{"response":{"docs":[{"id":"nge_ngen_katharine-du-pre-lumpkin-1897-1988","title":"Katharine Du Pre Lumpkin (1897-1988)","collection_id":"nge_ngen","collection_title":"New Georgia Encyclopedia","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5"],"dcterms_creator":["Romine, Scott"],"dc_date":["2002-07-09"],"dcterms_description":["Encyclopedia article about Katharine Du Pre Lumpkin who spent a lifetime studying and combating economic and racial oppression as a sociologist, activist, teacher, and writer. She is best known for her autobiography, The Making of a Southerner. The attended Brenau College in Gainesville, Columbia University in New York, and the University of Wisconsin. 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LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL PLAINTIFF'S MOTION IN LIMINE RECEIVED JUL - 8 2002 OFFICE OF DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTER VEN ORS INTER VEN ORS Plaintiff Little Rock School District (\"LRSD\") for its Motion in Limine states: 1. May 15 Order: Joshua's Witness List. On May 15, 2002, the Court ordered the parties on or before June 21, 2002 to \"identify the name of each of their witnesses, the date and - time each witness will be called, and the anticipated time it will take for direct examination of each witness. A detailed statement must be included of each witnesses anticipated testimony on each issue the witness will address.\" Order filed May 15, 2002, p. 2 ( emphasis in original). Joshua's witness list is attached hereto as Exhibit 1. As can be seen, Joshua failed to comply with the Court's order in every respect. Upon information and belief, Joshua has not even contacted many of the individuals identified to discuss their appearing at the hearing and testifying, and Joshua has no intention of calling all of the witnesses identified. The LRSD moves in limine that Joshua be ordered on or before 5:00 p.m. on July 10, 2002 to identify the date and time on which each witness will be called, to identify the issue(s) on which each witness is expected to testify and to provide a detailed statement of the witnesses' expected testimony on each issue. The LRSD further requests that Joshua be precluded from calling any witness for which it fails to provide this information on or before 5 :00 p.m. on July 10, 2002. Finally, the LRSD asks that Joshua be instructed to only identify witnesses that it has interviewed and confirmed their availability for the hearing. 2. May 15 Order: Joshua's Exhibits. On May 15, 2002, the Court also ordered the parties to exchange pre-marked exhibits on or before June 21 , 2002. The Court further stated that \"[a]ny exhibit not pre-marked and exchanged on or before June 21, 2002 will not be received into evidence during the July 22 hearing, absent highly unusual circumstances. A copy of Joshua's Exhibit list and the exhibits provided to the LRSD are attached hereto as Exhibit 2. Joshua failed to provide the LRSD with copies of Exhibits 793, 794, 799, 800 and 801 stating \"[r]equest is hereby made for those exhibits ... \" This request by Joshua is untimely. See Order filed July 1, 2002, p. 1. To the extent Joshua may be in possession of these documents, the LRSD moves in limine to exclude Joshua Exhibits 793, 794, 799, 800 and 801. 3. May 15 Order: Exhibit 803. The LRSD also moves to exclude any additional documents which Joshua may intend to introduce as Exhibit 803. Joshua identified as Exhibit 803, \"The exhibits filed by the Little Rock School District for this hearing.\" This fails to comply with the Court's May 15, 2002 order, as the LRSD understood it. 4. May 9 Order: Good Faith. The Court stated in its order of May 9, 2002 that Joshua would be permitted to present additional evidence on the issue of the LRSD's good faith \"but only to the extent that: (a) it relates directly to the issues of advanced placement courses, guidance counseling, extracurricular activities and student achievement; and (b) it does not duplicate testimony already presented by Joshua on the issue of good faith.\" Order filed May 9, 2002, p. 14 (emphasis in original). Consistent with the Court's Order, the LRSD moves in limine as follows: a. Sadie Mitchell. Joshua called Mitchell to testify on August 1 and 2, 2001. See Tr. August 1, 2001, pp. 564-570 and August 2, 2001, pp. 848-896. Joshua specifically questioned Mitchell about student achievement (see,~. Tr. August 1, 2001, p. 575) and advance placement courses (see,~. Tr. August 1, 2001 , p. 600). Additional testimony from Mitchell on these issues would be duplicative. Accordingly, the LRSD moves to prohibit Joshua from questioning Mitchell about student achievement and advanced placement courses. 2 b. Junious Babbs. Joshua called Babbs to testify on July 5 and 6, 2001. See Tr. July 5, 2001 (all) and July 6, 2001 , pp. 283-340. Joshua specifically questioned Babbs about advanced placement courses (see,~' Tr. July 5, 2001, p. 219), guidance counseling (see,~. Tr. July 5, 2001, p. 228), extracurricular activities (see,~ Tr. July 5, 2001 , p. 218) and student achievement (see,~ Tr. July 5, 2001 , p. 231 ). Accordingly, the LRSD moves to prohibit Joshua calling Babbs as a witness. c. Exhibits. The LRSD moves to exclude the following exhibits not directly related to the issues of advanced placement courses, guidance counseling, extracurricular activities and student achievement: 743, 746, 747, 749, 750, 752, 754, 755, 756, 757, 758, 759, 760, 761 , 762, 763, 764, 771 , 773, 775, 777, 778, 779, 780, 782, 783, 784, 785, 786, 787, 788, 789 801 and 802. 5. Relevance Generally. The LRSD moves to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors pursuant to Fed. R. Evid. 401,402 and 403. The LRSD's memorandum brief in support of this Motion is hereby incorporated by reference. The LRSD also incorporates by reference its Memorandum Brief in Support of Motion for an Immediate Declaration of Unitary Status and its Reply Brief in Support of Motion for an Immediate Declaration of Unitary Status. 6. Jim Mosby and Jodie Carter. The LRSD also moves to exclude evidence and testimony related to the removal of Jim Mosby and Jodie Carter as the principals of Southwest Middle School and McClellan High School, respectively, pursuant to Fed. R. Evid. 401,402 and 403. Both men are represented by counsel for Joshua, and filed Complaints against the LRSD on July 7, 2002 related to their removal which are now pending before this Court. The July 22 hearing on whether the LRSD should be declared unitary is not the appropriate forum to decide the merit of their Complaints, and this Court has a long-standing practice of not hearing individual claims as a part of this case. See,~' Docket No. 1874, Order filed June 30, 1993. 3 7. Rebuttal Evidence. This Court's order of May 15, 2002 granted Joshua 30 minutes to present rebuttal evidence pertaining to the three issues tried virtually to conclusion during previous hearings before Judge Wright. Joshua failed to identify any witnesses or exhibits for this purpose. Moreover, none of the witnesses or exhibits would reasonably be construed as \"true\" rebuttal, as defined by Judge Wright. Judge Wright defined rebuttal evidence as evidence necessary to respond to evidence presented by the other side which could not have been anticipated. Tr. Nov. 20, 2001, 399. The LRSD submitted no evidence which could not have been anticipated by Joshua because it had all been previously outlined in the LRSD's Interim Report and/or Final Report. Therefore, the LRSD moves in limine that Joshua be prohibited from presenting any rebuttal evidence on July 22, 2002, at 8:30 a.m. 8. Letters from Joy Springer. Joy Springer is counsel for Joshua's paralegal, and she has not been identified as a witness. However, Joshua has identified as Exhibits 767- 776 a series of letters from her to District personnel related to individual student/parent complaints. The LRSD moves to exclude these letters for several reasons. First, the letters are hearsay reporting hearsay, and they fail to fall within any exception to the hearsay rule. See Fed. R. Evid. 801, 802 803 and 804. Second, the letters are irrelevant in that there is no evidence that these complaints were brought to the attention of the Board. See Fed. R. Evid. 401 and 402 and paragraph 5, supra. Third, any relevance is outweighed by the danger of unfair prejudice where no evidence will be presented that would allow this Court to assess the merit of the complaints made in the letters. See Fed. R. Evid. 403. 9. Joshua Exhibit 791 . Joshua Exhibit 791 appears to be notes from a meeting with Ms. Jo Evelyn Elston, the LRSD's Director of Pupil Services. The LRSD assumes that the notes were prepared by Springer or another Joshua monitor. However, neither Springer nor any other Joshua monitor has been identified as a witness in this case. The LRSD moves to exclude Joshua Exhibit 791 for the same reasons set forth in paragraph 8 above. Joshua Exhibit 791 should also be excluded for an additional reason: the document, standing alone, cannot be 4 authenticated, and Joshua has not identified any witness who will be able to authenticate the document. See Fed. R. Evid. 901. WHEREFORE, the LRSD prays that its Motion in Lirnine be granted; that it be awarded the relief sought herein; and that it be awarded all other just and proper relief to which it may be entitled. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRlCT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE \u0026amp; CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 37 ----~BY: CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by U.S. mail on July 3, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 (VIA z~~~L,l -~ Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 F:IHOME\\FENDLEYILRSO 200 I ldes-mot-limine-7-09-02. wpd 5 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Ms. Ann Brown Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV00866 WRW PULASKJ COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANT INTERVENORS INTER VENO RS MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. JOSHUA INTERVENORS' WITNESS LIST REGARDING JULY 22-26, 2002 HEARINGS The Joshua Intervenors plan to call the following persons during the July 22-26, 2002 hearings: I. Ms. Sadie Mitchell - Associate Superintendent for School Services Will dis~uss guidance counseling and her oversight or lack of it within the schools. She will be called on July 23, 2002, and her testimony will be expected to take approximately ten minutes. 2. Mr. Junious Babbs - Associate Superintendent for Administrative Services Will address extracurricular activities and his oversight of those activities as Associate Superintendent for Administrative Services. His testimony will be approximately ten .... minutes and will occur on July 23, 2002. 3. Dr. Marian Lacey - Asst. Superintendent of Secondary Schools a EXHIBIT g 1 f Will discuss her oversight of the secondary schools with respect to guidance counseling advanced placement courses, and extracurricular activities. Her direct testimony will take approximately fifteen minutes. 4. Mr. Jodie Carter - Principal McClellan High School Will discuss special problems with advanced placement courses, guidance counseling, extracurricular activities and the District 's good faith . His testimony will take approximately two hours and will be presented on July 22, 2002. He will also discuss the support and involvement of school board members or the lack of. 5. Ms. Dorothy McDonald - Teacher Will discuss the District's counseling program and problems which affect A.mean American students which have not been effectively addressed by the District. Her testimony will take approximately fifteen minutes. 6. Dr. Michael Faucette - Teacher Central High School Will discuss in detail the problems with the administration of advanced placement courses, the racial effect of the placements, the manner in which the placements are made, how the placements tend to favor one group of children over another, the problems with scheduling and how those scheduling decisions interact with other decisions of placement and counseling; participation in extracurricular activities; the favor given to white students at Central High School; the disparate effect of advanced placement courses with respect to teaching, awards, and other opportunities; and he will discuss the District's good faith compliance. He testimony will presented on July 22nd and is expected to take approximately four hours on direct examination. 7. Ms. Pat Watson - Counselor at Hall High School 2 Will address the District's counseling program and how they are implemented. Her testimony will take approximately 15 minutes. 8. Mr. Kenneth Moore, Assistant Principal at Hall High S~hool Will discuss extracurricular activities and good faith compliance. His testimony will take approximately ten minutes and will be presented July 23, 2002. 9. Ms. Pam Mercer - Parent of Former Student of Central High School Will discuss her efforts as a parent with respect to securing fair and equitable treatment for her children, Crystal and Justin, while they were at Central and how she was rebuffed along the way. She will also discuss the atmosphere at Central High School as it relates to privilege being extended to white children from middle class families. It will also cover counseling and extracurricular activities. Ms. Mercer's testimony will take approximately twenty minutes on direct examination. l 0. Mr. Justin Mercer - Former Student at Central High School Will address the problems he experienced of a racial nature while at Central High School and his efforts to obtain assistance and help from teachers, counselors and administrators. His testimony will take approximately ten minutes. 11 . Crystal Mercer - Former Student at Central High School Will address the District 's counseling services from a African American student 's perspective. Her testimony will take approximately ten minutes. 12. Ms. Paulette Blevins - Former teacher at Central High School Will discuss how the grading system was manipulated so as to change grades and otherwise provide favor to white children at Central High School. Her testimony will take 3 approximately fifteen minutes on direct examination. 13 . Mr. Jimmy Mosby - Principal of Southwest Middle School Will discuss the efforts of the District to comply with the ~]an with respect to good faith, guidance counseling and extracurricular activities while at Southwest Middle School and Hall High School. His testimony will take approximately twenty minutes on direct examination. 14. Ms. Sharon Brooks - Principal of Stephens Elementary School Will testify regarding good faith compliance and how she avoids it. The specific matter she will address will be unreported punishment without the involvement of a guidance counselor regarding the taking away of educational privileges for black boys for a period of two months while she was principal ofRightsell Elementary School. Her testimony will take ten minutes. I 5. Ms. Susie Davis - LRSD Coordinator of English Will discuss the efforts of the Instruction Department to communicate Instruction Department standards to principals and teachers with respect English and Reading and other subjects which she supervises in her capacity as special assistant to Dr. Bonnie Lesley. Although this is not her title, she was regarded as the agent for Dr. Lesley within the schools. She will also discuss the extent of her and Dr. Lesley's association with respect to principals and counselors. Her testimony will take approximately ten minutes. 16. Ray Gillespie - Fonner Athletic Director Will discuss his role with respect to extracurricular activities and monitoring activities to ensure the absence of racial discrimination. His testimony will take approximately fifteen 4 minutes. 17. Cassandra Norman - Principal at J.A. Fair High School Will discuss the District's good faith compliance and her school;'s disparate treatment of black and white students. She will also discuss the support and involvement of school board members or the lack of 18. Judith Pickering - Teacher - J.A. Fair High Schools Will discuss the racial atmosphere, advanced placement courses and extracurricular activities at J.A. Fair. Her testimony should take approximately fifteen minutes. 19. Foster Allen - Teacher at Central High Will discuss advance placement practices at Central High School and his relationship to those practices. His testimony will take five minutes. 20. Romona Horton and Bennie Horton - Parents of Former Central High Student Will discuss problems with AP placement of their child at Central High School. Their testimony will take five minutes a piece. 21 . Alisha Allmon - Teach er Will discuss advanced placement practices at Central High School and his relationship to those practices. Her testimony will take five minutes. 22. Chris Payne- Former Student at J.A. High School Will discuss his efforts to participate in Quiz Bowl at J. A. Fair. His testimony will take ten minutes. 23 . Ms. Sue Strickland, Dr. Katherine Mitchell, Dr. Michael Daugherty, Mr. Tony Rose Mr. Larry Berkley, Ms. Judy Magness and Mr. H. Baker Kurrus 5 Will each give testimony regarding good faith compliance and their involvement in and knowledge of the development and implementation of guidance and counseling programs, advanced placement courses, regular courses, class sizes of regular courses, pupil teacher ratios between regular , advanced placement, honors and gifted and talented courses. Their testimony together is expected to take one hour on direct examination. 24. Jeanette Carter and Dr. Vertie Carter Will discuss problems which they experience with respect to the AP teachers and administrators and counselors regarding placement, retention and fair treatment in the AP program. Their testimony will take fifteen minutes. 25 . Ms. Ethel Dunbar - Principal Franklin Elementary School Will discuss elementary good faith compliance, gifted and talented courses, guidance counseling and the assistance received with respect to these issues from the Division of Instruction. Her testimony will take approximately thirty minutes. 25. Mazie Phillips - Counselor at Fair High School Will address the District's counseling program and how they are implemented. Her testimony will take approximately 15 minutes. 