{"response":{"docs":[{"id":"bcas_bcmss0837_1483","title":"\"Strategic Plan (1998 Update), District Information,'' Little Rock School District","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":["Little Rock School District"],"dc_date":["1998"],"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--20th century","Education--Arkansas","Educational law and legislation","Education--Standards","Education--Finance","Education--Curricula","School enrollment","School management and organization","School improvement programs","School integration","Parents","Student activities","Student assistance programs","Educational innovations"],"dcterms_title":["\"Strategic Plan (1998 Update), District Information,'' Little Rock School District"],"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/1483"],"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":["documents (object genre)"],"dcterms_extent":["69 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_721","title":"SWAT visits","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":["1998/1999"],"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--20th century","Little Rock School District","Education--Arkansas","Education--Evaluation","Little Rock (Ark.). Office of Desegregation Monitoring","School facilities"],"dcterms_title":["SWAT visits"],"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/721"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"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\nODM 1998 SWAT VISIT SCHEDULE SWAT VISIT TEAMS Team A - Margie and Gene Team B - Melissa and Horace North Little Rock School District Friday, August 21, 1998 Team A Team B 9:00 - 10:30 11:00-12:30 1:30-3:30 Amboy Elementary Lakewood Middle NLR High, East Campus Boone Park Elementary Lakewood Middle NLR High, East Campus Little Rock School District Tuesday - Thursday, August 25, 26, 27, 1998 Team A Team B Tuesday, Aug. 25 9:00-10:30 11:00- 12:30 1:30-3:00 Booker Elementary Wakefield Elementary Hall High Washington Elementary Rightsell Elementary Hall High Wednesday, Aug. 26 9:00 - 10:30 11:00- 12:30 Forest Heights Jr. Bale Elementary Mabelvale Jr. Otter Creek Elementary Pulaski County Special School District Tuesday - Thursday, September 1, 2,3,1998 Team A Team B Tuesday, Sept. 1 9:00-10:30 11:00- 12:30 Mills High Fuller Jr. Mills High Bates Elementary Wednesday, Sept. 2 9:00-10:30 11:00- 12:30 1:30-3:00 Clinton Elementary Harris Elementary Jacksonville Elementary Robinson Jr. Crystal Hill Elementary Oakbrook ElementarySWAT Revisit Schedule Melissa Wednesday, December 2 Bale Hall Robinson Jr. Thursday, December 3 Cloverdale El. Wakefield Bates Mills I Friday, December 4 Boone Park Lakewood Jr. Monday, December 7 Jacksonville El. OakbrookeMemo To: From: Staff Polly Subject: LRSD Meeting Date: August 19, 1998 The LRSD Tea Party is set for 9:30 a m. on Wednesday, September 2. Dr. Gamine, Dr. Bonnie Lesley, and Dr. Katherine Lease will be the ones from LRSD that attend. We have blocked a two- hour timeframe for this meeting. When Ann returns to work, we will discuss and finalize the agenda and plan the details of the meeting. The SWAT visits that were scheduled on September 2 will be done on Monday, August 31. Also, remember that the SWAT visits scheduled for Friday, August 21, have been rescheduled to Monday, August 24..K Office of Desegregation Monitoring United States District Court  Eastern District of Arkansas Ann S. Brown, Federal Monitor 201 East Markham. Suite 510 Heritage West Building Little Rock, Arkansas 72201 (501) 376-6200 Fax (501) 371 -0100 CP^ September 21, 1998 Dr. Les Carnine, Superintendent Little Rock School District 810 West Markham Street Little Rock, AR 72201 Dear Les: As I explained when we met on August 31, each fall as the school year gets underway, ODM monitors briefly and informally visit a few schools in all three districts. The observations we make at that time are in the same vein as those of parents, students, and staff as they enter the building to start the new year. That's why we pay attention to the aspects of a school that are most likely to initially impress those entering it, such as the condition of the grounds, building upkeep and cleanliness, displays and furnishings, student and staff conduct, and so forth. This year we dropped in on ten LRSD schools during the first full week of classes\nBale, Booker, Cloverdale, Otter Creek, Rightsell, Wakefield, and Washington Elementaries\nForest Heights and Mabelvale Junior Highs\nand Hall High School. A list of our observations about each school is attached. As I told you last month, overall we were favorably impressed with the condition of the buildings and the many fine preparations for the opening of school that we saw. We intend for these comments to give you, your administrators, and the principals of these buildings the benefit of our impressions. Therefore, as has been our custom, we will not publish or file these observations at this time, although we might eventually factor them into some aspect of a report. I hope the enclosed information is helpful. Please dont hesitate to call if you have any questions or comments. Sincerely yours, S. Brown Enc. cc: Sadie Mitchell Building principalsBale Elementary School We were pleased to note that: An attractive circle drive, decorated with shrubs and trees, led to the entryway. The playground offered shaded areas with appropriate climbing equipment and a basketball court. Despite long years of use, the corridors glistened from floor to ceiling. The small entryway and foyer were warmly and attractively furnished with benches, murals, student photographs, and decorative plants. A large display featuring color photographs of every student dominated one wall in the main area. Almost every wall in the corridors had a freshly painted mural with a multicultural or child- oriented theme. A large aquarium in the central corridor was very interesting. Cafeteria furnishings were clean and in good repair. Figurines added a warm touch to the shelf above the cafeteria serving line. A Welcome Students banner and other colorful banners hung from the metal rafters of the cafeteria, brightening the room considerably. Ceiling fans in the cafeteria helped air flow on the extremely hot day. Wet mats were in place in the kitchen area. The stage floor was clean and waxed. A curtain made from bed sheets and decorated with stars helped hide the cluttered stage. The media center was clean and inviting. The girls restroom was handicapped accessible and free of graffiti. The one boys restroom was well supplied and appeared to be clean, although smelly. The urinals and commodes were functional. We also noted some areas needing attention:  Four portable buildings housed music, speech, gifted and talented. Title I, and two small sixth grade classes.  Much of the playground was barren, rocky, and in need of sod.  The pavement for the basketball court was old and cracked.  The air quality in the corridors was stultifying.  Maneuverability in the kitchen was limited because of the small facility.  The kitchen restroom had no ventilation of any kind.  Serious tile damage in the kitchen area posed a safety hazard.  The cafeteria was cluttered with several boxes, pieces of furniture, and a freezer that lined the rooms walls.  Furniture and boxes containing clothes and other miscellaneous items were strewn about the stage.  The media center was far too small to effectively house a media program, but the media specialist was doing the best possible under the circumstances.  The stationary shelves in the media center allowed little opportunity for developing reading centers or interesting displays. The materials collection was packed into the shelving, leaving little room to develop the collection.  Faucets in a girls restroom were operational, but water pressure was poor.  In the girls restroom, one stall door was broken and all stalls lacked interior locks.  Some litter was scattered on the floor in the girls restroom, and the facility lacked paper towels.  Some students reported roaches in the girls restroom.  The boys restroom had a foul odor.Booker Magnet School We were pleased to note that:  The U.S. flag was properly displayed on the flagpole at the entrance to the school.  The schools mission statement was prominently displayed in several locations throughout the building.  The interior hallways and the office were filled with bright, colorful displays that enhanced the appearance of the school and announced Bookers Arts theme to any and all visitors. The hall walls were enlivened by a series of colorful murals painted by the schools art specialist. Artwork was also present in an area overlooking the gymnasium.  Evidence of the schools art theme was present throughout the building: a display near the front entrance celebrated the Artist of the Week, Vincent Van Gogh\nthe hallways were adorned with student artwork\nand each pod of classrooms and the individual hallways were named after famous artists and performers.  School rules (e g., pertaining to the cafeteria or playground) were posted and expressed as expectations rather than rules.  Floors throughout the building were clean and shiny.  Lockers had been painted an attractive, neutral color and were in good condition.  Most of the fountains throughout the building were clean and operating with adequate pressure.  The cafeteria, which had fully operating interior lighting and large banks of windows, was light and airy.  The cafeteria floors, tables, and seating were clean and in good condition.  The kitchen had adequate work space.  Two kitchen fire extinguishers were easily accessible in the event of an emergency.  The media center was large and attractive.  The floors in the boys restrooms were in good condition and clean. The basins, toilets, and urinals were functioning normally.  The boys restrooms were supplied with toilet paper and soap. We also noted some areas needing attention:  The exterior of the school had an unkempt appearance\na planter in front of the flagpole was weed-choked and unsightly\nthe schools entry was devoid of plantings that could enhance the appearance of the building.  The interior courtyards were unsightly: while the courtyard grass had been mowed, little had been done to beautify the area\npiles of grass clippings, broken limbs, and some discarded items filled the courtyards.  The girls restroom near the cafeteria was a mess: rolls of toilet paper were strewn on the floor\nthe entry area was very dark and cluttered with stored cleaning supplies and equipment. Further, the room did not have a handicapped accessible stall or soap dispensers, although a single bar of soap lay on a small shelf below one of the mirrors.  The boys restrooms were dimly lit, smelled excessively of urine, and lacked paper towels.Cloverdale Elementary School We were pleased to note that:  The campus was very attractive and the lawns had been mowed recently.  Healthy mature trees and shrubs accented the entry courtyard.  The breezeways connecting the various sections of the school were very clean.  The courtyard was neatly mowed and the shrubbery trimmed.  A covered sidewalk provided access from the main building to the schools one portable classroom.  The school was almost litter free.  The office, which was very neat and uncluttered, had attractive, color-coordinated bulletin boards that brightened the area.  Children were very orderly as they walked to the cafeteria for lunch.  The cafeteria was quite clean, considering that we visited mid-way through the lunch period.  Cafeteria floors were clean and shiny.  Attractive displays and bulletin boards decorated the media center.  The media center carpeting was clean and in good condition.  The girls restroom was clean and supplied with paper products.  The boys restroom was supplied with both toilet paper and paper towels, and the floor was clean and in good repair.  Posted in the boys restroom were signed Bathroom Pledges by which the signatories committed to practice proper restroom behavior and encourage others to do likewise. We also noted some areas needing attention:  No flag was flying from the pole in front of the school.  The exterior trim paint was quite worn in some areas.  Much of the paint on metal surfaces (such as hand rails) had worn off.  The play area for four-year-olds was small and had only one climbing structure.  A section of bleachers, which faces the junior high practice field, sat on the main playground, creating a potentially dangerous area for the younger children who are naturally attracted to climbing.  Many classroom windows were dirty or covered with tape residue.  We noted a small amount of litter near the cafeteria.  Outside the main office, a large stack of boxed supplies detracted from the otherwise neat appearance of the entry.  The cafeteria was colorless and lacked any decoration, resulting in a banen, institutional look.  The school apparently did not allow children to converse during their lunch time as adults constantly chided children for talking. While none of the reprimanded children were being overly loud, nearly all the adults spoke loudly to the children. One lunchroom supervisor was especially harsh with the preschool class by instructing them to put your head down and close your mouth.  Some of the ceiling tiles in the media center showed signs of water damage.  The globes on display in the media center were out of date.Otter Creek Elementary School We were pleased to note that: The campus was mowed and litter free. Floors throughout the building were clean and shiny. While little student work was on display, the halls featured a variety of attractive teacher-made bulletin boards. The cafeteria was clean and spacious, and all tables and seating were spotless and in good repair. The large media center was neat, clean, attractive, and appeared ready for student use. An attractive bulletin board in the media center illustrated the awards children could earn with points awarded for their good behavior. The furnishings and carpet in the media center were in good condition. The girls restroom in the main hall was clean and odor free. In the boys restroom, all plumbing was functioning normally, and the common basin area had paper towels. We also noted some areas needing attention:  No flag was flying.  A downspout near the main entry was causing a great deal of erosion.  Some classrooms lacked identifying room numbers.  Several areas of the hall ceilings were water stained and warped.  A grouping of large wooden cabinets, which appeared to be used to store materials for the afterschool CARE program, cluttered the hall near the cafeteria.  The girls restroom in the main hall lacked soap and had some floor tiles that were damaged or missing.f Rightsell Elementary Incentive School fVe were pleased to note that:  The exterior of the school was very attractive\nthe buildings dark red trim was in excellent condition.  The campus was neat and litter free.  The interior halls were bright and welcoming.  A striking mural enhanced a wall near the office, and colorful displays abounded.  