemcnbl)' NEW MAUMELLE /\\RE.A ELP.Ml!NTARY SCI-TOOi, (500) Pu1c Fores! Elcmcnlllry Oak Grove Elcrncnlllry (rcnovo1iun) llobiuson I::lcrncnl.lry NEW MJDDLTI SCHOOi, (S00) o~k Clmvi: J1111iur/Scnior 1-li,:h ZONE-4 Clinltln I::le111cn1ary Magncl Oakbl'ooke clcnic:uury (m~j11r ~-nnvarion) Slll'1'WOOJ Elcmculllry Sylvan llills ElcnicnLllry RI!PLACE SYLVAN llll.1.S MIDDLE SCHOOL Sylvan llilb Jligh (mnjor r1:nova1i0n) ZONES Arnold Drive Elcmcmruy Bayou Melo C'a10 r.lcmcntmy (rc11ov:11ion) DuprL'C F.lcmcnlary Tolkson F!h;mcnt:iiy Nnr1hwo11,l Junior High (1u.1jor renov:ilion) North Puh1.ski Hieh (major rcnov:itioo) ZONE6 Rl:.PLACF. JACKSONVlLU! fil.EMl!NTARY SCHOOL (600) Pinewood t::lcmcnt:iry Tuylor Rh:mcmn1y fockso11viUe Middle (shifl 1'\u003e nuw u.c) RHl'LACB JACKSONVJLI.I! MIODJ.Fi SCHOOL (1,000) 1~c:ksonvillc lligb ZON7 REPLACI! HARRIS bl .f.MENTAR.Y SCHOOL (3S0) Adkins Elc111cnl:iry Soon ElcmcnWy (rcnuvlion) Alrcnotivc Leurnins Ccnwr lllST.N.ICT Admini,ir:11ion fluillliue Adull T..wrnin, C'cmcr /\\11xiliary Scrvicc:s Moioltnancc / Warehouse 'rr;11s1,orlnti011  North Tr.in~pon.'lrlon  Soull1 TOTAL I EXHIBIT It li\u003c.:IIOOL TOTAL so S349,000 SS,411.000 $4,175,000 $6,900,000 $327,600 Sl,888,000 Sl,580,000 $11,300,078 $1,128,000 S49,000 S\u003ci,900,000 $225,000 Sl ,352,000 $387,000 $11,300,078 $973,000 $206,000 S1,929,000 $876,000 $700,000 $11,300,078 S9,370,000 $978,000 $358,000 $1,254,000 5426,000 $518,000 54,076,300 $6,49),000 $8,530,000 $1,071,000 S546,000 Sl,086,000 S13,810,094 SJ,258,000 SS,S00,000 S706,000 5668,000 so so so $0 $0 $386,000 $230,000 SllG,Sl!l,228 P. 02 ZONE TOTAL $!\u003e,9.lS,000 $23,123,678 521,186,078 S24,3:!l,078 $14,\\02,300 S26,3ill,094 SG,874,000 SGlG,000 $126,519,228 FEfl-Ol~Oi THU 04:36 PM FAX NO. fulaski County Special School Distritl 2/1/01 P11!aski County Special School District will ask voters for 3dditiona1 millage at a special election to be held in lhe Spring of 2001. Revenues gcncntcd from the millage will be used lo finance the constructing and equipping of new school buildings and making additions ond improvemt.\u003enls to existin: facilities. These additions and improvements are a current necessity of the DistricL Sorne of the most critical repair work needed in thcst! facilities will be complctud with these funds. As wdl, new construction which will t.ikc pL'lcc in high-growth areas will help to meet the present demand of incrca.~cd student enrollment ln order to satisfy these current needs of the Dis!dct, it is ncccssal)' to hold a special election to :isk patrons for lht!iT support. P. 03 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 KNIGHT, ET AL. MEMORANDUM IN SUPPORT OF MOTION TO APPROVE SPECIAL ELECTION PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS This Court has had occasion to approve motions seeking to hold special elections several times during its involvement in this case. Most recently, this Court approved a special election in the Little Rock School District which was successful. During a time of dire financial circumstances, this Court approved a special election in the PCSSD which was held in 1992. The legislature has fundamentally changed the law since 1992. Under the old law, special elections were authorized only because of circumstances such as a natural catastrophe. Today, ACA 6-14-102 simply provides that: (d) The board of directors of any school district shall have the authority to request the county board of election commissioners to call a special election for the purpose of considering a rate of tax for additional millages for maintenance and operations or for debt service as authorized by Arkansas Constitution, Amendment 74, provided that: (1) All constitutional and statutory requirements for a special school election are met; and 232186-v1 (2) The date of the election is approved by the director. (Ark. Code Ann. 6-14-102(d)) The PCSSD desires to hold a special election on May 8, 2001, to place before the voters a proposed millage increase sufficient to commence an ambitious program of school facility improvements. Thus, the measure comports with the new provisions of 6-14-102(d). All other constitutional and statutory requirements for a special election will be met and it is anticipated that the Director of the Arkansas Department of Education will approve the date of the election. This motion is being submitted to this Court for approval because of this court's role in monitoring the financial affairs of the PCSSD. 232186-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 2 CERTIFICATE OF SERVICE On February 11, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 232186-v1 3 EDWARD L. WRIGHT (1903-1977) ROBERTS . LINDSEY (1913-1991) ISAAC A. SCOTT, JR. JOHN G. LILE WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX, JR. TROY A. PRICE GORDON S. RATHER, JR. TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD , JR . PATRICK J. GOSS ALSTON JENNINGS , JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J . MULDROW N.M. NORTON CHARLES C. PRICE CHARLES T. COLEMAN JAMES J. GLOVER EDWIN L. LOWTHER, JR. CHARLES L. SCHLUMBERGER WALTER E. MAY GREGORY T. JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER McSPAOOEN ROGER 0 . ROWE JOHN 0 . DAVIS VIA HAND DELIVERY Ms. Ann Marshall ODM 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK, ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 376-9442 www. wlj .com OF COUNSEL ALSTON JENNINGS RONALD A. MAY M. TODD WOOD Writer's Di rect Dial No. 501-212-1273 mjones@wlj .com February 15, 2001 Heritage West Building, Suite 510 201 East Markham Little Rock, Arkansas 72201 RE: PCSSD Middle School Project Dear Ann: PATRICIA SIEVERS HARRIS JAMES M. MOODY, JR. KATHRYN A. PRYOR J. MARK DAVIS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J. SALLINGS WILLIAM STUART JACKSON MICHAEL D. BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON JENNIFER S. BROWN* C. TAD BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J . CHARLES DOUGHERTY-* M. SEAN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE W. DUKE ROBERT W. GEORGE J . ANDREW VINES JUSTIN T. ALLEN CHRISTINE J . DAUGHERTY, Ph .D.  Licensed only in Florida and Texas  Ucensed to practice before the Unffed States Patent and Trademark Offlce FEB l 6 20-l OfflCE OF DESEGREGATION MONiTORING I do not yet have a final approved version of the motion and brief I am submitting. However, I wanted to get the supporting materials to you today and ask that you flip through them. The main body of documents will be submitted with the motion and the first page is the PCSSD middle school curriculum course descriptions. That is followed, in chronological order, by the remaining documents I propose to submit directly to the Court. They cover the issues of student/parental involvement, teacher and staff training and frequently asked questions, parent surveys, parent meetings, athletics, and other topics. One of the notebooks I am submitting is the curriculum description for grades 6 through 12. I do not propose to submit that directly to the Court but will reference that it has been furnished to your office. The really thick notebook is the compilation of resource materials which the District has obtained, reviewed and relied upon through most of this process. It has been distributed to all buildings. Again, because of its size, I do not propose to submit it to Court but will reference that it has been furnished to your office. 234904-v1 CELEBRAT ING 100 YEARS 1900-2000 WR IGHT , LI N DSE Y \u0026 JENN INGS LLP February 15, 2001 Page 2 I will also furnish with the motion an additional copy of the Business Case and am submitting an additional one for your convenience. I should have mentioned that pages 001A through D are taken from the curriculum notebook and will be submitted to the Court. Please give me a call after you have had a chance to look some of this over as I need to get this motion filed. MSJ:ao Encls. Cordially yours, WRIGHT, LINDSEY \u0026 JENNINGS LLP \"--- amuel Jones, 111 CE LEBRATING 100 YEARS 1 900-2000 EDWARD L. WRIGHT (1903 1977) ROBERT S. LINO SEY (1913- 1991) ISAAC A. SCOTT . JR. JOHN G. LILE GORDON S. RATHER , JR. TERRY L. Mr .:WS DAVID M. P ROGER A. ( . W C. DOUGLAS ORO, JR . PATRICK J. GOSS ALSTON JENNINGS, JR. JOHN R. TISOALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J. MULDROW N.M. NORTON CHARLES C. PRICE CHARLES T. COLEMAN . JAMES J. GLOVER EDWIN L. LOWTHER, JR. CHARLESL. SCHLUMBERGER WALTER E. MAY GREGORY T. JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER McSPADOEN ROGER 0 . ROWE NANCY BELLHOUSE MAY WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK, ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 376-9H2 WEBSITE: www . wlj .com OF COUNSEL ALSTON JENNINGS RONALD A. MAY M. TODD WOOD Wrller's Dlrecl Olal No. 501-2121273 mjonesCwlj .com September 27, 2000 JOHN 0 . DAVIS JUDY SIMMONS HENRY KIMll!RLY WOOD TUCKER RAY F. COX. JR.  TROY A. PRICE PATRICIA SIEVERS HARRIS JAMES M. MOODY, JR. KATHRYN A . PRYOR J. MARK DAVIS CLAIRE SHOWS HANCOCK \"KEVIN W. KENNEDY JERRY J . SALLINGS WILLIAM STUART JACKSON MICHAEL 0 . BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON JENNlfER S. BROWN\" C. TAO BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J . CHARLES DOUGHERTY\"' M. SUN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE M. WEISENFELS ROBEIIT W. GEORGE J . ANDREW VINES JUSTIN T. ALLEN CHRISTINE J . DAUGHERTY, Ph.D. ' L.lcenad oni\\t., Ronda Md Tuu 'f \\ __ ,,. -,._,_.,,,,__,,,. __ i! -~\\\\ Vl':O r~ ~ , ., P_,. end T,_.,,..,. Offlce The Honorable Susan Webber Wright 600 West Capitol, Suite 302 Little Rock, Arkansas 72201-3325 ~ ~ \\~;_\\1 ~  0~t:-1\"-~ UESEGl\\r ;.,i~--- :\\i:'-~ 1' r,h ,, Re: Little Rock School District v. Pulaski County Special School District; et al. USDC Docket No.: LR-C-82-866 Dear Judge Wright: As the Court is aware, the PCSSD has for many months been studying the adoption of a middle school configuration. I enclose a copy of a business case, which the District has developed, which explains the District's plans in this regard. By copy of this letter to counsel for all of the parties and to Ms. Brown, I am furnishing a copy of the business case to each. MSJ/ao cc: Ms. Ann Brown Mr. John Walker Mr. Christopher Heller Mr. Stephen W. Jones Mr. Timothy Gauger Dr. Gary Smith 206060-v1 CELEBRATING Cordially yours, WRIGHT, LINDSEY \u0026 JENNINGS LLP :~ I Jor:;;11I 00 YEARS 1 9 0 0 - 2 0 0 0 Implementation of Middle Schools Pulaski County Special School District September 2000 Executive Summary: The Pulaski County Special School District (District) currently has 24 elementary schools, each encompassing grades kindergarten through six; one existing middle school, Jacksonville Middle School; and six junior high schools, each encompassing grades seven through nine. The six senior high schools . currently contain students in grades ten through twelve. Evidence from medical science, psychology, and other areas is beginning to show that middle school students are passing through a very special, very critical period of their lives. The change from childhood to adolescence, we now see, is a tremendously important time of life. It is also often a terribly difficult time. Children from age 10 through 15 must endure more changes than they will for the rest of their lives. The middle school has to be unique, but it must also be transitional. It has to lead from the elementary to the high school and still do something special in the middle. With this philosophy in mind, the District has explored the middle school concept as a means to address the specific needs of the students in grades six through eight. After discussions and workshops, the District's Board of Directors voted at its May 9, 2000, meeting to approve a district-wide conversion to middle schools, effective for the 2001-2002 school year. The Board also stipulated that the Oak Grove Junior/Senior High School not be converted that year, though its staff would be trained along with other district personnel. The Board wanted to allow for the construction and opening of a new facility in this attendance area, as referenced in the District's current desegregation plan. A letter to the District's counsel was sent on May 25, 2000, asking him to file the appropriate documentation with the court. (See attached). . Staff estimated that costs for staff development, expanded student services, transportation and facility remodeling would total $1,111,428. (This accounting excludes the cost of construction of a new building in the Crystal Hill area). The Board believes that implementing the middle school concept in the District will create an academic and social environment that is developmentally appropriate for these adolescents and will promote achievement, improved student behavior, and more co-curricular activities for students. Background: I The implementation of the middle school concept will not change student as nments, only the configuration cif the existing junior and senior high schools. Oak Grove Junior/Senior High School will be the exception. Toward this end, the District contracted a general evaluation of all of its schools. This facilities study provides the Board with a blueprint of construction needs. At this time, the District anticipates that the conversion to middle schools can be accomplished by converting the existing junior high facilities to middle school campuses and sending ninth grade students to the senior high school facilities. * Existing facilities have been examined for this movement of students. Two sites would need renovation to accomplish the conversion: Robinson High School will require classroom space conversion and renovation. Mills University Studies High School will need additional cafeteria space and a new media center. Problem Statement: Implementing the middle school concept to provide developmentally appropriate environments for the success of adolescents is recommended. The recommendation, if approved, would be implemented in the 2001-2002 school year, with the exception of Oak Grove Junior/ Senior High School. The middle school concept will promote the District's objective tci raise student achievement and improve student discipline by establishing appropriate and effective learning environments for adolescent youth. Alternatives: The alternative to this recommendation is to keep the current grade configuration the same. However, the District strongly believes that the middle school concept provides needed academic, social and developmental advantages for students. Action Recommended: By its vote on May 9, 2000, the Board of Directors approved a district-wide conversion to middle schools, to become effective for the 2001-2002 school year. The Board also renewed its support for construction of a new middle school/junior high school facility in the Crystal Hill area, as is referenced in the District's desegregation plan. With the hope that this construction is allowed to go forward, the Board chose to delay the conversion of Oak Grove Junior/Senior High School to the middle school concept. Staff members prepared tentative recommendations for the Board to illustrate plans for. the middle school conversion. These recommendations included an examination of facility capacity, expanded student-services, proposed curriculum and extracurricular offerings, parent and com~unity involvement, and district-wide professional development. Once the Board authorized the middle school concept, staff and community members have coAiued to work in committees to address these specific issues. Plans have alsffl\u003eeen developed for continuing parent and teacher input in the process. Objectives: The implementation of middle schools works to support the District's overall goals. Foremost, the creation of effective learning environments for the students in grades six through eight will support the District's goal of raising student achievement and successfully raising expectations. Students in sixth grade will have intensive use of technology and more opportunities to participate in co-curricular activities than is available in elementary schools. Ninth graders will enjoy increased opportunity for advanced academic pursuits and extracurricular activities._ The conversion to middle school focuses the District's current use of facilities and resources to ensure that equitable opportunity is available to all its students. Impact: The creation of developmentally appropriate environments will improve discipline, enhance student achievement and increase the chance for success for these students. As sixth graders move to the middle school campuses, openings will be created in the elementary schools. This additional space will allow for additional pre-K classes, after-school programs, and increased recruitment opportunities within the District. Expansion costs at the elementary level will be reduced by this configuration. Ninth grade students will benefit from the challenge of high school classes, increased curriculum opportunities and extracurricular activities. Resources: The conversion to middle schools can be accomplished with few facility changes. Robinson High School and Mills University Studies High School have been identified as the only buildings needing immediate renovations. These costs are estimated to be $1 ,019,800. Costs for expanding students services, which include media, student-teacher advisory, counseling, health services, and transportation for extracurricular activities, is estimated to be $82,078. Professional development has been designed for district-wide education, as well as targeted needs for teachers and staff. Parents will be surveyed to identify needs, concerns, and expectations. Focus groups will be held at the local campuses to identify teacher and staff questions, concerns, and needs. Data from the focus groups and parent surveys will allow input from our internal and external publics into the planning and implementation process of middle schools. -Plan-forlmpi-ementatio1~------------------------- fj The Pulaski Co-unty Special School District will make the facility renovations required to accommodate a middle school conversion. The committee work done to date will be refined, and resulting plans will be implemented. Upon the opening of school in 2001-2002, students in grades six through eight will attend the middle school, and ninth grade students will attend the high school in their attendance area.   PULASKI COUNTY SPECIAL SCHOOL DISTRICT May 25, 2000 Mr. Sam Jones Wright, Lindsey \u0026 Jennings LLP 200 West Capitol Avenue Suite 2200 Little Rock, Arkansas 72201 Dear Sam: . 925 East Dixon Road/P.O. Box 8601 Litt le Rock, Arkansas 72216 (501) 490-2000 The Board of Directors has approved the District's plan to adopt the middle school model, to become effective District-wide for the 2001-2002 school year. We need you to contact the court and file the appropriate documentation on our behalf as soon as is possible. In general, the plan will not change student assignments, only the configuration of the existing junior high schools and the senior high schools. We are confident that the adoption of middle schools will improve the delivery of services to this age group and will provide improvement in student achievement. ' Enclosed .;:ire the minutes. from the Board meeting, as well as information from the staff presentation. Please contact me if you need any other documentation or information. Sincerely, Theresa Wallent Director, Legal \u0026 Community Affairs . /tnw Encl. I I  I I I I I I Ill I I I I I I ,I I RECEIVED' FEB 16 2001 , OFFICE Of DESEGREGATION MOiroRING PULASKI COUNTY SPECIAL SCHOOL DISTRICT MIDDLE SCHOOL CURRICULUM 2001-2002  COURSE DESCRIPTIONS GRADES 6-8 001a . . . EDWARD L. WRIGHT I 1003- 1\"77) ROBERTS. LINDSEY I 1913- 1991) ISAAC A. SCOTT, JR. JOHN G. LILE GORDON S. RATHER, JR. TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD, JR. PATRICK J . GOSS ALSTON JENNINGS, JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J . MULDROW N.M. NORTON WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK, ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 376-9442 JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX, JR. TROY A. PRICE PATRICIA SIEVERS HARRIS JAMES M. MOODY, JR. KATHRYN A . PRYOR J. MARK DAVIS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J . SALLINGS WILLIAM STUART JACKSON MICHAEL D. BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON JENNIFER S. BROWN C. TAD BOHANNON JgA~M:E=S~ J::. GfLO ~V~E~Ri ~AN REC\u003c., EIVED EDWIN L. LOWTHER, JR. CHARLES L. SCHLUMBERGER www .wlj .com OF COUNSEL ALSTON JENNINGS RONALD A . MAY M. TODD WOOD MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J . CHARLES DOUGHERTY .. M. SEAN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE W. DUKE WALTER E. MAY GREGORY T. JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER McSPAODEN ROGER 0 . ROWE FEB 2 0 2001 Writer's Direct Dial No. 501-212-1273 mJones@wlJ .com ROBERT W. GEORGE J . ANDREW VINES JUSTIN T. ALLEN CHRISTINE J, DAUGHERTY, Ph.D. JOHN 0 . DAVIS OfFICE OF February 16, 2001  Licensed only in Florida and Texas - Licensed to practice before the Un#ed Stales Patent and Trademarl\u003c Office DESEGREGATION MONITORING Mr. John Walker John Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 RE: PCSSD Dear Counsel and Ms. Brown: Mr. Christopher Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Brian Brooks Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 RECEIVED FEB 2 O 7nn1 ftWCEOF ~ -1{6 Enclosed are copies of PCSSD motion to approve middle schools and revamped high schools and memorandum in support which are being filed today. MSJ/ao Encls. 235155-v1 Cordially, WRIGHT, LINDSEY \u0026 JENNINGS LLP CELEBRATING 100 YEARS 1 9 0 0  2 0 0 0 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 BE~ . ij\\l\\!e() DISTRICT NO. 1, ET AL. nS.\"' ii W ~ MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. FEB t fr 7nm ifflCEOf -lGREGATIOti MON\\lORHIG PCSSD MOTION TO APPROVE MIDDLE SCHOOLS AND REVAMPED HIGH SCHOOLS The PCSSD for its motion, states: PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. This Court approved a middle school plan for the LRSD as part of the LRSD's Revised Desegregation and Education Plan. 2. On September 27, 2000, the PCSSD submitted its comprehensive Business Case to this Court, the ODM and the other parties in this case, which Business Case is attached hereto as Exhibit \"A\". 3. During the spring of 2000 and commencing to this day, the PCSSD has proceeded carefully and thoughtfully toward this proposed conversion. Submitted with this motion is a comprehensive bound set of materials which are arranged chronologically and which have been numbered for the convenience of the Court. 4. These materials, other documents and highlights of the District's efforts since this planning effort began are included within this submission. 234946-v1 5. All of the foregoing matters are more thoroughly explained in the accompanying memorandum. WHEREFORE, the PCSSD requests that this Court lend its approval to the District's plan to establish middle schools and high schools for grades 9 through 12. 234946-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 2 CERTIFICATE OF SERVICE On February fl,, 2001, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Brian Brooks Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 234946-v1 3 EDWARD L. WAIGHl C,903-1177) IIOHRT S. LINDSEY (1113-1911) ISAAC A. SCOTT . JII. JOHN G. LIL GOIIDON S. RHHEII. JII. lRRY L. M~ .'NS DAVID M. P A OGE A A.