26. Leon Adams - Director of Federal programs Will discuss efforts to use Title I funds to promote the educational interests of \"all\" children rather than the children who were the intended beneficiaries of those funds; the correlation between counseling services, advanced placement courses and good faith compliance. His testimony will take approximately twenty minutes. 6 e . 27. D.J. Thames and Avis Thames - Student and Parent - Fair High School Will discuss the District's good faith compliance with respect to extracurricular activities. This testimony will take approximately ten minutes on direct examination. 28. Ann Marshall, Gene Jones, and Margie Powell - ODM Monitors Will discuss good faith compliance. Their testimony will take approximately thirty minutes. 29. Ray Simon Will discuss the District 's decision and the reason for it to retreat from the remediation requirement for loan forgiveness. His testimony will address the roles of Drs. Ross and Carnine with respect to discontinuing emphasis upon remediation of Black students relative achievement levels. It will take approximately twenty minutes. The exhibit which he will address is an agreement between the State of Arkansas and the Little Rock School District the description of about which I am not certain. 30. Dr. Terrence Roberts Will address the issue of good faith compliance, guidance counseling and relationship between regular and advanced courses. His testimony will take approximately twenty minutes and will be presented on July 23, 2002. 3 I . Dr. Stephen Ross Will testify about the District 's good faith compliance and advanced placement and honors courses. He will address the need for criteria for placement as will Dr. Roberts (see above). His testimony will take approximately thirty minutes. 7 Respectfully submitted, John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 501- 374-3758 501-374-4187 (fax) .--, ' (_~?__, .. _./{ John W. Walker - Bar No. 64046 CERTIFICATE OF SERVICE I hereby state that a copy of the foregoing witness list has been hand delivered to Counsel for the Little Rock School District on this 24th day of June, 2 02. 8 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANTS INTERVENORS INTER VEN ORS MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. JOSHUA INTERVENORS' EXHIBIT LIST REGARDING JULY 22-26, 2002 HEARINGS The Joshua Intervenors plan to use the following documents during the July 22-26, 2002 hearings: 743 . E-mail dated July 2, 2001 from Virginia Johnson to Bonnie Lesley (page 182) 744. E-mail dated October 19, 2000 from Gary Smith to Bonnie Lesley (page 290) 745 . E-mail dated June 29, 2001 from Sueellen Mann to Gail Hester and subsequent dated July 2, 2001 (page 167) 746. E-mail dated January 18, 2001 from Junious Babbs to Kathy Lease (page 12) 747. E-mail dated July 2, 2001 from Mona Briggs to Bonnie Lesley (page 191) 748. E-mail dated November 16, 2000 from Les Carnine to Bonnie Lesley 749. E-mail dated November 21 , 2000 from Ken Savage to Kathy Lease (page 38) 750. E-mail dated March 7, 2001 from Kathy Lease to T Rose and subsequent dated March 7, 2001 at 12:44 p.m. (page 7) 751 . E-mail dated July 15, 2001 from Bonnie Lesley to Lionel Ward and subsequent 1  EXHIBIT ~ 752. 753. 754. 755. 756. 757. dated July 16, 2001 (page 88) E-mail dated July 14, 2001, July 15, 2001 and July 16, 2001 from Bonnie Lesley to Ken James (page 96) E-mail dated July 15, 2001 from Bonnie Lesley to Chris Heller (page 102) E-mail dated April 18, 200 I from Bonnie Lesley to Kathy Lease and subsequent response (pages 708 and 709) E-mails dated October 25, 2000 from Bonnie to Irma Truett and Kathy Lease re: Benchmark scores (pages 16 and 17) E-mail dated June 28, 2001 8:00 p.m. from Mona Briggs to Bonnie Lesley (page 192 E-mail dated June 28, 2001 9:08 a.m. from Bonnie Lesley to members of her staff (Page 192 and 193) 758. E-mails dated September 29, 2000 between Bonnie Lesley and Kathy Lease re: Priorities 2000-01 (Page 51) 759. E-mail dated October 3, 2000 between Les Carnine. Bonnie Lesley and Kathy Lease Re: ALT Check-in (Page 50) 760. E-mail dated June 20, 2001 from Bonnie Lesley to Beverly Griffin re: semester test Exemption (Page 351) 761. E-mail dated June 25, 2001 from Bonnie Lesley to Clay Fendley (page 297) 762. F-mails dated June 29, 2001 between Sadie Mitchell, Deanna Eggeston and Bonnie Lesley (pages 2_18 - 219) 763 . E-mails dated February 12 and 13, 2001 Lesley, Ruffins, Lease and Carnine (page 19) 764. Email dated February 13, 2001 from Kathy Lease to Les Carnine (Pages 17 and 18) 765. Memo dated November 17, 2000 from Dr. Faucette to Mrs. Hargis re: exclusion of Regular English students fro Jennie Calder lecture 766. Email dated September 27, 2000 from Sadie Mitchell to Junious Babbs (Page 1) 2 767. Letter dated December 16, 1998 to Les Carnine from Joy Springer 768. Letter dated February 18, 1999 to Sadie Mitchell from Joy Springer 769. Letter dated March 17, 1999 to Rudolph Howard from Joy Springer 770. Letter dated October 14, 1999 to James Washington from Joy Springer 771 . Letter dated February 28, 2000 to James Washington from Joy Springer 772. Letter dated February 28, 2000 to James Washington from Joy Springer re: Scouts 773 . Letter dated August 28, 2000 to Ray Gillespie from Joy Springer 774. Letter dated September 12, 2000 to Les Carnine from Joy Springer 77 5. Letter dated October 10, 2000 to Les Carnine from Joy Springer 776. Letter dated September 13, 2000 to James Washington from Joy Springer 777. E-mail dated June 6, 2000 to Les Carnine from Don Stewart (Pages 100-0 1) 778. E-mail dated April 19, 2001 from Deanna Eggeston to Don Stewart (Page 37) 779. E-mail dated April 25, 2001 from Kathy Lease to Mark Mi!Ihollen 780. E-mail dated May 25, 2001 from Bonnie Lesley to Debbie Berry (Page 358) 781. E-mail dated June 7, 2000 from Clay Fendley to Bonnie Lesley 782. E-mail dated June 7, 2000 from Bonnie Lesley to Mary Paa! (Page 136) 783 . E-mail dated April 17-18, 2001 to Don Stewart from Bonnie Lesley 784. E-mail dated July 12, 2001 to Bonnie Lesley from Don Stewart (240) 785 . E-mail dated February 28, 2001 to Bonnie Lesley from Don Stewart 786. Memo dated February 24, 1999 to Gayle Bradford from James Washington 787. Memo dated March l 1, 1999 to Les Carnine from James Washington 788. Letter dated April 12, 1999 to Gayle Bradford from James Washington 3 789. Letter dated March 22, 1999 to Gayle Bradford from James Washington 790. Letter dated April 26, 1999 to John Walker from Les Carnine 791 . Memo dated May 3, 1999 regarding visit to Pupil Services \u0026amp; Administration buildings  792. Email dated 9/30/300 from Marian Lacey to Sadie Mitchell w/attachments 793 . High School Master Schedule Audit, Little Rock School District 2001-2002 794. School Yearbooks for Central, Hall, McClellan, Fair, Hall and Parkview for school years 1998-99 through 2001-2002 795. Letter dated February 28, 2002 from Dr. Michael Faucette to Jane Welch regarding enrollment in Creative Writing course 796. Little Rock Central - Requests for Course - Creative Writing 797. Essay by Justin Mercer entitled: \"Black at Central: My 45 Years of Struggle\" 798. Memo dated August 4, 1999 from Bonnie Lesley to Ann Marshall 799. Academic awards reports for the period 1998 through 2002. 800. Rank Lists for Hall, Parkview, Central, McClellan and Fair for graduating senior classed for the period 1998 through 2002 801. LRSD Quarterly Status Reports - School Services - 1999 through 2002 802. Deposition of School Board Members - a. Sue Strickland b. Tony Rose c. Judy Magness d. Larry Berkley e. Katherine Mitchell 803 . The exhibits filed by the Little Rock School District for this hearing Joshua notes that some of the foregoing exhibits are in the exclusive possession of the Plaintiff. Request is hereby made for those exhibits which include numbers 793, 794, 799, 800. 801. 4 By: Respectfully submitted, John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE 5 / I LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 2:24 PM 'heller@fec.net' Latest Fax I had Aniia fax over to you ihe latest-a bunch of stuff on our literacy plan. 743 1. He already has a copy of the PreK-3 Literacy Plan. Other information is in the Interim and Final Compliance Reports. 2. He also has the test results for SAT9, Grade 4 Benchmark, and ORA-so those are the results. 3. I don't know what he means by monitoring reports. A The assessment program is outlined in several pages in the Compliance Report. 5. I can copy those policies and regs for him. Want me to go ahead and send? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/ 324-2131 501/324-0567 (fax) - LESLEY, BONNIE From: LESLEY, BONNIE Sent: Monday, July 02, 2001 1 :44 PM To: JOHNSON, VIRGINIA Subject: RE: Needed Information-Important! Do you have dates for these three times? --Original Message-- From: JOHNSON, VIRGINIA Sent: Monday, July 02, 2001 1 :15 PM To: LESLEY, BONNIE Subject: RE: Needed Information-Important! Three times I sat in on sessions with Steve Ross along with other PRE staff. At no time did we review any NSF documents. The sessions focused on document review of the ESL and Pre-K Literacy reports. I have never \"consulted\" with him. I have never consulted with Dr. Roberts either. -Original Message-- From: LESLEY, BONNIE Sent: Monday, July 02, 2001 12:07 PM To: ADAMS, LEON; ARNOLD, LAURA BETH; AUSTIN, LINDA; BRANDON, BARBARA; BRIGGS, MONA R.; BROADNAX, KAREN; BUSBEA. PAT; CARR, MARCELLINE; CARSON, RENE': CLEAVER, VANESSA; CLIFFORD, ELIZABETH: CRAWFORD, PAMELA; DAVIS, SUZI; DEBBIE MILAM; DILLINGHAM, YVETTE; DONALDSON, MABLE; FINNEY, ANTONETTE; FLETCHER, DANNY; FREEMAN, ANN; GILLIAM, ANITA; GLASGOW, DENNIS; HARDING, CASSANDRA; HUFFMAN, KRIS; JACKSON, MARION; JOHNSON, VIRGINIA; JONES, DOCIA; JONES, STEPHANIE; KIILSGAARD, SHARON; KILLINGSWORTH, PATRICIA; KOVACH, RENEE; LAJUANA RAINEY; LOYA, STELLA; MARION BALDWIN; MARTIN, PAULETTE: McCOY, EDDIE; McNEAL, MARIE; MILAM, JUDY; NEAL, LUCY; PAAL, MARY M.; PAUL, ANNITA; PERRITT, YORIKO U.; PRICE, PATRICIA; RYNDERS, PAULA; SMITH, GARY; SMITH, PAULA; TEETER, JUDY; WALLS, COLLE::N; WARD, LIONEL; WIWAMS, BARBARA; WILLIAMS, ED: WILSON, LEVANNA; WOODS, MARION Subject: Needed Information-Important! 