The interior paint was in good condition, and the carpets were clean.  The schools Parent Center was fully furnished and in use during our visit.  The cafeteria floors were waxed, clean, and shiny, and the tables and seats were clean and in good condition.  The cafeteria and other areas of the building were decorated with inspirational posters and banners (such as Believe, Achieve, Succeed)  The media center was neat, clean, well stocked, and attractively appointed.  The boys restrooms contained paper towels and toilet paper, and all fixtures were functioning. We also noted some areas needing attention:  No flag was flying from the flagpole.  The play area assigned to four-year-olds was very small and featured only one piece of climbing equipment.  An odor, which seemed to emanate from the workroom, caused the basement area to smell very foul.  The basement area had a severe leak that left the carpet soggy and malodorous.  The classroom adjoining the basement area had wet spots along the adjoining wall.  While fully supplied, the girls restroom in the basement had an unpleasant odor (as did the entire basement).  Some baseboards in the girls restroom were damaged or missing.  The linoleum flooring was ripped in the boys restroom on the second floor.Wakefield Elementary School We were pleased to note that: The playground offered good equipment for younger children and lots of shade trees. Several picnic tables had been recently added to a pleasant shaded area. The floors were clean and highly polished. A large display board, featuring color photographs of each class, dominated the entryway. The 4-6 building had several colorful wall murals. Large, brightly colored paper banners, identifying rooms and specialty areas, hung along the corridors. The cafeteria was clean and the furnishings were in good repair. Ceiling fans improved air circulation in the cafeteria. A beautiful, wood-beamed ceiling accentuated by decorative dropped lighting gave the cafeteria a very homey appearance. Cafeteria workers set the tables with eating utensils for the kindergarten students. The girls restrooms had adequate supplies of paper products, and all the stall doors had locks. The boys restrooms were supplied with paper products and soap, and the floors and tile work were clean. We also noted some areas needing attention:  The windows, which form much of the exterior walls, have aged shabbily.  The asphalt covering one of the two basketball courts was broken and dangerous.  A seriously eroded area between two buildings created an eyesore and a hazard for children.  The concrete walk in front of the 4-6 building was badly damaged.  Ventilation in the corridors was nonexistent.  Two double fountains were inoperable, one because it lacked knobs and the other because water pressure was too poor to create any flow.  A large panel was missing from the display case, leaving unsightly globs of mud-colored adhesive.  The 4-6 building was not handicapped accessible.  Several desks with attached chairs were lined up against one corridor wall.  The wooden blinds attached to the cafeterias serving window were badly broken and could not be closed after lunch. As a result, according to a cafeteria worker, students would sometimes crawl through the opening and get into the kitchen area.  The dishwasher was leaking and creating a safety hazard\nthe kitchen had no wet mats.  The stage floor was scratched and chipped.  Several pieces of classroom furniture and work equipment, such as a paper roll stand, were on the stage.  The media center was small and appeared to have been converted from a classroom.  Shelving and equipment was crowded into every nook and cranny in the media center, but the specialist had arranged enough seating to accommodate a full class.  The carpet in the media center had two tom ragged seams across the entire room.  Although litter-free, one girls restroom was marred by graffiti on the stall walls. Another girls restroom was clean, but contained several pieces of litter.  One girls restroom had a small piece of soap, and the other had none.  In the girls restrooms, sinks were badly chipped and stained, one ceiling panel was missing and others were chipped and gouged, the stalls contained no disposals for feminine hygiene products, the floor under one sink was wet (possibly from a leak), several floor tiles were missing, and the cinder block walls in one of the restrooms were damaged badly.  One boys restroom had an unpleasant odor.Washington Magnet Interdistrict Elementary School We were pleased to note that:  The playground included well-made climbing structures, two paved basketball courts, and good grassy areas.  A paved drive traversed the entire length of the back lawn, allowing furniture to be moved easily in and out of classrooms.  The corridors reflected the buildings recent construction and were clean and attractive throughout.  Natural light coming from sky lights located near the entryways created a pleasant atmosphere.  The hallways were clean and the floors were spotless.  Colorful display boards featured several different themes (such as the environment, math in art, and map reading) that served to educate the viewer.  Each classroom area had tack strips attached to the concrete block walls, providing an easy way to display student work. Lots of student work was visible, including art displays and test papers.  Specialty rooms (such as art and Student Improvement Program for Success [SIPS]), were distinguished by colorful banners hanging outside the door.  The cafeteria was clean and the furnishings were in good repair.  Mats were in front of the doors leading from the kitchen to the outside.  The kitchen area was very well ventilated and air conditioned.  The large room housing the media center included lots of attractive book shelves.  A large storage room adjacent to the media centers entry provided adequate storage for audio visual equipment.  The girls restrooms had plenty of paper products and handicapped accessible stalls that included two handrails.  One of the girls restrooms had a dispenser for feminine hygiene products.  The hand washing station located between the boys and girls restrooms had plenty of soap.  The boys restrooms were well supplied and functional. We also noted some areas needing attention:  The flagpole was bare.  The playground lacked adequate shade.  Some exit doors were not secure.  The drop-in ceiling tile showed water damage from a leaky roof.  Carts and boxes cluttered the aisles in the kitchen, creating a safety hazard.  The kitchen contained no wet mats.  The stage curtain was tom and faded, and the carpet covering the stage was worn, stained, and wrinkled.  Multiple carpet stains in the media center detracted from the beauty of the room and its furnishings.  In the girls restrooms, locks were broken on some stalls, and the disposals for feminine hygiene products were missing bottoms, making them unusable.  In some of the girls restrooms, lighting was very poor, a ceiling panel was missing and others were water-stained, and one handicapped accessible stall had a very sharp turn, making it difficult to maneuver in a wheelchair.  Two girls restrooms contained litter on the floors and in the sinks, and one restroom had no identifying sign on the door.  The boys restroom near the front entry was messy from recent use.Forest Heights Junior High School We were pleased to note that:  The exterior of the building was well tended and despite a very dry, hot summer, the ground plantings were in good condition.  The shaded courtyard where students gathered to sit at picnic tables and on benches was litter free.  The entryway and all corridor floors were polished to a high shine.  Waste baskets were placed at intervals along each corridor, and no litter was evident anywhere on the campus.  Concrete walls were attractive and lockers were in like-new condition.  Some exterior doors in the older building were decorated with colorful murals.  Stairways were well lit and wide enough for heavy traffic.  The buildings and classrooms were very quiet.  Fire extinguishers were highly visible and plentiful.  The cafeteria was spotless and the tables were in good repair.  Wide aisles in the kitchen facilitated traffic flow.  The gymnasium was old but well maintained and had handicapped seating available in the bleacher area.  The basketball court sparkled, and the locker rooms were clean and neat.  The media centers special lighting over the checkout desk and magazine section greeted visitors with a dramatic effect, almost like sunlight. The room had well-kept carpeting, educational displays, attractive furnishings, an eye-catching materials collection, and a computer work station that was on-line to the Internet.  The girls restrooms were exceptionally clean with no litter or graffiti\nthe sinks and faucets (including those in the older buildings) were in excellent condition\nthey had plenty of paper products available\nthe stall doors looked new\nand each restroom was handicapped accessible.  The boys restrooms in the main building were spic-and-span, well supplied, and furnished with mirrors that glistened. The boys restrooms in the older sections of the building were similarly clean, despite their age. We also noted some areas needing attention:  The raised planting beds were overgrown with weeds.  The older areas of the campus had serious soil and concrete erosion.  The courtyard where students gathered was banen from heavy traffic.  One stairwell window had a horizontal crack that ran the entire length of the casement.  The cinder block wall at the entrance to the cafeteria was badly soiled and stained, creating a very unsightly and unappealing appearance.  In the cafeteria, the stools were in poor condition and the ceiling tile was seriously water damaged.  In the kitchen, the wet areas lacked mats\nseveral floor tiles were chipped, cracked, or broken\nan oven was broken\nand a wheel was missing from a large milk cart, causing it to tip to one side.  The temperature in the gymnasium was near 100.  Some girls restrooms lacked soap and disposals for feminine hygiene products.  The ceiling in one girls restroom that was located in an older building was badly peeled and insulation was pulled from one section of a heating vent pipe.  One restroom had no identifying sign.Mabelvale Junior High School We were pleased to note that:  The campus was immaculate. Lawns surrounding the school and in the courtyard were neatly mowed, and the entry was accented by a planting bed filled with perennials and a blooming crape myrtle.  Breezeways featured plenty of lined trash cans, and the campus was litter free.  Both the state and national flags were properly displayed on the pole in front of the school.  The school secretary was very friendly and welcoming, and the principal was very helpful and exhibited a pleasant demeanor with both students and adults.  Class change was orderly and plenty of adults were present.  The lockers were in good condition and free of graffiti.  In the cafeteria, the tables and seating were clean and in good condition, the floors were waxed and clean, the ceiling tiles were in good repair, and all flourescent lights were functioning properly.  The cafeteria was a comfortable temperature despite the 100 outside temperature.  The kitchens temperature was moderated by several fans, including a large window-mounted fan.  Kitchen lighting was adequate, and both a sprinkler system and a hand-held fire extinguisher were present.  The library had recently been recarpeted with a neutral-colored carpet that was attractive and coordinated well with the existing furnishings and decor.  The gymnasium was very warm, but some relief was provided by a large fan and open doors.  Both the gymnasium floor and bleachers were in good condition.  The girls restroom we visited was bright, clean, odor free, and fully supplied, but it lacked soap dispensers, although bar soap was available.  All toilets, urinals, and basins were functioning properly in the boys restrooms, and all the floors were in good repair, clean, and free of litter.  The boys restrooms were stocked with paper products and were well ventilated to keep down heat and odor. We also noted some areas needing attention:  The campus included several portable classrooms, most of which were unsightly.  While all other parts of the school were connected by covered walkways, students had to walk unprotected to all the portable buildings.  The water fountain near the restrooms on the second level was not operable.  Sections of floor tile were missing at the both the entrance and exit to the cafeteria.  Possibly due to its recent renovation, the library did not appear ready for students to use.Hall High School We were pleased to note that:  The litter-fi-ee campus, which had been recently mowed, included a variety of blooming annuals, as well as shrubs and trees. Attractive picnic tables and benches were scattered around the courtyard areas.  In keeping with Halls role as an LRSD Newcomers Center for non-English speaking students, signs in the front foyer welcomed visitors in several languages. The Newcomers Center is conveniently located, and bulletin boards with multilingual themes are present in the corridors.  The front doors were spotless and looked as if they had just been painted.  The entry hall featured a well-maintained planter filled with tropical plants.  Staff members and security officers were present throughout the campus.  Security personnel were very respectful, firiendly, and helpful to both visitors and students.  The halls contained a variety of bright banners and bulletin boards, and one corridor included an excellent display featuring Native American art. A Cleanliness is Contagious sign encouraged students to join efforts to keep the building clean.  Floors throughout the building were clean and shiny.  All fountains were functioning with adequate water pressure.  Hallway intersections were labeled with arrows and numbers to help students find their way.  Cafeteria floors were polished and free of debris despite the lunch crowd being present. Furnishings were in good repair and clean, and several colorful wall murals brightened the room.  The serving personnel were very efficient and courteous.  The kitchen area was spacious, allowing easy movement during food preparation and serving times.  The design of the media center was attractive and provided opportunities for developing reading and specialty centers. Computer work stations were scattered around the large room. The carpeting and furniture were well maintained.  All aspects of the gymnasium featured the schools colors, from the walls to the bleachers.  An attractive mural of Native Americans on horseback, symbolic of the schools mascot (the Warriors) adorned part of one gymnasium wall.  The gyms playing surface was shiny and in excellent condition, and the bleachers were functional, free of graffiti, and in good repair.  The restroom in the girls locker room was clean and supplied with paper products.  