\u003c. OW C. DOUG LA\u003e 0110. JII. PATRICK J. GOSS ALSTON JENNINGS, JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLI .. M SPIVEY 111 LEE J. MULDROW N.M. NORTON CHARLES C. PIIICE CH .. RLES T. COLEMAN , ~~~~= t: ~~~~~~R, JR. CH,.RLEIL. SCHLUMBEIIGER WALTER E, MAY GIIEGORY T. JONES H. KEITH UORIIISOII HTTINA l . BROWNSTEIN WAL TEA McSP,.DDEII ROGER D. ROWE N,_NCY BELLHOUSE M .. Y WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK. ARKA "},{"id":"bcas_bcmss0837_1709","title":"Court filings: District Court, order; District Court, notices of filing, Arkansas Department of Education (ADE) project managment tools","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-09/2001-01"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Arkansas. Department of Education","Education--Arkansas","Education--Finance","Education--Evaluation","Educational law and legislation","Educational planning","School management and organization"],"dcterms_title":["Court filings: District Court, order; District Court, notices of filing, Arkansas Department of Education (ADE) project managment tools"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1709"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["33 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  FILED EAsTMk 5 N gi,ii~1,g ~~~~SAS IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION SEP 11 2000 ~~:M\\3/W~\u0026t~2tERK DEPCd!RK LITTLE ROCK SCHOOL DISTRICT, * Plaintiff: * vs. * * * No. 4:82CV00866 SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL., * * Defendants, * MRS. LORENE JOSHUA, ET AL., Intervenors, KATHERINE KNIGHT, ET AL., Intervenors. * * * * * * ORDER RECEIVED SEP 1 2 2000 OfflCt Ur OESEGRE~l\\ON MONITORING Before the Court is the request of the Magnet Review Committee (''MRC\") for approval of the interdistrict magnet schools' final budget for the 1999-7000 school year. 1 Without objection, the Court hereby approves the budget as submitted. When the budget for the 2000-2001 school year is final, the MRC should submit it to the Court for approval. A. IT IS SO ORDERED this _LL day of September 2000. ~~2 ~'~ UNITED STATES DISTRICT COURT rHIS DOCUMENT ENTERED ON DOCKET SHEET IN COMP~C~ WITH RULE 58 ANC'.WOR !9(a) FRCP 0N -//-Oo __ IV _vt;:: - -- 1 The MRC communicated the final budget to the Court in a letter dated July 28, 2000. For a copy of the letter, see docket no. 3389, attachment. ---- - ----- I - I .IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION RECEIVED OCT 2 - 2000 ~o-mnEO-F  LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE's Project Management Tool for September, 2000. Respectfully Submitted, MARK PRYOR Attorney General Assistant Att e eneral 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. - IMPLEMENTATION PHASE ACTIVITY I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of September 30, 2000 B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION RECEIVED NOV 1 2000 OFF/Cf Of DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE' s Project Management Tool for October, 2000. Respectfully Submitted, MARK PRYOR Attorney General TIMO Assistant Atto neral 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. - IMPLEMENTATION PHASE ACTIVITY I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of October 31, 2000 information available at Septernbef 30, 2000, the ADE calculated the ===:a:F.,.;u::\"n\"'\"d\"'i=ng for FY 00/01 sul:fect to eriodic adjustm~\"nts, B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June. IN THE UNITED STA TES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION nc;.\\D~i v g;;,u DEC 1 2000 OfflCEOf IJESEGREGAllOM MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE' s Project Management Tool for November, 2000. Respectfully Submitted, MARKPRYOR Attorney General Assistant Atta e General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. - IMPLEMENTATION PHASE ACTIVITY I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of November 30, 2000 B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June. RECEIVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUN1Y SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE' s Project Management Tool for January, 2001. Respectfully Submitted, MARK.PRYOR Attorney General Assistant Atta ey General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education  This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources. "},{"id":"bcas_bcmss0837_1315","title":"Proceedings: ''Motion for Consolidation of Positions and Motion for Change in Student Assignments''","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-08-09"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","Pulaski County Special School District","Education--Arkansas","Education--Evaluation","Educational law and legislation","Educational planning","School enrollment","School management and organization","Court records"],"dcterms_title":["Proceedings: ''Motion for Consolidation of Positions and Motion for Change in Student Assignments''"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1315"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["233 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1357","title":"Proceedings: ''Motion for Consolidation of Positions and Motion for Change in Student Assignments''","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-08-09"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","Pulaski County Special School District","Education--Arkansas","Education--Evaluation","Educational law and legislation","Educational planning","School enrollment","School management and organization","Court records"],"dcterms_title":["Proceedings: ''Motion for Consolidation of Positions and Motion for Change in Student Assignments''"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1357"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["27 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1720","title":"Court filings: District Court, second amendment to Pulaski County Special School District (PCSSD) motion for protective order; District Court, third amendment to Pulaski County Special School District (PCSSD) motion for protective order; District Court, fourth amendment to Pulaski County Special School District (PCSSD) motion for protective order; District Court, Pulaski County Special School District (PCSSD) motion to withdraw portions of motion to modify student assignment plan; District Court, order; District Court, notice of deposition; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) project managment tool","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-08"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Pulaski County Special School District","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Educational law and legislation","Educational planning","School management and organization","School enrollment","School employees"],"dcterms_title":["Court filings: District Court, second amendment to Pulaski County Special School District (PCSSD) motion for protective order; District Court, third amendment to Pulaski County Special School District (PCSSD) motion for protective order; District Court, fourth amendment to Pulaski County Special School District (PCSSD) motion for protective order; District Court, Pulaski County Special School District (PCSSD) motion to withdraw portions of motion to modify student assignment plan; District Court, order; District Court, notice of deposition; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) project managment tool"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1720"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["32 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  RECEiVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION AUG 2 2000 LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. SECOND AMENDMENT TO PCSSD MOTION FOR PROTECTIVE ORDER DEFENDANTS INTERVENORS INTERVENORS The PCSSD, for its second amendment to motion for protective order states: 1. The District filed its motion seeking a protective order on July 28, 2000. The District filed its first amendment to motion for protective order on July 31, 2000. 2. Attached as Exhibit A-2 is the latest FOi request, received by the superintendent. As the Court can note, this request seeks copies of all FOIA requests presented to the District over the last three years. 3. On September 30, 1999, Joshua submitted a request to the District via Ms. Mildred Tatum seeking copies of all FOIA requests presented to the District over the last two years. Thus, as the Court can see, the District 193769-v1 continues to receive, in many instances, the same request from Joshua to which it has previously responded within the past twelve months. WHEREFORE, the District prays for the relief it has previously sought and for all proper relief. Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 37i-0808 FAX: (501) 376-9442 - By '- )  PulasJ4 C nty Special f S ct CERTIFICATE OF SERVICE On August_!_, 2000, a copy of the foregoing was served as follows on each of the following : Via Facsimile on: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail on: Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 193769-v1 2 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 193769-v1 3 JUL-31-00 MON 02:50 PM JOHN W. WAT.KER HALl'li WASHTNGTON \\RK aun~F.TTF: SHAWN CUTT.OS Dr. Gary Smith Superintendent of Schools FAX NO. JOHN W. WALKER, P.A. ATioRNl!:Y AT I.Aw 1723 BnoATJWAY LI'M'T.B RocK, ARKANSAS 72206 T~:r.~:l'HONE (501) 374-3758 FAX (501) 37 4-4187 Via lland Deliveay July 31, 2000 Pulaski County Special School District 925 Dixon Road Little Rock, AR 72206 Dear Dr. Smilh: P. 02 RECEIVED JUL 3 1 ZQGO This request is pursuant to the Arkansas :Freedom of Infonnation Act. Would you please provide the following for review, inspection and copying: CACI l) copies of all FOI A requests presented to the District over the Ja:;t three years; 2) copies of all invoices submitted by lhe District in response for FOJ A copies. r will be available to review your responses on f riday, August 4, 2000. EXHIBIT l IJ-.;,z 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 KNIGHT, ET AL. THIRD AMENDMENT TO PCSSD MOTION FOR PROTECTIVE ORDER RECEIVED AUG 2 ZDOD OFFICE OF OfSEGREGATION MmJJTORiUB PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The PCSSD defendants, for their third amendment to motion for protective order state: 1. Attached as serial Exhibit A-3 are copies of Joshua's latest FOi requests. All are addressed to Dr. Smith, two are dated August 1, 2000, and the third is dated July 31, 2000, although all were received on August 1, 2000. 2. The request dated July 31, 2000, is of particular significance. It contains 43 numbered requests, some of which have multiple subparts. 3. Several of the requests evidence an ulterior motive prompting the request. For instance, the July 31, 2000, letter requests job postings, list of all applicants, name of all applicants interviewed and rating forms for a warehouse supervisor, a custodial supervisor, a head custodian for Homer Adkins - Elementary School, a carpenter helper's position, a painter, a lead custodian for 193848-v1 Bayou Meto, a lead mechanic, a custodian for the administration building, a custodian for Robinson Elementary, a laborer for the Transportation Department, together with secretaries and paraprofessionals. It is respectfully submitted that none of the information demanded could reasonably implicate the issues of the pending requests for Central Office reorganization or the proposed reassignments to new Bates Elementary School, neither could they reasonably implicate implementation issues that might be raised in the future concerning Plan 2000. 4. As the Court can see from the dates furnished in the July 31 correspondence, many of the positions were posted more than one year ago. 5. The filing of the District's motion for protective order seems to have accelerated Joshua's request for records via the Arkansas FOIA. As previously noted, the earlier threat of disruption has now turned into actual disruption itself. 193848-v1 WHEREFORE, the PCSSD defendants renew their request for relief. Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 We8t Cc1pitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 2 CERTIFICATE OF SERVICE On August _L, 2000, a copy of the foregoing was served as follows on each of the following : Via Facsimile on: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail on: Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 193848-v1 3 AuG-Ji-uU IUt ud:JJ n~ 5013744187 WALKER LAW FIRM JoaN W. WALKER, P.A. ATrORllllY AT LA.w 1723 BIOADWAY Lmu: RooK, Aluv.NBA.8 7:1206 TELEPHO?\\'i (501) :!7,4,$758 FAX (1501) 37Hl87 RECEfVED JOHN W. WALICll RALPH WASHINGTON MARX BUltNE1'I'E SH.t\\WN CHI.WS Or. Gary Smith Superintendent of School, Pulaski County Special School Oisirioi 925 Dixon Road Little Rock, All 72206 Dear Dr. Smith: Via Fac1bnile  4900483 July 31, 2000 I, , .., 1 r,'..10 7.uOJ This request is pursuant to the Ar~u Freedom otlnformation Act. Would you please provide the following for review, Inspection and copying: - a copy of the Irnplen1ematio11 Plan for PCS SD Plan 2000 - job po$ting1, list of all applicants, name of all applicants interviewed and rating forms inclucilng the rating received for each applicant interviewed for these positiona: 1) MIS Operations \u0026 Proaramming - 7/21/2000 2) Assistant Prinoipal - Jacksonville Jr. High. 7-264 2000 3) Secondary A4si1tant Principal - 7-14--2000 Jacksonville Middle Mills High North l1ulaski Oak Grove Jr./High Robinson Jr, Sylvan Hills High 4) 21111 Century Community Leaming Center Program Coordinator 5) Director ofMaimenance Services. 7-12-2000 6) Direwtor ofTrP!'.!pcrtation  7-6-20(1 7) Computer Sttvlee Technician .. tS-6.2000 8) Administrative Assistant - Security \u0026 Safely - 4-7-2000 9) Principal - Baker  6--6-2000 10) Director of Support Staft'Peraonnel - 6-6-2000 11) Guidance Secretary Sylvan Hilla Jr. - 5-22-l0OO 1::2) Pupil Accounting Supc,visor  4262000 13) Director of Purchuirig- 12-1-99 14) Sp~ia.l Education teacher-Jacksonville Jr. - 4-25-2000 1.5) Warehoue Supervisor - 7-14-99 16) Custodial Supervisor - 7-99 ---- --------------- EXHIBIT I /l-s ALlG- Ji-uU tGt ~d:J J rlM CACI 5013744187 WALK~R LAW FIRM 17) Seere~ry for Safety \u0026 Security - 18) Head Cu~todian  Homer Adkins - 2-14-2000 19) Information Services Specialist  20) Carpenter Help position - 2-9-2000; l-11 2000 21) Director of Technology Services - 12-2-99 22) Painter- 11-1199 23) Payroll Specialist - J 1-8-99 24) Secretary Safety\u0026. Security- J 1-1-99 2S) Lead Custodian -Bayou Meto - 2-21-99 26) Lead Me\u003c:banic  l llCi-98 27) Paraprofessional - Harris Elementary 9-23-99 28) Eneri)' :M.anaaer Position - 9-l 99 921 P03 29) Maintenance Custodian for Administrative Bldg. - 8-13-99 30) Secretary - Special Ed - 8-6-99 31) Lead Custodian - Robinson Elementary  7.3 099 32) Administrative Asst. - Trinipo111tion - 8-2-99 33) Director of Transportation 8-4-99 34) 8 HoUJ' Laborer Transportation 7-29-SlSl 35) Jacuonvill Middle - 6-23-99 36) Oak Grove Jr./Sr . 6-23-99 37) As\u0026t. Supt. Business Affairs - 2-3-2000 38) Director of'Legal Afflun - 12-8-99 39) Principal  Lawson Elementary  9-29-99 40) Director of Accountability~ 9-29-99 41) Asst. Principal - Landmark  7-1-99 Baker Lawson 42) Principal- Landmark 7-1-99 43) Elemenury Asst. Principal - Arnold Dr. Batel College Station Oakbrooke Oak Grove I will be available to rm~ your respon~s on Friday, Augwt 4, 2000. AUG- 01-00 TUE 08:53 AM 5013744197 l.RKER L~ FIRM ,JOHN W. WALK.BR ~ WASHINGTON BUl\\NKTTt 8 WNOHILDS Dr. Gary Smith Superintendent of School, JOHN W, WALKER, P.A. ATTORNEY AT LAW 1728 BROADWAY LrmR ROCIC, MXANBAll 7ll206 TEUPHONE (601) S743758 FAX (601) S14-4187 Via Fncsimilt  490-0~83 August 1, 2000 Pulaski County Special School District 92S Di,;:n Road Little Rock, All 72206 Dear Dr. Smith: '322 ?02 RECEIV'.ED I,'u'U.., 1 I understand that you have agreed to provide to us a copy of the Board agenda booka and other supporting for each of your Board's meetings in the future, Would you also ,imultaneously share your BoardGrami, or will you require a Freedom of Infonnation request for each one? Thank you for your cooperation, Sincerely, JWW:js cc: Theresa Wallont AUG-01-00 TUE 08:54 AM FAX NO. ?. GS 50137441 87 Wl=U\u003cER ~F(J FIRM 922 F'03 ~G 01 0~ 0'3:03 JOHN W, WALK!ilR IULPK WA8HlNOTON MARK BURNETTE BKAWN CHILDS Dr. Gary Smith Superintendent of Schools JOHN W. WALKER, P.A. ATTOIINIY AT I..\\W 1728 BROADWAY Lt't'l'UI ROCK, Aluwl.w 72206 TZU:PH0N8 (501) 374-3758 FAX (501) 374-~ 187 Via Facsimile  490-04'3 Auguat l, 2000 J\u003eulasJci County Speci~ School District 925 Dixon Road Little Rock, AR 72206 Dear Dr. Smith: RECEIVED 1.uG 1 2oou Th.is request is punuant to the Arkansas Freedom of Act. Would you please provide for review, inspection and copying the following: J) requisition requests for office equipmen1, furniture, other materials and supplies for yourself and all Senior adrninJatrators (Assistant Superintendent,, Director of Accountability and Legal Affairs, and other Director\u0026) that have beon made for the period of June 1, 1999 to present: 2) all expenses reports (and requisitions) Including car~ car allowances, beeper,, mobile phonc:s, credit cards, etc. incurred by yourself' and Senior administrators for the period of June 1, 1999 to present; 3) bids submitted in response to request number 1 and 2; and 4) minute$ of the Board approving items 1, 2 and 3. Would you please make this information avPilable by Friday, Augoat ~. 2000. CACI 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 KNIGHT, ET AL. FOURTH AMENDMENT TO PCSSD MOTION FOR PROTECTIVE ORDER AUG 2 PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The PCSSD defendants, for their fourth amendment to motion for protective order state: 1. Attached as Exhibit A-4 is Joshua's latest FOi request directed to Ms. Wallent. 2. As nearly as we can interpret this request, it first asks for written instructions provided secretaries as regards responding to Joshua's FOi requests. We understand that if there are no written guidelines for responding to these requests that Joshua wishes to depose each secretary. 3. The PCSSD defendants respectfully submit that taking the depositions of secretaries regarding whether or not there were written FOi response instructions and, if not, what their oral instructions were transcends the 193901-v1 scope of discovery permitted by the Federal Rules of Civil Procedure, and the PCSSO defendants request that no such depositions be permitted. WHEREFORE, the PCSSO defendants pray for the relief previously requested and as supplemented above. Respectfully submitted , WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 060) aunty Special CERTIFICATE OF SERVICE On August _j_, 2000, a copy of the foregoing was served as follows on each of the following: Via Facsimile on: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail on: Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 193901-v1 2 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 193901-v1 3 AUG-01-00 TUE 01:14 PM FAX NO. P. 04 :;ll0l.l.('l4ltff WHu\u003c.t:t\u003c LHW 1-lt\u003crl HL..b ~l ' \\dlj l 41~b JOHN W, WALKER RALPH WASHINGTON MARK BURNll:T1'E SHAWN CHILDS Ms. Theresa Wallent JOHN W. WALKER, P.A. A'M'ORNZY Ar LAw 1728 BROADWAY UTl'LE ROCK, AR.KANSAS 72206 ' , TEt.EPHONI (~01) 874-8758 FAX (501) 314,4187 Via Facsimile AUS:,'\\ISt 1. 2000 Director of Legat and Community Affairs Pulaski County Special School District 925 Dixon Road Little Rock, AR 72206 Pear Ms. Wallent: RECEIVED AUG 1 ZOOCl This is a follow-up to the FOlA request for written communication from and b~ween Dr, Smith, Dr. Fox, senior administrators and others. This request also includes written correspondence where there has been a written evaluation done of any subordinate employee, In addition, r would like to have any written instructions provided to secretaries regarding requests for written correspondenca and files. If there are no written instructions, I would be interested in taking the depositions of all the secretaries of your Senior stuf\u00264ministrators, l r.walt your response. NIW:js ec: Mi, Sam Jones Ms, Ann Brown --- _ ,., __ Sincerely, EXHIBIT I RECEIVED AUG 4 2000 OffiCEOF IIIGREGATIOff MOITOAING :  . IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-82-866 PLAINTIFF PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. DEFENDANTS INTERVENORS INTERVENORS PCSSD MOTION TO WITHDRAW PORTIONS OF MOTION TO MODIFY STUDENT ASSIGNMENT PLAN The PCSSD, for its motion states: 1. On June 23, 2000, the PCSSD moved to modify its student assignment plan in respect of Landmark Elementary School and the new Bates Elementary School. Beginning at page 5 of the brief which accompanied the motion, the PCSSD explained that it was also seeking permission to shift the art and music specialty program from Landmark to new Bates for the 2001-2002,, school year. 2. The PCSSD now desires to withdraw that portion of the motion seeking Pf:lrmission to shi~this program for the 2001-2002 school without prejudice to raising the issue again at a later date. 194183-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 B ~~:;..__-r.--,--~~~o=)------ ty Special CERTIFICATE OF SERVICE On August ,2,-2000, a copy of the foregoing was served via U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway - Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504- Little Rock, Arkansas 72201 194183-v1 2 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 194183-v1 M I 3 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS AUG 2 3 2000 WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, * * * vs. * * No. 4:82CV00866 SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL., Defendants, MRS. LORENE JOSHUA, ET AL., Intervenors, KATHERINE KNIGHf, ET AL., Intervenors. * * * * * * * * * ORDER RECEIVED AUG 2 5 2000 Oiif',Cftlf OE\u0026Bffiflffl: MONITIJRlNW Before the Court is the request of the Magnet Review Committee (\"MRC\") for approval of the interdistrict magnet schools' final budget for the 1999-2000 school year, The MRC communicated the final budget to the Court in a letter dated July 28, 2000 (attached). The letter also contains a proposed budget for the 2000-2001 school year; however, the Court will address the proposed budget in a separate Order. The Court will allow the parties to and including 10 days from the date of entry of this Order to object to the MR.C's final budget for 1999-2000. Should no objections be filed within the time allowed, the Court will enter an Order iroving the budget. IT IS SO ORDERED this ,A3 day of August 2000. ~J,~lt;w CIIlEF JUDG UNITED STATES DISTRICT COURT rHIS DOCUMENT ENTERED ON DOCKET SHEET LN GOMPLIANC: Wl.~RULE 58 ANDJO~a) FRCP ! ?N~ ,i: 0V BY - Magnet Review Committee 1920 North Main Street, Suite 1 01  North Little Rock, Arkansas 72114 (501) 758-0156 {Phone}  (501) 758-5366 {Fax}  magnet@magnetschool.com {E-mail} July 28, 2000 The Honorable Susan Webber Wright Judge, U. S. District Court  Eastern District of Arkansas 600 West Capitol Suite 302  Little Rock, AR 72201 Dear Judge Wright:  .\"., At its July 14, 2000 special-called meeting, the Magnet Review Committee, by formal    motion and 5-0 vote (the Pulaski County Special School District representative was not present but later voted the District's approval via telephone), approved the interdistrict  magnet schools' actual budget for the six original magnet schools for the 1999-2000 school yec:U\" (Draft 1 ). FINAL 1999-2000 STIPULATED ORIGINAL MAGNET SCHOOLS BUDGET The total amount budgeted, $21,351,086, is based on a per-pupil expenditure of $5,597.00, calculated from an average third-quarter enrollment of3,814.79 . students. This budget reflects an increase of$470.00 per student over the . 1998-99 budget, with the fol;1rth year of the five-year proposed program improve~ ... ment plan included. This final 1999-2000 budget reflects actual figures and takes  into account the variables (teacher retirement and heajth insurance changes\u003e\" that' ' were uncertain when the proposed budget was submitted in June, 1999 .  \u003c: ''.. This :finai budget also reflects costs associated with the additional seats  . . -.. ,.. ,. ,, . i  ', ... which were added during the Little Rock School District's grade configurati~m{:: :  '.' . :,:;. ,,,~y~f f~;C .::0:: 2 : : 0 2:. 0 :~~,eo~i  .  '.5~:}xi~I;::,l}i ,(  . -\u003e: :;,:,;' ,prtammously approved the proposed budget for the six original St1pulat10n magnet , .: '.\u003c;--: . ,:t;,;.1_:~,!.{\\~ ::1i-:;.~'.ir~:; \"  , '\". tj, ... ~,\" J,; .  ' , ,  .  , J\"\"' ''f:   ., ' J , .. :,. t'~ ;r l  -: ... . schoolsforth~2000-200l'schoolyear.  .  , ;,_ -~-;\\\\;,: :.:\"t:f/\\'. '.'t'  ,   :: ' .. .:\\:-1.,':.t\\fp::~.:;~ ;' .. . , PROPOSED 2000-2001 STiPULATED ORIGINAL MAGNET SCHOOLS BUDGET ,.