182 \"\" smmitch@lrsdadm.lrsd.k12.ar.us -Original Message-- A From: CARNINE. L!:::SLIE V. W Sent: Thursday, October 19, 2000 1:59 PM To: MITC~ELL. SADIE Cc: NEAL, LUCY; LESLEY, BONNIE; L!:::ASE. KATHY R.; SMITH, GARY Subject: RE: Will we have the software available by 2nd Semester? What system(s) are being looked at? -Original Message- From: MITCHELL, SADIE Sent Thursday, October 19, 2000 10:33 AM To: CARNINE, LESLIE V. Subject: FVI/: Sadie Mitchell smmitch@lrsdadm.lrsd.k12.ar.us -Original Message- From: SMITH, GARY Sent: Thursday, October 19, 2000 10:25 AM To: LESLEY, BONNIE Cc: WARD, LIONEL; GADBERRY, BRADY L.; NEAL. LUCY; MITCHELL, SADIE; CAWTHON, FRANCES H.; LACEY, MARIAN G.; Subject: Dr. Lesley, ADAMS, LEON; AUSTIN, LINDA; BRADFORD, GAYLE; BRIGGS, MONA; BROADNAX, KAREN; CLEAVER, VANESSA; COLFORD, SUSAN: DAVIS. SUZI: DONALDSON, MABLE; Eddie McCoy; ELSTON, JO; FULLERTON, JAMES; GLASGOW, DENNIS; HAWKS. EVERETT; KEOWN, ADA: MARION BALDWIN; NORMAN, CASSANDRA R.; PRICE. PATRICIA; TATUM. KATHY; WYATT-ROSS. JANICE The consensus recommendation of the SAIP committee is for a SAIP be created for students at all grade levels who are not proficient based state mandated benchmark tests and/or District mandated Achievement Level Tests (ALT) - Our specific recommendations to implement this are;  obtain/create the software necessary to identify students not proficient on state benchmarks/district assessment that will also generate/print the adopted SAIP form with student information and test scores printed on the SAIP form  obtain/create the software that will generate/print specific strategies (along with and printed checklists for those who wish not to use computer) developed by a committee made up of teachers and curriculum specialists as a resource available for teachers to use (especially secondary teachers) - this can be attached to the SAIP form as needed  develop an \"instructional\" sheet for the SAIP form that will explain in more detail the information to documented and procedures to follow  provide training on the use of SAIP form directly to teachers (the exact training may have to be determined at a future date based on the development of software noted above) - delivery of training would need to be coordinated with staff development for most effective and comprehensive presentation to all teachers to all of you in Cyber Land - is there anything else I forgot? - thanks Gary 290 LESLEY, BONNIE - From: Sent: To: Cc: Subject: Message Flag: Due By: Flag Status: BABBS, JUNIOUS Monday, July 02, 2001 8:08 AM ELSTON, JO NEWBURN, LINDA; LESLEY, BONNIE RE: Counseling Program Kit Follow up Monday, July 09, 2001 5:00 PM Flagged It is positive to see that things are moving forward on this \"01 - 02 priority. 745 Prior to coming to closure, I ask that your look to set up a time to fill me in on the \"buy in\" of players called upon (committee members) to develop districtwide literature to be distributed. The connection to Curriculum and Instruction is a biggee that should be run through Dr. Lesley. I will look to give you a call a bit later regarding B/W high school scholarship information and the 3 - 4 year comparisons. To date, this information has not been provided. Junious C Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District -Original Message- From: VANN, SUELLEN Sent: Friday, June 29. 2001 11 :08 AM To: HESTER. GAIL Cc: ELSTON, JO; BABBS. JUNIOUS Subject Counseling Program Kit Jo Evelyn Elston is in my office, and we're working on a counseling program kit with insert sheets. Mr. Babbs will pay for this out of his budget. I'm going to talk with Kristy Black about the design of the kit and sheets, but I figured we'd better give you the info for the quote since it looks like a pretty good-sized job. The kit will be one-pocket on right side with a business card slot; the kit will print front and back with one pocket. There won't be a separate \"wing\" like the recruitment kit had. Quantity: 25,000 Jo Evelyn likes the paper we used for the recruitment kit and insert sheets, so we could just go with those. The insert sheets: 1. JOBBS sheet - print front only; quantity 30,000 -2. Early college planning sheet - print front only; quantity 20,000 3. PCEP sheet - print front only; quantity 20,000 4. What Does Counselor Do? sheet - print front only; quantity 30,000 5. Counseling program sheet - print front and back; quantity 30,000 6. Couseling fact sheet - print front only; quantity 30,000 The kit and insert sheets would print 4-color. Have I forgotten anything? No bleeds. THANKS! (Mr. Babbs, you might want to set up a lemonade stand on Sherman to pay for this!!!!!) Suellen 5. Vann; APR Director of Communications Little Rock School District (SO 1) 324-2020 167 LESLEY, BONNIE - From: LEASE, KATHY R. Sent: To: Thursday, January 18, 2001 6:06 PM BABBS, JUNIOUS Subject: RE: Section 2 Thanks for the input! We have been with the program evaluation consultant all qi3y, so I just finished editing the report to send to Bonnie. I will incorporate your changes and suggestions, and send it to her again. Do you want the Power Point as an Appendix or the outline for it incorporated into the body of the report? I'm so sorry I am just getting around to my email, but I'll take the heat for sending another correction. Not enough hours in the day!! Kathy PS--Thanks for the encouragement! ---Original Message--- From: BABBS, JUNIOUS Sent: Thursday, January 18, 2001 10:53 AM To: LEASE, KATHY R. Cc: GADBERRY, BRADY L. Subject: PN: Section 2 Good information. Working with timelines and specific report information submissions for this division, I have not been able to dissect in great detail but my original thinking touches upon 2 - 3 items that may warrant some review. You will note that Brady is also being forwarded who can provide his thinking as well. Future compliance sessions will toss this about for further revision. 1. Inclusion of the power point presentation. ~ -When touching upon Or. Ross - It may be advantageous to refer to \"looks to build or acknowledges\" specific district W'ettorts as opposed to \"praising\". 3. It would be appropriate to list current data that is available. Be reminded that when writing materials for our report submission, we will include \"districtwide\" not be there yet bui this will help to serve as an indicator of established bas Ine information from which we will jump off of. Keep your chin up . . Junious C Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District -Original Message- Frorn: LEASE. KATHY R. Sent: Wednesday, January 17, 2001 6:14 PM To: LESLEY. BONNIE Cc: BABBS. JUNIOUS; DILLINGHAM. YVETTE; HUFFMAN, MAC; JOHNSON, VIRGINIA; McCOY. EDDIE; SUMMERVILLE, ROSALYN P.; TRUETT, IRMA; WILLIAMS, ED Subject: Section 2  File: Oeseg Report (2.7.1).doc  Bonnie, Here is the first draft of Section 2.7.1. Please let me know what additions or revisions you want made. Thanks, Kathy PS-PRE folks-Look to see what I left out, what typos I have. and what needs tc be edited. Thanks 12 747 Chris, I am in LR this week-end and you can reach me at 868-4289. I can come to your office to help, or I can work from my office. Call if you need me. - Are we having fun yet? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District  3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: LESLEY, BONNIE Sent: To: Monday, July 02, 2001 8:16 AM BRIGGS, MONA R. Subject: RE Thank you, my friend. I \"vegged\" all week-end, seriously \"vegged.