The entire area in the boys locker room was immaculate. The restroom was supplied with paper products and all plumbing was functioning normally. The dressing area contained well-maintained lockers in the school colors.  The girls restrooms were very well lit and had colorful, well-maintained floor tiles, good ventilation and pleasant air quality, and plenty of soap and paper products.  The girls restroom in the math building was clean, odor-free, and fully supplied with paper products.  Boys restrooms were clean and well supplied. We also noted some areas needing attention:  No flags were displayed on the flagpole located on the east side of the building.  A large pile of discarded furniture was stacked behind the kitchen, apparently awaiting removal.  The ceiling tiles in the area adjacent to the cafeteria were water stained and warped.Hall High School Page 2 Some exterior doors were not secured. A wall in an alcove by the cafeteria had a diagonal crack approximately two feet long. Ceiling tiles in the 400 corridor had been vandalized. A large alcove by the serving area contained several pieces of equipment and supplies, creating a very unsightly view from the eating area. The ceiling plaster over the serving lines was peeling, creating a health hazard. In the kitchen, door plates were protruding in two entryways, several floor tiles were missing, and no wet mats were accessible. The bottom windows in the kitchen lacked screens\ntherefore, they could not be opened to improve air flow. In the girls locker room, several of the lockers were damaged and a strong pungent odor evident, even though no PE classes were being held on the day we examined the facility. The restroom in the boys locker room lacked stalls and soap. was  The girls restrooms contained some litter and graffiti. None of the stall doors had locks, and some stall doors had no exterior handles.  One of the girls restrooms was not handicapped accessible.  The girls restroom in the math building lacked soap, and the restroom in the girls locker room lacked a dispenser for feminine hygiene products.  One of the girls restrooms had wall tiles that contained several holes as a result of missing plumbing fixtures. In another, one side of a heating unit had broken away from the wall, making the unit appear to be slipping down the wall.  Two of the boys restrooms had been damaged to the extent that toilet seats and a stall door were missing.Date: November 24, 1998 To: Melissa From,!' Ann Re: Follow Up on SWAT Monitoring I need you to do a follow-up on some of the schools that were the subject of our first-of-the-year swats in August. I want to know the extent to which the schools have corrected the problems we noted early in the school year. Im particularly interested in the schools listed below, because they seemed to be the ones with the most problems that could be corrected without major undertakings (such as enlarging the media center, for example). If you have others you want to investigate, thats fine. You dont have to monitor the whole school\npay particular attention to the areas that the team rated as needing attention to determine whether or not improvements have been made. That list can serve as your monitoring guide, although you might also see other things that you want to comment on. Depending on what you uncover (really good or really bad), well discuss whether to write up your findings in some sort of follow-up communication to the superintendents. Regardless, let me have your written findings in a list format that follows that of the SWATs. Unless you get some unexpected action on your enrollment figures to put you back on that report, plan on giving me this information by December 11. Thanks very much. LRSD PCSSD NLRSD Bale Elementary Cloverdale Elementary Wakefield Elementary Hall High Bates Elementary Jacksonville Elementary Oakbrooke Elementary Robinson Junior High Mills High Boone Park Elementary Lakewood Middle SchoolDate: December 10, 1998 To: From Melissa Re: Swat Follow-up Thanks for your good work on the Swat follow up. Looks like the schools and districts made many improvements, but also a significant number of detractions remain. Im appalled by some of the indefensible adult behavior you noted, especially at Bates, environments. What despicable role models! Talk about negative learning I think we should send this information out. It shows that were keeping our eyes open, and it will alert the schools and superintendent to areas that need attention. Hopefully, the comments on adult behavior will get some action. I idly made some editing notes as I read your findings, although I know you werent writing a document for publication. Please make all needed changes and compose a draft letter that I can send to the superintendents with copies to the principals. Thanks very much. Memo To: Ann From: ( Melissa Subject: Follow-up to Swat Visits Date: December 10, 1998 Attached are copies of my findings regarding the schools due for follow-up visits. As you asked, this format mirrors the original. If we decide to send the information to the schools, I think that the format might need to be revised somewhat. Let me know what you think. Thanks!Bale Elementary School We were pleased to note that: Thecate and National flags were flying. The asphalt in the parking lot had been repaired. The exterior was neat, attractive, and litter-ffee. The interior of the school was clean and filled with attractive holiday decorations. An appealing display featuring a Christmas tree, wrapped presents, and toys brightened the spacious entry area. A large floor mat personalized with the school name also brightened the entry. The floors were clean and shiny, and the staff had clearly made the most of an older, rather plain building. The formerly cluttered areas of the stage and cafeteria had been cleared and now appeared neat and tidy. Students and staff were polite, friendly, and very orderly. We also noted some areas needing attention: While locks had been added to the stall doors in the girls restroom, the fittings were not properly aligned and the doors would not lock. Water pressure in the girls restroom was still poor. The boys restroom still had a very strong urine odor.Cloverdale Elementary School We were pleased to note that: The oflBce and the surrounding area were neat and uncluttered. An attractive bulletin board enhanced the appearance of the outer office. Most of the windowsjooked as if they had been washed since our last visit, but some tape residueandpaint gplash^ remained. Staff members wereln^dly to visitors. No flag was flying, but our follow-up visit took place on a rainy day when it would have been inappropriate to displayZL  We also noted some areas needing improvement: The front of the school was quite littered. No change had been made in the unadorned, institutional cafeteria. Throughout the school, we heard adults shouting at students who were going to and from lunch. In the cafeteria the adults routinely spoke very sharply to the children. These same adults would the^speak very pleasantly to other staff members or visitors. Conditions in the media center were unchanged. Although the space was neat and attractively decorated, the only globes were out of date. Playground conditions were unchanged.Wakefield Elementary School We were pleased to note that: Staff members were fiiendly and welcoming. Workers were in the process of removing the large quantity of recently fallen leaves that covered the grounds. What had formerly been unsightly, damaged display case had been replaced with a new, large bulletin board. New lettering proclaiming the school name had been applied to the exterior of the building. The broken dishwasher in the kitchen had been repaired. The stage floor was clean and usable^ but some furniture and paper rolls were stored around the perimeter. We also noted some areas that needed attention: The flag pole did not display either the state or national flag. The front walk and other areas of the campus were littered. The concrete slabs that anchor some of the basketball goals protruded several inches above the surrounding terrain. These rough concrete slabs pose both a tripping hazard and danger to anyone who might fall or be knocked down in that area. The broken wooden blinds in the cafeteria still had not been fixed. Nearly all of the problems noted with the facility in August still remain. The principal indicated that she had sent in work orders for each of the items mentioned in our earlier summary.Hall High School We were pleased to note that: Flags were flying in front of the school. A member of the security staff was stationed at the main entrance, monitoring the parking lot. All exterior doors, except the main entry were properly secured. The office staff were very friendly and welcoming. Staff and students throughout the school were fnendly and helpful. The overall impression of the school was very positive. The grounds were neat, and the interior was clean with shiny floors. The large pile of discarded furniture outside the cafeteria had been removed, and the area was spotless. The cluttered alcove near the cafeteria serving area had been cleared and the entire area looked neat. The peeling paint over the serving line had been scraped and workers had applied some type of opaque primer over the spots. We also noted some areas needing attention: The kitchen still lacked window screens. No repairs had been made to the damaged kitchen floor. The girls locker room was odor-fiee and relatively neat, but it suffered from some vandalism. Two of the five restroom stalls were missing doors, and one of the commodes was missing its seat. Restrooms throughout the school were clean, odor-free, and supplied with soap and paper towels. When we visited late in the day, some of the stalls lacked toilet paper. While the restrooms were not disreputable, many were showing their age. Few of the restroom stalls had locks.Bates Elementary School We were pleased to note that: The broken birdbath had been removed from the front lawn. Both the state and the national flags were flying. , -7 The exterior of the school was enhanced by large, healthy holly trees.  The office staff was fnendly and welcoming even though they were also involved in hosting a COE visit from ADE. More student work was on display than the last time we visited. We also noted some areas needing attention: Students were running and shouting in the hall after leaving the cafeteria. Conditions in the cafeteria had not changed since our earlier visits. One boys restroom lacked any type of identifying sign. Odor in several restrooms was still strong. The handicapped stall in one restroom was locked. We noted one teacher who was being terribly verbally abusive to her first grade students. The children had been running in the hall and two of the group were involved in some horseplay. The teacher screamed at the top of her lungs at the entire group. She yelled at the entire class in a loud and abusive voice and finally took two children to the office to call their parents. When she left for the office, she left the remainder of the children unattended. A monitor remained in the room with the class for about ten minutes until a group of older student helpers arrived.Jacksonville Elementary School We were pleased to note that: The grounds were neat and attractive. The entire school was very clean and attractively decorated with an international holiday theme. The stage was set for an upcoming play. The storage area behind the stage contained a variety of furniture and other items, neatly stored. While stall doors still lacked locks, the girls restrooms were clean, free of odor and litter, and supplied. Staff and students were very fnendly and welcoming toward visitors. We also noted some areas needing attention: Conditions in the kitchen were unchanged from our previous visit. The principal said that they have wet mats, but the mats were not visible because they were taken out and washed each day after lunch. The principal also indicated that she had the Fire Marshal return to the school, and that he assured her that the kitchen met their safety standards. A work order had been turned in regarding the garbage disposal, but it was not yet repaired.Oakbrooke Elementary School We were pleased to note that: The grounds were neat and free of debris. The school was attractively decorated with seasonal displays of student work. The gym area of the former Woodland Hills building was much neater than when we visited in August. The flaking paint in the hall had been scraped and repainted. Floor mats at each entry ensured that the floors remained clean and dry on a rainy day. While a portion of the third grade hall was still being used for storage and photocopying, the work area was quite neat. No flag was flying, but our follow-up visit took place on a rainy day when it would not have been appropriate to raise the flag. A new, large wall map had been added to the media center. We also noted some areas needing attention: One of the restrooms still lacked any identifying sign. While a new map had been purchased for the media center, the large globe displayed near it was out of date. Handrails were quite rusty. The mismatched floor tiles still marred an otherwise clean and shiny floor.Robinson Junior High School We were pleased to note that: The office door had been repainted The fallen tree and other organic debris noted in August had been removed. Qldtlhe courtyards were in the process of being raked. The principal and office staff were fnendly and welcoming. We also noted some areas needing attention: None of the other items noted as needing attention in the August report had been addressed. All the other deficiencies remained in virtually unchanged condition. As the principal notec^ many of the items on our list would require an investment by the PCSSD. One no-cost item was also ignored# -nee again, no flags were flying.Mills High School We were pleased to note that:  The public spaces appeared generally neat and attractive.  Work had obviously been done on the restrooms. The walls had been repainted as had the graffiti covered stall partitions. Girls restrooms were odor-free and supplied, but many stalls lacked a toilet paper dispenser.  The new computers in the media center were now available for Internet access.  Students were very fnendly, and students dining in the cafeteria were very well-behaved. The atmosphere in the cafeteria was relaxed and pleasant. After students concluded their meals, they engaged in a variety of activities including guitar playing, dominoes, and card games. Several staff members were on duty in the area. We also noted some areas that needed attention:  Other than some improvement to the restrooms, we noted little improvement in the deficiencies noted in the August report.  The kitchen floor remained in very poor condition. More tiles were missing than noted at the beginning of the school year. Kitchen staff reported that a worker tripped and fell in early October.  The areas around the dumpster continued to be littered and unsightly.  The unofficial smoking area located outside the auditorium^as a blight with discarded chairs, an old mop, and assorted other broken and rusting furnishings.  