~..... t;  I  -:, -'i/: ., . , ,;, . ,, .~~ The total proposed budget for the 2000-2001 school year is $22,500,211, which. ' - results in a per-pupil expenditure of$5,898.00 and an increase of $30i .OO over/;_ :. ..  .,  the 1999-2000 actual budget. Salary negotiations are in progress, and it should~ :    ' noted that these negotiations may have an impact on the 2000-2001 proposed, : /_  :: budget. It is the intention of the Magnet Review Committee, therefore, to submit :    1,:    .. this budget with the recognition that some flexibility may be necessary. -  \"Pursue the Possibilities of Magnet School Enrollment\"  .. , .,. , ', ,. . , ... , . ':: _;/.;t , .. .al.;,  ( '.\u003e~ .t~//~\u003c:,:~~'  i --~,,.. ,.,...: .;;'Jtt;\\,    I , ~: 'tJtils\u003e\u003e( The Honorable SusanWebher Wright . . . ' . . . -2- \\.l ,  Magne~-Review 0?~ r~~trulfy requ~-~~ tii~' Court's. r.eVIe~ ~n~-~~~~i~y~~f-the 1999-2000 fiilaliz.ed budg~t, as 'Y~ll as tlie proposed 2000-2001 b~dget;-l?othflttach~d :_ herewith.    , '  - :  '~:. .,   -  -- -, ., 'h , .~t?  . ~ ,-._,; ,. ... ' ..' .. ,: . _1.:).' .. : ,i::\\ ...  .. ~~',: .. ;, ... :. ... ~--~~--\\:':,1~':-:./-:'!\u003e  The ~etJ~:~~ew_ Cominitt~ is_f ~IDpi~~-fo ~t~iE)~g.m~.~~l!l~~q~f9.f ie-'. origiilal ~et~schobls. We~ CQnt~uM~;.v.vor~ ~tlie.hg~disti,ict as we:'efj ercise sttjngent oveijig):ii 9f the magnet ~hQ\u003cSJsf oodgt?f ~ ah. effort io \"iichlev ait~.e~ , _\u003e . ., efficient ttiimage~nt and cost: coii~V\u003c?- th~:gr~t~st e:irte,nt po~sibI~~ -C:, / -  ..... . . ' .,_ .... ;..  . . . . . smc~r.eiy, ,  t~: Yiutc1.11t~ Sadie Mitchell, Chairperson ~etRevie:w comttrittee cc:, ' .., .. ,. .: . '- \\~... ,;' ,-, -~ , '!:' ~ --~ .... '. ~  I ':\"' ' 't -~'~:-( .. ~ ::' 'i\\;~_; ':. ;, ?'',. . . .  .  t,,, : :}(::'..:: 1 ,'._._;~,..- _ :__._:,:_~:'-_;_~_,:._:_:::;:_-:__-, :. :,_;,._:_i_.:~,:_:::-~_:,;'.'.~.-.:_._~_:_ ;:;f './. ,,\\, -:\\ - ? : .\\}?r~i-. -;~ -~ ~. ., , . .-~ ', ,.... ,_:: . ~ .-.~ .  f)'.'!t ?,1ff~~tt . . . rt~~\u0026~FM~~~~f-:1~:::::::::::::::::::::::: :::~: ::::n::!~:~:.:.: ::;~~: :::~f::::~::: CERTIFIED 01 Princioal 6.0 $423,711 6.0 $441,017 STAFF 02 Asst. Prin. 10.0 $540,287 10.0 $572,704 SUPPORT STAFF 03 Soecialists 40.2 $1 ,638,478 40.2 $1,736,787 04 Counselors 13.4 $592,038 13.4 $627,561 05 Media Scee. 6.5 $288,210 6.5 $305,502 06 Art-Perf./Prod. 1.0 $35,443 1.0 $37,570 07 Music 0.0 $0 0.0 $0 08 Foreign LanQ. 0.0 $0 0.0 $0 09 Vocational 7.6 $349,156 7.6 $370,106 10 Soecial Education 9.2 $340,504 9.2 $360,934 11 Gifted 5.4 $227,711 5.4 $241,374 12 Classroom 190.8 $7,180,546 188.8 $7,611,379 13 Substitutes 0.0 $196,924 0.0 $206,000 14 Other-KinderQarten 15.0 $621,745 16.0 $659,050 TOTAL CERTIFIED SALARY 305.1 $12,434,753 304.1 $13,169,982 15 Secretaries 20.4 $517,493 21.4 $568,543 16 Nurses 6.0 $223,684 6.0 $237,105 17 Custodians 30.0 $431,533 30.0 $457,425 18 Information Services 1.0 $51,156 1.0 $54,225 19 Paraprofessionals-Other 6.0 $165,698 6.0 $175,640 20 Other-Aides 35.0 $405,160 35.0 $429,470 21 Fringe Benefits(20' ~  $3,599,572 ~  $4,022,814 TOTAL SUPPORT SALARY 98.4 $5,394,297 99.4 $5,945,223 TOTAL (10-20) ~ j $17,829,050 ~  $19,115,205 PURCHASED 22 Utilities ~ j $454,368 ~  $485,060 SERVICES t--23--t-T-ra_v_e_l- -------~-,:-\"\"::' \".\"':'\" .'\":./,.,t--------$-2_9. .,..9 _3_7~, .,,..,\".\"':'\" :,\".',:.,'.\\,..1----$,-4_1_ ,4_50--1 (30) 24 Maintenance Aareements ~  $0 ~ : $0 MATERIALS, SUPPLIES (40) CAPITAL OUTLAY (50) OTHER (60) 25 Other ~  $393,895 ~ i $187,123 TOTAL (30) ~ i $878,200 ~ i $713,633 26 Princioal's Office ~  $419 ~ i $1,750 27 Reaular Classroom ~ i $632,772 ~  $503,452 28 Media ~  $45,163 ~ : $46,900 29 Other ~ : $25,424 ~ : $20,797 TOTAL (40) ~  $703,778 ~ : $572,899 30 Eauioment ~  $369,502 ~ i $452,387 31 Buildino Reoair, etc. 32 Other TOTAL(50) ~ i $369,502 ~ $452,387 33 Dues and Fees ~ : $33,474 ~  $17,500 34 Other TOTAL (60) ~ i $33,474 ~ i $17,500 TOTAL (30-60) ~ j $1,984,954 ~  $1,756,419 TOTAL (10-60) 403.5 $19,814,003 403.5 $20,871,625 TOTAL LINE ITEMS- (SECOND PAGE) ~ : $1,537,083 ~ j $1,628,587 :\u003c\u003e\u003e i)iS.AANOJ'.O.lAt)!H?t : ~  ) t $.~f;)$.'Ul$.$i ~  ) j/ $~ZOOPi~1l: Stipends $21 ,871 $37,400 Other Objects $0 $0 Indirect Costs $1 ,411,708 $1 ,487,687 Vocational $32,000 $32,000 Athletics $33,000 $33,000 Gifted Proorams $504 $500 Plant Services $32,000 $32,000 Readino $500 $500 Science $0 $0 Enolish $1 ,500 $1,500 Special Education $4,000 $4,000 $0 $0 xxxxxx $0 $0 xxxxxx $0 $0 Total Line Items $1 ,537,083 $1,628,587 e.~fJiii111:c6st:::ri::i,:,:::,::iin i:n:::j !lil!M!on:::,: ni:n,::2000.--01::::,u:: 3rd Qtr. ADM or Proi. 3,814.79 3,814.79 Total Costs $21 ,351,086 $22,500,211 P~rJ!ib.1t:(i~t:niun:::n:t ,,i:: ::: :::::n,:i,n:iiJ$.=s-91:: :i::n,::::::i:i::$.i:i;8~t:: fjl~~immw.~m~ffimM~ffl-~illl!l!lil!!l!!illl1l !llllill :::::: :i:::::::::.::~::::::::::: :::'rtE\\i: :::::1::i~::it~:::::1:1 CERTIFIED 01 Principal 1.0 $69,272 1.0 $ 73,428 STAFF 02 Asst. Prin. 1.0 $56,669 1.0 $ 60,069 SUPPORT STAFF PURCHASED SERVICES (30) MATERIALS, SUPPLIES (40) CAPITAL OUTLAY (50) OTHER (60) 03 Specialists 7.0 $293,910 7.0 $ 311 ,544 04 Counselors 2.0 $87,214 2.0 $ 92,446 05 Media Spec. 1.0 $47,376 1.0 $ 50,219 06 Art-Perf./Prod. 1.0 $35,443 1.0 $ 37,570 07 Music $0 $0 08 Foreign Lang. $0 $0 09 Vocational $0 $0 10 Special Education 1.3 $62,744 1.3 $ 66,509 11 Gifted 1.0 $43,999 1.0 $ 46,639 12 Classroom 32.6 $1,165,224 31 .6 $ 1,235, 13 Substitutes $18,609 $ 14 Other-Kindergarten 4.0 $171 ,635 5.0 $ TOTAL CERTIFIED SALARY 51.9 ,052,095 51 .9 $2,176,495 15 Secretaries 2.0 ,286 2.0 $ 36,344 16 Nurses 1.0 $37,591 1.0 $ 39,846 17 Custodians 4.0 $57,275 4.0 $ 60,712 18 Information Services 0.2 ,528 0.2 $ 9,039 19 Paraorofessionals-Other $0 $0 20 Other-Aides 7.0 $93,153 7.0 $ 98,743 21 Fringe Benefits(20 ~ . $603,562 ~ : $648,855 TOTAL SUPPORT SALARY 14.2 $834,396 14.2 $893,538 TOTAL (10-20) ~ ' $2,886,491 ~ : $3,070,033 22 Utilities ~  $57,485 ~ : $61,400 23 Travel ~ : $6,356 ~ : $10,000 24 Maintenance Agreements 25 Other ~  $16,038 ~ i $26,025 TOTAL(30) ~ $79,879 ~  $97,425 26 Principal's Office 27 Regular Classroom ~ . $86,038 ~ : $67,403 28 Media ~ . $6,572 ~ : $7,000 29 Other ~ : $3,490 ~  $5,050 TOTAL (40) ~ . $96,101 ~ i $79,453 30 Equipment ~  $86,476 ~  $108,560 31 Building Repair, etc. 32 Other TOTAL (50) ~  $86,476 ~i $108,560 33 Dues and Fees ~  $6,258 ~ : $2,500 34 Other TOTAL (60) ~ $6,258 ~  $2,500 TOTAL (30-60) ~ $268,714 ~ $287,938 TOTAL (10-60) 66.1 $3,155,205 66.1 $3,357,971 TOTAL LINE ITEMS - (SECOND PAGE) ~ $217,044 ~ i $228,001 U/ i)d~AA'tilP.iT-O.T:A1;i)/HHH fflffii' i))/$:3\\:31ZZ4it nitxibtii i)f:)\";S$$;~72i :w,~,)t~:~~~:?::::::u::::::::::::: :::1:n::A~~~1::u::::: 1:u:p;tjpp~~::::::: J~(i!ii~ij-!HJ::nt::::::u:::::r::::ur 1999-00 2000-01 Stipends $9,891 $10,000 Other Objects $0 $0 Indirect Costs $201,576 $212,425 Vocational $0 $0 Athletics $0 $0 Gifted Programs $151 $151 Plant Services $4,569 $4,569 Reading $71 $71 Science $0 $0 English $214 $214 Special Education $571 $571 xxxxxx xxxxxx Total Line Items $217,044 $228,001 P~f ~~P.i~:9.~fi!1::::::::::::::::::::::::: :::::::d~~~~~:::::::: u:::::~99H~1.::::::::; 3rd Qtr. ADM or Proj. 544.71 544.71 Total Costs $3,372,249 $3,585,972 P~!~~Pi~!.~~t:::::::::::::::::::::::::::::: ::::::::::::::1:::$.~!1:~j!! :::::::::::::u:~~~~ij1! ~:~1~~~~~l~~~mq~~~RMtr~:r::::::::::::::::::::::::: :::~.:. ::::,:,:,:::~::::::: :!~+~::: ::,:::~~:.:~~,:::::,: CERTIFIED 01 Princioal 1.0 $65,840 1.0 $ 69,790 STAFF 02 Asst. Prin. 1.0 $51,989 1.0 $ 55,108 03 Soecialists 8.0 $314,459 8.0 $ 333,327 04 Counselors 2.0 $72,367 2.0 $ 76,709 05 Media Soec. 1.5 $61,802 1.5 $ 65,510 06 Art-Perf./Prod. $0 $0 07 Music $0 $0 08 Foreign Lang. $0 $0 09 Vocational $0 $0 10 Soecial Education 1.5 $38,627 1.5 $ 40,945 11 Gifted 1.4 $56,496 1.4 $ 59,886 12 Classroom 21 .3 $683,203 21 .3 $ 724,195 13 Substitutes $28,558 $ 30,000 14 Other-Kindergarten 5.0 $185,552 5.0 $ 196,685 TOTAL CERTIFIED SALARY 42.7 $1,558,893 42.7 $1,652,155 SUPPORT 15 Secretaries 3.0 $61,721 3.0 $ 65,424 STAFF 16 Nurses 1.0 $36,340 1.0 $ 38,520 17 Custodians 4.0 $55,669 4.0 $ 59,009 18 Information Services 0.2 8,528 0.2 $ 9,039 19 Paraprofessionals-Other $0 $0 20 Other-Aides 11 .0 $107,386 11.0 $ 113,829 21 Fringe Benefits(20) ~ $479,870 ~  $ 542,901 TOTAL SUPPORT SALARY 19.2 $749,514 19.2 $828,724 TOTAL (10-20) ~ - $2,308,407 ~ : $2,480,879 PURCHASED 22 Utilities ~ - $49,101 ~ ! $52,300 SERVICES 23 Travel ~ $5,151 ~ : $12,000 (30) 24 Maintenance Aareements 25 Other ~ $14,934 ~  $13,055 TOTAL (30) ~ $69,186 ~ ! $77,355 MATERIALS, 26 Princioal's Office SUPPLIES 27 Regular Classroom ~ - $118,231 ~  $56,046 (40) 28 Media ~ - $8,911 ~ : $9,500 29 Other ~ - $3,904 ~ : $3,000 TOTAL (40) ~ : $131,046 ~  $68,546 CAPITAL 30 Eauioment ~ - $49,822 ~ ! $41,802 OUTLAY 31 Buildina Reoair, etc. ~ $0 ~ : $0 (50) 32 Other TOTAL (50) ~ $49,822 ~ ! $41,802 OTHER 33 Dues and Fees ~ $5,154 ~ ; $2,000 (60) 34 Other TOTAL(60) ~ $5,154 ~ ! $2,000 TOTAL (30-60) ~ $255,209 ~ : $189,703 TOTAL (10-60) 61 .9 $2,563,615 61.9 $2,670,582 TOTAL LINE ITEMS - (SECOND PAGE) ~  $205,684 ~' $223,951 Stioends $4,277 $12,000 Other Objects $0 $0 Indirect Costs $195,985 $206,533 Vocational $0 $0 Athletics $0 $0 Gifted Proarams $147 $144 Plant Services $4,442 $4,442 Readino $69 $69 Science $0 $0 English $208 $208 Special Education $555 $555 xxxxxx xxxxxx Total Line Items $205,684 $223,951 J~ei:J~~i)!liC9$~:n::,:::,::::n:::::::n::,:: :::::n::,:$~9.~I):::::::: ::::::::~P~iHHi:. 3rd Qtr. ADM or Proi. 529.60 529.60 Total Costs $2,769,300 $2,894,533 1F.1et:P.~Pft,co~t::,1:u::1:::1::::::n::::,::: :::::::::::::,::::is;~~:: .,:,:::::,:::,:u:$.SA$$:: ~:1,,~~~illlifm~ffimM~ffl~ffi~J~::ilillililllllil:iilil11l l::::::1 ::::::::::::::~::::::::::: :::+r~:l: ::::::::~~:flt~:::::::: CERTIFIED 01 Principal 1.0 $64,456 1.0 $ 68,323 STAFF 02 Asst. Prin. 1.0 $46,301 1.0 $ 49,079 03 Specialists 6.8 $239,142 6.8 $ 253,491 04 Counselors 1.0 $48,372 1.0 $ 51 ,274 05 Media Spec. 1.0 $49,380 1.0 $ 52,343 06 Art-Perf./Prod. $0 $0 07 Music $0 $0 08 Foreign Lang. $0 $0 09 Vocational $0 $0 10 Special Education 2.0 $78,541 2.0 $ 83,253 11 Gifted 1.0 $36,021 1.0 $ 38,182 12 Classroom 13.5 $501,102 13.5 $ 531,168 13 Substitutes $13,155 $ 14,000 14 Other-Kindergarten 3.0 $126,118 3.0 $ 133,685 TOTAL CERTIFIED SALARY 30.3 $1 ,202,588 30.3 $1,274,799 SUPPORT 15 Secretaries 1.4 $29,738 1.4 $ 31,522 STAFF 16 Nurses 1.0 $33,314 1.0 $ 35,313 17 Custodians 3.0 $46,030 3.0 $ 48,792 18 Information Services 0.2 8,528 0.2 $ 9,039 19 Paraprofessionals-Other $0 $0 20 Other-Aides 5.6 $40,981 5.6 $ 43,440 21 Fringe Benefits(20) ~  $338,590 ~ : $392,172 TOTAL SUPPORT SALARY 11.2 $497,181 11 .2 $560,278 TOTAL(10-20) ~ : $1,699,769 ~  $1,835,077 PURCHASED 22 Utilities ~ : $27,159 ~ i $29,660 SERVICES 23 Travel ~ : $4,646 ~ : $5,000 (30) 24 Maintenance Aoreements ~  $0 ~ : $0 MATERIALS, SUPPLIES (40) CAPITAL OUTLAY (50) OTHER (60) 25 Other ~ : $10,739 ~  $13,818 TOTAL (30) ~ : $42,544 ~ : $48,478 26 Principal's Office ~  $0 ~ : $1,000 27 Reoular Classroom ~ : $46,173 ~ : $40,000 28 Media ~ : $2,257 ~ : $3,500 29 Other ~  $2,740 ~ : $334 TOTAL (40) ~ : $51,170 ~ : $44,834 30 Eauipment ~ - $19,503 ~ : $8,497 31 Buildino Repair, etc. 32 Other TOTAL (50) ~ - $19,503 ~  $8,497 33 Dues and Fees ~ $6,977 ~  $1,000 34 Other TOTAL (60) ~ $6,977 ~ ; $1,000 TOTAL (30-60) ~ $120,194 ~ ' $102,809 TOTAL (10-60) 41 .5 $1,819,963 41.5 $1 ,937,886 TOTAL LINE ITEMS - (SECOND PAGE) ~ - $108,028 ~  $113,686  :t=)J~AAND.:tO.'tAk)))) ~  /(:)$.1(927:~92H xmio( )))~~05Mu,2 .. W@rn~:~tit::::n::t:\\:H\\: n::::::HAi::'t~~n:::::n: }1/ P#iDP~~::j:jj\" :~~~l:/:\\:\\J:H\\/t/HH/: 1999-00 2000-01 Stipends $0 $0 Other Obiects $0 $0 Indirect Costs $105,120 $110,777 Vocational $0 $0 ~~~ ~ ~ Gifted Programs $79 $79 Plant Services $2,383 $2,383 Readino $37 $37 Science $0 $0 Enolish $112 $112 Special Education $298 $298 )00()()()( )00()()()( Total Line Items $108,028 $113,686 tPer:~ij11:c;o~t::::::::i:::iti:::::::i:i: 1:::::::1~~9.~a:::::1:1 :::::i::~PQP~~ :ni:::: 3rd Qtr. ADM or Proj. 284.06 284.06 Total Costs $1,927,992 $2,051,572 p~:Fc'uomoo~t:ri:::i:::::i::::::::: 1:::1::::::::i::$.Ekl\u0026.1: ::i:::::i:i:u~iz:i ~~~1~il1if~\u0026l~ffll~ITT~ffi~~illlllilllillillll:i:ililii ::::w:: l:::::::l:l:W~~:::::l:l:l: ::~~w:: rn:::::~~:.t:rn:::::::: CERTIFIED 01 Principal 1.0 $76,612 1.0 $ 81,209 STAFF 02 Asst. Prin. 1.0 $46,301 1.0 $ 49,079 SUPPORT STAFF 03 Specialists 5.0 $221 ,42 "},{"id":"bcas_bcmss0837_1724","title":"Court filings concerning PCSSD's motion to approve modification to student assignment plan, ODM report, ''Achievement Disparity between the Races in the North Little Rock School District (NLRSD)'', and the Pulaski County Special School District (PCSSD) motion for protective order","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-07"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Pulaski County Special School District","Office of Desegregation Monitoring (Little Rock, Ark.)","North Little Rock School District","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Education--Standards","Educational law and legislation","Educational planning","School management and organization","School enrollment","School integration"],"dcterms_title":["Court filings concerning PCSSD's motion to approve modification to student assignment plan, ODM report, ''Achievement Disparity between the Races in the North Little Rock School District (NLRSD)'', and the Pulaski County Special School District (PCSSD) motion for protective order"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1724"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["23 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"District Court, opposition to Pulaski County Special School District's (PCSSD's) motion to approve modification to student assignment plan; District Court, notice of filing, Office of Desegregation Management report, ''Achievement Disparity between the Races in the North Little Rock School District (NLRSD)''; District Court, Pulaski County Special School District (PCSSD) motion for protective order; District Court, memorandum in support of Pulaski County Special School District (PCSSD) motion for protective order; District Court, first supplement to Pulaski County Special School District (PCSSD) motion for protective order; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool  The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  RECEIVED JUL 7 2000 IN THE UNITED STATES DISTRICT COURT JUL n 6 2000 OFFICE OF DESEGREGATION MONITORING EASTERN DISTRICT OF ARKANSAS JAMES W McCORMACK.,C LERK By .. WESTERN DIVISION  DEP CCERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. OPPOSITION TO PCSSD'S MOTION TO APPROVE MODIFICATIONTO STUDENT ASSIGNMENT PLAN DEFENDANTS The Joshua Intervenors oppose the PCSSD's Motion to Approve Modification to Student Assignment Plan. The basis for the Joshua Motion is as follows: 1. The proposed Motion to Approve Modification to Student Assignment Plan was not presented to the Joshua Intervenors and the other parties until it was filed with the Court. This is a deviation from the desegregation plan requirement. It is important to note that the Office of Desegregation of the Pulaski County District has had no contact directly or indirectly with counsel regarding this matter and counsel is therefore left in the position of being uninvolved in the evolution of the modification. The Intervenors are also unaware that the district has shared its proposed modification proposal with the educational advisors to the district particularly, Dr. Steven Ross, which brings the Joshua Intervenors to point No. 2. 2. The proposal does not indicate how the modifications will strength the delivery of education to the affected children and how it will contribute to the remediation of preexisting and well-entrenched patterns of educational disparities between majority and minority students. In fact, the proposal is silent on tile educational benefits to the students. 3. The district indicates that it proposes to save money by making the modification to the student assignment plan. The purported business case does not delineate the amount of money ti-mt is involved in its proposal nor the amount of saving which would be effectuated. It suggests that by reduction of busing, it would reduce cost. But there is no demonstration that busing will actually be reduced. The map presented as Exhibit 1 to the motion is very general and does not set forth the geographical areas of any of the schools. Therefore, it is impossible to accurately ascertain the transportation impact upon students which brings us to the next point. 4. The text of the PCSSD brief shows (at 3) that the district proposes to implement option 3 set forth on Exhibit B. The Landmark school would be 75% white and the new Bates 70% black. Prior to the new construction, the three schools (Landmark, Old Bates, and Fuller) ranged from 42- 5 7% black. The district proposes a range of 25-70% black. Thus, new construction would promote segregation. That brings us to the next point. 5. The district argues in page 3 of its brief that these racial imbalances can be improved but its presents no plan for that improvement nor any date nor responsible authority for insuring that these schools will not become racially identifiable. 6. The proposal is patently racial because it proposes to shift white students from the majority African American school to the predominately white Landmark school and it proposes to shift African American students from predominately white Landmark school to the predominantly African American Bates school. The district simply cannot justify this racial assignment by noting that it will shift some programs from Landmark to Bates. Those shifts have not been documented nor discussed with Joshua nor have they been approved by the Court. Furthermore, shifting programs from one school to another cannot meet or satisfy the district's obligation to desegregate  in full. The Joshua Intervenors again observe that there has been no educational program presented to the Court which would insure that the educational advantages available to children in the southeast quadrant of the school district will be equal to those in the north west quadrant. The schot\u003el district has not developed under the new administration any vision regarding improvement of educational opportunity for students in the southeast quadrant any of its schools. 7. The district makes reference to other matters under consideration such as moving schools in the southeast quadrant to the middle school concept. But those proposals have not been developed and are therefore are not being responded to by Joshua at this time. To respond to speculation would be an exercise in futility. WHEREFORE, the Joshualntervenors respectfully oppose the proposal of the school district to substantially change the racial identification of the Landmark and Bates schools. The Joshua Intervenors respectfully request a hearing on the subject, after reasonable opportunity to engage in discovery, and after such hearing, they respectfully request that the proposed modification be rejected. By: Respectfully submitted, JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 CERTIFlCATE OF SERVICE I hereby certify that a copy of the foreging has been mailed, postage prepaid to the following counsel or record, postage prepaid on this day of July, 2000. Mr. M. Samuel Jones, III Wright, Lindsey \u0026 Jennings 2000 NationsBank Plaza 200 W. Capitol Little Rock, Arkansas 7220 l Mr. Tim Humphries Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arknasas 72201 Mr. Richard Roachell 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Bldg. 400 W. Capitol Little Rock, Arkansas 7220 I Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY To,vers 425 W. Capitol Little Rock, Arkansas 7220 I Ms. Ann Brown 201 E. Markham, Ste. 510 Little Rock, Arkansas 72201 . Walker Ann S. Brown Federal Monitor ACHIEVEMENT DISPARITY BETWEEN THE RACES F I INTHE !L,E~ NORTH LITTLE ROCK SCHOOL DISTRICT EAsr~~N~1~1t'Mc~ A~R~~sAs July 12, 2000 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Norman W. Marshall Associate Monitor JUL 1 2 2000 ~~{AES W. McCORMACK. CL!::~K Dt:P C.::.~ Polly Ramer Office Manager I  1 1 I  I I I I I I I   I 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 KNIGHT, ET AL. PCSSD MOTION FOR PROTECTIVE ORDER The PCSSD defendants, for their motion state: R ,HJl 3 1 2000 OrFICE Gr DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. Attached as serial Exhibit A are multiple FOIA requests received by the PCSSD and certain of its personnel during the past two weeks. Attached as serial Exhibit B are FOIA requests received from Joshua by the PCSSD generally dating from the Fall of 1999. 2. The PCSSD respectfully submits that Joshua is improperly utilizing the Arkansas FOIA as a substitute for the discovery specified by the Federal Rules of Civil Procedure. 3. Certain of the information sought pursuant to Joshua's FOi requests is irrelevant to the issues scheduled for hearing on August 9, 2000, or to any other issues which could reasonably arise in this litigation. 4. The current requests are often oppressive, burdensome and annoying. 193297-v1 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEIVED DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ~UL 31 2000 OFFICE OF DESEGREGATION MOfJITORING MEMORANDUM IN SUPPORT OF PCSSD MOTION FOR PROTECTIVE ORDER Rule 26(c) of the Federal Rules of Civil Procedure provides in pertinent part that: Upon motion by a party ... accompanied by a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action, and for good cause shown, the court in which the action is pending ... may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following: (1) that the disclosure or discovery not be had; (2) that the disclosure or discovery may be had only on specified terms and conditions, including a designation of the time or place; (3) that the discovery may be had only by a method of discovery other than that selected by the party seeking discovery; (4) that certain matters not be inquired into, or that the scope of the disclosure or discovery be limited to certain matters; Attached to the PCSSD motion, as serial Exhibit A, are copies of many of the FOi requests that have been served by Joshua since this Court entered its order scheduling 193040-v1 - this matter for hearing on August 9, 2000. Any perusal of the FOi requests makes it apparent that Joshua is seeking to utilize the Arkansas Freedom of Information Act in lieu of the discovery rules specified by the Federal Rules of Civil Procedure. The Arkansas Freedom of Information Act is codified beginning at ACA 25-19- 101. 25-19-105 provides in pertinent part that: (a) Except as otherwise specifically provided by this section or by laws specifically enacted to provide otherwise, all public records shall be open to inspection and copying by any citizen of the State of Arkansas during the regular business hours of the custodian of the records. (b) It is the specific intent of this section that the following shall not be deemed to be made open to the public under the provisions of this chapter: (8) Documents which are protected from disclosure by order or rule of court. While the PCSSD is not seeking to protect certain records from disclosure, it is - seeking an order of this Court which harmonizes the provisions of the Federal Rules of Civil Procedure and the Arkansas FOIA for purposes of this litigation. While the public policy considerations underpinning the Arkansas FOi are sound and are not challenged by this motion, what is questioned is the propriety of substituting the FOi for traditional discovery. The public's right to know is one matter; however, the attempted conversion of a sunshine law into a truncated and oppressive discovery weapon is quite another. For the reasons that follow, this Court should enter an order consistent with the relief sought herein. 