\" I know this will be a HARD week. Yes, I hear Kathy is on his witness list. It'll be interesting. -Original Message- F rom: BRIGGS, MONA R. Sent: Monday, July 02, 2001 6:53 AM To: LESLEY, BONNIE Subject: RE: I have been thinking a lot about you. You can't let this bring on a stroke or something. You don't need this kind of pressure all by your self!! It is not worth it-no job is worth it. And you can't take on the woes of a district that has been screwing up for a decade or more. I hope Kathy does get called to testify. She needs to have to answer to John Walker and if it bodes ill for the district so be it! She and Carnine just waltzes out of here and leaves everyone else holding the rope. You make time for sleep and food!! /v\\ona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 \"Seek First to Understand; then to be understood\" (Covey) -----Original Message----- From: LESLEY, BONNIE Sent: Friday, June 29, 2001 7:55 AM Tc: BRIGGS , MONA R. 191 STEWART, DON.ALO M: . From: CARNINE, LESLIE V. Sent: Thursday, November 16, 2000 12:23 PM To: LESLEY, BONNIE Cc: BABBS, JUNIOUS; Mitchell, Sadie; GADBERRY, BRADY L.; STEWART, DONALD M. Subject: Upper Division Cl2sses and Afric2n Americans Were you able to pull together the numbers--l2st year and this year's enrollment? John Walker also has called and is questioning his non involvement in the policy development(IKF). I told him I thought the evidence was so strong for Black kids and that I would send him the information. When was the first time he would have received the policy for comment? He is raising much the same issue-impact on black kids as Katherine ... lKF Subject: L::SL-'Y, BONNIE; CARNINE, LESUE V. RE: C~art Revisions Ken, Th2nks so much for this expl2nation of what happened. The important thing about making a mist2ke is finding a way not to make it again. I think you have done this, and we will all profii from ii. I know you fee! re2lly badly about this, but the most important thing is to correct the process. We all make mistcakes. We are committed to quality in PRE and that includes continuous improvement and continuous learning. This experience has provided us with both. What a bonus!' Thanks for helping with the corrections. I will take care of getting them to the appropriate Cabinet people and getting them redistributed to the Board. -Original Message- F rom: SAVAGE, KEN Sent: Tuesday, November 21 , 2000 10:31 AM To: LEASE. KATHY R. Subject: Chart Revisions Dr Lease, I have reviewed the charts that I created from the benchmark d2t2. When I creaied the charts originally I had encountered a problem simil2r io the one described by Dr. Lesley, but I specifically remember correcting ihe error prior to sending the charts to you. Needless to say, I was more than a little alamned that the charts you received contained errors because the charts I have appe2r to coincide with the data I have. I went on further to investigate by looking at the email I sent you. And there, big as day, the error had reappeared. So the c:-iarts I had sent you were incorrect because they were never updated in the manner that I expected. Here is what I believe happened based on what I remember and what I learned this morning: e: I created the charts in an Excel document that contained the data. I copied the charts only out into another document, creating what is called a linked object. I printed and reviewed the charts and this is when I found the error. I corrected the error and reopened the \"linked\" charts. They appear to have accepted the corrections. I emailed the file wiih the linked charts to you rather than the file containing the charts and data. Here's where the problem arose and information that I have just become aware of this morning. First, when using linked objects, each time you open the file you are given a choice to update the information. Unfortunately, I only sent you the ch2rts and not the daia that drives them. So regard less, you could not have updated the charts. Second, and more importantly, even though a chart has been updated previously, it will always revert back to the original chart that was corrected no matter how many times the data has been updated. Third, if the file with the original data is already open, when the \"linked\" item is opened it automatically updates without intervention. I believe that the second option above is what occurred. The charts were created, an error was encountered and corrected, the link was updated but the chart reverted back to its original when the file was closed. What I propose to do to prevent this kind of fiasco in the future is: 1. Only send charts embedded in files which cont2in the data--no linking. 2. Only create the \"linked\" charts after ALL data h~s been proofed and corrected. \" The erroneous data was only last year's data for black students in the comparison between this year and lasfyear for both) Math and Literacy. I 2m printing and will send ten revised copies of the charts. Ken. 38 LESLEY, BONNIE - From: Sent: To: Subject: LEASE, KATHY R. Wednesday, March 07, 2001 12:44 PM BABBS, JUNIOUS , RE: Research Committee Meeting 75a Bonnie said that the evaluations weren't part of the court submission. Is that still correct? If so, then it looks like we shoula slow down a bit and do It rigm. Are you In agreement? ----,. KL --Original Message--- From: BAS6S, JUNIOUS Sent: Wecnesday, March 07, 2001 12:36 PM To: L=.\u0026lt;1.SE, KATrlY R. Subject: RE: Research Committee Meeting Original thinking was to get another date scheduled prior to the March 15th couri submission but with iniorm2tion you h2ve nored, considerc::tion of a later date is necessary. I don't see major conflict. Junious C Babbs, Jr jcba bbs@stuasn .lrsd. kl 2.ar. us Little Rock School District - Original Message- F rom: LEASE. KATHY R. Sent: Wednesday, March 07, 2001 12:27 PM To: 'trrose@ualr.edu'; BABBS. JUNIOUS Subject: Researc~ Committee Meeting Importance: High We have had another committee member who will not be able to come to the meeting on the 13th. We now have agenda meeting 2t 5:00, and Steve can only be with us by phone. What do you all think about postponing the meeting until after spring break? That would give John plenty of time to make revisions, and we can schedule a meeting when Steve can be with us. I hope to have the template/program evaluation guidelines completed by then as well. Let me know what you thin kl Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc. lrsd .kl2.ar. us 7 LESLEY, BONNIE From: LESLEY, BONNIE Sent: Monday, July 16, 2001 7:2.d. PM To: MITCHELL, SADIE Subject: RE: Documents yes, th2nks. I need as2p. -Oriainal Messaae- From:  MITCHELL. SADIE Sent: Monday, July 16, 2001 5:51 PM To: LESL::Y, BONNIE - Cc: WASHINGTON, CHARLOTTE Subject: Docum~nts We got the list of documents on file done but I forgot to remind Ch2rlotte to send it to you. She is gone for the day and it is on her computer. You will have it first thing in the morning. Sadie Sadie Mitchell smmitch@lrsdadm.lrsd .kl2.ar.us LESLEY, BONNIE From: LESLEY, BONNIE A Sent: W To: Monday, July 16, 2001 7:24 PM WARD, LIONEL Subject: RE: SAIP He requested info from me. I told him I had given him all I had but that you are the administrator on this issue. I was following up to see if he had contacted you. -Original Message- From: WARD, LIONEL Sent Monday, July 16, 2001 4:29 PM To: LESLEY. BONNIE Subject: RE: SAIP Are you irying to tell me something? I have not received any such request from Mr. Walker. If he talks with me, I will talk to you about a proper response first. One basic problem with implementation is in the thought some might harbor which explains why their efforts started late in the game. I am sure some folks faced more struggles than others. Clearly, schools must satisfy the requirements with wise, careful and timely deliberations this year . ., ----__ ....  / --Original Message- From: LESLEY, BONNIE Sent: Sunday, July 15, 2001 3: 49 PM To: WARD, !..!ONEL SubjeC::: SAIP Lionel, h2s Mr. Walker requested anything from you about the implementation of SAIPs? If so, what did you send . to him? Thanks. v-- Dr. Bonnie A. Lesley, Associace Superinte!7dent for Instruction Uttie Rock Scheel District 88 752 501/324-0567 (fax) - LESLEY, BONNIE From: LESLEY, BONNIE. Sent: Monday, July 16, 2001 8:16 AM To: JAMES, KENNETH Subject: RE: Work in Progress Absolutely! -Original Message- From: JAMES. KENNETH Sent: Monday, July 16, 2001 7:54 AM To: L::SLEY, SONNIE Subject: RE: Work in Progress Bonnie: I agree. The work and time that you have invested in this will indeed pay off. as the testimony unfolds. It will be interesting to see how the judge handles all of this information and to observe her thought process. Ken -Original Message-- From: LESLEY, BONNIE Sent: Sunday, July 15, 2001 9:4.2 PM To: JAMES, KENNETH Subject: RE: Work in Progress When I left today, I left a lot still un-done, but I left feeling more and more certain that we have strong evidence that we did the plan. This is going to be helpful to me in remembering all the efforts-even if Chris decides not to use some of it as evidence. I think it will particularly be strong when we combine what Sadie has with ours in this Division. -Original Message- From: JAMES, KENNETH Sent: Sunday, July 15, 2001 9:34 PM To: LESLEY, BONNIE Subjec~: RE: Work in Progress Bonnie: I have reviewed both documents and they are excellent at showing what has been accomplished in the are2s of evaluation and assessment 1 Great job' We will touch base tomorrow. Ken -Original Message- From: LESLEY, BONNIE Sent: Saturday, July 14, 2001 6:24 PM To: 'heller@fec.net'; JAMES, KENNETH; MITCHELL, SADIE Subject: Work in Progress I've worked today on getting the ideas laid out about assessment/program evalu2tion. That includes collecting and organizing stacks of p2per that document our work and processes. In addition, ple2se see the attached documents to determine if this is where we want to go. I welcome your feedback.  Fiie: 1 Program i:1aluation.doc \u0026gt;\u0026gt;  File: 1 Assessment Grid.doc  96 Little Rock, ArkaT1S2s 72206 501/324-2131 - 501/ 324 -'.)567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject: LESLEY, BONNIE Sunday, July 15, 2001 3:41 PM 'heller@fec.net' JAMES, KENNETH SAIPs Mr. Walker requested on June 20 the follow: \"Please advise whether you have information regarding the District's implementation of STt!dent Academic Improvement Plan (SAIP) as required by the State. If so, please share with this this office.