The faulty locking device on the folding bleachers has not been repaired.  While the new computers in the media center are no online with the Internet, they are not fully operational. Students cannot print from these terminals or use them for any task other than Internet access. The new file server has not yet been installed, and this limits the capability of the entire system of computers in the media center. Student demand for computer time far outweighs the available equipment.Boone Park Elementary School We were pleased to note that: \u0026gt; * t y if 3 The exterior of the school looked neat and attractive and was free of litter. The hallways were clean, bright, and well-lit. The entire interior of the building had recently been repainted in a cream and blue color scheme. The fresh, cream-colored hall walls really brightened the interior spaces. All classrooms had been labeled with both the teachers name and the room number. Students were quiet and orderly in the halls and the cafeteria. Restrooms were clean and supplied with the basics, except paper towels. Teachers stood just outside the restroom doors distributing paper towels to the children. The broken window in the auditorium door had been repaired. We also noted some areas that needed attention: e No flags were flying from the flag pole. Exit lights in the cafeteria remained unlit. V The wall-mounted cork strips in the halls were damaged and unsightly in some spots.Lakewood Middle School We -were pleased to note that: c The flags were properly displayed from the pole in front of the building. All exterior doors, except one, were locked. ' The entire campus was neat and free of litter. ' The interior of the school was neat, litter-free, and attractively decorated with student art and seasonal touches. ' Installation of the new elevator had been completed. The elevator blended beautifully with the existing building and looked as if it could have been original. Stairwells were uncluttered. Repairs to the girls restroom near the office had been completed. ' All restrooms were neat, supplied, and well-lit. We also noted some areas needing attention: ' While the school is very attractive and well-kept, it is about due for interior repainting. Many spots such as hand rails have worn, chipped paint.Office of Desegregation Monitoring United Stales District Court  Eastern District of Arkansas Ann S. Brown, Federal Monitor 201 East Markham, Suite 510 Heritage West Building Little Rock, Arkansas 72201 (501)376-6200 Fax (501) 371-0100 January 7, 1999 Les Carnine, Superintendent Little Rock School District 810 West Markham Street Little Rock, AR 72201 Dear Les: As you know, at the beginning of each school year, ODM monitors make brief, informal visits to some schools in all three Pulaski County school districts. In September, I sent you the summaries of our visits to LRSD schools. In December we paid brief, unannounced, follow-up visits to a few of those same schools. We selected for follow-up those schools that had a number of deficiencies which the district could address without major building modifications. During the December visits, our monitoring concentrated on those areas we had noted as needing attention at the beginning of the school year. We also made note of any improvements we observed. We hope that the enclosed comments give you and your staff the benefit of our impressions. As has been our custom, we will not publish or file these observations at this time, although we might eventually include them in some aspect of a formal report. Please don t hesitate to call if you have any questions or comments. Sincerely yours, Ann S. Brown Enc. cc: Building principalsBale Elementary School IVe were pleased to note that:  The state and national flags were flying.  The asphalt in the parking lot, which had been riddled with potholes, had been repaired.  The exterior was neat, attractive, and litter-free.  The interior of the school was clean and filled with attractive holiday decorations.  An appealing display featuring a Christmas tree, wrapped presents, and toys brightened the spacious entry area.  A large floor mat personalized with the school name also brightened the entry.  The clean and shiny floors, a wealth of attractive displays, and brightly decorated classrooms indicated that the staff had made the most of an older, rather plain building.  The formerly cluttered areas of the stage and cafeteria had been cleared and now appeared neat and tidy.  Staff and students were polite, friendly, and very orderly. We also noted some areas that still had not been addressed:  While locks had been added to the stall doors in the girls restroom in the main hall, the fittings were not properly aligned and the doors would not lock.  Water pressure in the girls restroom was still poor.  The boys restroom still had a very strong urine odor. Cloverdale Elementary School IVe were pleased to note that:  The office and the surrounding area were neat and uncluttered. An attractive bulletin board enhanced the appearance of the outer office.  Most of the windows looked as if they had been washed since our last visit, but some tape residue and paint splashes remained.  Staff members were friendly to visitors.  No flag was flying, but our follow-up visit took place on a rainy day when it would have been inappropriate to display a flag. We also noted some areas that still had not been addressed:  The front of the school was quite littered.  No change had been made in the unadorned, institutional-looking cafeteria.  Throughout the school, we heard adults shouting at students who were going to and from lunch. In the cafeteria the adults routinely spoke very sharply to the children. These same adults would then speak very pleasantly to other staff members or visitors.  Although the space was neat and attractively decorated, ceiling tiles in the media center had not been replaced. The only globes were out of date.  Playground conditions were unchanged: play equipment for the four-year-olds was still limited, and bleachers still occupied one section of the larger play area.Wakefield Elementary School We M ere pleased to note that:  Staff members were friendly and welcoming.  Workers were in the process of removing the large quantity of recently fallen leaves that covered the grounds.  What had formerly been an unsightly, damaged display case had been replaced with a new, large bulletin board.  New lettering proclaiming the school name had been applied to the exterior of the building.  The broken dishwasher in the kitchen had been repaired.  The stage floor was clean and usable, but some furniture and paper rolls were stored around the perimeter. We also noted some areas that still had not been addressed:  The flag pole did not display either the state or national flag.  The front walk and other areas of the campus were littered.  The concrete slabs that anchor some of the basketball goals protruded several inches above the surrounding terrain. These rough concrete poses both a tripping hazard and danger to anyone who might fall or be knocked down in that area.  The broken wooden blinds in the cafeteria still had not been fixed.  Nearly all of the problems noted with the facility in August still remain: weathered walkways, the general disrepair and lack of handicapped access to the building serving grades 4-6, run-down restrooms, inoperable water fountains, and the like. The principal indicated that she had sent in work orders for each of the items noted in our earlier summary.Hall High School IVe were pleased to note that:  Both the state and national flags were flying in front of the school.  A member of the security staff was stationed at the main entrance, monitoring the parking lot.  All exterior doors, except the main entry, were properly secured.  The office staff were very friendly and welcoming.  Staff and students throughout the school were friendly and helpful.  Our overall impression of the school was very positive. The grounds were neat, and the interior was clean with shiny floors.  The large pile of discarded furniture outside the cafeteria had been removed, and the area was spotless.  The cluttered alcove near the cafeteria serving area had been cleared and the entire area looked neat.  The peeling paint over the serving line had been scraped and workers had applied some type of opaque primer over the spots. We also noted some areas that still had not been addressed:  The kitchen still lacked window screens.  No repairs had been made to the damaged kitchen floor.  The girls locker room was odor-free and relatively neat, but it suffered from some vandalism. Two of the five restroom stalls were missing doors, and one of the commodes was missing its seat.  Restrooms throughout the school were clean, odor-free, and supplied with soap and paper towels. When we visited late in the day, some of the stalls lacked toilet paper. While the restrooms were not disreputable, many were showing their age.  Few of the restroom stalls had locks.\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 Resoources.\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_1502","title":"Testing: Benchmark Examination comparison, Little Rock School District, Primary, Grade 4","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":["Little Rock School District"],"dc_date":["1998/2000"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. 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District Court (Arkansas: Eastern District)","Joshua Intervenors"],"dc_date":["1997-12-12"],"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--20th century","Joshua Intervenors","Little Rock School District","Education--Arkansas","Education--Economic aspects","Educational law and legislation","Lawyers","Education--Evaluation","Educational planning","School management and organization"],"dcterms_title":["Court filings: District Court, emergency motion of the Joshua intervenors concerning the payment of attorneys' fees by the Little Rock School District (LRSD)"],"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/1697"],"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":["judicial records"],"dcterms_extent":["53 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.  I  FILED U.S. DISTR ICT COURT IN THE UNITED STATES DISTRICT COtmTERN DISTRICT ARKANSAS EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION DEC 1 2 1997 LITTLE ROCK SCHOOL DISTRICT vs. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. NO. LR-C-82-866 RECEIVED DEC 1 5 1997 OFFICE OF DEFENDANTS INTERVENORS INTERVENOR Emergency Motion of ~~Wt{-hWNlmifHGrvenors Concerning The Payment of Attorneys' Fees by the LRSD The Joshua Intervenors respectfully move for the entry of an order providing for the payment of interim attorneys' fees by the LRSD to intervenors, periodically, in the manner described at the conclusion of this motion. The purpose of this motion is to ensure that the plaintiff class has adequate representation in the proceeding to consider the proposed, revised plan of the LRSD, and thereafter. This motion is based upon the accompanying memorandum and the following allegations: (1.) The LRSD has filed a motion, which this court has scheduled for a hearing beginning February 2, 1997, seeking approval of a \"Revised Desegregation and Education Plan.\" This plan is 16 pages in length. In contrast, the current plan of the LRSD is approximately 230 pages in length and the Interdistrict Plan is 64 pages in length. (2.) It is the stated purpose of the LRSD, in part, to have 1 / the Revised Plan \"supersede and extinguish\" the current LRSD Plan and the Interdistrict Plan. Revised Plan, at 1. (3.) The Revised Plan is in substantial part and in areas of critical importance merely an outline for a plan, rather than a plan that could be enforced by the court. For example: (a.) In 15 instances, in paragraphs II.B. through II.P, the words \"LRSD shall implement programs, policies, and\\or procedures,\" followed by a particular subject matter, appear. Revised Plan at 1-3. The \"programs, policies, and\\or procedures\" are not identified in the Plan. Compare Rule 65(d), Fed.R.Civ.Pro. (b . ) In Part V. of the Revised Plan, which deals with \"Student Achievement,\" the Plan specifies outcome goals for students in a way making it impossibe to determine the level of mastery intended. See Parts V.B.1.a. (at 8), V.B.2.a. (at 9-10), and V. B. 3. a. ( at 10) . (c.) In Part VII, the Revised Plan addresses a \"Compliance Program,\" without setting forth compliance standards. Revised Plan at 13. (4 . ) The Joshua Intervenors propounded written discovery requests to the LRSD concerning the Revised Plan. See copy of answers attached as exhibit A. One purpose of the discovery was to determine if the LRSD was willing to work with the Joshua Intervenors to render Part II. of the Plan, addressing \"Obligations,\" more specific. The LRSD made a nonresponsive answer to this query. Interrogatory 4 at 3. 2 /  (5.) One purpose of the discovery was to secure the identification of the underlying \"programs, policies and procedures\" which would appear to be determinative of the efficacy of the plan with regard to the plaintiff class. The answers to written discovery indicate that to a substantial degree, the underlying materials have not been identified. See Interrogatories 2, 18, 19, 20, 21, 22(i), 23, 27, 30. (6.) One purpose of the discovery was to identify the reason or reasons why in many instances the proposed plan did not identify the particular programs, policies or procedures to be implemented. The LRSD responded that \"LRSD believes, in order for the Revised Plan to be successful, the details related to implementation of the revised plan must be subject to modification without district court involvement.