193040-v1 2 Certain of the information sought is irrelevant to the issues scheduled for. hearing on August 9, 2000, or to any other Issues which could reasonably arise in this litigation The August 9 issues The issues scheduled for hearing on August 9, 2000, are the PCSSD proposal to reorganize the assistant superintendentships for personnel and desegregation and a PCSSD proposal to modify some student assignments to the new Bates Elementary School. Although it will be obvious to the Court from examination of the FOi requests that Joshua has plans to bring Plan 2000 compliance issues to the Court's ultimate attention, those are not currently the subject of the August 9 hearing. Indeed, as the Court can see from examining Joshua's letter of July 19, 2000, Joshua has necessarily - elected to invoke the 30-day \"complaint\" procedure specified in Plan 2000. The PCSSD will respond to the complaint letter in the time allocated under Plan 2000. Thereafter, assuming that Joshua remains dissatisfied with the PCSSD response, Joshua will have the option to invoke the dispute resolution process specified with the Department of Justice. If, in fact, this dispute resolution process proves unsuccessful, then, but only then, may Joshua seek to invoke the jurisdiction of this Court. The foregoing is offered to illustrate the fact that even if Joshua is serious about ultimately raising compliance issues before this Court, the interim process will necessarily take some time and it is respectfully submitted that no hearing could be reasonably scheduled for such issues until some time this fall. Accordingly, the PCSSD believes it is reasonable to propose that Joshua's current FOi requests be reasonably limited to the discreet issues currently set for hearing, and that in respect of all other 193040-v1 3 - issues, that Joshua be ordered to utilize the traditional discovery techniques as specified in the Federal Rules of Civil Procedure. The current requests are oppressive, burdensome and annoying Any fair reading of the current FOi requests demonstrate that the requests are not all bottomed upon \"the public's right to know\" as envisioned by the Arkansas FOi. Neither can Joshua point to anything within the Arkansas FOIA which authorizes its use as a litigation tactic calculated to disrupt school district operations, seek information, such as thank you notes, get well cards, and anything \"in writing\" or \"all writings\" whatever they may be. Rather, the breadth and unbridled scope of the requests strongly suggests an ulterior motive; i.e. to keep administrators and staff from their regular jobs and to watch them jump through the hoops created by Joshua's requests. The Federal rules contain reasonable deadlines for discovery compliance which permit documents to be produced in a manner that is not disruptive to normal business and educational activities and responsibilities. The Arkansas FOIA, on the other hand, requires an almost instantaneous response which, when coupled with the volume of materials requested by Joshua, threatens chaos and disruption. The PCSSD suggests that this is an unwarranted perversion of the Arkansas FOi not calculated or contemplated by the Arkansas Legislature. Many of the FOi requests duplicate matters previously furnished to Joshua pursuant to FOi requests and duplicate requests for information routinely furnished to Joshua as part of PCSSD's desegregation philosophy Included as serial Exhibit B are FOi requests dated generally from 1999, to which the PCSSD then responded. At a minimum, the PCSSD should not be 193040-v1 4 put to the trouble of regurgitating again that which it has previously furnished Joshua within the last twelve months. Further, many of the requests implicate reports to the Board and the ODM which have been routinely generated during the last ten years and just as routinely, furnished to Joshua including, for instance, the annual PCSSD affirmative action reports, discipline reports, special education reports and other similar reports well know to the ODM and to this Court. It seems no great request that Joshua be ordered to discipline itself to the extent that it first ascertain whether or not it already has the information requested before blindly seeking it again and again from the PCSSD. Conclusion For the foregoing reasons, the PCSSD requests an order of this Court granting the relief sought herein. 193040-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 - By \\..- ;T-- ~ . ;-1--n- _,,, ' .._ . ( .______ M. Sa_!J)tlel ones Ill _(760,60) . . Attorneys f Pulaski C~ Special spt,ool Di ict '-_/ 5 CERTIFICATE OF SERVICE On July2:\u0026ooo, a copy of the foregoing was served as follows on each of the following: Via Hand Delivery Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail: Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower  425 West Capitol Avenue Little Rock, Arkansas 72201 193040-v1 6 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 KNIGHT, ET AL. FIRST SUPPLEMENT TO PCSSD MOTION FOR PROTECTIVE ORDER The PCSSD, for its first supplement to motion states: RECEIVED AUG 1 2000 i.HH10F OESE~OO-,mJ MmJITORIMG PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS 1. Attached as Exhibit A-1 are FOi requests, received by Dr. Smith, all dated July 28, 2000. These requests were actually received on July 31, 2000. 2. These two requests supplement Exhibit A to the District's motion for protective order filed July 28, 2000. WHEREFORE, the PCSSD defendants renew the relief sought in theirmotion for protective order dated July 28, 2000, and for all proper relief. 193567-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 CERTIFICATE OF SERVICE On July :3(, 2000, a copy of the foregoing was served as follows on each of the following: Via Facsimile on: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Via U.S. Mail on: Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown QOM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 193567-v1 2 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 193567-v1 3 i I i I I I i  I  ! JUL-31 -00 MON 07:36 AM FAX NO. t' , Uc'./Uli 5013744187 WALKER ~AW FIRM 909 P02 JU.. 28 100 17 : 15 JOHN W, WALXZll RALPH WASHINGTON MAllX BUllN!TTI SHAWN CHILDS Dr. Gary Smith Superintendent of Schools JOHN W. W~R, P.A. ATrOa.-.lY kr LAw 1723 BIOADWAY J.rrrLI R0CK, AilnNSAS 72206 TELEPHONE (i,01) s7,-S7118 FAX (~01) ~14-4187 Via Fac,imile - 490-0483 July 28, 2000 Pulaski County Special Sehool Dinrict 92S Dbcon :Read Little Rocle, AR 72206 Dear Dr. Smith: RECEIVED JUL 3 1 2000 This request is pursuant to the Arkansas Freedom 0lnfotmation Act. Would you please providl;l i!ll writings (lneoming and outaoins) thai ha-ve talcen pl~ between you, Dr. James Fox, ~ -Billy Bowles, Dr. Ruth Herta, Mr. Gary Miller, Mr. Eddie Collin11 Dr. Jerry Welch, Mr. Jim Johnson, Dr. Don Henderson. Ml. Beverly Williams, Ms. Manha Asti, M$. MttciJ Chapman, Mr. David Hendrix, Ms. Theresa Wallent and anyone else with desegregation responsibility since July 1, 1999, It also includes writing, (incoming and outgoins) of any kind whether they arc rcgardinn peraonnel, student assignment, educational initiative\u0026, tranaporta~on. pay, proposals to the Coun. as well a.e any other mauers. ThiJ req1,mt also includH cmalla and ecmputer files. I would abo like to have access to the notet (incoming and outgoing) of yourself and those of Dr. Fox, Mr. Bowlea, Mt. Collins, Mr. Miller, Dr. Herts, Dr. Weloh, Dr. Henderson, Ms. Williams, Ms. Ast~ Ma, Chapman, Mr. Hendrix, Mr. Johnson and Ms. WaJJent, a.s they relate to the proposals that ha.ve been considered for presentation to the Court or to the school board in reference to the school desesreaation plan. I would ippreciato this infonnation not later than Wednesday, August 2, 2000. Would you also please provide the following: (l) list of applicants for the Director of Secondary Education position; (2) a. copy of the Elomentary/Seconduy School Civil Rights . Compliance Report/Individual School keport: I\u003e 102 from the U.S. Department of :Education/Civil Rights; (3) Minutes of the Steering Committee meetings relli.tive to education plans of Dr. Steven Ross; (4) all numbered memorandums ofth.: above referenced lndividua1s from July J, 1999 to present; (5) e-mail addresses ofalt the abov~ referenced individuals; (6) responses from principal\u0026 to Eddie Collini regardina ms letter ofAl-lS\\'st 2, t 999 regarding Disclplittary Management Plan; (7) Annual Disciplinary Summaey for all schools; (8) Incoming and outgoing type-written and hand-written writing\u0026 of all secret.uies of the above ~fcrenccd indrviduGJ1; (9) resportaes from all parties referenced to in your March 13, ZOOO letter relating to plan ZOOO; ( 1 O) copies of rriemo books from all lndlviduaJ.1 referenced to above; ( 11) a I.QPY of the written report of all annual reviews regarding speci\u0026l ed~tion to Martha Asti; (12) copies of revised elementary and secondary student handbooks; and (12) list ofrecipi,nta (race and EXHIBIT I fi-1 ~ - - - ---- -- ---- --  JUL-31-00 MON 07:37 AM FAX NO. 5013?44187 ~LKER LAW FIRM 909 P03 t', U3/U4 Jl..1... 28 '00 17:1~ sender) who were honored durlOi the SAT lncentivc Award program duritli 1999-2000 school year. Caro CACI JUL-31-00 MON 07:37 AM rAX NU. 501374418? W~R LAW FIRM JOHN W, WALKER, P.~. '311 P02 r', U4/ U'i J\\.L 29 '00 17:43 AT'l'ORNIY AT LAW 1,2s BitOADWAY R Ee E 1v ED L1TJ1,! RoCIC, AluwlsAS 72206 TELEPHONE (601) 874-3758 JOHN W, WALKiR JW..PH WABHlNOTON MARK BURNE'l'Tt SHAWN CHILDS FAX (501) 974-4187 JUL 3 1 2000 Via Facsimile - 490-0433 Dr. Gary Smith Superintendent of Schools Pulaski County Special Sr.boo[ District 91.5 Dixon Road Little Rock. AR 72206 Dear Dr. Smith: July 28. 2000 This request is pursuant to the Arkansas Freedom oflnformation Act. Would you please provide for review, inspection and oopyine the following: 1) a copy of the ADI! TAG Monitoring Repon dated February, 2000; 2) a copy otthe 2000-2001 Student Handbook approved by the Board of Education; 3) all writing, (incomina and outsoine) regar~ing pupil personnel (discipline and student assignments and enrollment) including notes, e-mails, computer files, numbered memorandums, ete. between yourself, Dr. Jam.es Fox, Mr. Bi~y Bowles, Dr, Ruth Herts, Mr. Gary Miller, Mr. Eddie Collins, Dr. Jerry Welch, Ms. Beverly Williams, Ms. Martha Ast~ Ms. Marcia Chapman, Mr. David Hendrix, ~. Theresa Wallent, Mr, Doug Lin.gton, Ms. Georgia Norris, Ms. Ann ____ (Bddie Collins Secretary) or any other person in Pupil Personnel with the responsibility of receiving and/or inputtina pupil persoMel data. Please make this information available by Thursday, Auewt 3, 2000. Sincerely, CACI IN THE UNITED STATES DISTRICT (;OURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION RECEIVED AUG I 2000 LITILE ROCK SCHOOL DISTRICT Off!CEOF DESEGREGATION MONITORING PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of ADE's Project Management Tool for July, 2000. Respectfully Submitted, MARKPRYOR Attorney General Assistant Attom neral 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. IMPLEMENTATION PHASE ACTIVITY . I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of July 31, 2000 B. Include all Magnet students in the resident District's average daily membership for calculation. 1 . Projected Ending Date Last day of each month, August - June.  This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources. "},{"id":"bcas_bcmss0837_1711","title":"Court filings concerning Court approval of administrative reorganization, ODM report, ''Disciplinary Sanctions in the Little Rock School District (LRSD)'', and PCSSD motion to approve modification to student assignment plan","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-06"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Pulaski County Special School District","Office of Desegregation Monitoring (Little Rock, Ark.)","Little Rock School District","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Education--Finance","Education--Economic aspects","Educational law and legislation","Educational planning","School management and organization","School integration","School employees","School administrators","School discipline","Student suspension","School enrollment"],"dcterms_title":["Court filings concerning Court approval of administrative reorganization, ODM report, ''Disciplinary Sanctions in the Little Rock School District (LRSD)'', and PCSSD motion to approve modification to student assignment plan"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1711"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["42 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"District Court, order; District Court, Pulaski County Special School District's (PCSSD's) motion for Court approval of administrative reorganization; District Court, notice of filing, Office of Desegregation Management report, ''Disciplinary Sanctions in the Little Rock School District (LRSD)''; District Court, Pulaski County Special School District (PCSSD) motion to approve modification to student assignment plan; District Court, brief in support of Pulaski County Special School District (PCSSD) motion to modify student assignment plan; District Court, opposition of the Joshua intervenors to Pulaski County Special School District's (PCSSD's) motion for Court approval of administrative reorganization; District Court, supplement to Pulaski County Special School District's (PCSSD's) motion for Court approval of administrative reorganization; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool  The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  IN THE UNITED STATES DISTRICT COURT FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS JUN O 5 2000 EASTERN DISTRICT OF ARKANSAS JAME]W.~McO RMJACK, CLERK WESTERN DMSION By '\\ t l (\\ /\\A V ~  ' - .... ~ DEP filRi\u003c'- LITTLE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * No. LR-C-82-866 * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. I, et al., * Defendants, * * MRS. LORENE JOSHUA, et al., * Intervenors, * * KATHERINE KNIGHT, et al., * lntervenors. * ORDER Before the Court are the proposed budgets for the Office of Desegregation Monitoring for 1999-2000 and 2000-2001.1 Without objection, the Court finds the proposed budgets should be and are hereby approved. -f'l\"-- IT IS SO _ORDERED THIS s._ DAY OF JUNE, 2000 i ~,t~21t C FJUD ' UNITED STATES DISTRICT COURT 1 Docket no. 3361. rHIS DOCUMENT ENTERED ON DOCKET SHEET IN COUPLJ/tN7! WITH RULE 58 AND/OR 79(1) FRCP JH 0~ ~Qp BY zzt\u003e . _ 3. 3 6 4 EDWARD L. WRIGHT (1903-1977) RO BERTS. LINDSEY ( 1913-1991) IS.A.AC A. SC OTT. JR . JOHN G. LILE WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW JOHN 0 . DAVIS JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX . JR , GORDON S. RATHER . JR . TERRY L . MATHEWS OAVIO M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD. JR . PATRICK J. GOSS ALSTON JEN NINGS , JR. JOHN R. TISDALE KA THLYN GRAVES M. SAMUEL JONES 111 JOHN WILLIAM SPIVEY Ill LEE J. MULDROW N.M. NORTON CHAR LES C. PRICE CHARLES T . CO LEMAN JAMES J . GLOVER EDWIN L. LOWTHER. JR. CHARLES L. SCHLUMBERGER WALTER E . MAY GREGORY T . JONES H. KEITH MORRISON BETTINA E. BROWNST EIN WALTER McSPADOEN ROGER 0 . ROWE NANCY BELLHOUSE MAY Mr. John Waiker John Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 RE: PCSSD Dear Counsel and Ms. Brown: 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK. ARKANSAS 72201-3699 (501) 371 -0808 FAX (501) 376 -9442 WE BSITE : www .wl j .com OF COUNSEL ALSTON JENNINGS RONALD A. MAY M. TOCO WOOD Writ er's Di rect Dial No . 501-212 -1 273 m1ones(llwlj .com June 9, 2000 TROY A. PRICE PATRICIA SIEVERS HARRIS JAMES M. MOODY. JR . KATH RYN A. PRYOR J. MARK DAVIS CLAIRE SHOWS HANCOCK KEVtN W. KENN EDY JERRY J . SALLINGS FRED M. PERKINS Ill WILLIAM STUAR T JACKSON MICHAEL 0 . BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM KYLE R. WILSON C. TAO BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J. CHARLES DOUGHERTY M. SEAN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE JANE M. WEISENFELS ROBERT W. GEORGE J . ANDREW VINES JUSTIN T . ALLEN Mr. Christopher Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 RECEIVED Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 JUN 1 2 2000 OFFICE OF DESEGREGATION MONITORING , Enclosed is a copy of PCSSD's Motion for Court Approval of Administrative Reorganization which is being filed today.  MSJ/ao Encl. 182475-v1 Cordially, WRIGHT, LINDSEY \u0026 JENNINGS LLP IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PCSSD's MOTION FOR COURT APPROVAL OF ADMINISTRATIVE REORGANIZATION 1. Attached to this motion as Exhibit A is a Business Case dated June 9, 2000, supporting the combining of the responsibilities of the current offices of desegregation and pupil personnel. The specific reasons prompting and supporting this request are set forth in the Business Case. 2. In 1992, the PCSSD proposed a reorganization that, among other things, would have combined the responsibilities of the Offices of Desegregation and Pupil Personnel. The matter was litigated, but before it became necessai y for the Court to rule, an unexpected infusion of funds permitted the PCSSD to abandon this reorganization at that time. 3. The issue eventually was adjudicated in the context of a request for attorney's fees. In an Order dated December 1, 1992, this Court held that: [t]he Court finds that this reorganization was not so fundamentally in violation of the goals of the settlement plan that the Court would have reversed it. On the other hand, this Court would have permitted this reorganization to go forward with the understanding that the Court would 182441-v1 continue to monitor compliance with the settlement plan and would order a different organizational structure only if the new one proved unsatisfactory. 4. The PCSSD now, of course, operates pursuant to a new plan which does not contain the same rigid administrative hierarchy as the previous plan. 5. The district believes that it would be prudent, among other organizational changes it is making, to now effect the same reorganization that was proposed and evaluated by this Court in 1992. 6. This matter will be presented to the PCSSD Board of Directors on Tuesday, June 13, 2000. The Administration expects that the Board will approve the reorganization. WHEREFORE, the PCSSD prays for an order of this Court approving the reorganization as described herein. 182441-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 By -:-:-~..,,,---:- nes Iii (7 ulaski C t 2 CERTIFICATE OF SERVICE On June 9, 2000, a copy of the foregoing was served by U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 182441-v1 .amueloneslll 3 Pulaski County Special School District Business Case June 9, 2000 Submitted to Judge Susan Weber Wright 1. Executive Summary: Pulaski County Special School District seeks to consolidate the positions of Assistant Superintendent for Pupil Personnel and Assistant Superintendent for Desegregation into one new, blended position entitled Assistant Superintendent for Equity and Pupil Personnel. This administrative change will allow for greater accountability, efficiency of operation, as well as cost savings for the District. 2. Background: . The Assistant Superintendents for Pupil Personnel and for Desegregation will both retire from the District on June 30, 2000. These positions have compatible areas of accountability and responsibility for equity and student affairs . within the District. These positions share an affinity that the District wishes to build on. Streamlining these positions into one area of responsibility will be an efficient way to address the Issues of accountability and equity faced by the District. 3. Problem Statement: Pulaski County Special School District has been experiencing decreasing enrollment, triggering declining State funding levels. Reductions In personnel are being carried out to provide revenue for employee raises in 2000 - 2001. Besides the elimination of fifty-four (54) teaching positions, the Superintendent is proposing eliminating five (5) district office and three (3) assistant principal positions. In his proposed reorganization, he proposes streamlining operations with fewer people and reconfigured job responslbllltles. 4. Alternatives: Since personnel salaries make up over eighty percent (80%) of the operating budget and remaining expenses are largely fixed costs, Increasing salary costs In-a condition of declining revenues leaves two other alternatives, in addition to the proposed action. First, the District could continue current overstaffed parameters and pay for raises out of fund reserves (savings) which amount, at present, to about $8 million. Gradually, the fund reserve would be depleted, causing deficits and leaving the District In a precarious financial state. The second alternative would be to deny employees raises, including experience steps and cost of living adjustments. I EXHIBIT jJ 5. Action Recommended: Because both the Assistant Superintendent for Pupil Personnel and Assistant Superintendent for Desegregation are retiring June 30, 2000, there is a propitious opportunity is being afforded to consolidate the two positions into one new one entitled Assistant Superintendent for Equity and Pupil Personnel. 6. Objective: To reduce one assistant superintendent position and to save $105,000 per year by merging the two divisions. A. Goal Support: The functions of the pupil personnel and desegregation divisions have a clear affinity and significant interface. Attendance zoning, majority -to-minority issues, transfer requests, and minority student and personnel recruitment are major examples. The two connected areas can more effectively produce results to advance the goals of the District and Plan 2000 in a consolidated division. B. Benefits: . Benefits to the District would be in accountability, streamlining, efficiency of operations, reduction of administrative overhead, and the resulting cost savings. 7. Impact: The Impact on District programs will be positive, as the administrative accountability will be more concise. In the same manner, the District's desegregation plan, Plan 2000, will not suffer any negative consequence of this action and will, in fact, also be more efficiently managed. 8. Hesourcec: The two divisions will be merged. Existing personnel will be available as will the financial resources of these divisions. Reconfiguration to afford more productivity and proficient use of resources will be the result. Recurring cost savings of $10~,000 per year will be yielded. 9. Plan for Implementation: The Superintendent will bring his proposal to the Board of Directors at the June 13, 2000 meeting. With the Board's approval and the Court's acceptance, the plan will be Implemented as soon as is expedient. 2 Margie L. Powell Associate Monitor DISCIPLINARY SANCTIONS IN THE LITTLE ROCK SCHOOL DISTRICT June 14, 2000 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Ann S. Brown Federal Monitor PoJly Ramer Office Manager IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION RECEIVED JUN 2 6 ZOOQ OfFICE OF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. DEFENDANTS INTERVENORS INTERVENORS PCSSD MOTION TO APPROVE MODIFICATION TO STUDENT ASSIGNMENT PLAN The PCSSD, for its motion states: 1. The PCSSD proposes to modify certain student assignments within the southeast sector. 2. The proposal is fully explained in the accompanying memorandum brief and the exhibits and business case attached to this motion. WHEREFORE, the PCSSD prays for an Order of this Court approving its proposed modification of student assignments in the southeast sector. Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 .:. By 'i(,1, ~u..d- ~ '~ ~,4.JIJ,., -, 6J,Ju;b_ M. Samuel Jones 1(76060) l'1 16 , '\\ Attorneys for Pulaski County Special 1 'iJ School District 185439-v1 CERTIFICATE OF SERVICE On June 2-3 , 2000, a copy of the foregoing was served by U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 185439-v1 2 SCHOOL CAPACITY INFORMATION PULASKI COUNTY SPECIAL SCHOOL DISTRICT JUNE 30, 1999 - HIGH SCHOOL SCHOOL CAPACITY Jacksonville 1025 Mills 780 North Pulaski 900 Oak Grove Jr./Sr. 935 Robinson 506 Sylvan Hills 998 JUNIOR HIGH SCHOOLS SCHOOL CAPACITY Fuller 945 Jacksonville Middle 800 Jacksonville Junior High 800 Northwood 964 Robinson (2-rooms devided) 486 Alpha Academy 300 Sylvan Hills 925 - ELEMENTARY SCHOOL SCHOOL CAPACITY Adkins 370 Arnold Drive 420 Baker 330 Bates 768 Bayou Mete 660 Cato 576 Clinton 833 College Station 340 Crystal Hill 820 Dupree 465 Fuller 526 Harris 525 Jacksonville 785 Landmark 568 Lawson 325 Oak Grove 476 Oakbrooke 500 Pine Forest 556 Pinewood 523 - Robinson 450 Scott  280 Sherwood 460 EXHIBIT Sylvan Hills 456 TMoullrereslol nT aylor 455700 I 4 OLD BATES White Black Total SALINE CO. STUDENTS White 62 Black 3 153 199 57% 352 LANDMARK White 224 58% Black 163 42% Total 387 OPTION 1 OPTION 2 Landmark Landmark minus minus Wrightsville Wrightsville plus Arch Street White 214 75% White 275 Black 71 25% Black 107 Total 285 Total 382  72% 28% ---- ARCH ST. STUDENTS White 61 -- Black 36 OPTION 3 Landmark minus Wrightsville plus Arch Street \u0026 Saline Co. White 337 75% Slack 110 25% Total 447  -----~~---~-O-L~D ~FU-L-L-E-R~ ----, - ,,,_ Whitt! 161 43% ----- ', --------+-------+----1 ----.,,. .,. Blaclc 217 - - -- Totz,I 378 57% \\ ,,' WRIGHTSVILLE , , ' STUDENTS White 11 Black 92 Total 103 NEW BATES White 314 43% Black 416 57% Total 730 OPTION 1 OPTION 2 :?T!ON 3 New Bates New Bates ~Jaw 3a~=s plus plus J/us Wrightsville Wrightsville .'iriQ ntsiilia minus minus Arch Street ,J..rr;h .3:r;at 3 S8linJ C;:i. White 325 39% White 264 36 \\1'/hite 202 30~',, Black 508 61% Black 472 64% Slack --169 70% Total 833 Tota l 736 Total Oi 1  1. PCSSD BUSINESS CASE FOR MODIFICATION OF STUDENT ASSIGNMENT PLAN JUNE 23, 2000 Executive Summary: The PCSSD seeks to modify certain aspects of its student assignment plan respecting Landmark and new Bates Elementary Schools in the southeast sector to reassign certain students closer to their neighborhoods and to reduce the amount of transportation for those students. The particulars of the reassignment are reflected in Exhibit 8 to the motion, which accompanies this Business Case. 2. Background: Last year this Court approved the construction of the new Bates Elementary School and the transfer of the student bodies from old Bates and Fuller Elementary School to new Bates. Since the Court's decision, and as construction of new Bates has proceeded, interest has increased in the affected communities to effect a reassignmenL of certain students to schools closer to their homes. - 3. Problem Statement: The reassignment proposed projects that new Bates would have an initial student body that would be 70% black and 30% white. At the same time, the proposed reorganization would reduce transportation, assign more students to schools closer to their homes and likely assist the District in reacquiring students who have left the District. The problem, thus, becomes essentially one of a balancing act and selection from among competing priorities. 4. Alternatives: One alternative is to simply retain the status quo and make no reassignment proposals. The alternatives are set forth and explained in Exhibit 8. This action would be detrimental to both children and their parents by requiring larger bus routes. 5. Action Recommended: The impetus for this move has come from the African American Community. Because the District believes that the projected opening enrollment percentages can be ameliorated over time and that the number of students attending schools in the southeast sector could ultimately grow, that the proposed reassignment should be implemented in the interest of children, particularly the black children in Wrightsville who - would otherwise be bused away from their neighborhood school (new Bates). EXHIBIT 185373-v1 I 6. Objective: To accommodate the desires of many in the community to have their students assigned to the closest available elementary school and to reduce transportation without departing unreasonably from the District's student assignment goal. 7. Impact: The reassignment should save the District money in terms of transportation, should promote parental involvement in the schools, should promote additional voluntary transfers and should result in re-attracting students to this area who have previously left the District. 8. Resources: The proposed reassignment should reduce transportation costs in an amount not yet quantified. ;. 9. Plan for Implementation: The District's Board of Directors, on June 15, 2000, approved this rezoning subject to discussions with Joshua and approval by the Court. If approved, the District proposes to implement all aspects of the reassignment for the upcoming 2000-01 school year with the exception of the shift of the arts and music programs from Landmark to new Bates which would not occur until the following school year when the District anticipates it will have implemented the middle school concept district-wide. 2 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 KNIGHT, ET AL. BRIEF IN SUPPORT OF PCSSD MOTION TO MODIFY STUDENT ASSIGNMENT PLAN Introduction 11Ece1:veo -JUN '2' 6 -~ioOb OfflCEOf, ______., i~ \\BEGRESATION 'MONIT-ORINU PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Last year this Court approved the closing of Bates and Fuller Elementary Schools and the transfer of their student bodies to the new Bates Elementary School located off 145 Street, just west of the Community of Wrightsville in the southeast sector of the PCSSD. (Docket #3281 ). As the new Bates School nears completion, pressure has mounted from the community to consider changes in the student assignment pattern for new Bates and Landmark Elementary. Pursuant to a motion proposed by the African American Board Member representing the greater Wrightsville area and virtually all of the southeast sector of the district, the District's Board of Education voted recently to propose certain student assignment rearrangements and to submit those to Joshua and the Court for consideration. The proposed changes, and the reasons for them, are fully explained in the business case (Exhibit \"C\" attached to the motion) and in this memorandum. 184914-v1 Background As part of the territorial exchange ordered in this case, the United States Court of Appeals for the Eighth Circuit ordered the transfer of the Granite Mountain community from the LRSD to the PCSSD. This transfer, together with the transfer of the southwest Little Rock area to the LRSD, created a land-locked, majority black area of the PCSSD which the parties have consistently referred to throughout this litigation as the southeast sector. In the wake of the territorial transfer which left the PCSSD short of elementary seats, the PCSSD acquired the old Timex facility as an emergency measure, converted it to an elementary school, and opened it as Bates Elementary with an enrollment in excess of 800 students. Since that date, the enrollment of \"old\" Bates has dropped to 41t 352 students, of whom 43% are white and 57% are black. During the same time period, the PCSSD has seen the enrollment at Fuller Elementary shrink to 378 students, of whom 161 are white and 217 are black. (Exhibit \"B\" attached to the motion). As previously noted, the Court has approved the transfer of these two student bodies to the new Bates Elementary School. The current capacity of old Bates is 768 students and that of Fuller Elementary is 526 students. (Please see Exhibit \"A\" attached to the motion). Landmark Elementary, with a current capacity of 468 students, had an enrollment last year of 387 students, of whom 224 were white and 163 were black. Of the white enrollees, approximately 51 are white students recruited from north of the river for the school art and music specialty programs. 184914-v1 2 The Proposed Changes As Exhibit \"B\" reflects, there are three areas of student population proposed for reassignment. They are a mostly white area currently assigned to Bates hereafter referred to as the Arch Street students. A group of predominantly white students, heretofore assigned to Fuller, will be referred to as the Saline County students. A group of predominantly black students from the Wrightsville area, and proximate to the new school, will be referred to as the Wrightsville students. They are currently assigned to Landmark. Although it will statistically impact initial racial balance projections, the PCSSD proposes to shift the Saline County and Arch Street students from new Bates to Landmark and to assign the Wrightsville students from Landmark to new Bates. The - initially projected enrollments occasioned by these shifts project Landmark to be 25% black and new Bates to be 70% black. However, for reasons that will be explained hereafter, the District genuinely believes that these percentages can be rather expeditiously improved and that the immediate and proximate impact is to benefit children of both races and reduce unnecessary busing. The Wrightsville Students These students are located, geographically, on the far east side of the southeast sector. Until the early 1990s, these Wrightsville students were all schooled in the neighborhood at J.C. Cook Elementary School. After it burned, the decision was made not to rebuild and these students were shifted to Landmark. If no change is made, the same students will be transported twice daily past the new Bates Elementary School en - route to Landmark. To eliminate this prospect, and to substantially reduce the 184914-v1 3 - transportation burdens on these students, the PCSSD believes it to be educationally sound to reassign these students to new Bates which, in the context of the geography of the PCSSD, would act as a neighborhood school for the Wrightsville students. The Arch Street Students These students are located, geographically, on the west side of the southeast sector. Most of these students attended Baseline Elementary when it was part of the PCSSD. After the territorial shift, they were necessarily reassigned to new Bates. While the assignment to old Bates did not create a substantial transportation burden for these students, their continued assignment to new Bates would. Because this group o( students largely mirrors the racial composition of the PCSSD as a whole, and because :::.. their assignment to Landmark would represent a somewhat reduced transportation obligation for them, the PCSSD believes it to be educationally sound for these students to be assigned to Landmark Elementary. The Saline County Students These students are located, geographically, on the far west side of the southeast sector. Prior to the desegregation plan, these students were assigned to Landmark Elementary as their closest school. In an effort to racially balance Fuller Elementary, these students were reassigned during the late 1980s to Fuller Elementary School, a considerable distance from their homes. To partially replace the Wrightsville students proposed for reassignment to new Bates, to reduce the transportation obligation for the Saline County students, who would otherwise be bused from the west to the east side of the sector, and to hopefully recoup some of the student losses that the District has 184914-v1 4 experienced from the Saline County area, the PCSSD believes it to be educationally sound to transfer the Saline County students from new Bates to Landmark. The Landmark Specialty Students The PCSSD is also seeking permission to shift the art and music specialty program from Landmark to new Bates for the 2001-2002 school year. Even without the specialty students, Landmark is projected to be comfortably within the student assignment ratios for the PCSSD. The PCSSD further believes that new Bates would prove an attractive alternative to the specialty students since it would provide a shorter and more convenient transportation trip and would house the specialty students in a brand new school. All of these specialty students are white. Their transfer to new Bates would significantly reduce the initially projected minority enrollment at the school and, over time, the PCSSD believes that the transfer of the program would increase the number of white transfer students electing to attend the school, thereby annually moving new Bates closer to its ultimate racial balance goals. Because the sixth graders will be at the new Bates for the 2000-2001 year until the sixth grade is shifted to what will be Fuller Middle in 2001-2002, the transfer of the specialty program needs to be delayed until space opens up. By delaying the movement of this program until 2001-2002, the PCSSD should have ample time to educate and persuade the specialty students and their parents that movement of the specialty program to new Bates is a sound educational move. 184914-v1 5 The Long Term As this court is aware, the PCSSD proposes to shift to a middle school structure district wide beginning with the 2001-2002 school year. Little Rock has already completed this reorganization and the Court has previously approved the middle school concept in PCSSD's Jacksonville area. (Docket #2647). The PCSSD believes that the middle school concept, combined with the shifting of the Saline County students to Landmark and the reconstitution of the art and music specialty program at new Bates, will ultimately result in an increased white enrollment in these southeast sector schools. Except for the middle school concept, nothing about the current proposal will modify the feeder pattern to Fuller Junior High School and Mills High School. Neither will any of the proposals contained, herein, affect the current student assignment effort at College Station Elementary. It is also worth mentioning that the shift of the Fuller Elementary student body to new Bates will bring with it the string orchestra specialty program currently provided at Fuller Elementary. The PCSSD believes that the reconstitution of the art and music program from Landmark at new Bates, combined with the move of the string orchestra program from Fuller Elementary to new Bates, and the institution of a full-time physical education curriculum, will work a synergy making these programs even more attractive to white students from north of the Arkansas River since those interested in music in all of its dimensions will have more opportunities for this experience at new Bates if the PCSSD proposal is approved. 184914-v1 6 For all the foregoing reasons, PCSSD prays for an order of this Court approving its motion to modify student assignment plan. 184914-v1 Respectfully submitted, WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 By V . J~~ 'f:f i-~6..J, ~ M. Samuel Jones 7(i666oj ( q7( 5\u003c-J) Attorneys for Pulaski County Special School District 7 CERTIFICATE OF SERVICE On JuneZ..3 , 2000, a copy of the foregoing was served by U.S. mail on each of the following: Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Richard W. Roachell Roachell and Street First Federal Plaza 401 West Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 184914-v1 8 - -- REC.EIV~D bJi__;--:[) EAST~ffN ~if ~,hl ~~~~SAS JUN 2 J 2000 JAMES 'N. McCGRMACK, LERK By: _____ _,,D.,...E\"\"P-,-.C\"LE-.-RroK JUN 2 8 2000 OFFICE OF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V CASE NO. 82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PLAINTIFF DEFENDANT INTER VENO RS INTER VENO RS OPPOSITION OF THE JOSHUA INTERVENORS TO PCSSD'S MOTION FOR COURT APPROVAL OF ADMINISTRATIVE REORGANIZATION The Joshua Intervenors oppose the defendants' motion. First, there were no discussions as contemplated by the desegregation plan between the parties prior to this matter having been presented to the Court. See Letter from Mr. Jones to the Court dated May 24, 2000 as Exhibit A; Letter to the Court from undersigned Counsel dated June 12, 2000 as Exhibit B. Second, there is no brief attached to the motion as required by the local rules. Third, the business case does not address desegregation issues nor does it address how the changes will effectuate the desegregation commitments of the revised desegregation plan. Fourth, the business case is one which purports to save the school district money and nothing else. It does not address the desegregation staff nor define the work duties and responsibilities of those individuals. There is not a proposed job description of the new position that has been shared with Joshua. Indeed, there are myriad problems that should have been considered in the normal course of addressing desegregation issues that have not been addresse\u0026' by the proposal. These matters could have been dealt with as contemplated by the desegregation plan had the administration not sought to evade the Joshua Intervenors and had they not sought to denigrate Joshua's role in the desegregation process. Fifth, the Superintendent for Desegregation had a responsibility in the past for oversight of the Pupil Personnel Department and other departments, at least to the extent of identification of potential problems, which impeded desegregation and to make recommendations to the Superintendent directly. The current proposal is unclear, at the least, about what the duties of the position are or will be in the future. Sixth, the combination of the two positions will mean the elimination of two black - administrators from the major administrative hierarchy of the District. There is no reference to the process that the District will use to fill positions and it was, therefore, highly suspect that the District will fill the two vacated positions with white administrators who have already been selected. Seventh, to this date. Neither the Superintendent nor his major administrator, Dr. James Fox, have had any meetings whatsoever with counsel for Joshua Intervenors regarding any issue. As stated earlier, it is Joshua's opinion that they are uninformed and uncertain to the desegregation initiatives and commitments that have been in place in the District for years. (See Joshua's previous brief to the Court regarding the District's Motion to Approve Revised Desegregation Plan). Because of the uncertainties of the Defendants' proposal and how it will impact desegregation, and because Defendants' by p "},{"id":"bcas_bcmss0837_1706","title":"Court filings: District Court, two orders; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-05"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Educational law and legislation","School integration","Magnet schools","Education and state","School districts","Education--Finance","Education--Economic aspects","Educational statistics","School enrollment"],"dcterms_title":["Court filings: District Court, two orders; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1706"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["129 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  IN THE UNITED STA TES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS MAY 12 2000 LITTLE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. I, et al., Defendants, MRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors. * * * * * * * * ORDER No. LR-C-82-866 ED MAY 1 5 2000 OftlCE OF DESEGREGATION MONITORING The Arkansas Department of Education (\"ADE\") filed a motion seeking approval of a revised monitoring plan [ docket no. 3327]. The Little Rock School District (\"LRSD\") and the Joshua Intervenors (\"Joshua\") responded in opposition [docket nos. 3340 \u0026 3334], and ADE replied [docket no. 3350]. After careful consideration, the Court determines ADE's motion should be denied. I. The parties' settlement agreement, Part ill.A., in pertinent part, states: The State shall be required (as a non-party) to monitor, through the ADE, the implementation of compensatory education programs by the Districts. . . . Monitoring by the State shall be independent of that of the other parties. It is being done to ensure that the state will have a continuing role in satisfactorily remediating achievement disparities. Any recommendations made by ADE shall not form the basis of any additional funding responsibilities of the State. A State plan for monitoring implementation of compensatory education will be submitted to the parties within 60 days following the execution of the settlement agreement. In 1989, Mr. H. William Allen, on behalf of ADE, submitted the monitoring plan referenced in Part ill.A above. Since then, the parties have referred to the monitoring plan as the \"Allen Letter.\" ADE moves this Court to replace the Allen Letter with a revised monitoring  plan, entitled the Desegregation Monitoring and Assistance Plan (\"DMAP\"). II. Regarding the State's obligations under the Allen Letter, this Court stated: This plan goes beyond monitoring compensatory education in the three Pulaski County school districts and includes many more areas which ADE promised to extensively monitor and evaluate, including magnet schools, M-to-M transfers, and magnet school transportation. Likewise, the settlement agreement includes other obligations undertaken by ADE in addition to its financial agreement with the parties and, in its monitoring plan, ADE reaffirmed its commitment to undertake extensive monitoring that would fulfill those obligations. ADE never changed its monitoring plan or moved to change the settlement agreement. Therefore, the obligations contained in these two documents [the settlement agreement and monitoring plan] are the obligations to which ADE has committed. 1 Thus the Allen letter contains substantive terms of a consent decree, which relate to the vindication of constitutional rights. Disputed modifications of such terms are governed by a stricter standard than agreed-to modifications. See Appeal of Little Rock Sch. Dist., 949 F.2d 253, 258 (1991). When parties to a consent decree oppose modification, the moving party must show that (1) a significant change in fact or law warrants revision and (2) the proposed modification is tailored to resolve the problems created by the change in circumstances. Rufo v. Inmates of Suffolk County Jail, 112 S.Ct. 748, 765 (1992). ADE makes four points in support ofDMAP. First, ADE notes that since 1989, the 1 Docket no. 2045, page 2. 2 I I I I I - Court has withdrawn supervision over various portions of the Districts' desegregation plans, and LRSD and PCSSD have revised their plans. While changes in the Districts' desegregation plans may warrant revision of the Allen Letter, ADE fails to explain how it has addressed those changes with the proposed revised monitoring plan. Second, ADE maintains its revisions are needed because \"one of the major reasons the State agreed to extensively monitor the Districts was that the Districts were scheduled to receive millions of dollars ... for 'compensatory education' programs ... [and] those additional funds are no longer being provided to the Districts.\"2 ADE does not specify how DMAP responds to the cessation of state funding for compensatory education. Furthermore, the Court can find no provisions contained in the Allen Letter delineating specific monitoring and reporting obligations related solely to compensatory education funding.3 Third, ADE states that when the State submitted the Allen Letter, the Eighth Circuit had yet to establish the Office of Desegregation Monitoring (\"ODM\"),4 but ADE fails to explain how the proposed plan is tailored to resolve any issues related to ODM monitoring. 2 Docket no. 3328, page 2. 3 The Allen Letter states: The primary focus of the process shall be a continuous assessment of the remedial effectiveness of programs supported partially or fully by special state funding resulting from Little Rock School District v. Pulaski County Special School District, et al., No. LR-C-82-866. The programs and services receiving special funding include: 1. Compensatory Education 2. Magnet Schools 3. Magnet School Transportation 4. Majority to Minority Transfers 4 ADE does not contend that ODM monitoring supplants ADE's monitoring obligations. 3 Fourth, ADE emphasizes that the parties have expressed a need for more focused monitoring and assistance from ADE than called for in the Allen Letter and that ADE consulted the parties and ODM in developing the revised monitoring plan. However, two parties, LRSD and Joshua, oppose approval of the revised plan. The Court acknowledges that changed circumstances may warrant revision of ADE's monitoring plan but finds that ADE has failed to demonstrate that DMAP is tailored to address the changed circumstances. Consequently, the Court must deny ADE's motion. m. Joshua opposes approval ofDMAP on grounds the plan is vaguely worded. Additionally, Joshua asserts the proposed plan would duplicate reporting functions already carried out by ODM and the Districts5 and contends ADE should assist the Districts in a \"hands on manner.