\" I replied: \"You will find that information in the March 2001 Compliance Report in Section 2. 7. I do not have any information beyond what you will find there since the implementation is done at the school level. Leonel Ward is in charge of implementation.\" When I searched everything for the documents I needed from you, I found several memos in Learning Links that I had forgotten about-about the philosophy in implementing SAIP, sample SAIPs done by Price, Glasgow, and Davis, the memo establishing the committee to develop the program. the memo to the board, etc. Should I forward those to Mr. Walker as well? . Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District A 3001 5. Pulaski W little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: LESLEY, BONNIE Sent: Saturday, July 14, 2001 6:24 PM To: Subject: 'heller@fec.net'; JAMES, KENNETH; MITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, ple2se see the attached documents to determine if this is where we want to go. I welcome your feedback. ~ 1 Program Evalualion.aoc i Assessment Grid.doc Dr. Sonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 5. Pulaski a :ttle Rock, Arkansas 72206 ~ 01/324-2131 501/ 324-0567 (fax) 102 . LESLEY, BONNIE - From: Sent: To: Cc: Subject: Don Crary [dcrary@newfuturesforyouth.org] Wednesday, April 18, 2001 1 :33 PM LESLEY, BONNIE mopierce@newfuturesforyouth.org Re: Computer with Access Great. We can pay for it. I'm sure it will be cheaper if it is purchased through the district contract. The district can invoice us and we will reimburse them for the cost. Don -Original Message- From: LESLEY, BONNIE \u0026lt;BALESLE@IRC.LRSD.K12.AR.US\u0026gt; To: 'dcrary@newfuturesforyouth.org' \u0026lt;dcrary@newfuturesforyouth.org\u0026gt; Cc: BRIGGS, MONA R. \u0026lt;MRBRIGG@ANNEX.LRSD.K12.AR.US\u0026gt;; PAAL, MARY M. \u0026lt;MMPAAL@ANNEX.LRSD.K12.AR.US\u0026gt; Date: 04/18/2001 12:50 PM Subject: Computer with Access \u0026gt;I talked with Mona about your need for a dedicated computer somewhere in the \u0026gt;district so that your evaluator can come work on direct access to the data \u0026gt;base. She is arranging for an additional computer drop in the office that \u0026gt;Mary Paa! will have at Garland. Can you all purchase the computer out of . your budget? \u0026gt;Dr. Bonnie A. Lesley, Associate Superintendent for Instruction \u0026gt;Little Rock School District \u0026gt;3001 S. Pul;:3ski \u0026gt;Little Rock, Arkansas 72206 \u0026gt;501/324-2131 \u0026gt;501/324-0567 (fax) \u0026gt; \u0026gt; LESLEY, BONNIE From: Sent: To: Cc: Subject: Bonnie, LEASE, KA THY R. Wednesday, April 18, 2001 12:32 PM LESLEY, BONNIE MITCHELL, SADIE; CAWTHON, FRANCES H.; LACEY, MARIAN G. RE: ALT Results --.......__ What group of principals did you meet with yesterday? Do I need to contact them? I explained to all of them when we did the testing calendar that we could get results back to everyone before school was out, if they followed the schedule. If there are some that we need to follow up with, please let me know who they are. We are returning ALT results as quickly as schools get them in. The whole purpose of setting up the schedule like it is centers around being able to get the results back to everyone before school is out. District results can't be calculated until  I schools are in. That is why it is imperative that everyone stay on schedule. Both teachers and parents will get their suits unless someone doesn't follow the schedule. Second grade results have all been returned to the schools, along with two copies of the parent report. High school preliminary results have been returned to Parkview and Fair. McClellan's results are here and are being scored. Central and Hall have not turned in their answer sheets yet. All make-ups were to have been completed by this past Monday. Reiests for high schools are due back on Friday. The first page of the parent report can be printed, but we can 't print the longitudinal report for parents unless all high schools are in.  708 Our elementary schools did a great job during 2nd grade testing; so if they keep that up, we will sail right through their scoring and printing. They have all of their results. .  \\/Ve're still missing two of the middle schools' Algebra I I geometry results as of this morning. We are having a scoring robiem with the high school science tests, but NWEA is working on it. The subject specific math and science tests require no retests, so that shouldn't hold things up. Also, we have provided data on request any school who wants to know last fall's ALT scores for their rising grade students. If you have any other questions, please let me know. Kathy ---Original Message---- F rom: LESLEY, BONNIE Sent: Wednesday, April 18, 2001 10:37 AM To: LEASE, KATHY R. Subject: ALT Results l met with a group of principals yesterday who suggested to me that if they can't receive their ALT results before school is out that there is no use in sending them at all. Kids and parents need them quickly, and the school needs them quickly in order to plan for next school year. What our your chances of being able to do that? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE \u0026amp; om: . ent: To: Subject: Rose.doc Paulette Mabry [pmabry@newfuturesforyouth.org] Wednesday, April 18, 2001 10:59 AM Bonnie Lesley; Brady Gadberry; Junious Babbs; Linda Austin; Marian G. Lacey; Sadie Mitchell Words to encourage us Thought you might enjoy this today as a way to jumpstart the afternoon when things seem impossible. Paulette LESLEY, BONNIE From: BRIGGS, MONA R. Sent: To: Wednesday, April 18, 200110:10 AM LESLEY, BONNIE Subject: Cost of Tools for Learning (Fred Jones); Parent Component Importance: High The discounted costs of books is: 500 books @ $18.00 (regularly priced at 29.95) 300-499@ $18.50  0-299@ $18.95 0-199@ $19.95 Shipping for 500 is $546.75; it may be slightly less for fewer numbers but not significantly. RE: Parent involvement with training 709 GADBERRY, BRADY L. -From: Sent: To: Subject: LEASE, KATHY R. Tuesday, November 28, 2000 4:31 PM BABBS, JUNIOUS; FRANCES CAWTHON; Gadberry, Brady L.; Hurley, Richard; LESLEY, BONNIE; Leslie Carnine; LINDA WATSON; MARIAN LACEY; Milhollen, Mark; Sadie Mitchell; STEWART, DONALD M.; Vann, Suellen Steve Ross-Program Evaluation.ppt Steve Ross-Program Evaluation-.. FYI--Here is a copy of Steve's presentation to the Board. KL GADBERRY, BRADY L. From: LEASE, KATHY R. Sent: To: Thursday, November 16, 2000 8:32 AM GADBERRY, BRADY L. Subject: RE: PRE List Requested - ~hared with Babbs that I thought we could provide some assistance in PRE to make the surveying process a little easier.  eve got the equipment and the software! I just talked with Gene Jones to confirm his schedule, and he said that he was invited to the compliance meeting tomorrow morning. I told him, \"Great! See you then!\" KL ---Original Message- From: GADBERRY, BRADY L. Sent: Thursday, November 16, 2000 8: 17 AM To: BABBS. JUNIOUS Cc: LEASE, KATHY R. Subject: RE: PRE List Requested We were told early in the year by Dr. Carnine that all surveys would be done through PRE. ----Original Message----- F rom: BABBS, JUNIOUS Sent: Tuesday, November 14, 2000 7:15 PM To : GADBERRY, BRADY L. Cc: LEASE, KATHY R. Subject: FW: PRE List Requested To my knowledge Vic and I both allowed department \"Quality of Service Surveys\" that went to appropriate building staff to be returned and worked through our own division shops. What is your thinking to continue with this format or consideration through PRE ? Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us little Rock School District - Original Message- From: L~SE, KATHY R. Sent: Friday, November 10, 2000 12:18AM To: 'Clay Fendley'; LESLEY, BONNIE; BABBS, JUNIOUS; MITCHELL. SADIE; GADBERRY, BRADY L.; STEWART, DONALD M. Cc: CARNINE, LESLIE V. Subject: List Requested Dear Folks, Attached is the list of programs or strategies that have either received some evaluation services or have requested evaluaiion services. If you need additional information, please let me know. 15 Thanks, Kathy - \u0026lt;\u0026lt; File: Addition2I Programs and Strategies Requesting Evaluation.doc GADBERRY, BRADY L. From: Sent:  To: Subject: logo memo.doc LEASE, KATHY R. Friday, October 27, 2000 2:52 PM MITCHELL, SADIE; LESLEY, BONNIE; BABBS, JUNIOUS; GADBERRY, BRADY L.; STEWART, DONALD M. Memo to Gene Jones Here is what I am having Irma send on Monday. If you see anything that needs to be changed, let her know ASAP. KL GADBERRY, BRADY L. From: LEASE, KA THY R. Sent: Wednesday, October 25, 2000 8:37 PM To: CARNINE, LESLIE V.; MITCHELL, SADIE; BABBS, JUNIOUS; GADBERRY, BRADY L. Subject: FW: Benchmark Scores - ear Folks. If Bonnie wants to continua lly harass me that is one thing , but I would appreciate it if she didn't pick on my assistant. Please read the exchanges below. She also left Irma a voice message that was very curt. Irma h2s been working like a dog in room 16 to finish up the answer documents for the CRTs, so she wasn't immediately available to read email or answer the telephone. No one came down here looking for her, so she didn't know that there was an urgent message. I emailed a reply message to Bonnie and sent you all a blind copy; so I'm sure I'll be in trouble again. However, there has to be an end to this. We are working as hard as we can to produce these test reports, implement the assessment program, and produce program evaluations. I don't know how much more I can stand. She also continues to work behind my back through Eddie McCoy. This is ridiculous!! Who could be successful in such an environment? I'm sorry for ranting, but I am exhausted mentally, physically, and emotionally. Kathy -Original Message- From: TRUETT, IRMA Sent: Wednesday, October 25. 