\" Interrogatory 3. In responding to an interrogatory about school construction, the LRSD again indicated its intent to have the power to define and redefine standards determinative of the value of the revised plan for the plaintiff class. Interrogatory 23. (7.) The LRSD seeks the approval of a new plan which is vague and standardless in many important respects, and designedly so, in a context in which the court and ODM have, over the years, found the performance of the agents of the LRSD in implementing the court-approved agreements to be deficient. See, for example, the court's statement to the LRSD school board members in March 1993; Mem. and Order, March 11 , 1996, at 8 (\"The LRSD has frequently exhibited indifference or outright recalcitrance 3 I  . ' towards its comitments and has been slow to implement many aspects of its agreements although some improvements have been made.''); Transcript June 23, 1995, at 34, 72, 87; July 6, 1995, at 123-24, 176-77, 241. (8.) In view of the foregoing allegations, it is reasonable to characterize the activities of the Joshua Intervenors in responding to the Revised Plan as protecting the extensive relief, previously agreed upon and approved by the courts. However, the relief sought in this motion is appropriate whether or not the court agrees with the foregoing position regarding the proposed Revised Plan. (9.) Assuming for the purposes of this motion the existence of the agreement on future fees found by this court in its Memorandum Opinion and Order, September 25, 1996, at 6-7, the agreement dealt with \"the life of the settlement plans ... \" (Chachkin); see also Mr. Heller (\"in our settlement plans\"). The activities of the Joshua Intervenors to date and in the future, with reference to the Revised Plan which would \"supersede and extinguish\" the LRSD and Interdistrict plans, are outside the parameters of the agreement found to exist by the court. Therefore, the Joshua Intervenors should be permitted to secure fees and costs for such work, and other work related to the Revised Plan, in accord with the standards last discussed by the Court of Appeals for the Eighth Circuit in Jenkins v. Missouri, 115 F.3d 554 (1997). (10.) Assuming for the purposes of this motion the existence 4 I' of the agreement on future fees found by this court in its Memorandum Opinion and Order, September 25, 1996, at 6-7, it is appropriate, in the totality of the circumstances of this case, to modify the agreement to delete the limitation on fee awards in the post-judgment phase of this case [see Appeal of the LRSD, 949 F.2d 253, 258 {8th Cir. 1991)], thereby restoring the applicability of the standard discussed in Jenkins v. Missouri. supra. The agreement will have been in force for seven years, during which an extraordinary amount of activity by the representatives of the Joshua Intervenors has been necessary, both in and out of court, much due to the deficient performance of the agents of the LRSD. This deficient performance has often been noted by this court, as evidenced by the examples cited above. See also Transcript, August 19, 1996, at 102. In addition, the continuation of the agreement will undermine the ability of the Joshua Intervenors to adequately represent the class. See the attached Affidavit of John W. Walker. (11.) Considerable work will be necessary in connection with the consideration of the Revised Plan, including responding to voluminous written discovery requests submitted by LRSD to intervenors' representatives. In addition, the LRSD proposal is for the Revised Plan to take effect eight months hence and to be in effect for at least three school years. {12.) This court has the authority to provide for an interim .award of fees and litigation costs, particularly when needed to protect the functioning of the private attorney general concept. 5 --- -- - -----  (13,) With regard to the hourly rates sought for the work of the representatives of the Joshua Intervenors, as noted in the prayer for relief below, see the following materials previously filed: John W. Walker -- Fee Petition, Nov. 21, 1995, Aff. of John w. Walker, at 1-7, 12-14; Supplemental Response of the Joshua Intervenors, Aug. 29, 1996, at 7 and Enclosure Two; Robert Pressman -- The Joshua Intervenors Motion for an Award of Attorneys' Fees (Sept. 1996), Sept. 27, 1996, Declaration of Robert Pressman and Attachments; Joy C. Springer -- Fee Petition, Nov. 21, 1995, Affidavit of Joy C. Springer, at 1-5, 19-20. WHEREFORE the Joshua Intervenors respectfully pray that the court enter an order: (a.) declaring that the work of the Joshua Intervenors' representatives concerning the Revised Plan is outside the scope of the agreement, previously found to exist by the court, limiting fee awards; (b.) declaring that the agreement of the Joshua Intervenors and the LRSD is modified, pursuant to the .court's authority to modify a consent decree, by eliminating the limitation on fee awards in the postjudgment stage of this case (with the understanding that the general standard governing fees at the postjudgment stage of a case will then apply); (c.) providing that the LRSD pay the Joshua Intervenors' representatives monthly their reasonable fees and costs, upon submission of adequate documentation, with the court available to rule on any portion of a request considered by the LRSD to be 6 outside the bounds normally governing fee awards; (d.) providing that the fees be paid at the following rates: John w. Walker ($ 250 per hour), Robert Pressman ($ 200 per hour), and Joy c. Springer($ 50 per hour); and (e) providing that the LRSD shall have the right to request the court to reconsider the procedure detailed in (c.) and (d.) after it has been in operation for 12 months; (f) providing such other and\\or different relief as the needs of justice may require. Robert Pressman MA 405900 22 Locust Avenue Lexington, MA 02173 617-862-1955 W. Walker AR 64046 W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing pleading was sent via United States mail on thi D e 1997 to all counsel of record and sent via counsel for LRSD. 7 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. RECEiVED DtL 1 5 1997 I, John W. Walker, a.ffiant herein, state under oath the following: FLED U.S. DISTRICT COURT EASTERN DISTrllCT ARKANSAS DEC 1 2 1997 JAMES W. McCORMACK, CLERK Bv: PLAINTIFF = -~ t:lEP.eLE1:111: DEFENDANTS INTERVENORS INTERVENORS 1. A majority of the cases being handled by my office are in the nature of civil rights litigation. 2. The clients in these cases are usually not fee paying clients whereby this office could on a regular basis bill them for our services. There are in such a practice unexpected losses, such as when the entire fee in the Judy Smith case was lost due to the bankruptcy of Harvest Foods. 3 Many of these cases are handled on a contingency fee basis thus causing the office to utilize a substantial amount of the fees collected on other cases to be a basis for support of these cases. 4. In the case ofLRSD, when the Eighth Circuit awarded fees to be paid in the case herein, a substantial amount was paid to the Legal Defense Fund (LDF) and to the estate of Wiley Branton, Sr. who had worked on this case for many years. Moreover, a substantial amount of the fee award was expended for expenses incurred in connection with the litigation herein. Furthermore, because of the taxing accounting method for purposes of making payments to the Internal Revenue Service (IRS), and the Department of Finance and Administration (DFA), large amounts of the Little Rock portion of the fee award were paid in that year or the next for federal and state income taxes. S. The costs of the representation of the class are enonnous and involve fees and costs to staff who monitor the case and who assist class members in their efforts to secure or retain rights believed by counsel to be afforded by the settlement. 6. The present scheduled hearing involves considerable preparation time including discovery, costs of extensive depositions from the two superintendents and five major level administrators and response to the substantial set of interrogatories propounded to the plaintiff class. This time and expense involvement comes during the period of the holidays, the end of the year, and the beginning of of the new year, when there is a need for attention, not only to legal presentation, but also to the overall business. It also comes at a time when the Pulaski County Special School District (PCSSD) is launching a serious attack upon the court approved settlement plan and is seeking to be declared unitary .. 7. In order to provide the court with insight into the plaintiff, LRSD's, tactic to overburden an already weakened office (no fees for more than $1,000,000.00 worth of work over a seven year period), the Friday firm proposes to take depositions of our representative simultaneously with our deposing the Superintendent and the staff. A response to that undertaking takes considerable time and effort. It distracts from inquiry into the plan. It also comes at a time when we still have our monitoring obligations which become more time consuming as the semester end approaches, based upon past experiences. Moreover, we are further handicapped because of the fact that we do not have the benefit of the usual Office of Desegregation Monitoring (ODM) reports for the past eighteen (18) months which would reflect the current or ongoing status of the LRSD's implementation of the desegregation plan. 8. The class stands to be adversely affected if our preparation for and participation in the February 2, 1998 hearing is not adequate. As it stands now, although the public belief is to the contrary, a fee drought for seven years from this case leaves us unable to meet the efforts of defense - counsel, supported by unregulated and unlimited funds, in an effort to defeat the very plan which they bugled in 1989 before the Court and the 8th Circuit. I have read the foregoing statements and they are true and correct to the best of my knowledge information and belief. SUBSCRIBED and SWORN before me this ~day of December, 1997.  ()fa a' Poivelx  Ex h; h,t A IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. vs. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PLAINTIFF LRSD'S ANSWERS TO PLAINTIFF:S DEFENDANTS INTERVENORS INTERVENORS THE JOSHUA INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LRSD'S MOTION FOR APPROVAL OF THE REVISED DESEGREGATION AND EDUCATION PLAN Plaintiff Little Rock School District (\"LRSD\") for its Answers to The Joshua Intervenors' First Set of Interrogatories and Requests for Production of Documents states: INTERROGATORY NO. 1: Please state the name, title, address and telephone number of each and every individual assisting in the preparation of the answers to these interrogatories. ANSWER: Objection. This inte~rogatory requests information which is privileged under the work product doctrine and/or the attorney-client privilege. Without waiving this objection, LRSD states that the following persons assisted in the preparation of these answers: Dr. Les Carnine, Christopher Heller and John c. Fendley, Jr. INTERROGATORY NO. 2: In 15 instances in paragraphs II. B. through II. P. of the proposed new plan, the words \"LRSD shall implement programs policies and/or procedures\" followed by a particular subject matter appear. Please identify separately for OEC5S97 7 each ot these 15 paragraphs all programs, policies and procedures  which you maintain ar~ currently implemented and are intended to be encompassed by the reference in the particular subparagraph of Pa~t II. of the proposed plan. In addition, please specify when the implementation of the particular program, policy or procedure began. Lastly, as to each sub-paragraph, please indicate whether work is underway to develop a particular program, policy or procedure to implement the obligation and, if so, describe generally the nature of the initiative(s) and the anticipated completion date(s).  ANSWER: Except as otherwise provided in LRSD' s Revised Desegregation and Education Plan (\"Revised Plan\"), the obligations set forth in Section II were not intended to encompass any particular implemented. program, policy and procedure currently being As stated in Section XI of the Revised Plan, the 1997-98 school year will be a transition year in preparation for implementation of the Revised Plan during the 1998-99 school year. During the transition year, LRSD will be evaluating current programs, policies and procedures and developing new programs, policies and procedures to be implemented in order to meet its obligations under the Revised Plan. Some of this work has already been completed and is contained in the work team reports submitted to the LRSD Board of Directors in August of this year. INTERROGATORY NO. 3: Please explain the reason(s) that the proposed plan does not include in the 15 instances referred to in Interrogatory No. 2, or in any instance, the identification of the 11-.\"\"'4..,._jo,I,._ 2  particular programs, policies and procedures to be implemented. (If LRSD believes that there is identification of a particular standard in one or more instances, please answer as to obligations where you agree that there is no identification of a particular standard or program). ANSWER: The Revised Plan includes specific programs, policies and/or procedures with regard to student assignments (Section III \u0026 IV), African-American academic achievement (Section V), equitable allocation of certified personnel (Section VI) and compliance (Section VII). With regard to the remaining obligations, LRSD believes that, in order for the Revised Plan to be successful, the details related to implementation of the Revised Plan must be subject to modification without district court involvement. LRSD firmly believes that flexibility is essential to instilling in the  qistrict a_ sense of responsibility and accountability. INTERROGATORY NO. 4: Would the system refuse to support adoption of the revised plan if the plan included the identification of particular programs, policies and/or procedures, or other steps, to implement the \"obligations\" identified in Part II? If so, explain the reason(s) for the system's position. ANSWER: The Revised Plan does identify particular programs, policies and/or procedures. See Answer to Interrogatory No. 3. INTERROGATORY NO. 5: Do you agree that as written, there would be compliance with the provisions of II.B. through II.P. of the proposed plan if the system implemented, as to the particular sub-paragraph, programs QI: policies QI: procedures regarding the ~11..a\\lonl~-- 3 I I I I \\  particular matter addressed in the paragraph. If the answer is negative, please explain the basis for the answer. ANSWER: Yes. INTERROGATORY NO. 6: As the plan is written, would the court have the authority, in the opinion of the LRSD, to hold a system official (s) (sic) in contempt of court for failure to implement a term of a particular policy of the district, which the LRSD views as encompassed by one of the sub-paragraphs in II.B. through II.P. of the plan, but which is not specified in the plan. If your answer is in the affirmative, please explain the basis f~r the answer. ANSWER: Objection. This interrogatory calls for the lega1 opinion of counsel for LRSD which is privileged under the attorneyclient privilege. Without waiving this objection, LRSD states that the district court would have authority to enforce the Revised Plan using its contempt power. INTERROGATORY NO. 7: As the plan is written, does any provision of paragraphs II.B. through II.P. of the plan require any action on the part of the LRSD if at a particular school there is substantial racial disparity, atypical in the LRSD system, in the numbers of black students suspended, the numbers of black males placed in special education classes, or the numbers of black students in the gifted and talented program. If the answer is affirmative, please identify the provision(s) which is the basis of the answer. 