\"6 According to LRSD, ADE's current monitoring reports consist of reformatted data, originally provided to ADE by LRSD. The District argues that ODM provides sufficient, independent monitoring, rendering ADE's monitoring and reporting activities superfluous. LRSD understands the original objectives of ADE monitoring to be (1) ensuring fiscal accountability to the tax payers of Arkansas (in light of the State's obligation to fund compensatory education programs) and (2) involving the State in improving achievement disparities. Because State funding for compensatory education has ceased, LRSD contends State's role \"should shift from one of monitoring to one of active participation in the district's 5 The Court notes that Part ill.A of the settlement agreement states, \"Monitoring by the State shall be independent of that of the other parties.\" 6 Docket no. 3334. 4 efforts to eliminate the achievement disparity.\"7 LRSD concludes this Court should require a meeting between ADE and LRSD for the purpose ofreaching an agreement regarding the State's role in eliminating achievement disparities. Additionally, LRSD proposes that the Court modify the parties' settlement agreement to increase the financial obligations of the State. Specifically, LRSD requests the State pay for the cost of ODM for the current year and future years and provide the Districts additional resources in the form of personnel or funding equivalent to resources ADE planned to devote to DMAP. This Court remains mindful that \"we are dealing with a settlement\"8 and disagrees that the absence of state funding for compensatory education should shift the State's monitoring role to one of active participation in eliminating achievement disparities. As previously explained, the Allen Letter \"goes beyond monitoring compensatory education ... and includes many more areas which ADE promised to extensively monitor and evaluate, including magnet schools, Mto- M transfers, and magnet school transportation.\"9 Nor does the Court find that increasing the State's financial obligations will resolve problems related to the State's monitoring obligations. A consent decree is a final judgment that  may be reopened only to the extent that equity requires, and this Court finds that the record before the Court does not justify increasing the State's financial obligations. See Rufo, 112 S.Ct. 7 Docket 3340, 16. 8 Little Rock School Dist. v. Pulaski County Special School District, 921 F.2d 1371, 1390 (8th Cir. 1990). 9 Id. 5 - at 764 (\"Once a court has determined that changed circumstances warrant a modification in a consent decree, the focus should be on whether the proposed modification is tailored to resolve the problems created by the change in circumstances. A court should do no more, for a consent decree is a final judgment that may be reopened only to the extent that equity requires.\"). As for requiring ADE to negotiate with LRSD, this Court strongly encourages the parties to proceed diligently with negotiations regarding ADE's monitoring obligations, but declines ordering such negotiations at this time. If the parties are unable to reach an agreementregarding the State's monitoring role, upon proper motion, the Court will hold hearings on the matter and take action necessary to ensure the State's monitoring obligations are carried out efficiently and effectively. IV. For the reasons stated, it is hereby ordered that ADE' s motion for approval of a revised monitoring plan be DENIED [docket no. 3327]. IT IS so ORDERED nns J)l)A Y OF MAY, 2000 UNITED STATES DISTRICT COURT rH1S OOCUMENT ENTERED ON DOCKET SHEET IN COUPS. ,E Wl:?;1 RULE 5e ANn 79(~ FRCP ON  (,h/JQ !Y '- - 6 MAY 18 2000 tlfiCEOF 9f-5E6RE6Allll IIJ!l10RIII IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTI.,E ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * No. LR-C-82-866 * PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * * MRS. LORENE JOSHUA, et al., * Intervenors, * * KATIIERINE KNIGHT, et al., * Intervenors. * ORDER FILED EAsTMRsriio1sTR1cr COURT DISTRICT ARKANSAS MAY 16 2000 The Court has received the proposed 1999-2000 and 2000-2001 budgets for the Office of Desegregation Monitoring. The budgets and a cover letter are attached to this Order for the parties' review. Parties have to and including fifteen days from entry of this Order to file objections regarding the proposed budgets. IT IS SO ORDERED THIS _/L~ AY OF MAY, 2000 UNITED STATES DISTRICT COURT rH1S OOCUMENT ENTERED ON DOCKET SHEET IN_ COUPLWiE WITH RULE 58 AH~a) FRCP , ON 5=:- J '7- o-v ev ________ .!!:L .   Office of Desegregation Monitoring United States District Court  Eastern District of Arkansas Ann S. Brown, Federal Monitor April 20, 2000 The Honorable Susan Webber Wright U.S. District Court, Eastern District of Arkansas Little Rock, AR 72201 Dear Judge Wright: 201 East Markham, Suite 510 Heritage West Building Little Rock, Arkansas 72201 (501) 376~200 Fax (501) 371--0100 ODM budgets for two years, 1999-00 and 2000-01, are attached for the parties' review and your approval. Because one of the school districts did not furnish us a final October 1 student enrollment count (upon which we base the apportionment of charges to the districts) until last month, we are issuing the current-year budget late in the year. By accompanying it with next year's budget as well, we begin a new practice that will enable us to issue our annual budgets in advance of the new fiscal year . From now on, we will propose our budget for the upcoming year before the close of the current fiscal year, using an estimated total for revenue and expenditures, along with the current-year enrollment numbers (which we use as the basis for the portion each district contributes to the ODM budget). Then, when we know actual revenues and expenditures and the new October 1 enrollment numbers, we will adjust each district's contribution accordingly. The format of the budgets follows that of previous budget documents, including annotation to explain revenue calculations; budget category definitions; and budget allocations and anticipated expenditures by category for 1999-00 and 2000-01 . Note that the 1999-00 budget is only 1. 7 6% higher than that of the previous year, and that the 2000-01 budget is a 2.53% increase over that of the previous year. Salary increases for ODM staff are 3.29% per year, which is the prevailing annual experience step increase on the salary scales of the three local districts. We have continued to contain our expenditures such that they are below the projected annual budget at year's end. As is our practice, we credit that difference proportionately to each of the school districts according to their pro-rated contributions to our budget, a return that averages over 12%. If you or the parties should need any additional information, I will be happy to provide it. Sincerely yours, . ~~ Ann S. Brown Enc.    OFFICE OF DESEGREGATION MONITORING: BUDGETS FOR 1999-00 AND 2000-01 REVENUE State of Arkansas LRSD Credit* NLRSD Credit* PCSSD Credit* Interest  1998-99 BUDGET 200,000.00 219,128.14 37,714.98 81 ,227.78 13,929.95 169,293.99 30,344.16 0.00 1998-99 1999-00 1999-00 2000-01 ACTUAL BUDGET ESTIMATED BUDGET 200,000.00 200,000.00 200,000.00 200,000.00 219,128.14 232,137.33 232,137.33 244,131.66 37,714.98 36,967.69 36,967.69 34,175.51 81 ,227.78 82,836.58 82,836.58 87,116.67 13,929.95 13,191.66 13,191.66 12,195.29 169,293.99 172,300.09 172,300.09 181 ,202.67 30,344.16 27,438.65 27,438.65 25,366.20 8,788.39 0.00 5,407.00 0.00  !zje~jtz~~i 1 :: z:i: ;,ijz-- t;,1:  :.-1.-.-.,:-:;!:;:::::::t:::::t i;,ee : i ij1n1;19  Every budget cycle, ODM credits each district a pro rata proportion of the unspent amount of the previous year's budget. We apply this amount toward the curr~nt budget allocation. See annotated budget. EXPENDITURES 1998-99 1998-99 1999-00 1999-00 2000-01 BUDGET ACTUAL BUDGET ESTIMATED BUDGET Communications 9,180.00 9,157.28 10,000.00 9,832.00 10,000.00 Dues and Fees 3,300.00 3,320.67 3,850.00 3,827.00 4,000.00 Equipment 6,339.00 6,337.94 3,000.00 1,905.00 3,000.00 Food Services 200.00 93.17 200.00 133.00 200.00 Management Services 1,500.00 0.00 1,500.00 0.00 1,500.00 Periodicals 400.00 334.97 450.00 436.00 450.00 Printing and Binding 6,000.00 4,625.75 6,000.00 4,606.00 6,000.00 Prof. and Tech. Services 26,497.00 6,207.50 26,497.00 1,847.00 26,497.00 Rent 50,917.00 50,916.67 51,935.00 51,935.00 52,890.00 Repairs and Maintenance 1,500.00 720.37 1,200.00 627.00 1,000.00 Resource Library 500.00 28.40 250.00 0.00 200.00 Salaries 492,614.00 474,173.79 508,159.00 482,159.00 523,937.00 Benefits 125,122.00 103,788.82 124,431.00 116,009.96 127,114.00 Staff Development 1,000.00 500.00 1,000.00 1,025.00 1,000.00 Supplies 7,750.00 7,713.27 7,750.00 7,729.00 7,750.00 Travel 18,000.00 14,090.83 18,000.00 15,825.00 18,000.00 Insurance 820.00 820.00 650.00 646.00 650.00  LRSD ANNOTATED ODM BUDGETS FOR 1999-00 AND 2000-01 REVENUE The Court's Interim Order of June 27, 1989 required that: ... [T]he amount previously ordered for the Pulaski County Educational Cooperative (Co-op) [$200,000.00] shall be applied toward the budget of the office of the Metropolitan Supervisor ... The balance of the budget will be apportioned among the school districts on a per pupil basis ... Eighth Circuit Order of December 12, 1990: ... [T]he office previously known as the Office of the Metropolitan Supervisor will be reconstituted as the Office of Desegregation Monitoring...  10/1/99 o/o of Total 1999-00 Enrollment Enrollment Budget Allocation 1998-99 Credit (Budget not spent) 1999-00 Budget Payment 2000-01 Budget Allocation 25,116 47.64 269,105.02 36,967.69 232,137.33 278,307.16 1999-00 Estimated Credit* (Budget not spent) 34,175.51 NLRSD 8,960 17.00 96,028.24 13,191 .66 82,836.58 99,311.96 12,195.29 2000-01 Estimated Budget Payment* 244,131.66 87,116.67  PCSSD 18,638 35.36 199,738.74 27,438.65 172,300.09 206,568.88 25,366.20 181,202.67  State of AR N/A NIA 200,000.00 NIA 200,000.00 200,000.00 NIA 200,000.00 - ::::i::i:1~w11i;::::::::i::::::i11~l~i1:1 :111111:.11: 1JFt,1iij;,i:i1 ::iiji~iii;qg:: :z~1i11:.1g} ::::::i1~iifi  :11,iil1~11 *Because the 2000-01 budget has been prepared before the close of the 1999-00 fiscal year, we have estimated the 1999-00 credits to the districts and the 2000-01 payments due from the districts. After the close of the current fiscal year, we will notify each district of the exact amount due for their share of ODM's 2000-01 budget, incorporating each district's exact credit. Also, adjustments in the apportioned payments for each district in 2000-01 will be made to correspond with the October 1, 2000 enrollment count. Descnbed below is the step-by-step process, reflected in the charts above, that we used to determine each district's contnbution to ODM's budgets: 1. The State of Arkansas' contribution ($200,000.00) is subtracted from ODM's total budget. 2. Based on the previous year's October 1 enrollment, the districts are charged their pro rata share of ODM's budget (minus the state's contnbution). 3. Each district is credited with its pro rata share (or estimated share) of ODM's unspent budget for the previous year. 4. Each district contnbutes that sum to ODM's budget or, if the credit has been estimated, each district will be notified at the close of the current fiscal year of the exact amount due for their share ofODM's budget.    EXPENDITURES Note: Definitions of expense categories are based on the Arkansas School Financial Accounting Manual. Communications: Services provided by persons or businesses to assist in transmitting and receiving messages or information. This category includes telephone services as well as postage machine rental and postage. 1998-99 Budget 9,180.00 1998-99 Expenditures 1999-00 Estimated Expenditures The budget increase accommodates the rising costs of postage and basic services for various communications, such as telephone and internet. Dues and Fees: Expenditures or assessment for membership in professional or other organizations or associations or payments to a paying agent for services provided, such as conference registration fees. 1998-99 Budget 3,300.00 1998-99 Expenditures 3,320.67 1999-00 Estimated Expenditures 3,827.00 The budget increase gives more staff members the opportunity to participate in regional and national conferences. Equipment: Expenditures for the initial, additionai and replacement items or equipment, such as furniture and machinery. 1998-99 Budget 6,339.00 1998-99 Expenditures 1999-00 Estimated Expenditures During 1999-00, we will replace a laser printer, color printer, scanner, and printing server and hub; during 2000-01, we will upgrade two computers.    Food Services: Expenditures for food or preparation and serving of food, which may include catering. 1998-99 Budget 200.00 1998-99 Expenditures 93.17 1999-00 Estimated Expenditures 133.00 Management Services: Services performed by persons qualified to assist management either in the broad policy area or in general operations. This category includes consultants, individually or as a team, to assist the chief executive in conference or through systematic studies. 1998-99 Budget 1,500.00 1998-99 Expenditures 0.00 1999-00 Estimated Expenditures 0.00 Periodicals: Expenditures for periodicals and newspapers for general use. A periodical is any publication appearing at regular intervals ofless than a year and continuing for an indefinite period. 1998-99 Budget 400.00 1998-99 Expenditures 334.97 1999-00 Estimated Expenditures 436.00 Printing and Binding: Expenditures for job printing and binding, usually according to specifications. This includes the design and printing of forms as well as printing and binding publications. 1998-99 Budget 6,000.00 1998-99 Expenditures 1999-00 Estimated Expenditures We are able to contain the cost of this budget category by doing most printing inhouse.    Professional and Technical Services: Services which by their nature can be performed only by persons with specialized skills and knowledge. 1998-99 Budget 26,497.00 1998-99 Expenditures 6,207.50 Mansas Financial Services Temporary help/specialized services 1999-00 Estimated Expenditures 23,497.00 3,000.00 26,497.00 To date, ODM has not needed Arkansas Financial Services (AFS) to complete the terms of a previous agreement. However, because services ultimately may be required, we are electing to maintain the AFS agreement and, thus, have budgeted an allotment for AFS. Rent: Expenditures for leasing or renting land and buildings for both temporary and long-range use. 1998-99 Budget 50,917.00 1998-99 Expenditures 1999-00 Estimated Expenditures Per our lease agreement, the 1999-2000 and 2000-0 l budgets reflect a 2% per year increase in rent. Repairs and Maintenance: Expenditures for repairs and maintenance services which restore equipment to its original state or are a part of a routine preventive maintenance program. This includes service contracts and contractual agreements covering the maintenance and operation of equipment and equipment systems. 1998-99 Budget 1,500.00 1998-99 Expenditures 720.37 1999-00 Estimated [!ti\u0026 IJ i.i~Jii Expenditures 627.00 Resource Libr~ry: Expenditures for regular or incidental purchases of library books available for general use. 1998-99 Budget 500.00 1998-99 Expenditures 28.40 1999-00 Estimated Expenditures    Salaries: Salaries are the amounts paid to employees who are considered to be in positions of a permanent or temporary nature. 1998-99 Budget 492,614.00 1998-99 Expenditures 1999-00 Estimated Expenditures Salary changes between 1998-99 and 1999-00, as well as between 1999-00 and 2000-01 , reflect a 3.29% increase, which is comparable to the annual step increase in the three Pulaski County school districts. Salaries: Name of Employaa 1998-99 Salary 1999-00 Salary 2000-01 Salary Ann Brown 104,164.00 107,591 .00' 111 ,131 .00 Melissa Guldin 2 48,533.00 50,130.00 51 ,779.00 Gene Jones 3 50,858.00 52,724.00 54,373.00 Norman Marshall 60,666.00 62,662.00 64,724.00 MaroiePowell 60,666.00 62,662.00 64,724.00 Horace Smith 60,666.00 62,662.00 64,724.00 Research Associate4 26,000.00 26,000.00 26,000.00 Pollv Ramer 45,537.00 47,035.00 48,582.00 Linda Brvant 25,252.00 26,083.00 26,941 .00 Jackie Banks5 10,272.00 10,610.00 10,959.00 Ill ;;, ::: 1I::::Illlilt1il I tt:iiroaasttM @ iitti s2a~ Jon 1Ann Brown's last salary increase was in 1993-94. 2Melissa Guldin works 4/5 time. 3Gene Jones works 4/5 time. Mr. Jones elected to receive payment for annual insurance premiums in lieu of the insurance benefits; his salary reflects that decision. 4Position not filled. 5Jackie Banks works 3/5 time .    Benefits: Benefits are the amounts paid in behalf of employees and not included in the gross salary, but are over and above. Such payments are fringe benefit payments. 1998-99 Budget 125,122.00 1998-99 Expenditures 1999-00 Estimated Expenditures 116,009.96 Below is a breakdown by category of each emoloyee's 1999-00 budgeted fringe benefits: Name Travel Social Retire- Hospital- Life Dental Hospital Allowance Security ment lzatlon Ins. Indemnity Brown 1,800.00 6,310.57 13,126.92 2,233.60 44.16 192.54 60.96 Guldin 1,200.00 3,926.75 6,159.60 2,233.60 44.16 192.54 60.96 Jones 960.00 4,106.83 0.00 0.00 0.00 0.00 0.00 Marshall 1,200.00 4,885.44 7,663.44 2,233.60 44.16 192.54 60.96 Powell 1,200.00 4,885.44 7,663.44 2,233.60 44.16 192.54 60.96 Smith 1,200.00 4,885.44 7,663.44 2,233.60 44.16 192.54 60.96 Research 600.00 2,034.90 3,192.00 2,233.60 44.16 192.54 60.96 Ramer 0.00 3,598.18 5,644.20 2,233.60 44.16 192.54 60.96 0.00 1,995.35 3,129.96 2,233.60 27.60 192.54 60.96 Banks 0.00 811 .67 1,273.20 2,233.60 27.60 192.54 60.96 Short Total Term Benefits 62.88 23,831.63 62.88 13,880.49 0.00 5,066.83 62.88 16,343.02 62.88 16,343.02 62.88 16,343.02 62.88 8,421 .04 62.88 11,836.52 62.88 7,702.89 62.88 4,662.45 ,,, :::::::::::::: ::1aB:I I wii~il  :ooij1i;m  Muir :ati3afoiE i::::::::::::::::::::,:::,:-:-:- :,:,:,:,:=?:::=,}?:,:,:::,:}:,;;:,;;:/: --:-::::::::: ::rn: oo.g112  Below is a breakdown by category of each employee's 2000-01 budgeted fringe benefits: Name Travel Social Retire- Hospital- Life Dental Hospital Short Total Allowance Security ment lzatlon Ins. Indemnity Term Benefits Brown 1,800.00 6,361 .90 13,551.72 2,233.60 44.16 192.54 60.96 62.88 24,307.76 Guldin 1,200.00 4,052.89 6,357.48 2,233.60 44.16 192.54 60.96 62.88 14,204.51 Jones 960.00 4,232.97 0.00 0.00 0.00 0.00 0.00 0.00 5,192.97 Marshall 1,200.00 5,043.19 7,910.88 2,233.60 44.16 192.54 60.96 62.88 16,748.21 Powell 1,200.00 5,043.19 7,910.88 2,233.60 44.16 192.54 60.96 62.88 16,748.21 Smith 1,200.00 5,043.19 7,910.88 2 233.60 44.16 192.54 60.96 62.88 16,748.21 Research 600.00 2,034.90 3,192.00 2,233.60 44.16 192.54 60.96 62.88 8,421 .04 Ramer 0.00 3,716.52 5,829.84 2,233.60 44.16 192.54 60.96 62.88 12,140.50 Bryant 0.00 2,060.99 3,232.92 2,233.60 27.60 192.54 60.96 62.88 7,871 .49 0.00 838.36 1 315.08 2,233.60 27.60 192.54 60.96 62.88 4,731 .02    Staff Development: Services performed by persons qualified to assist in enhancing the quality of the operation. 1998-99 Budget 1,000.00 1998-99 Expenditures 500.00 1999-00 Estimated Expenditures 1,025.00 Supplies: Expenditures for all supplies for the operation, including freight and cartage. Amounts paid for material items of an expendable nature that are consumed, worn out, or deteriorated in use or items that lose their identity through fabrication or incorporation into different or more complex units or substances. 1998-99 Budget 7,750.00 1998-99 Expenditures 7,713.27 1999-00 Estimated 1!:ii~-~~Ufgiltf/:] Expenditures 7,729.00 Travel: Expenditures for transportation, meals, hotel, and other expenses associated with traveling or business. Payments for per diem in lieu of reimbursements for subsistence (room and board) also are charged here. 1998-99 Budget 18,000.00 1998-99 Expenditures 14,090.83 1999-00 Estimated Expenditures 15,825.00 Insurance: Expenditures for all types of insurance coverage such as property, liability, fidelity, as well as the costs of judgments. 1998-99 Budget 820.00 1998-99 Expenditures 820.00 1999-00 Estimated Expenditures 646.00 RECEIVED IN THE UNITED STATES DISTRICT COURT / E~ASTERN DISTRICT OF ARKANSAS JUN 2 2000 Off\\GEOf t\u0026GRfGAllON MONITORING  WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. NOTICE OF FILING PLAINTIFF DEFENDANTS In accordance with the Court's order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of AD E's Project Management Tool for May, 2000 .  ' _j\\ffr/ . :~/ .-.:~. Respectfully Submitted, MARK PRYOR Attorney General Assistant Attorney eral 323 Center Street, uite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KA THERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. IMPLEMENTATION PHASE ACTIVITY I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each morith, August - June. 2. Actual as of May 31, 2000 B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June.  This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources. "},{"id":"bcas_bcmss0837_1117","title":"Motion to Substitute A Complete Copy of Little Rock School District's (LRSD'S) Interim Compliance Report","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["2000-04-18"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","Education--Arkansas","Education--Evaluation","Educational law and legislation","School integration"],"dcterms_title":["Motion to Substitute A Complete Copy of Little Rock School District's (LRSD'S) Interim Compliance Report"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1117"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["98 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nIncludes correspondence, vitas for Terrence J. Roberts and Steven M. Ross\nThe transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.\nIN 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 MOTION TO SUBSTITUTE A COMPLETE COPY OF LRSD'S INTERIM COMPLIANCE REPORT Rf C iE_j ~ ~i.li APR 19 1000 PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The Little Rock School District (LRSD) for its Motion to Substitute A Complete Copy of LRSD's Interim Compliance Report states: 1. On March 15, 2000, LRSD filed its Interim Compliance Report outlining the programs, policies and procedures implemented in accordance with LRSD's Revised Desegregation and Education Plan. 2. Since that time, it has come to LRSD's attention that attachments 1 through 4 of the Interim Compliance Report were inadvertently omitted from the report during printing. 3. A complete copy of the report, including attachments 1 through 4, are attached to this Motion. LRSD respectfully requests that this report be substituted for the one filed March 15, 2000. WHEREFORE, LRSD prays that the complete copy of LRSD's Interim Compliance Report attached hereto be substituted for the one filed March 15, 2000. Otfiee of Desegregation Monitoring ALECOPY Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026amp; CLARK First Commercial Bldg., Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376-2011 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on this 18th day of April, 2000. Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, AR 72222 Ms. Ann Brown - HAND DELIVERED Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 3 FRIDAY, ELDREDGE \u0026amp; CLARK HERSCHEL H. FRIDAY (1922-1994) WILLIAM H. SUTTON, P.A. BYRON M. EISEMAN, JR., P.A. JOE D. BELL, P.A. JAMES A. BUTTRY, P.A. FREDERICKS. URSERY, 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 Ill, 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. JAMES M. SAXTON, P.A . J , SHEPHERD RUSSELL Ill, P.A . DONALD H. BACON, P.A. WILLIAM THOMAS BAXTER, P.A. BARRY E. COPLIN, P.A . RICHARD D. TAYLOR, PA. JOSEPH B. HURST, JR., PA. ELIZABETH ROBBEN MURRAY, PA. CHRISTOPHER HELLER, PA. LAURA HENSLEY SMITH, P.A. ROBERTS. SHAFER, P.A. WILLIAM M. GRIFFIN Ill, P.A. MICHAELS. MOORE, P.A. DIANE S. MACKEY, P.A . WALTER M. EBEL Ill , P.A KEVIN A. CRASS, P.A. WILLIAM A. WADDELL, JR . . P A SCOTT J. LANCASTER, P A. M GAYLE CORLEY, P.A . ROBERT B. BEACH, JR., P.A J . LEE BROWN, P.A JAMES C. BAKER, JR., P A. HARRY A. LIGHT, PA Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Steve Jones Jack, Lyon \u0026amp; Jones, P.A. 425 West Capitol, Suite 3400 Little Rock, AR 72201-3472 A LIMITED LIABILITY PARTNERSHIP ATTORNEYS AT LAW 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 TELEPHONE 501-376-2011 FAX NO. 501-376-2147 April 18 , IECEIVE!ii:, APR 1 ~ 2!JGC m:FICEOF DESESUTJQN MONITORING. Mr. Sam Jones SCOTT H. TUCKER, P.A. GUY ALTON WADE, P.A. PRICE C. GARDNER, P.A. TONIA P. JONES. P.A. DAVID D. WILSON, P.A. JEFFREY H. MOORE, P.A. DAVID M. GRAF, P.A. CARLA GUNNELS SPAINHOUR, P.A . JOHN C. FENDLEY, JR. , P.A. JONANN CONIGLIO FLEISCHAUER, P.A. R. CHRISTOPHER LAWSON, P.A. GREGORY D. TAYLOR, P.A . TONY L. WILCOX, P.A . FRANC. HICKMAN, P.A. BETTY J. DEMORY, P.A. LYNDA M. JOHNSON, P.A. JAMES W. SMITH CLIFFORD W. PLUNKETT DANIELL. HERRINGTON K. COLEMAN WESTBROOK, JR . ALLISON J. CORNWELL ELLEN M. OWENS HELENE N. RAYDER JASON B. HENDREN BRUCE B. TIDWELL CHRIS A. AVERITT KELLY MURPHY MCQUEEN JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN ROBERT T. SMITH OF COUNSEL WILLIAM J . SMITH B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON, JR. H.T. LARZELERE, PA. JOHN C. ECHOLS, P.A. WRITER'S DIRECT HO (501) 370-3323 Wright, Lindsey \u0026amp; Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Finn P.O. Box 17388 Little Rock, AR 72222 Ms. Ann Brown - Hand Delivered Desegration Monitor Mr. Timothy G. Gauger Office of the Attorney General Heritage West Bldg., Suite 510 323 Center Street 201 East Markham Street Little Rock, AR 72201 200 Tower Building Little Rock, AR 72201 RE: LRSD vs. Pulaski County Special School District No. 1, et. al.\nMrs. Lorene Joshua, et. al.\nKatherine Knight, et. al. USDC, Eastern District. Western Division No. LR-C-82-866 Dear Ms. Brown \u0026amp; Gentlemen: Enclosed please find a Motion to Substitute a Complete Copy ofLRSD 's Interim Compliance Report which we are filing today. As indicated in the motion, attachments 1 - 4 ofLRSD's interim compliance report were inadvertently omitted during the printing process. We are enclosing attachments 1 - 4 which you can insert in the original copy of the report served on you. F\\HOMEIFENDLEYILRSD\\pcssd-brown d al h.wpd Office of Desegregation Monftorfng FILE r,opy Ms. Brown \u0026amp; Gentlemen April 18, 2000 Page2 If you would ratherreceive a second and complete copy of the report, please do not hesitate to call, and we will try to provide one. Sincerely, John C. Fendley, Jr. JCF/bgb enclosure(s) F:IHOMEIFENDLEY\\LRSD\\pcssd-brown ct al ILwpd Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026amp; CLARK First Commercial Bldg., Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376-2011 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on this 18th day of April, 2000. Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, AR 72222 Ms. Ann Brown - HAND DELIVERED Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 C. Fendley, Jr. ~ 3 EDUCATION: Ph.D. MSW BA VITAE TERRENCE J. ROBERTS, Ph.D. Clinical Psychology - Southern Illinois University, 1976, Psychology - University of California, Los Angeles, 1970 - California State University, Los Angeles, 1967 LICENSING AND CERTIFICATION: California State Licensed Psychologist, Lie. #PSY8892 California State Licensed Social Worker, Lie. #5600 EXPERIENCE: Attachment 1 Chief executive officer for Terrence J. Roberts \u0026amp; Associates, a management consultation firm active in California since 1975. A dynamic group with a wide range of skills and professional abilities. Workshops and Seminars in the areas of: Stress Management Effective Communication Managing Human Relationships Employment Transition Team Building Management Skills Managing Racial and Ethnic Diversity Self Growth and Development Conflict Resolution Developing Multicultural Awareness Employee Evaluation Staff Development Office of Desegregation Monitoring ALECOPY Created training programs and materials for employees in the department. Participated in program delivery, evaluation and revision. Provided social welfare services to children and families in the child welfare division. CONSULTATION\\PSYCHOLOGICAL SERVICES General psychology and consultation practice office in Pasadena, Ca. Practice includes psychological assessment, psychotherapy for individuals\nfamilies, and groups, and psychological consultation to education, business and industry. MEMBERSHIPS: Member, American Psychological Association Board Member, African American Cultural Institute Board Member, Eisenhower World Affairs Institute Board Member, Economic Resources Corporation PUBLICATIONS_\n_ __ \"Managing Trial Stress,\" in Jonathan M. Purver, Douglas R. Young, and James J. Davis III, Trial Handbook For California Lawvers, Bancroft-Whitney Co., 1987. __ \"Understanding Choice: Gateway to Sound Mental Health,\" Journal of Mental Health Administration, Vol.9, No.l, 1978. _ _ \"Social Welfare in Black America,\" in Cox\net al, eds. Introduction to Black America:A Cultural Perspective, Southern Illinois University Press, 1974. AWARDS: Spingarn Medal, 1957 Annual award presented by NAACP to that person or persons making outstanding .contributions to the area of human rights. Robert S. Abbott Memorial Award, 1958 Annual award presented to those who do most to extend the frontiers of democracy. Outstanding Teacher of the Year, College of Human Resources Southern Illinois University, 1974. NAACP Legal Defense and Education Fund, Inc. Award, 1982 Award commemorating twenty-fifth anniversary of \"Little Rock Nine's\" integration of Central High School in Little Rock, Arkansas. Southern Christian Leadership Conference Women Martin Luther King, Jr. \"Drum Major for Justice\" Award, 1995 Presented in Atlanta, Georgia. REFERENCES: Available upon request. Consultation services :provided to: California Attorneys for Criminal Justice California Medical Center Cedars Sinai Hospital Children's Bureau of Southern California Claremont Graduate School Cleveland College of Chiropractic Coca-Cola, Mid-Atlantic Division Crown City Medical Episcopal Diocese, Los Angeles Fairfield Community Hospital Heller, Ehrman, White \u0026amp; McAuliffe Internal Revenue Service, Los Angeles Kaiser Foundation King-Drew Medical Center, Los Angeles Los Angeles County Department of Children's Services Oskar J's Sightseeing Tours, Inc. Pacific Union College Pasadena Community College Pasadena T ournarnent of Roses Pepperdine University Pomona College Redwood Empire Central Service Association Riverside County Children's Services Department Santa Clara Valley Medical Center The Fielding Institute The March of Dimes Foundation TRW University of California, (Davis, Los Angeles, San Diego) Chair, Master's in Psychology Antioch University, Los Angeles 1993 - present Responsibilities of the Chair include developing and overseeing curriculum, coordinating student programs, creating and managing yearly budgets, participating in the governance of the University, and hiring and supervising adjunct faculty and staff. Included in the job description as well are activities designed to enhance the quality of the program and to maintain connections with psychology programs at schools in the southern California area. Assistant Dean, Student Services UCLA School of Social Welfare 1985 - 1993 Responsible for overall direction of student services including recruitment, admissions, retention, financial aid, student government, and coordination of both MSW and Ph.D. candidate programs. Supervisory responsibilities for student services assistant and student workers. Classroom teaching responsibilities included preparation and delivery of courses in cross-cultural awareness and group conflict and change. Director, Mental Health Services St. Helena Hospital and Health Center Deer Park, CA. 1975 - 1985 General administrative responsibility for sevent'een bed acute care mental health unit. Duties included staJ:fi.ng, program development, budget allocation, sta.i.\"':f development, quality control, coordination of ancillary services, and other related tasks. Served also as \"troubles-shooter\" for other ur,jts in the hospital providing assessment and consultation around changes in procedures and personnel. Lectured and led groups in Health Center programs including cardiac, alcohol, and pulmonary rehabilitation\nsmoking cessation\nweight management\nand eating disorders. Program Director, Social Work Pacific Union College .Angwin, CA 1975 - 1978 Responsible for development of social work curriculum 2nd coordination of program within a behavioral science department. Instructor, Social Work Southern Illinois University Carbondale, Illinois 1972-1975 Taught courses and advised majors in undergraduate social work program. Los Angeles County Children's Service 1. Staff Development Specialist: 1970 - 1972 2. Chiid Welfare Worker: 1967 - 1970 Institution Pennsylvania State University Undergraduate Major: Graduate Major: BRIEF VITA PERSONAL DATA Steven M. Ross EDUCATION Psychology Educational Psychology PROFESSIONAL ASSOCIATIONS American Psychological Association, Fellow American Educational Research Association, Member Mid-South Educational Research Association, Member Attachment 2 Degree-Year B.A. 1969 M.S . 1972 Ph.D. 1974 Association for Educational Communications \u0026amp; Technology, Member International Congress for School Effectiveness and School Improvements, Member EXPERIENCE Instructor, Continuing Education, 1973-74, Pennsylvania State University Instructor, Psychology, Spring Semester, 1974, Lock Haven State College Lock Haven, Pennsylvania Evaluator, Summer, 1974, Mitre Corporation, McLean, Virginia Assistant Professor, Educational Psychology, 197 4-79, University of Memphis Associate Professor, Educational Psychology, 1980-1985 Professor, Educational Psychology, 1.985 - Present  Senior Researcher, Center for Research in Education Policy, Univ. of Memphis, 1995 - Present COURSES RECENTLY TAUGHT Theories of Learning (Undergraduate) Individual Differences and Learning (Graduate) Educational Statistics (Undergraduate and Graduate) Educational Research (Graduate) Computers in Education (Graduate and Undergraduate) Thesis Writing (Graduate) Educational Assessment (Graduate) Attachment 2 HONORS AND DISTINCTIONS 1. NDEA Fellowship for graduate study at the Pennsylvania State University, 1971-1973. 2. Graduate Student Associate, Southwest Regional Laboratory, Summer, 1971. 3. Distinguished Teaching Service Award, University of Memphis, 1980. 4. Phi Delta Kappa Professional Research Award, Memphis Chapter, 1983. 5. Elected Fellow, Division 15, American Psychological Association, 1986. 6. Visiting Scholar, National Center for Research on Improving Postsecondary Teaching and Learning. University of Memphis, 1987. 7. Distinguished Research Award, University of Memphis, 1987. 8. Distinguished Teacher Service Award, University of Memphis, 1988. (First eligibility since 1980\nno longer eligible) 9. Memphis State University nominee, CASE Professor of the Year Award, 1989. 10. Superior Performance in University Research (SPUR) Award, University of Memphis, 1990, 1991, 1992 11. Distinguished Research Award, University of Memphis, 1993. 12. Board of Visitors Eminent Faculty Award, University of Memphis (first recipient), 1993 13. Editor, Educational Technology Research and Development, 1993-present 14. Editorial Board, Journal of Education for Students Placed at Risk, 1995- present 15. Editorial Board, Computers and Human Behavior, 1994-present SCHOLARSIIlP Publications in Refereed Journals: Books Book Chapters Papers Presented at Professional Meetings SELECTED RECENT PUBLICATIONS 115 6 16 170 Ross, S.M., Henry D., Phillipsen, L., Evans, K., Smith, L., \u0026amp; Buggey, T. ( 1997). Matching restructuring programs to schools: Selection, negotiation, and preparation. School Effectiveness and School Imorovement, ~ 45-71. Ross, S.M., Troutman, A., Horgan, D., Maxwell, S., Laitinen, R., \u0026amp; Lowther, D. (1997). The success of schools in implementing eight restructuring designs: A synthesis of first-year evaluation outcomes. School Effectiveness and School Improvement, t 95-124. Ross, S.M., Smith, L.J. \u0026amp; Casey, J. (1997). Preventing early school failure: Impacts of Success for all on standardized test outcomes, minority group performance, and school effectiveness. Journal for Research on Students Placed at Risk,~, 29-54. Attachment 2 Stringfield, S., \u0026amp; Ross, S.M. (1997). A \"reflection at time three of marathon: The Memphis restructuring initiative in mid-stride. School Effectiveness and School Improvement, l 151-161. Ross, S. \u0026amp; Smith, L.J. (1997). Improving the academic success of disadvantaged children: An examination of Success for All. Psvcholo!Zv in the Schools, 1.1, 171-180. Jayasinghe, M.G. Morrison, G.R. \u0026amp; Ross, S.M. (1997). The effect of distance learning classroom design on student perceptions. Educational Technolo~ Research and Develooment, 4 5, 5-20. Ross, S.M., \u0026amp; Smith, L.J. (in press). Improving school achievement and inter-group relations for children placed at risk. Euronean Journal of Intercultural Education. Smith, L.J., Ross, S.M., McNelis, M., Squires, M., and others (1998), The Memphis restructuring_initiative: Analysis of activities and outcomes that impact implementation success. Education and Urban Societv, 3 0 (3), 326- 357. Stringfield, S., Datnow, A., Ross, S., \u0026amp; Snively, F. (1998). Scaling up school restructuring in multicultural multilingual contexts: Early observations from Sunland County. Education and Urban Societv, 3 0 (3), 326-357. Ross, S.M., Smith, L.J. \u0026amp; Casey, J.P. (in press). \"Bridging the Gap\": The effects of the Success for All Programs on elementary school reading achievement as a function of student ethnicity and ability level. School Effectiveness and School Improvement. Summary of Interests During the past ten years, I have worked extensively with school districts, both regionally and locally, to develop and evaluate programs for improving student achievement. The primary fo~us of these studies has been schools predominantly serving disadvantaged inner-city minority children. In 1992, I was the lead researcher for the school equity study for the State of Alabama Financial Equity Case and am currently lead researcher on a comparable study in Louisiana. Additional ongoing research projects are studies of school restructuring designs as they are implemented in Memphis City Schools and Dade County (FL) schools and of professional development schools in seven national sites as part of the NEA Teacher Education Initiative (NEA-TEI). Attachment 3 1998-99 (DRAFT 2/7 /00) Relationship Between Total Scores and Percent of African American Students Correlations Percent of African-Americ Total Score: an Students: 1998 1998 1 oral Score: 1998 Pearson Correlation 1.000 .158 Sig. (2-tailed) .285 N 48 48 Percent of Pearson Correlation .158 1.000 African-American Sig. (2-tailed) Students: 1998 .285 N 48 48 .:.\n, 100 c::, D D C') D 0 D 0 en 90  0 D T'\" U) D c D Cl) 8 C -0 80 ::J C Cf) 8 D C 0 D ctl (.) 70  0 0 \n:: 0 ::: 0 Cl) E 0 \u0026lt;i: 0 C c::: 60, ctl 0 C (.) \n:: co C ..... . 0 \u0026lt;i: C 0 C 8 C 8 C 50 C :l 0 Cl) C C u '- 0 Cl) CL 40 30 40 50 60 Total Score: 1998 70 ' Attachment 4  1999-00 (DRAFT 2/7/00) Relationship Between Total Scores and Percent of African-American Students Correlations Percent of African-Americ Total Score: an Students: 1999 1999 1 otal Score: 1999 Pearson Corretauon 1.000 -.0A6 Sig. (2-tailed) .758 N 48 48 Percent of Pearson Correlation -.046 1.000 African-American Sig. (2-tailed) .758 Students: 1999 N 48 48 .:, 100 0  0 0 0 O\"l 90, 8 O\"l  0 .O..\"-l 0 0  tJ) 0 c 80, C 0 0 Q) u C C  .3 C  C (f) 70  C C ro C C u \n:: C a: 0  i= ] C C \u0026lt;   C I C 0 ro aC 0 .g 0 0 \" \u0026lt; 4J  0 0 0 C C 3al 0 Q) f:: Q) c.. 20 30 40 50 60 Total Score: 1999  70\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_1725","title":"Court filings: District Court, the Pulaski County Special School District (PCSSD) defendants' response to motion to extend time and for referral; District Court, motion to substitute a complete copy of Little Rock School District's (LRSD's) interim compliance report; District Court, two orders; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2000-04"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Pulaski County Special School District","Little Rock School District","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Educational law and legislation","Educational planning","School management and organization","School integration"],"dcterms_title":["Court filings: District Court, the Pulaski County Special School District (PCSSD) defendants' response to motion to extend time and for referral; District Court, motion to substitute a complete copy of Little Rock School District's (LRSD's) interim compliance report; District Court, two orders; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1725"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["76 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  EDWARD L . WRIGHT (1903 - 1977 ) ROBERTS . LINDSEY (1'1 13-1991 ) ISAAC A. SCOTT, JR . JOHN G . LILE WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW JOHN O DAVI S JU DY SIMMONS H ENR Y KIMBERLY WOOO TUCKER RAY F CO X. JR . GORDON S . RATHER . JR . TERRY L. MATHEWS OA VIO M. POWELL ROGER A . GLASGOW C. DOUGLAS BUFORD, JR . PATRICK J . GOSS ALSTON JENNINGS. JR . JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J. MULDROW N.M. NORTON CHARLES C . PRICE CHARLES T . COLEMAN JAMES J . GLOVER EDWIN L . LOWTHER. JR . CHARLES L. SCHLUMBERGER WALTER E. MAY GREGORY T . JONES H. KEITH MORRISON BETTINA E . BROWNSTEIN WALTER McSPAOOEN ROGER 0. ROWE NANCY BELLHOUSE MAY Mr. John Walker John Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 RE: PCSSD Dear Counsel and Ms. Brown: 200 WEST CAPITOL AVENUE SUITE 2200 LITTLE ROCK. ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 376-9442 WEBSITE : www .wlj .com OF COUNSEL ALSTON JENNINGS RONALD A . MAY M. TOCO WOOD Wri ter ' s Direcl Dial No . 501-21 2-1273 mjones@wlj .com April 11, 2000 Mr. Christopher Heller Friday, Eldredge \u0026 Clark TROY A PRI CE PA TRICIA A. SI EVERS JAMES M. MOODY . JR KA THRYN A PR YOR J . MARK DAVIS CL AIRE SHOWS HANCOCK K EV IN W. KENNEDY JERRY J . SALLINGS FRED M. PERKINS 111 WILLIAM STUART JA CKSON MICHAEL 0 . BARNES STEPHEN R . LANCASTER JUDY ROBINSON WILBER BETSY MEACHAM K YLE R. WILSON C . TAO BOHANNON MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J . CHARLES DOUGHERTY M. SEAN HATCH PHYLL I S M. McKENZIE ELISA MASTERSON WHITE JANE M. FAUL KNER ROBERT W. GEORGE J. ANDREW VINES JUSTI N T. ALLEN 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 RECEIVED Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 APR 1 2 2000 OfflGEOf DESEGREGATIOtl MORJTORJNQ Enclosed is a copy of the PCSSD defendants' response to motion to extend time and for referral which is being filed today. Cordially, WRIGHTEDSLEIY \u0026 JENNINGS LLP c?~ M. Sam I Jones, Ill MSJ/ao Encl. 169467-v1 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 KNIGHT, ET AL. THE PCSSD DEFENDANTS' RESPONSE ECEIVED APR 1 2 2000 QffiCEOi OESESREGAD ~ PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS TO MOTION TO EXTEND TIME AND FOR REFERRAL The PCSSD defendants for their response to motion to extend time and for referral, state: 1. Pursuant to the rules of this Court, Joshua's time for the submission of a fee petition began to run on July 19, 1999 (docket no. 3282]. Thus, Joshua's time for submitting a fee petition has long since expired. 2. Since July 19, 1999, the activities of the parties have revolved around the PCSSD's submission of Plan 2000 to which, as this court has previously found, Joshua did not object and to which no member of the Joshua Class submitted either comments or objections. 3. While the PCSSD defendants thus respectfully submit that there are no fee issues that can be now timely advanced by Joshua, nevertheless, the PCSSD has no objection to submission of the issue to the Department of Justice, Community Relations Service, but it will be the position of the PCSSD, if such referral occurs, that 169379-v1 any colorable claim for attorney's fees by Joshua is time-barred pursuant to the rules of this Court, this District and this Circuit. WHEREFORE, the PCSSD defendants pray that this Court enter an order consistent with this response and for all proper relief. WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 By-:-:---=--r-,--r.---:-:--:-=~c+------- M. At Sc CERTIFICATE OF SERVICE On April I(, 2000, a copy of the foregoing was served by U.S. mail on each of the following : Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Building, Suite 510 201 East Markham Street Little Rock, Arkansas 72201 169379-v1 2 FRIDAY, ELDREDGE \u0026 CLARK HERSCHEL H. FRIDAY (1922-1994) WILLIAM H. SUTTON , P.A. BYRON M. EISEMAN, JR., P.A. JOE D. BELL, P .A. JAMES A. BUTTRY, P.A.  DERICK S. URSERY, P.A. ARE. DAVIS , JR ., P.A. ES C. CLARK, JR ., P.A. OMAS P. LEGGETT , P.A. JOHN DEWEY WATSON , P.A. PAUL B. BENHAM Ill , 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. JAMES M. SAXTON, P.A. J . SHEPHERD RUSSELL Ill , P.A . DONALD H. BACON, P.A. WILLIAM THOMAS BAXTER , P.A. BARRY E. COPLIN, P.A. RICHARD 0 . TAYLOR, P.A. JOSEPH B. HURST, JR., P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER, P.A. LAURA HENSLEY SMITH, P.A. ROBERTS. SHAFER , P.A. WILLIAM M. GRIFFIN Ill, P.A. MICHAELS. MOORE. P.A. DIANE S. MACKEY, P.A. WALTER M. EBEL Ill , P.A. KEVIN A. CRASS, P.A. WILLIAM A . WADDELL , JR . . P.A. SCOTT J. LANCASTER , P.A. M. GAYLE CORLEY, P.A. ROBERT 8 . BEACH. JR .. P.A. J. LEE BROWN, P.A. JAMES C. BAKER , JR ., P.A. HARRY A. LIGHT, P.A. Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Steve Jones Jack, Lyon \u0026 Jones, P.A. 425 West Capitol, Suite 3400 Little Rock, AR 72201-3472 A LIMITED LIABILITY PARTNERSHIP ATTORNEYS AT LAW 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 TELEPHONE 501 -376-2011 FAX NO. 501-376 -2147 April I 8, IECEIVED ~ICE0F 0t5.i:9rur\u0026rriCN MONffOHING Mr. Sam Jones SCOTT H. TUCKER, P.A. GUY ALTON WADE, P.A. PRICE C. GARDNER, l' .A. TONIA P. JONES, P .A. DAVID D. WILSON. P.A. JEFFREY H. MOORE. P .A . DAVID M. GRAF, P .A. CARLA GUNNELS SPAINHOUR , P.A . JOHN C. FENDLEY, JR . , P.A. JONANN CONIGLIO FLEISCHAUER. P.A. R. CHRISTOPHER LAWSON, P.A. GREGORY 0 . TA YLOR, P.A. TONY L. WILCOX, P.A. FRANC. HICKMAN, P.A. BETTY J. DEMORY, P.A. LYNDA M. JOHNSON, l' .A. JAMES W. SMITH CLIFFORD W. PLUNKETT DANIELL. HERRINGTON K. COLEMAN WESTBROOK, JR . ALLISON J. CORNWELL ELLEN M. OWENS HELENE N. RAYOER JASON B. HENDREN BRUCE 8 . TIDWELL CHRIS A. AVERITT KELLY MURPHY MCQUEEN JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN ROBERT T. SMITH o, COUNS EL WILLIAM J. SMITH B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H.T. LARZELERE, P.A. JOHN C. ECHOLS , P .A. WRITER'S DIRECT NO, (501) 370 -3323 Wright, Lindsey \u0026 Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, AR 72222 Ms. Ann Brown - Hand Delivered Desegration Monitor Mr. Timothy G. Gauger Office of the Attorney General Heritage West Bldg., Suite 510 323 Center Street 201 East Markham Street Little Rock, AR 72201 200 Tower Building Little Rock, AR 72201 RE: LRSD vs. Pulaski County Special School District No. I, et. al.; Mrs. Lorene Joshua, et. al.; Katherine Knight, et. al. USDC, Eastern District, Western Division No. LR-C-82-866 Dear Ms. Brown \u0026 Gentlemen: Enclosed please find a Motion to Substitute a Complete CopyofLRSD' s Interim Compliance Report which we are filing today. As indicated in the motion, attachments 1 - 4 ofLRSD's interim compliance report were inadvertently omitted during the printing process. We are enclosing attachments 1 - 4 which you can insert in the original copy of the report served on you. F:IHOME\\FENDLEY\\LRSDlpcssd-brown et ,I It. wpd Ms. Brown \u0026 Gentlemen April 18,2000 Page2 If you would rather receive a second and complete copy of the report, please do not hesitate to call, and we will try to provide one. Sincerely, John C. Fendley, Jr. JCF/bgb enclosure(s) F:IHOME\\FENDLEY\\LRSD\\pcssd-brown et al lt.wpd 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 KNTGHT, ET AL MOTION TO SUBSTITUTE A COMPLETE COPY OF LRSD'S INTERIM COMPLIANCE REPORT RE.Cif~~ili APR 19 2000 PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The Little Rock School District (LRSD) for its Motion to Substitute A Complete Copy of LRSD's Interim Compliance Report states: 1. On March 15, 2000, LRSD filed its Interim Compliance Report outlining the programs, policies and procedures implemented in accordance with LRSD's Revised Desegregation and Education Plan . 