4 \\ ANSWER: Paragraphs G., H. and I. of Section II state LRSD's I obligations with regard to special education, student discipline and gifted and talented, respectively. Compliance with the~e paragraphs would require LRSD to investigate a racial disparity which varies substantially from what would be expected. INTERROGATORY NO. 8: Do you maintain that the .LRSD complies, currently, with each obligation set forth in Part II. of the plan. If not, please describe in detail the area(s) of noncompliance. ANSWER: The obligations set forth in Section II encompass the core obligations from LRSD' s current desegregation plan. LRSD maintains that it has substantially complied with its current desegregation plan. INTERROGATORY NO. 9: With respect to II.B. of the proposed plan, please identify as to each category of positions to which it applies, the proportion black in the relevant labor market and the source of this information, and the proportion black of the work force at present. ANSWER: LRSD intends to rely on federal EEOC statistics for Pulaski County, the State of Arkansas and the nation as a whole to determine the percentage of qualified African-Americans in the relevant labor market. With regard to the proportion of AfricanAmerican teachers and administrators, see Exhibits A, B and C attached. LRSD's noncertified personnel is 73.8% African-American. INTERROGATORY NO. 10: With respect to II.C. of the proposed plan, please identify as to each category of positions to which it applies, the meaning of the words \"the pool of candidates eligible 5 for promotion\", the proportion black in that pool and the source of  the information, and the proportion black of the persons employed in the category at present.  ANSWER: The \"pool of candidates eligible for promotion\" includes current employees who satisfy all eligibility requirements imposed by law or by the Board for a position. LRSD objects to identifying every position for which every employee is currently eligible for promotion as unduly burdensome. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 11: With respect to II.D. of the proposed plan, please identify the positions covered within the term \"certified personnel\" and provide as to each category the number of persons currently employed in the LRSD by race . ANSWER: \"Certified personnel\" are LRSD employees who must possess teaching or administrative certificates issued by the State of Arkansas in order to hold their position. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 12: With respect to II.E. of the proposed plan, please identify any category of certified personnel where the LRSD does not have the right to assign personnel for the good of the system and the basis of the limitation. ANSWER: See Articles XV through XVIII of the PN Agreement, attached hereto as Exhibit D, and the Arkansas Teacher Fair Dismissal Act. 6 \". INTERROGATORY NO. 13: With respect to II.H. of the proposed e plan, please describe in detail any specific initiative(s) in the LRSD a.t present, whether involving particular personnel, or standards, designed to guard against black students' receiving discipline for conduct for which white students are not disciplined, black students' receiving discipline for trivial matters, and/or black students' receiving more severe discipline than white students for similar conduct. ANSWER: LRSD expects all of its students, regardless of race or socioeconomic background, to comply with the Student Rights and Responsibilities Handbook. If a student fails to comply, the student will be disciplined as provided in the Handbook. Discipline information including the race of the student, the race of the administrator, the nature of the offense and the sanction imposed is compiled by the schools and maintained by LRSD. LRSD's Associate Superintendent for information in an attempt discrimination. Student Discipline reviews this to identify possible racial INTERROGATORY NO. 14: With respect to II.I. of the proposed plan, please define, with specificity, the word \"qualified,\" as it applies to each of the three areas discussed in the obligation; namely \"extracurricular activities\", \"advanced placement courses\", and \"gifted and talented\" programs. ANSWER: The phrase \"qualified African-American students\" means African-American students who satisfy the eligibility criteria for an activity or program. For many activities and 7  programs, there are eligibility criteria other than student interest. INTERROGATORY NO, 15: With respect to II.J. of the propos~d plan, does LRSD agree that as written the system would be in compliance with this provision if the system continued to implement any two programs with its federal Title I monies to improve the academic achievement of African-American students. If not, lease (sic) explain the basis for the disagreement. ANSWER: No. LRSD must also implement the programs, policies and/or procedures set forth in Section V of the Revised Plan. INTERROGATORY NO. 16: With respect to II.L. of the proposed plan, please define the terms \"equitable allocation,\" \"technological resources,\" and \"educational resources.\" Also, please identify any data source allowing a determination of whether these resources are equitably allocated to LRSD schools at present. ANSWER: The phrase \"equitable allocation\" means to allocate based on need and without bias or favoritism. The term \"technological resources\" means up-to-date computer and information technology. The term \"educational resources\" includes teachers, teacher aides, equipment and supplies. With regard to a data source for determing whether these resources are currently equitably allocated, see the technology work team report, the individual school profiles and the LRSD budget. INTERROGATORY NO. 17: With respect to II.M. of the proposed plan, please define the term \"equitable\" and identify the matters encompassed in the terms \"maintenance and repair.\" In addition, 8 ., . please identify any source of data available to -ascertain compliance with this obligation on a school-by-school basis. ANSWER: The term \"equitable\" means based on need and witho~t bias or favoritism. The terms \"maintenance and repair\" include the routine upkeep of the building and grounds and the repair or replacement of elements of the building and grounds which are no longer functional. LRSD maintains records which would indicate maintenance requests submitted by schools, the priority assigned to those requests and when and if those requests were acted upon. INTERROGATORY NO. 18: With respect to II.N. of the proposed plan, please identify any specific initiatives currently undertaken in the LRSD to ascertain whether or not guidance or counseling services provided to African-American students involve steering to a restricted range of courses and/or postsecondary educational opportunities. ANSWER: LRSD recognizes that African-American students are underrepresented in upper-level courses and has implemented strategies to address that issue. Specifically with regard to guidance and counseling services, LRSD has requested a National Science Foundation grant to fund training modeled after TESA and EQUALS to assist counselors in motivating African-American students to take the courses necessary to later be successful in upper-level science and math courses. INTERROGATORY NO. 19: With respect to II.O. of the proposed plan, does LRSD maintain that this subparagraph adds anything to 9 other obligations of the plan. If so, please describe with specificity what it adds. ANSWER: Yes. The obligations in Section II should be interpreted consistent with Paragraph o. INTERROGATORY NO. 20: With respect to II. P. of the proposed plan, please set forth the number of persons the LRSD plans to assign on a full-time basis to compliance/monitoring activities and the categories of positions to be staffed. In addition, please describe any steps to insure that the make-up of the staff includes a substantial number of African-American persons and any role which LRSD is willing to give the representative of the Joshua Intervenors in the selection of this staff. ANSWER: These decisions have not yet been made. INTERROGATORY NO. 21: With respect to III. A. 1. of the proposed plan, please identify any document , and any existing analysis stored in any other manner projecting school make-up by race if the steps described in this subparagraph are implemented. If any such data does not currently exist, please describe how such a projection could be done with data and resources available to the LRSO. ANSWER: LRSD is currently working with Edulog software to project school make-up under scenarios consistent with Section III of the Revised Plan. INTERROGATORY NO. 22: With respect to III. B. I.-5 of the proposed plan, please: (i) identify all written standards governing these transfers and (ii) describe any unwritten practices governing flllaN\"\"-1'\"711 ....... ,...._ 10 one or more of these transfers. (iii) In addition, please define the concepts of \"capacity limitations\" and \"reasonable requirement\" identifying any designations of schools capacities to be utilized. (iv) In addition, please explain the language \"a special need arising out of circumstances unique to a particular student\" by reference to the circumstances of youth receiving such transfers in 1997-98 and explain who does and who would decide that the requisite circumstances exist. (v) Lastly, please identify the numbers of students by race utilizing each category of such transfers in 1997-98. ANSWER: (i) No additional standards have been developed beyond what is contain in the Revised Plan. (ii) None. (iii) A school's capacity is a function of the physical plant and the educational programs being implemented at a school. At this time, LRSD is using the school capacity numbers attached hereto as Exhibit E. The \"reasonable requirements\" described in subparagraphs 1 through 5 of Section III.B. relate to procedural requirements which may be imposed by LRSD to ensure that student assignment occurs in a timely and efficient manner. ( iv) Special circumstances transfers as described by the Revised Plan are currently handled through an appeals committee composed of five members with individual members selected by the LRSD Board of Directors, the Biracial Committee, the PTA Council 11 and the Little Rock CTA. The committee reviews requests for transfers based on geographic isolation, racial isolation, medical hardship and other extenuating circumstances. This committee was established by the Tri-District plan and has been continued by LRSD under its current plan. (v) Records concerning transfers will be made available upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 23: With respect to III. E. of the proposed plan, please identify any potential sites for the school in west Little Rock, including any sites set forth in any study. In addition, please state whether the LRSD envisions the court's approving the site prior to its final approval. ANSWER: No potential site has been identified. Although LRSD anticipates keeping both the court and the parties informed about the site selection process, the site would not have to be approved by the court except as provided in Section IX.B. of the Revised Plan. INTERROGATORY NO. 24: With respect to IV.E. of the proposed plan, please describe any existing agreements, standards, and practices relating to cooperative efforts of the LRSD and PCSSD. ANSWER: See Interdistrict Desegregation Plan. INTERROGATORY NO. 25: With respect to V.B. and C. of the proposed plan, please (i) identify the author or authors of the provisions, committees and entities, designating the provision or provisions associated with each such author; ( ii) identify any document(s) providing further explanation of any provision(s) of r:--~Jooh.- 12  the proposal; (iii) regarding parts B.l.a., B.2.a., and B.J.a., I please identify any standards describing the level of competency envisioned in each instance and how it would be assessed; is developing the standards and the general timelines for that effort; and (iv) regarding these three parts of the plan, please state whether LRSD plans to have students satisfy a test requirement prior to moving to the next grade; if the matter is not decided, but such a requirement remains an option, please indicate. ANSWER: See curriculum work team report. INTE "},{"id":"kdl_abrad_19971212","title":"Interview with Anne Braden, December 12, 1997","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Fosl, Catherine"],"dcterms_spatial":["United States, Alabama, Calhoun County, Anniston, 33.65983, -85.83163","United States, Alabama, Jefferson County, Birmingham, 33.52066, -86.80249","United States, New York, New York County, New York, 40.7142691, -74.0059729","United States, Rhode Island, Newport County, 41.4998, -71.281","United States, Rhode Island, Newport County, Little Compton, 41.5101, -71.17116","United States, Virginia, City of Danville, 36.58597, -79.39502","United States, Virginia, Hanover County, 37.76015, -77.49087","United States, Virginia, Hanover County, Ashland, 37.75903, -77.47998"],"dcterms_creator":["Braden, Anne, 1924-2006"],"dc_date":["1997-12-12"],"dcterms_description":["Interview with Anne Braden, December 12, 1997 conducted by Catherine Fosl.","Anne Braden was a white southern anti-racist activist, organizer and journalist from Louisville, Kentucky. In this interview Anne Braden discusses her perceptions of her mother, father, and other Annistonians. She talks about the social climate of Anniston during and after World War II and the ways in which it impacted her and her family. Braden also discusses her early journalism career at The Anniston Star, the stories she covered there, her intellectual awakening to racism, and her friendships with fellow journalists. She speaks of college days at Randolph-Macon and Stratford, the friendships she established there, and how they evolved in her post-college life. She particularly speaks about her life-long friendship with Harriet Fitzgerald and Harriet's life as a lesbian and artist. Other topics include Braden's thoughts on dualism, historical materialism, educational reform, and the establishment of black schools in segregationist Anniston, Alabama."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Women civil rights workers--Interviews","Civil rights movements--United States","African Americans--Civil rights","Anniston Star (Anniston, Ala.)","Racism","Friendship","Educational change","Dualism","Historical materialism","College students","World War, 1939-1945--Alabama--Anniston","African Americans--Education","Randolph-Macon College","Stratford College (Danville, Va.)","United Service Organizations (U.S.)","Women college students--Virginia","United States. Congress. House. Committee on Un-American Activities","Peace movements--United States","Picketing--New York (State)--New York","Lesbians--United States","Education, Rural--Alabama","Race relations","Southern States--Race relations","Alabama--Race relations","Anniston (Ala.)--Race relations","Segregation in education--Alabama--Anniston","Poll tax--Alabama","Reporters and reporting--Alabama","Newspapers--Alabama--Anniston","Newspapers--Alabama--Birmingham","Drinking of alcoholic beverages--Alabama","Traffic accidents--Alabama","Dance","Civil rights workers--Alabama","African American civil rights workers--Alabama","Women civil rights workers--Alabama","Clergy--Alabama"],"dcterms_title":["Interview with Anne Braden, December 12, 1997"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt71jw86hr3t"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:34:26]"],"dlg_subject_personal":["Braden, Anne, 1924-2006","Braden, Anne, 1924-2006--Childhood and youth","Braden, Anne, 1924-2006--Interviews","Arnall, Ellis Gibbs, 1907-1992","McCarty, Anita","McCarty, Gambrell","Fitzgerald, Harriet, 1904-1984","Beech, Gould","Folsom, James Elisha","Silver, Dorothy B. (Dorothy Berea), 1925-2008","Roosevelt, Franklin D. (Franklin Delano), 1882-1945","Shuttlesworth, Fred L., 1922-2011","Vivian, C. T."],"dcterms_subject_fast":null,"fulltext":null},{"id":"kdl_abrad_19971211yater","title":"Interview with George Yater and Marjorie Yater, December 11, 1997","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Yater, Marjorie"],"dcterms_spatial":["United States, Indiana, Clark County, 38.47718, -85.70728","United States, Indiana, Clark County, Jeffersonville, 38.27757, -85.73718","United States, Kentucky, Daviess County, 37.73177, -87.08723","United States, Kentucky, Daviess County, Owensboro, 37.77422, -87.11333","United States, Kentucky, Jefferson County, Louisville, 38.25424, -85.75941"],"dcterms_creator":["Yater, George H."],"dc_date":["1997-12-11"],"dcterms_description":["Interview with George Yater and Marjorie Yater, December 11, 1997 conducted by Catherine Fosl.","In this interview George and Marjorie Yater, who were friends of Anne and Carl Braden at the time of their 1954 trial for sedition, give their impressions of the Bradens and their political activities. They describe the social and political climate of Louisville during the 1950s, including discussions of racial relations and McCarthyism. George Yater was working as a journalist at the time and explains how McCarthyism affected members of the media in the Louisville area. In addition, the Yaters describe the court proceedings and the trial's impact on the community."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Women civil rights workers--Interviews","Civil rights movements--United States","African Americans--Civil rights","Fellowship of Reconciliation (U.S.)","Kentucky Alliance Against Racist and Political Repression","Segregation","Racism","Courier-journal (Louisville, Ky.)","Veterans--Education--Kentucky","Libel and slander--Kentucky--Louisville","Reporters and reporting--Kentucky","Reporters and reporting--Indiana","Cold War--Influence","McCarthy, Joseph, 1908-1957--Influence","Fear--Kentucky","Intimidation--Kentucky","Communist Party of the United States of America","Communists--United States","Race relations","Louisville (Ky.)--Race relations","Segregation--Kentucky--Louisville","Civil rights demonstrations--Kentucky--Louisville","Lawyers--Kentucky--Louisville","Progressive Party (U.S. : 1948)","Strikes and lockouts--Kentucky--Louisville","Trials--Kentucky--Louisville","Subpoena--Kentucky--Louisville","Employees--Dismissal of--Kentucky--Louisville","Women's International League for Peace and Freedom","United States. Federal Bureau of Investigation","Trials (Sedition)--Kentucky","American Civil Liberties Union","Bombings--Kentucky--Louisville","African Americans--Violence against--Kentucky--Louisville","Discrimination in housing--Kentucky--Louisville","Governors--Kentucky"],"dcterms_title":["Interview with George Yater and Marjorie Yater, December 11, 1997"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt72jm23bx29"],"dcterms_temporal":null,"dcterms_rights_holder":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:29:10]"],"dlg_subject_personal":["Yater, George H.--Interviews","Yater, Marjorie--Interviews","Braden, Anne, 1924-2006","Braden, Carl, 1914-1975","McCarthy, Joseph, 1908-1957","Johnson, Lyman T., 1906-1997","Ethridge, Mark F. (Mark Foster), 1896-1981"],"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1693","title":"Court filings: District Court, interrogatories and requests for production to the Joshua intervenors","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":["1997-12-10"],"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--20th century","Little Rock School District","Joshua Intervenors","Education--Arkansas","Educational law and legislation","Court records"],"dcterms_title":["Court filings: District Court, interrogatories and requests for production to the Joshua intervenors"],"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/1693"],"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":["judicial records"],"dcterms_extent":["49 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 STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS ' WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT v. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL INTERROGATORIES AND REQUESTS FOR PRODUCTION TO THE JOSHUA INTERVENORS PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Plaintiff Little Rock School District (\"LRSD\") submits the following Interrogatories and Requests for Production to the Joshua Intervenors (\"Joshua\") in accordance with Fed. R. Civ. P. - 33 and 34: GENERAL DEFINITIONS AND INSTRUCTIONS (A) \"you\" or \"your\" Shall mean Joshua or any person acting on Joshua's behalf; (B) \"person\" Shall mean any individual, corporation, partnership, joint venture, firm, associaiion, proprietorship, agency, board, authority, commission, and other such entities; (C} \"communicate\" or \"communication\" Shall mean every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of f:\\homolfendlcy~rod-jooh.m. information whether orally or by document or whether face to face, by telephone, mail, personal delivery, or otherwise; (D) \"document\" Shall mean any original written, typewritten, handwritten, printed or recorded material, as well as all tapes, disks, non-duplicate copies and transcripts thereof, now or at any time in your possession, custody or control; and, without limiting the generality of the foregoing definition, but for the purposes of illustration only, \"document\" includes notes, correspondence, memoranda, business records, diaries, calendars, address and telephone records, photographs, tape recordings, financial statements and records. Without limitation of the term \"control\" as used in the preceding sentence, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person or a public or private entity having actual possession thereof. If a document that is responsive to a request for identification or production is in your control, but is not in your possession or custody, identify the person with possession or custody. If any document that is responsive to a request for identification or production was, but is no longer, in your possession or subject to your control, state what disposition was made of it, by whom, and the date or dates or approximate date or dates on which disposition was made, and why; f:\\homolfcnd l.:yU ...ildoo-jcoh..- 2 (E) \"identify\" (i) As to a person (as defined), shall mean the persons name, business and residence address(es); and, if not an individual, state the type of entity and the address of its principal place of business; (ii) As to a document, shall mean the type of document (letter, memo, etc.) the identity of the author or originator, the date authored or originated, the identity of each person to whom the original or copy was addressed or delivered, the identity of such person known or reasonably believed by you to have present possession, custody, or control thereof, and a brief description of the subject matter thereof, all with sufficient particularity to request its production under Rule 34 of the Federal Rules of Civil Procedure; (iii) As to a communication, shall mean the date of the communication, the type of communication (telephone conversation, meeting, etc.), the place where the communication took place, the identity of the person who made the communication, the identity of each person who received the communication, and of each person present when it was made and the subject matter discussed; (F) \"Pertaining to\" Shall mean constituting, embodying, arising out of, incident to, referring to, mentioned, bearing upon, reflecting, evidencing, affecting, concerning, providing evidence for, or relating to the transaction, individual, entity, act, object, 3 conference, contention, communication, allegation or activity identified; (G) To \"describe in detail\" Shall mean to provide with respect to any act, occurrence, transaction, event, statement, communication or conduct (hereinafter collectively, \"act\") all facts pertaining to any such act known to the person answering after due inquiry, including but not limited to a description of each act, the d~te, the location, and the identify of each person involved; (H) \"or\" shall be construed either conjunctively or disjunctively to bring within the scope of these Interrogatories any information which might otherwise be construed to be outside their scope; (I) \"Revised Plan\" shall mean LRSD Revised Desegregation - and Education Plan dated September 18, 1997; (J) \"current plan\" shall mean the LRSD Desegregation Plan dated April 29, 1992; all page and line citations to the current plan shall refer to current plan as set forth in LRSD's \"Desegregation Tool Kit,\" a copy of which is enclosed; (K) \"Interdistrict Plan\" shall mean the Interdistrict Desegregation Plan dated April 29, 1992; all page and line citations to the Interdistrict Plan shall refer to Interdistrict Plan as set forth in LRSD's \"Desegregation Tool Kit,\" a copy of which is enclosed; The singular includes the plural number, and vice versa. The masculine includes the feminine and neuter genders. The past l:lhomolfcndleyUn,d'dco-jooh.Ull 4 tense includes the presence tense where the clear meaning is not distorted by change of tense. If you do not answer any Interrogatory or Request for Production because of a claim of privilege, set for the privilege claimed, the facts upon which you rely to support the claim of privilege, and identify all documents for which such privilege is claimed. INTERROGATORY NO. 1: Please identify all persons who participated in the preparation of responses to these interrogatories and requests for production of documents . INTERROGATORY NO. 2: Please identify all persons who you intend to call as a lay witness at the hearing on the Revised Plan . INTERROGATORY NO. 3: Please identify all persons who you - intend to call as an expert witness at the hearing on the Revised Plan. REQUEST FOR PRODUCTION NO. 1: Please produce a written report signed by each expert witness identified in your response to Interrogatory No. 3 which contains a complete statement of all opinions to be expressed and the basis and reasons therefor; the data or other information considered by the witness in forming the opinions; any exhibits to be used as a summary of or support for the opinions; the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten years; the compensation to be paid for his testimony; and a listing of any other cases in which the witness f:lhcmo\\kndieyUrod\\deo-jcoh.w 5 has testified as an expert at trial or by deposition within the preceding four years. ' REQUEST FOR PRODUCTION NO. 2: Please produce all items, th~ngs and documents which you intend to introduce as an exhibit at the hearing on the Revised Plan. INTERROGATORY NO. 4: Do you contend that LRSD is not unitary with regard to student assignments? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 3: Please produce all documents identified in your response to Interrogatory No. 4 above. INTERROGATORY NO. 5: Do you contend that LRSD is not unitary with regard to faculty? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 4: Please produce all documents identified in your response to Interrogatory No. 5 above. INTERROGATORY NO. 6: Do you contend that LRSD is not unitary with regard to staff? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 5: Please produce all documents identified in your response to Interrogatory No. 6 above. INTERROGATORY NO. 7: Do you contend that LRSD is not unitary with regard to transportation? If so, describe in detail f:lhcmo\\fcndlcyUnod\\doo-joah.inl 6 the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 6: Please produce all documents identified in your response to Interrogatory No. 7 above. INTERROGATORY NO. 8: Do you contend that LRSD is not unitary with regard to extra-curricular activities? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 7: Please produce all documents identified in your response to Interrogatory No. 8 above. INTERROGATORY NO. 9: Do you contend that LRSD is not unitary with regard to facilities? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 8: Please produce all documents identified in your response to Interrogatory No. 9 above. INTERROGATORY NO. 10: Do you contend that LRSD has failed to substantially comply with the Early Childhood Education component (pp. 4-19) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 9: Please produce all documents identified in your response to Interrogatory No. 10 above. INTERROGATORY NO. 11: Do you contend that LRSD has failed to substantially comply with the Special Programs component (pp. 20-27) of the current plan? If so, describe in detail the f:\\homolfcrdlcyUr,d\\doe-j\u003c\u003eoh ... 7 basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 10: Please produce all documents identified in your response to Interrogatory No. 11 above. INTERROGATORY NO. 12: Do you contend that LRSD has failed to substantially comply with the School Operations component (pp. 28-47) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 11: Please produce all documents identified in your response to Interrogatory No. 12 above. INTERROGATORY NO. 13: Do you contend that LRSD has failed to substantially comply with the Program for Accelerated Learning/Academic Support Programs (pp. 48-57) of the current - plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 12: Please produce all documents identified in your response to Interrogatory No. 13 above. INTERROGATORY NO. 14: Do you contend that LRSD has failed to substantially comply with the Gifted Education component (pp. 58-62) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 13: Please produce all documents identified in your response to Interrogatory No. 14 above. f:lhomolfcndlcyllrod'doo-jooh.u,t 8 INTERROGATORY NO. 15: Do you contend that LRSD has failed to substantially comply with the Multicultural Curriculum component (pp. 63-80) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 14: Please produce all documents identified in your response to Interrogatory No. 15 above. INTERROGATORY NO. 16: Do you contend that LRSD has failed to substantially comply with the Focused Activities component (pp. 81-85) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 15: Please produce all documents identified in your response to Interrogatory No. 16 above. - INTERROGATORY NO. 17: Do you contend that LRSD has failed to substantially comply with the Parkview Science Magnet School component (pp. 86-92) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 16: Please produce all documents identified in your response to Interrogatory No. 17 above. INTERROGATORY NO. 18: Do you contend that LRSD has failed to substantially comply with the McClellan Community School component (pp. 93-94) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. f:\\homclfcndleyllnd'dcojooh.mi 9 REQUEST FOR PRODUCTION NO. 17: Please produce all documents identified in your response to Interrogatory No. 18 above. INTERROGATORY NO. 19: Do you contend that LRSD has failed to substantially comply with the Recruitment of Private School students component (p. 95) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO . 18: Please produce all documents identified in your response to Interrogatory No. 19 above. INTERROGATORY NO . 20: Do you contend that LRSD has failed to substantially comply with the Federal Programs component (pp. 96-97) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 19: Please produce all documents identified in your response to Interrogatory No. 20 above. INTERROGATORY NO. 21: Do you contend that LRSD has failed to substantially comply with the Vocational Education component (pp. 98-99) of the current plan? If so, describe in detail the basis(es) for this contention and i dentify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 20: Please produce all documents identified in your response to Interrogatory No. 21 above. INTERROGATORY NO. 22: Do you contend that LRSD has failed to substantially comply with the Library Media Services component (pp. 106-10) of the current plan? If so, describe in detail the f:\\homc\\/erdlcyUnd'\u003cbjooh.inl 10 basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 21: Please produce all documents identified in your response to Interrogatory No. 22 above. INTERROGATORY NO. 23: Do you contend that LRSD has failed to substantially comply with the Special Education component {pp. 111-23) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 22: Please produce all documents identified in your response to Interrogatory No. 23 above. INTERROGATORY NO. 24: Do you contend that LRSD has failed to substantially comply with the Staff Development component {pp. 20-27) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 23: Please produce all documents identified in your response to Interrogatory No. 24 above. INTERROGATORY NO. 25: Do you contend that LRSD has failed to substantially comply with the Support Services component (pp. 129-30) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 24: Please produce all documents identified in your response to Interrogatory No. 25 above. f:lhomo\\kmlcyllrodldcojooh.n 11 INTERROGATORY NO. 26: Do you contend that LRSD has failed to substantially comply with the Parent Involvement/Community Linkages component (pp. 131-38) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 25: Please produce all documents identified in your response to Interrogatory No. 26 above. INTERROGATORY NO. 27: Do you contend that LRSD has failed to substantially comply with the Student Assignments component (pp. 139-44) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 26: Please produce all documents identified in your response to Interrogatory No. 27 above. - INTERROGATORY NO. 28: Do you contend that LRSD has failed to substantially comply with the New Futures For Little Rock component (p. 145) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 27: Please produce all documents identified in your response to Interrogatory No. 28 above. INTERROGATORY NO. 29: Do you contend that LRSD has failed to substantially comply with the Facilities component (pp. 146- 148) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. lc\\home\\fcndlcyllnodldoejooh.inl 12 REQUEST FOR PRODUCTION NO. 28: Please produce all documents identified in your response to Interrogatory No. 29 above. INTERROGATORY NO. 30: Do you contend that LRSD has failed to substantially comply with the Incentive School Academic Programs and Curriculum Development component (pp. 152-70) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 29: Please produce all documents identified in your response to Interrogatory No. 30 above. INTERROGATORY NO. 31: Do you contend that LRSD has failed to substantially comply with the Incentive School Operations component (pp. 171~189} of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 30: Please produce all documents . identified in your response to Interrogatory No. 31 above. INTERROGATORY NO. 32: Do you contend that LRSD has failed to substantially comply with the Incentive School Staffing component (pp. 190-204) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 31: Please produce all documents identified in your response to Interrogatory No. 32 above. INTERROGATORY NO. 33: Do you contend that LRSD has failed to substantially comply with the Incentive School Parent f:\\hamolfendleyllradldeo-jooh.w 13 Involvement component (pp. 205-14) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 32: Please produce all documents identified in your response to Interrogatory No. 33 above. INTERROGATORY NO. 34: Do you contend that LRSD has failed to substantially comply with the Incentive School Parent Recruitment (pp. 215-23) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 33: Please produce all documents identified in your response to Interrogatory No. 34 above. INTERROGATORY NO. 35: Do you contend that LRSD has failed to substantially comply with the Educational Equity Monitoring component (pp. 224-26) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 34: Please produce all documents identified in your response to Interrogatory No. 35 above. INTERROGATORY NO. 36: Do you contend that LRSD has failed to substantially comply with the Computerized Transportation System component (pp. 227-29) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 35: Please produce all documents identified in your response to Interrogatory No. 36 above. l:\\hamollordlcyllrtd\\doo-Jo,h.bo 14 INTERROGATORY NO. 37: Do you contend that LRSD has failed to substantially comply with the Introduction component (pp. 1-2) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 36: Please produce all documents identified in your response to Interrogatory No. 37 above. INTERROGATORY NO. 38: Do you contend that LRSD has failed to substantially comply with the Overview component (pp. 3-7) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 37: Please produce all documents identified in your response to Interrogatory No. 38 above. - INTERROGATORY NO. 39: Do you contend that LRSD has failed to substantially comply with the student Choices and Options component (pp. 8-12) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 38: Please produce all documents identified in your response to Interrogatory No. 39 above. INTERROGATORY NO. 40: Do you contend that LRSD has failed to substantially comply with the Summer School component (pp. 13- 20) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. f:\\homclfc.-dlcyUnid'dcojcob.inl 15 REQUEST FOR PRODUCTION NO. 39: Please produce all documents identified in your response to Interrogatory No. 40 above. INTERROGATORY NO. 41: Do you contend that LRSD has failed to substantially comply with the Staff Development component (pp. 21-22) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 40: Please produce all documents identified in your response to Interrogatory No. 41 above. INTERROGATORY NO. 42: Do you contend that LRSD has failed to substantially comply with the School Operations component (pp. 23-34) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 41: Please produce all documents identified in your response to Interrogatory No. 42 above. INTERROGATORY NO. 43: Do you contend that LRSD has failed to substantially comply with the Special Education component (pp. 35-53) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 42: Please produce all documents identified in your response to Interrogatory No. 43 above. INTERROGATORY NO. 44: Do you contend that LRSD has failed to substantially comply with the Guidance and Counseling Program component (pp. 54-55) of the Interdistrict Plan? If so, describe f:lhom\u003c\\fcrdlcylll'ld'd.,o-jooh.n 16 in detail the basis(es) for this contention and identify all - facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 43: Please produce all documents identified in your response to Interrogatory No. 44 above. INTERROGATORY NO. 45: Do you contend that LRSD has failed to substantially comply with the Parental Involvement/Community Linkages component (pp. 56-58) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 44: Please produce all documents identified in your response to Interrogatory No. 45 above. INTERROGATORY NO. 46: Do you contend that LRSD has failed to substantially comply with the Public Relations component (pp. i-2) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 45: Please produce all documents identified in your response to Interrogatory No. 46 above. INTERROGATORY NO. 47: Do you contend that LRSD has failed to substantially comply with any order of the District Court pertaining to the current plan or Interdistrict Plan? If so, identify the order of the district court, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 46: Please produce all documents identified in your response to Interrogatory No. 47 above. r:lhorno1ren:11cy11nw1-.i..-jooh.in 17 INTERROGATORY NO. 48: Please describe .in detail Joshua's monitoring of LRSD during the 1992-93 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 47: Please produce all documents identified in your response to Interrogatory No. 48 above. INTERROGATORY NO. 49: Please describe in detail Joshua's monitoring of LRSD during the 1993-94 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 48: Please produce all documents identified in your response to Interrogatory No. 49 above. INTERROGATORY NO. 50: Please describe in detail Joshua's monitoring of LRSD during the 1994-95 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 49: Please produce all documents identified in your response to Interrogatory No. 50 above. INTERROGATORY NO. 51: Please describe in detail Joshua's monitoring of LRSD during the 1995-96 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO . . 50: Please produce all documents identified in your response to Interrogatory No. 51 above. INTERROGATORY NO. 52: Please describe in detail Joshua's monitoring of LRSD during the 1996-97 school year, including the f:lhomolfcndloyllndldco-jo,h.in 18 identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 51: Please produce all documents identified in your response to Interrogatory No. 52 above. INTERROGATORY NO. 53: Please describe in detail Joshua's monitoring of LRSD during the 1997-98 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 52: Please produce all documents identified in your response to Interrogatory No. 53 above. INTERROGATORY NO. 54: Please identify all persons not currently employed by LRSD known to you to have personal knowledge of LRSD's failure to comply with any obligation under either the current plan or the Interdistrict Plan. INTERROGATORY NO. 55: Please identify all of your communications with persons currently employed by LRSD pertaining to LRSD's compliance with either the current plan or the Interdistrict Plan. REQUEST FOR PRODUCTION 53: Please produce all documents pertaining to the communications identified in your response to Interrogatory No. 55 above. INTERROGATORY NO. 56: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in academic achievement? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. f:lhcmclfcndlcyllnd'dcejooh.inl 19 REQUEST FOR PRODUCTION NO. 54: Please produce all documents identified in your response to Interrogatory No. 56 above. INTERROGATORY NO. 57: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in student discipline? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 55: Please produce all documents identified in your response to Interrogatory No. 57 above. INTERROGATORY NO. 58: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in special education? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 56: Please produce all documents identified in your response to Interrogatory No. 58 above. INTERROGATORY NO. 59: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in the gifted and talented program? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO . 57: Please produce all documents identified in your response to Interrogatory No. 59 above . INTERROGATORY NO. 60: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in participation in honors and advanced f:lhome\\fc,d loyllrodldco-jcoh.ir\u003c 20 placement courses? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 58: Please produce all documents identified in your response to Interrogatory No. 60 above. INTERROGATORY NO. 61: Do you believe that continued implementation of the current plan and the Interdistrict Plan would result in LRSD achieving unitary status? If so, please identify when LRSD would be unitary and describe in detail the basis(es) for your response. If not, please describe in detail why and identify those aspects of school operations which would not be unitary. INTERROGATORY NO. 62: Please identify by page number(s) the components of the current plan and Interdistrict Plan which you believe should be modified , and for each component identified, please: a. describe in detail why you believe the component should be modified; b. identify all facts and documents which support your belief that the component should be modified; c. describe in detail the program, policy or procedure which you believe should be substituted for the component; and, d. identify all facts and documents which support your belief that the program, policy or procedure described inc. above should be substituted for the component . f:lhomclfcndlcyll..d\\dco-jooh. in. 21 REQUEST FOR PRODUCTION NO. 59: Please produce all documents identified in your response to Interrogatory No. 62 above. INTERROGATORY NO. 63: Please identify by page number(s) those components of the current plan and Interdistrict Plan which you contend should be continued under the Revised Plan, and with regard to each component identified, please describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 60: Please produce all documents identified in your response to Interrogatory No. 63 above. INTERROGATORY NO. 64: Do you agree with the recommendations 9on~ained in the Student Assignment Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identi fy all facts and documents which support your position. REQUEST FOR PRODUCTION NO. 61: Please produce all documents identified in your response to Interrogatory No. 64 above. INTERROGATORY NO. 65: Do you agree with the recommendations contained in the Curriculum Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identify all facts and documents which support your position. !:\\homo\\fcndlcy\\l..dldco-jooh.inl 22 REQUEST FOR PRODUCTION NO. 62: Please produce all documents identified in your response to Interrogatory No. 65 above. INTERROGATORY NO. 66: Do you agree with the recommendations contained in the Technology Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identify all facts and documents which support your position. 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