2. Since that time, it has come to LRSD's atte~tion that attachments 1 through 4 of the Interim Compliance Report were inadvertently omitted from the report during printing. 3. A complete copy of the report, including attachments 1 through 4, are attached to this Motion. LRSD respectfully requests that this report be substituted for the one filed March 15, 2000. WHEREFORE, LRSD prays that the complete copy of LRSD ' s Interim Compliance Report attached hereto be substituted for the one filed March 15, 2000. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026 CLARK First Commercial Bldg., Suite 2000  400 West Capitol Little Rock, AR 72201-3493 (501) 376-2011 BY,pe~ ~ ofu;c. '~y,J. 'r21a2) 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on this 18th day of April, 2000. Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026 Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026 JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Roachell Law Firm P.O. Box 17388 Little Rock, AR 72222 Ms. Ann Brown - HAND DELIVERED Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 C. Fendley, Jr. ~ 3 --- - - ----- ------ - - - - EDUCATION: Ph.D. MSW BA VITAE TERRENCE J. ROBERTS, Ph.D. Clinical Psychology - S.outhem Illinois University, 1976, Psychology - University of California, Los Angeles, 1970 - California State University, Los Angeles, 1967 LICENSING AND CERTIFICATION: California State Licensed Psychologist, Lie. #PSY8892 California State Licensed Social Worker, Lie. #5600 EXPERIENCE: Attachment 1 Chief executive officer for Terrence J. Roberts \u0026 Associates, a management consultation firm active in California since 1975. A dynamic group with a wide range of skills and professional abilities. Workshops and Seminars in the areas of: Stress Management Effective Communication Managing Human Relationships Employment Transition Team Building Management Skills Managing Racial and Ethnic Diversity Self Growth and Development Conflict Resolution Developing Multicultural Awareness Employee Evaluation Staff Development Created training programs and materials for employees in the department. Participated in program delivery, evaluation and revision. Provided social welfare services to children and families in the child welfare division. CONSULTATION\\PSYCHOLOGICAL SERVICES General psychology and consultation practice office in Pasadena, Ca. Practice includes psychological assessment, psychotherapy for individuals; families, and groups, and psychological consultation to education, business and industry. MEMBERSHIPS: Member, American Psychological Association Board Member, African American Cultural Institute Board Member, Eisenhower World Affairs Institute Board Member, Economic Resources Corporation PUBLICATIONS,;_ __ \"Managing Trial Stress,\" in Jonathan M. Purver, Douglas R. Young, and James J. Davis III, Trial Handbook For California Lawyers, Bancroft-'Whitney Co., 1987. - __ \"Understanding Choice: Gateway to Sound Mental Health,\" Journal of Mental Health Administration, Vol.9, No.l, 1978. __ \"Social Welfare in Black America,\" in Cox; et al, eds. Introduction to Black America:A Cultural Perspective, Southern Illinois University Press, 1974. AWARDS: Spingarn Medal, 1957 Annual award presented by NAACP to that person or persons making outstanding .contributions to the area of human rights. Robert S. Abbott Memorial Award, 1958 Annual award presented to those who do most to extend the frontiers of democracy. Outstanding Teacher of the Year, College of Human Resources Southern Illinois University, 1974. NAACP Legal Defense and Education Fund, Inc. Award, 1982 Award commemorating twenty-fifth anniversary of \"Little Rock Nine's\" integration of Central High School in Little Rock, Arkansas. Southern Christian Leadership Conference Women Martin Luther King, Jr. \"Drum Major for Justice\" Award, 1995 Presented in Atlanta, Georgia. REFERENCES: Available upon request. '--- --- ---- - - Consultation services provided to: California Attorneys for Criminal Justice California Medical Center Cedars Sinai Hospital Children's Bureau of Southern California  Claremont Graduate School Cleveland College of Chiropractic Coca-Cola, Mid-Atlantic Division Crown City Medical Episcopal Diocese, Los Angeles Fairfield Community Hospital Heller, Ehrman, White \u0026 McAuliffe Internal Revenue Service, Los Angeles Kaiser Foundation King-Drew Medical Center, Los Angeles Los Angeles County Department of Children's Services Oskar J's Sightseeing Tours, Inc. Pacific Union College Pasadena Community College Pasadena Tournament of Roses Pepperdine University Pomona College Redwood Empire Central Service Association Riverside County Children's Services Department Santa Clara Valley Medical Center The Fielding Institute The March of Dimes Foundation TRW University of California, (Davis, Los Angeles, San Diego) Chair, Master's in Psychology Antioch University, Los Angeles 1993 - present Responsibilities of the Chair include developing and overseeing curriculum, coordinating student programs, creating and managing yearly budgets, parti!=ipating in the governance of the University, and hiring and supervising adjunct faculty and staff. Included in the job description as well are- I - --- _J Institution Pennsylvania State University Undergraduate Major: Graduate Major: BRIEF VITA PERSONAL DATA Steven M. Ross EDUCATION Psychology Educational Psychology PROFESSIONAL ASSOCIATIONS American Psychological Association, Fellow American Educational Research Association, Member Mid-South Educational Research Association, Member Attachment 2 Degree-Year B.A. 1969 M.S. 1972 Ph.D. 1974 Association for Educational Communications \u0026 Technology, Member International Congress for School Effectiveness and School Improvements, Member EXPERIENCE Instructor, Continuing Education, 1973-74, Pennsylvania State University Instructor, Psychology, Spring Semester, 1974, Lock Haven State College Lock Haven, Pennsylvania Evaluator, Swnmer, 1974, Mitre Corporation, McLean, Virginia Assistant Professor, Educational Psychology, 1974-79, University of Memphis Associate Professor, Educational Psychology, 1980-1985 Professor, Educational Psychology, 1.985 -Present  Senior Researcher, Center for Research in Education Policy, Univ. of Memphis, 1995 - Present COURSES RECENTLY TAUGHT Theories of Leaming (Undergraduate) Individual Differences and Leaming (Graduate) Educational Statistics (Undergraduate and Graduate) Educational Research (Graduate) Computers in Education (Graduate and Undergraduate) Thesis Writing (Graduate) Educational Assessment (Graduate) activities designed to enhance the quality of the program and to maintain connections with psychology programs at schools in the southern California area. Assistant Dean, Student Services UCLA School of Social Welfare 1985-1993 Responsible for overall direction of student services including recruitment, admissions, retention, financial aid, student government, and coordination of both MSW and Ph.D. candidate programs. Supervisory responsibilities for student services assistant and srudent workers. Classroom teaching responsibilities included preparation and delivery of courses in cross-cultural awareness and group conflict and change. Director, Mental Health Services St. Helena Hospital and Health Center Deer Park, CA. 1975-1985 General administrative responsibility for sevent'een bed acute care mental health unit. Duties included staffing, program development, budget allocation, staff development, quality control, coordination of ancillary services, and other related tasks. Served also as \"troubles-shooter\" for other units in the hospital providing assessment and consultation around changes in procedures and personnel. Lectured and led groups in Health Center programs including cardiac, alcohol, and pulmonary rehabilitation; smoking cessation; weight management; and eating disorders. Program Director, Social Work Pacific Union College Angwin, CA 1975 - 1978 Responsible for development of social work curriculum  and coordination of program within a behavioral science department. Instructor, Social Work Southern Illinois University Carbondale, Illinois 1972-1975 Taught courses and advised majors in undergraduate social work program. Los Angeles County Children's Service 1. Staff Development Specialist: 1970 - 1972 2. Child Welfare Worker: 1967 - 1970 - -  1. 2. 3. 4. 5. 6. 7. 8. 9. Attachment 2 HONORS AND DISTINCTIONS NDEA Fellowship for graduate study at the Pennsylvania State University, 1971-1973. Graduate Student Associate, Southwest Regional Laboratory, Summer, 1971 . Distinguished Teaching Service Award, University of Memphis, 1980. Phi Delta Kappa Professional Research Award, Memphis Chapter, 1983. Elected Fellow, Division 15, American Psychological Association, 1986. Visiting Scholar, National Center for Research on Improving Postsecondary Teaching and Learning. University of Memphis, 1987. Distinguished Research Award, University of Memphis, 1987. Distinguished Teacher Service Award, University of Memphis, 1988. (First eligibility since 1980; no longer eligible) Memphis State University nominee, CASE Professor of the Year Award, 1989. 10. Superior Performance in University Research (SPUR) Award, University of Memphis, 1990, 1991, 1992 11. Distinguished Research Award, University of Memphis, 1993. 12. Board of Visitors Eminent Faculty Award, University of Memphis (first recipient), 1993 13. Editor, Educational Technology Research and Development, 1993-present 14. Editorial Board, Journal of Education for Students Placed at Risk, 1995- present 15. Editorial Board, Computers and Human Behavior, 1994-present SCHOLARSHIP Publications in Refereed Journals: Books Book Chapters Papers Presented at Professional Meetings SELECTED RECENT PUBLICATIONS 115 6 16 170 Ross, S.M., Henry D., Phillipsen, L., Evans, K., Smith, L., \u0026 Buggey, T. ( 1997). Matching restructuring programs to schools: Selection, negotiation, and preparation. School Effectiveness and School Improvement, \u0026, 45-71. Ross, S.M., Troutman, A., Horgan, D., Maxwell, S., Laitinen, R., \u0026 Lowther, D. (1997). The success of schools in implementing eight restructuring designs: A synthesis of first-year evaluation outcomes. School Effectiveness and School Improvement,~. 95-124. Ross, S.M., Smith, L.J. \u0026 Casey, J. (1997). Preventing early school failure: Impacts of Success for all on standardized test outcomes, minority group performance, and school effectiveness. Journal for Research on Students Placed at Risk, 1., 29-54. Attachment 2 Stringfield, S., \u0026 Ross, S.M. (1997). A \"reflection at time three of marathon: The Memphis restructuring initiative in mid-stride. School Effectiveness and School Improvement, l 151-161. Ross, S. \u0026 Smith, L.J. (1997). Improving the academic success of disadvantaged children: An examination of Success for All. Psvcholo12v in the Schools, 3 4, 171-180. Jayasinghe, M.G. Morrison, G.R. \u0026 Ross, S.M. (1997). The effect of distance learning classroom design on student perceptions. Educational Technology Research and Development, .ij_, 5-20. Ross, S.M., \u0026 Smith, L.J. (in press). Improving school achievement and inter-group relations for children placed at risk. Euronean Journal of Intercultural Education. Smith, L.J., Ross, S.M., McNelis, M., Squires, M., and others (1998), The Memphis restructuring initiative: Analysis of activities and outcomes that impact implementation success. Education and Urban Societv, 3 0 (3), 326- 357. Stringfield, S., Datnow, A., Ross, S., \u0026 Snively, F. (1998). Scaling up school restructuring in multicultural multilingual contexts: Early observations from Sunland County. Education and Urban Society, 3 0 (3), 326-357. Ross, S.M., Smith, L.J. \u0026 Casey, J.P. (in press). \"Bridging the Gap\": The A effects of the Success for All Programs on elementary school reading W achievement as a function of student ethnicity and ability level. School Effectiveness and School Improvement. Summary of Interests During the past ten years, I have worked extensively with school districts, both regionally and locally, to dev~lop and evaluate programs for improving student achievement. The primary fos:us of these studies has been schools predominantly serving disadvantaged inner-city minority children. In 1992, I was the lead researcher for the school equity study for the State of Alabama Financial Equity Case and am currently lead researcher on a comparable study in Louisiana. Additional ongoing research projects are studies of school restructuring designs as they are implemented in Memphis City Schools and Dade County (FL) schools and ofprofessional development schools in seven national sites as part of the NEA Teacher Education Initiative (NEA-TEI). - Attachment 3 1998-99 (DRAFT 2/7/00) Relationship Between Total Scores and Percent of African American Students Correlations Percent of African-Americ Total Score: an Students: 1998 1998 Total Score: 1998 Pearson Correlation 1.000 .158 Sig. (2-tailed) .285 N 48 48 Percent of Pearson Correlation .158 1.000 African-American Sig. (2-tailed). Students: 1998 .285 N 48 48 :..,1 100 0 0 co O') 0 0 0 0 O') 90  . ..-- 0 0 \u003cJl C c C B Q) C \"O 80  .a C U) B C cCo C C CJ 70 C C c 0 0 0 Q) E C \u003c( ' 0 0 Cco 60 0 0 CJ ..c... . 00 0 0 \u003c( 0 0 0 8 0 B 0 50, c 0 0 Q) C 0 .C..J. 0 Q) 0.. 40 30 40 50 60 Total Score: 1998 70 Attachment 4 1999-00 (DRAFT 2/7/00) Relationship Between Total Scores and Percent of African-American Students Correlations Percent of African-.A.meric Total Score: an Students: 1999 1999 Total Score: 1999 Pearson Correlation 1.000 -.046 Sig. (2-tailed) .758 N 48 48 Percent of Pearson Correlation -.046 1.000 African-American Sig. (2-tailed) .758 Students: 1999 N 48 48 .:1 100 0 0 0 0 0 en 90 , 8 en 00 0 .e,.n.. 0 0 0 t/l 0 c 80 0 0 Q) 0 \"O 0 0 C .2 0 0 Cf) 0 70 0 0 C C1l 0 C tc) C Q) C 0 E 60 C 0 \u003c( C 0 0 I 0 C ro oO 0 (.) 50, 0 0 c 0 ~ 0 0 0 0 c 40 , 0 0 Q) .(...) Q) 0... 30 20 30 40 50 60 Total Score: 1999 0 70 - FILED EASTMlN '6',il~',g ~2~~SAS IN THE UNITED STATES DISTRICT COURT APR 2 5 2000 EASTERN DISTRICT OF ARKANSAS JAME:3!.JV WESTERN DIVISION .By:--'/~j ~~~'7\\RK DEP~ LITTLE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al., Defendants, MRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors. * * * * * * * * * * * ORDER No. LR-C-82-866 RECEIVED uFFICE orOESEGREGATIOM MONITORING The Joshua Intervenors filed a motion requesting that the Court refer the matter of attorney's fees related to the Pulaski County Special School District's revised desegregation plan to the Department of Justice, Community Relations Service [docket no. 3352]. Additionally, Joshua requests that the Court postpone the deadline for filing a petition for attorney's fees until such time as it is determined the parties cannot resolve the matter on a voluntary basis. The Pulaski County Special School District (PCSSD) has no objection to Joshua's request for a referral but asserts the time for submitting a fee petition has expired [docket no. 3354]. In an Order entered February 22, 2000 this Court conditionally approved PCSSD's revised desegregation plan stating, \"Joshua may file a motion for attorney's fees pursuant to 42 U.S.C.  1988.\"1 On March 20, 2000, this Court officially approved the revised plan. Joshua 1 See docket no. 3337. 1 - filed the present motion for referral and extension on March 31, 2000, eleven days after the Court formally approved the revised desegregation plan. Under Local Rule 54.1, Joshua had fourteen days to submit a petition for attorney's fees or a motion to extend the time for submitting such a petition. The Court finds Joshua's motion timely. THEREFORE, for good cause shown, Joshua's motion is GRANTED [docket no. 3352]. The matter of attorney's fees is hereby referred to the Department of Justice, Community Relations Service. Additionally, the Court extends the deadline for Joshua to file a petition for attorney's fees until such time as it is determined the matter cannot be resolved between the parties on a voluntary basis. FURTHER, the Clerk is directed to send a copy of this Order to: Mr. Gus Taylor Community Relations Service U.S. Department of Justice 1100 Commerce Street Dallas, TX 75242 ..f{A.__ ITIS SOORDEREDTHis'2:!i._DAYOF APRIL,2000 UNITED STA TES DISTRICT COURT 2 r- - FILED t U.S. DISTRICT COURT  EASTERN DISTRICT ARKANSAS f IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION APR 2 5 2000 LITTLE ROCK SCHOOL DISTRICT, * Plaintiff, * VS. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al., Defendants, MRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors. * * * * * * * * * * * ORDER No. LR-C-82-866 The Little Rock School District (\"LRSD\") filed a motion to substitute a complete copy of the district's interim compliance report for a copy originally filed March 15, 2000.1 The motion is GRANTED [docket no. 3355]. . ~-f(_ IT IS SO ORDERED THIS~DAY OF APRIL, 2000 UNITED STATES DISTRICT COURT n-flS DOCUMENT ENTERED ON DOCKET SHEET IN :MP'11J~ULE s~;N~a) FRCP _ 1 Docket no. 3344. ,~ 'jW- / ~ RECErVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 .. , ,; l j _._\\ jU~ Ml', I J. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al . DEFENDANTS NOTICE OF FILING In accordance \\,;rh tJ1e Court's order of December 10, 1993, tJ1e Arkansas Department of Education hereby gives notice of tJ1e filing of AD E's Project :\\Ia11agement Tool for April, 2000. Respectfully Submitted, MARK PR\"i.'OR Attorney General 1-/~~~i,;- TIMOTHY G. GA :c R #95019 Assistant Attorney eral 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorney for Arkansas Department of Education  IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL V. PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE W. KNIGHT, ET AL NO. LR-C-82-866 PLAINTIFFS DEFENDANTS INTERVENORS INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. IMPLEMENTATION PHASE ACTIVITY I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of April 30, 2000 B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June .  This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources. "}],"pages":{"current_page":17,"next_page":18,"prev_page":16,"total_pages":46,"limit_value":12,"offset_value":192,"total_count":544,"first_page?":false,"last_page?":false},"facets":[{"name":"type_facet","items":[{"value":"Text","hits":544}],"options":{"sort":"count","limit":16,"offset":0,"prefix":null}},{"name":"creator_facet","items":[{"value":"United States. District Court (Arkansas: Eastern District)","hits":313},{"value":"United States Court of Appeals for the Eighth Circuit","hits":35},{"value":"Little Rock School District","hits":14},{"value":"Bushman Court Reporting","hits":11},{"value":"Walker, John W.","hits":6},{"value":"Pulaski County Special School District","hits":3},{"value":"Springer, Joy C.","hits":3},{"value":"Arkansas. Department of Education","hits":2},{"value":"Cobb Court Reporting","hits":2},{"value":"Joshua Intervenors","hits":2},{"value":"Chancery Court of Pulaski County, Arkansas, Sixth Division","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"subject_facet","items":[{"value":"Education--Arkansas","hits":439},{"value":"Educational law and legislation","hits":396},{"value":"Little Rock School District","hits":378},{"value":"Pulaski County Special School District","hits":354},{"value":"Little Rock (Ark.)--History--20th century","hits":329},{"value":"School integration","hits":317},{"value":"Educational planning","hits":295},{"value":"Education--Evaluation","hits":268},{"value":"School management and organization","hits":249},{"value":"Education--Finance","hits":223},{"value":"Court records","hits":206}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"subject_personal_facet","items":[{"value":"Springer, Joy C.","hits":6},{"value":"Walker, John W.","hits":3},{"value":"Heller, Christopher","hits":2},{"value":"Wright, Susan Webber, 1948-","hits":2},{"value":"Armor, David","hits":1},{"value":"Eddington, Ramsey","hits":1},{"value":"Jones, Sam","hits":1},{"value":"Jones, Stephen W.","hits":1},{"value":"Joshua, Lorene","hits":1},{"value":"Lester, Bobby","hits":1},{"value":"Porter, Austin, Jr.","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"event_title_sms","items":[{"value":"Housing Act of 1961","hits":2}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"location_facet","items":[{"value":"United States, 39.76, -98.5","hits":544},{"value":"United States, Arkansas, 34.75037, -92.50044","hits":537},{"value":"United States, Arkansas, Pulaski County, 34.76993, -92.3118","hits":535},{"value":"United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959","hits":472},{"value":"United States, Arkansas, Pulaski County, Maumelle, 34.86676, -92.40432","hits":4},{"value":"United States, Arkansas, Pulaski County, North Little Rock, 34.76954, -92.26709","hits":2},{"value":"United States, Kansas, 38.50029, -98.50063","hits":2},{"value":"United States, Missouri, 38.25031, -92.50046","hits":2},{"value":"United States, Arkansas, Phillips County, 34.42829, -90.84802","hits":1},{"value":"United States, Arkansas, Pulaski County, Jacksonville, 34.8662, -92.11015","hits":1},{"value":"United States, Arkansas, Scott County, Waldron, 34.89843, -94.09076","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"us_states_facet","items":[{"value":"Arkansas","hits":537},{"value":"Kansas","hits":2},{"value":"Missouri","hits":2},{"value":"Connecticut","hits":1},{"value":"Illinois","hits":1},{"value":"Massachusetts","hits":1},{"value":"Oklahoma","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"year_facet","items":[{"value":"1994","hits":50},{"value":"1995","hits":44},{"value":"1992","hits":41},{"value":"1996","hits":40},{"value":"1993","hits":38},{"value":"2001","hits":32},{"value":"2011","hits":31},{"value":"1997","hits":28},{"value":"2002","hits":24},{"value":"1991","hits":23},{"value":"1998","hits":22},{"value":"2012","hits":20},{"value":"2010","hits":16},{"value":"1999","hits":15},{"value":"2003","hits":15},{"value":"1989","hits":12},{"value":"2000","hits":12},{"value":"2004","hits":12},{"value":"2013","hits":12},{"value":"2007","hits":11},{"value":"2005","hits":10},{"value":"2006","hits":10},{"value":"2009","hits":8},{"value":"1988","hits":7},{"value":"1990","hits":7},{"value":"1984","hits":6},{"value":"2008","hits":6},{"value":"1986","hits":4},{"value":"1985","hits":3},{"value":"1987","hits":2},{"value":"1954","hits":1},{"value":"1983","hits":1},{"value":"2017","hits":1}],"options":{"sort":"count","limit":100,"offset":0,"prefix":null},"min":"1954","max":"2017","count":564,"missing":0},{"name":"medium_facet","items":[{"value":"filing","hits":544}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"rights_facet","items":[{"value":"http://rightsstatements.org/vocab/InC-EDU/1.0/","hits":544}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"collection_titles_sms","items":[{"value":"Office of Desegregation Management","hits":544}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"provenance_facet","items":[{"value":"Butler Center for Arkansas Studies","hits":544}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"class_name","items":[{"value":"Item","hits":544}],"options":{"sort":"count","limit":100,"offset":0,"prefix":null}},{"name":"educator_resource_b","items":[{"value":"false","hits":544}],"options":{"sort":"count","limit":100,"offset":0,"prefix":null}}]}}