2000 8:21 PM To: LEASE. KATHY R. Subject: FW: Benchmark Sccres -Original Message- From: LESLEY, BONNIE Sent: Wednesday, October 25, 2000 5:05 PM To: TRUETT, IRMA Subject: RE: Benchmark Sccres I'm sorry, Irma, but I can't accept that response. -Original Message- From: TRUETT, IRMA Sent: Wednesday, October 25, 2000 2:08 PM To: LESLEY, BONNIE Subject: RE: Benchmark Sccres Sorry, I'm just now getting your e-mail, but I've been working in room 16. I don't have this information and frorn what I underst2nd Dr. Lease has it with her to give to the principals this afternoon. Sorry! - Original Message- 16 From: L::SLEY, BONNIE Sent: Wednesday, October 25, 2000 9:44 AM To: TRUETT, IRMA Subject: Benchmark Scores I need copies of the state test results by school in my office asap. Board members and others are calling for information. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) GADBERRY, BRADY L. From: Sent: To: Subject: Bonnie, LEASE, KATHY R. Wednesday, October 25, 2000 8:17 PM LESLEY, BONNIE Benchmark Scores Irma forwarded your messages to her about the test scores. As I told you when we met with Suellen, I would have your curriculum copies ready by Friday. They are ready now. After learning that you were insistent on having the scores immediately, I stayed late tonight and finished them up. Irma came back down here from home to help me. I am just waiting on your initials on the memos. I will bring them to the Institute tomorrow. Irma can come pick them up and make copies. I understood Dr. Carnine to say that the Board reports could be sent in the Friday report. I had them ready at the Board meeting, but he didn't want them distributed until we had more time to confirm the data. Since you  ave asked for them, I printed what we have at this time in draft copy. I will give the copies to you that are printed for the oard. If you think they need to be sent by special courier rather than in the Friday report, that will be your choice. I was nly trying to follow the directions I was given. If you needed the scores so quickly, why didn't you call me out of the meeting today? Irma didn't even know where we had secured the copies of the reports. It was very unfair of you to keep harassing her and making her feel badly because she couldn't produce the reports instantly for you. If you need something, please do me the courtesy of asking me for it. I understood that the Friday timeline was satisfactory with you. If it wasn't, you should have let me know. Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.k12.ar.us 17 Subject: RE: This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Friday! -Original Message- From: BRIGGS, MONA R. Sent: Thursday, June 28, 2001 8:00 PM To: LESLEY, BONNIE Subject: RE: Bonnie, I hate all this, don't you? I guess you will have your \"day in court.\" Too bad Kathy didn't get in on it ... I understand from Eddie that she took all her files with her. What a deal. Surely, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Brig~ N1iadI~ [~~~I Specialist Little Rock School District 501-324-2412 \"Seek First to Undersfal7d; then to be understood\" (Covey) -----Original Message----F rom: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN; GLENN, RANDALL; WATSON, LINDA; ELSTON, JO; WIEDOWER, JULIE; EGGLESTON, DEANA; ADAMS, LEON; ARNOLD, LAURA BETH; AUSTIN, LINDA; BRANDON, BARBARA; BRIGGS, MONA R.; BROADNAX, KAREN; BUSBEA, PAT; CARR, MARCELLINE; CARSON, RENE'; CLEAVER, VANESSA;  CLIFFORD, ELIZABETH; CRAWFORD, PAMELA; DAVIS, SUZI; DEBBIE MILAM; DILLINGHAM, YVETTE; DONALDSON, MABLE; FI!\\JNEY, ANTONETTE; FLETCHER, DANNY; FREEMAN, A~~N; GILLIAM, ANITA; GLASGOW, DENNIS; HARDING, CASSAt\\JDRA; HUFFMAN, KRIS; JACKSON, MARION; JOHNSON, VIRGINIA; JONES, DOCIA; JONES, STEPHANIE;_ l92 Subject: RE: This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Friday! -Original Message- Frorn: BRIGGS, MONA R. Sent: Thursday, June 28, 2001 8:00 PM To: LESLEY, BONNIE Subject: RE: Bonnie, I hate all this, don't you? I guess you will have your \"day in court.\" Too bad Kathy didn't get in on it ... I understand from Eddie that she took ell her files with her. What a deal. Surely, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Brig~ Mia-a,~ [~~~I Specialist Little Rock School District 501-324-2412 \"Seek First to Understand; then to be understood\" (Covey) -----Original Message----From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN; GLENN, RANDALL; WATSON, LINDA; ELSTON, JO; WIEDOWER, JULIE; EGGLESTON, DEANA; ADAMS, LEON; ARNOLD, LAURA BETH; AUSTIN, LINDA; BRANDON, BARBARA; BRIGGS, MONA R.; BROADNAX, KAREN; BUSBEA, PAT; CARR, MARCELLINE; CARSON, RENE'; CLEAVER, VANESSA;  CLIFFORD, ELIZABETH; CRAWFORD, PAMELA; DAVIS, SUZI; DEBBIE MILAM; DILLINGHAM, YVETTE; DONALDSON, MABLE; FINNEY, ANTONETTE; FLETCHER, DANNY; FREEMAN, ANN: GILLIAM, ANITA; GLASGOW, DENNIS; HARDING, CASSAt'\\JDRA; HUFFMAN, KRIS; JACKSON, MARION; JOHNSON, VIRGINIA; JONES, DOCIA; JONES, STEPHANIE; 192 LESLEY, BONNIE From: Sent: To: Subject: ?57 KIILSGAARD, SHARON; KILLINGSWORTH, PATRICIA; KOVACH, RENEE: LAJUANA RAINEY; LOYA, STELLA; MARION BALDWIN; MARTIN, PAULETTE; McCOY, EDDIE; McNEAL, MARIE; MILAM, JUDY; NEAL, LUCY; PAAL, MARY M.; PAUL, ANNITA; PERRITT, YORIKO U.; PRICE, PATRICIA; RYNDERS, PAULA; SMITH, GARY; SMITH, PAULA; TEETER, JUDY; WALLS, COLLEEN; WARD, LIONEL; WILLIAMS, BARBARA; WILLIAMS, ED; WILSON, LEVANNA; WOODS, MARION Cc: 'heller@fec.net' Subject: I just spoke with Chris Heller, our attorney. He asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Please make sure the staff not named in th is e-mail also understand this directive. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/3 24-2131 501/324-0567 (fax) LESLEY, BONNIE Friday, June 29, 2001 2:47 PM ADAMS, LEON; ARNOLD, LAURA BETH; AUSTIN , LINDA; BRANDON, BARBARA; BRIGGS, MONA R.; BROADNAX, KAREN; BUSBEA, PAT; CARR, MARCELLINE; CARSON, RENE'; CLEAVER, VANESSA; CLIFFORD, ELIZABETH; CRAWFORD, PAMELA; DAVIS, SUZI; DEBBIE MILAM; DILLINGHAM, YVETTE; DONALDSON, MABLE; FINNEY, ANTONETTE; FLETCHER, DANNY; FREEMAN, ANN; GILLIAM, ANITA; GLASGOW, DENNIS; HARDING, CASSANDRA; HUFFMAN, KRIS; JACKSON, MARION; JOHNSON, VIRGINIA; JONES, OOCIA; JONES, STEPHANIE; KIILSGAARO, SHARON; KILLINGSWORTH, PATRICIA; KOVACH, RENEE; LAJUANA RAINEY; LOYA, STELLA; MARION BALDWIN; MARTIN, PAULETTE; McCOY, EDDIE; McNEAL, MARIE; MILAM, JUDY; NEAL, LUCY; PAAL, MARY M. ; PAUL, ANNITA; PERRITT, YORIKO U.; PRICE, PATRICIA; RYNDERS, PAULA; SMITH, GARY; SMITH, PAULA; TEETER, JUDY; WALLS, COLLEEN; WARD, LIONEL; WILLIAMS, BARBARA; WILLIAMS, ED; WILSON, LEVANNA; WOODS, MARION; BABBS, JUNIOUS; FRANCES CAWTHON; GADBERRY, BRADY L. ; HURLEY, RICHARD; JAMES, KENNETH; LINDA WATSON; MARIAN LACEY; MILHOLLEN, MARK; Sadie Mitchell; STEWART, DONALD M.; VANN, SUELLEN; WATSON, LINDA; ANDERSON, BARBARA; ASHLEY, VIRGINIA; BRANCH, SAMUEL; BROOKS, SHARON; CARSON, CHERYL; CARTER, LILLIE; COURTNEY, THERESA; COX, ELEANOR; DARIAN SMITH; DEBORAH MITCHELL; ETHEL DUNBAR; Faith Donovan; FIELDS, FREDERICK; GOLSTON, MARY; HALL, DONNA; HARKEY, JANE; HOBBS, FELICIA L; JONES, BEVERLY; KEOWN, ADA; Lillie Scull; MANGAN, ANN; MANNO, ROBERTA; MARY BARKSDALE; MENKING, MARY; MORGAN, SCOTT; NANCY ACRE; OLIVER, MICHAEL; PHILLIPS, TABITHA; SHARON BROOKS; SMITH, MARY; TAYLOR, LESLIE; TUCKER, JANIS A.; WILSON, JANICE M. ; WORM, JERRY; ZEIGLER, GWEN S.; BERRY, DEBORAH; BLAYLOCK, ANN; FULLERTON, JAMES; HUDSON, ELOUISE; Larry Buck; MOSBY, JIMMY; PATTERSON, DAVID; ROUSSEAU, NANCY; SAIN, LLOYD ORA Results by Middle School Feeder Pattern 193 the AL Ts, and so they were down there yesterday and again today just kind of picking it up, but they do not necessarily know what they are supposed to be doing. They need direction, and I don't feel that I should provide it. - ow do you want to handle this? LESLEY, BONNIE From: LEASE, KA THY R. Sent: To: Monday, October 02, 2000 6:48 PM CARNINE, LESLIE V. Subject: FW: Priorities 2000-2001 Dr. C., I'm sorry. I guess I don't quite know what to do with the plan I sent to Bonnie. I guess I missed the mark. I thought we were to develop what we were doing in our department to meet the areas you outlined in your critical priorities processes. Do you want me to send the parts to the people Bonnie mentioned below? Or are you going to put it all together using what you want out of what we sent? Let me know what you want me to do. KL -Original Message- From: LESLEY, BONNIE Sent: Friday, September 29, 2000 3:04 PM To: LEASE, KATHY R. Subject: RE: Priorities 2000-2001 You need to send the technology stuff to Lucy Neal. You need to send the Campus Leadership stuff to Sadie Mitchell. I suggest that you forward the other two pieces directly to Dr. Carnine. They are much more detailed than the other items in the Division of Instruction Work Plan and therefore don't \"fit\" with what we have. Alsp; I know nothing about the Quality Initiative Plan, so that makes no sense. to.roe0 Perhaps he can just include your items separately.     -- -  -  -0-riginal Message- From: LEASE, KATHY R. Sent: Friday, September 29, 2000 2:50 PM To: LESLEY, BONNIE Subject: Priorities 2000-2001 Importance: High I had massive computer failures today. It took Ed, Ken, Virginia, and Irma to help me get it all back. Here are the priorities from PRE. Call me, if you want me to go over them with you. Thanks, Kathy \u0026lt;\u0026lt; File: Priority II Technology 2000-2001 .doc   File: Priority 11I-2000.doc   File: Priority IV InstructionAssessment. doc   File: Priority IV Instruction-evaluation.doc \u0026gt;\u0026gt; Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd .k12.ar.us 51 sounds like the our data is available. - ESLEY, BONNIE From: Sent: To: Subject: Dr. C., LEASE, KA THY R. Tuesday, October 03, 2000 6:09 PM CARNINE, LESLIE V. CTA issues 75.1 Did Clementine come in today to discuss assessment issues with you? I invited her in last spring to talk with me, but she never came. If she has some specific issues that you think we need to address in the questionnaire, let me know. I started drafting some ideas about questions, but I think I need some input from you. It looks like from one of the emails you sent that folks have been communicating with you about their concerns. They may have shared some things we haven't thought about. Let me know if you have any time tomorrow afternoon to visit with me (phone or in person) about the survey. Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl 2.ar.us LESLEY, BONNIE a rorn: LEASE, KA THY R.  ent: To: Tuesday, October 03, 2000 5:45 PM CARNINE, LESLIE V. Subject: RE: ALT Check-In, Etc. This is pure fabrication . This is not the situation here in PRE. We have a fox in the hen house. I thought this kind of thing was supposed to be over. The digs have continued. The ALT process has to have someone who shepherds it. I said originally that I would need Gayle at least six weeks to two months. I fully understand the strain that Sadie is under because she has come to depend on Gayle as well. If Gayle cannot fulfill her commitment with ALT, then I think she would let me know. She had to go over to the administration building to get some work done to be ready for the Bi-Racial committee report that she is scheduled to give tonight. Roz told her that she could take care of anyone who checked in things today. I guess the real question is that if my staff thinks they are having a problem \"handling\" the ALT today, why didn't they contact me? We had Ed here scanning and scoring, and Irma received no calls that she couldn't handle. I'm afraid I am left with no other conclusion but that this is continued harassment by the person that I thought had agreed to quit harassing. Can you help me with any other explanation? KL -Original Message- From: CARNINE, LESLIE V. Sent: Tuesday, October 03, 2000 11 :10 AM To: LEASE, KATHY R. Cc: Mijchell, Sadie Subject: FW: ALT Check-In, Etc. I know you know how assumptions can get you in trouble. Obviously, there appears to be a communication problem and I would hope you and Sadie could work it out. -Original Message- Arom: LESL!::Y, BONNIE wrent: Tuesday, October 03. 2000 10:55 AM To: CARNINE, LESLIE V. Subject: ALT Check-In, Etc. I have had three complaints already today-two from IRC staff and one from building-level. Gayle has returned to downtown, and Kathy is sitting in the school improvement meetings. Neither of them organized the staff for the return cif so 76D - LESLEY, BONNIE From: Sent: To: Subject: Thanks, Bev. -Original Message- LESLEY, BONNIE Wednesday, June 20, 2001 1:13 PM GRIFFIN, BEVERLY RE Semester Test Exemption From: .GRIFFIN, BEVERLY Sent: Wednesday, June 20, 2001 1:15 PM To: LESLEY, BONNIE Subject: RE: Semester Test Exemption i gave a copy of th~ minutes from the February Board meeting to Mr:3. Lacey earlier this week. I don't think I have;--, copy of the kids proposal, but I will check. l was under the impression that this action was for this years seniors only. I might be wrong . . . but, it might be worth checking with Board members to see if they intended for it to be a permanent change to the policy. I will fax you the minutes in just a minute. -Original Message- From: LESLEY, BONNIE , Sent: Wednesday, June 20, 2001 12:51 PM To: GRIFFIN, BEVERLY Subject: Semester Test Exemption Bev, there is wide disagreement about what people remember as the motion the board made regarding the exemption of seniors from their spring semester tests. I don't remember the month they did that-probably February or March? Will you send to me the text of the motion, as well as the text of the language used by the kids in their proposal. I don't have that and will need it to update those regulations/policies. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, .Arkansas 72206 501/324~2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Wednesday, June 20, 2001 1 :12 PM TRUETT, IRMA Compliance i - - --- ~ The compliance report lists several \"program evaluations\" that PRE reported that they had completed, but which I have never seen. Please provide me with three copies each of the following reports. They have been requested by Mr. Walker. '  Extended Year Schools Summer School HIPPY Program  parter Scho0I W'.ampus Leadership Teams Engiish as a Second Language , Lyceum Scholars Program at Philander Smith Colleae Southwest Middle School's SEDL Program - Onward to Excellence (Watson Elementary) Collaborative Action Team (CAT) 351 - LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, June 25, 2001 12:37 PM 'Clay Fendley'; 'heller@fec.net' RE: Meeting schedule Yea! Thanks you! I can't tell you how important this is! 76/ I just talked with Ann Brown. She wanted all the test scores. I put her off until the end of the week. We need to talk about what to give her. -Original Message- From: Clay Fendley [SMTP:FENDLEY@fec.net] Sent: Monday, June 25, 2001 12:42 PM To: BALESLE@IRC.LRSD.K12.AR.US Cc: Chris Heller Subject: RE: Meeting schedule Leaving at 1 :05 on the 6th is fine. We will tell Walker that if he wants to call you as a witness, he will need to call you on the 5th. Thanks. \u0026gt; \"LESLEY, BONNIE\" \u0026lt;BALESLE@IRC.LRSD.K12.AR.US\u0026gt; 06/25/0111:49AM \u0026gt; I just called the airlines. I would need to catch a plane at 1 :05 on the 6th to get to Amarillo in time for the rehearsal dinner for this big wedding. If I can't do that, then the latest I could leave to get there at all on Friday is at.5:35 Then I would-come. home on Sunday. What do you advise? \u0026gt; -Original Message- \u0026gt; From: Clay Fendley [SMTP:FENDLEY@fec.net] \u0026gt; Sent: Monday, June 25, 2001 9:41 AM \u0026gt; To: BALESLE@IRC.LRSD.K12.AR.US; blgadbe@lrsdadm.lrsd.k12.ar.us; \u0026gt; DMSTEWA@lrsdadm.lrsd.k12.ar.us; lvcami@lrsdadm.lrsd.k12.ar.us; \u0026gt; SMMitch@lrsdadm.lrsd.k12.ar.us; JCBABBS@STUASN.LRSD.K12.AR.US \u0026gt; Cc: Chris Heller; KJAMES@lrsdadm.lrsd.k12.ar.us \u0026gt; Subject: Meeting schedule \u0026gt; \u0026gt; Here's the meeting schedule so far: \u0026gt; \u0026gt; Mr. Gadberry - Wednesday at 2:00 at our office. \u0026gt; Dr. Lesley - Thursday at 1 :DO at our office. \u0026gt; Ms. Mitchell - Friday at 9:00 at our office. \u0026gt; \u0026gt; We should get Joshua's objections today and have requested a witness list \u0026gt; by Wednesday. \u0026gt; \u0026gt;Weare leaving Monday (July 2) open until we get Joshua's witness list. \u0026gt; Everybody plan on meeting Tuesday (July 3) all day at our office. Let me \u0026gt; know if that presents a problem for you, and we can try to work around \u0026gt; your schedu_le. \u0026gt; \u0026gt; Remember, the most important thing in preparation for the hearing is for \u0026gt; you to know what's in the Revised Plan and the interim and final \u0026gt; compliance reports. \u0026gt; \u0026gt; We will provide copies of Joshua's objections as soon as they are \u0026gt; received. \u0026gt; \u0026gt; Let me know if you have any questions. \u0026gt; selected to receive Merit Scholarship awards. The info in italics is from the National Merit web site. So, of the 1.2 million entrants, only 7,900 are named Finalists for National Merit scholarships and corporate-sponsored scholarships. That amounts to 6/10 of 1 % of the entrants. Mr. Walker's statement on page 22 is: \"We note here that the district is yet to have a single Black national merit scholar in the nineteen years of this active litigation.\" THIS IS INCORRECT. Without reviewing 19 years of data (and we don't have al(b:f the data for those years), as recently as 4 years ago Salonica Gray, an A.fiican American female senior at Central, was a National Merit Finalist. Hope this helps! Suellen 5. Vann, APR Director of Communications Little Rock School District (501) 324-2020 LESLEY, BONNIE From: LESLEY, BONNIE Sent: Thursday, June 28, 200111 :36 AM To: MITCHELL, SADIE Subject: RE: ~ am wondering how he is feeling as well. This is baptism by fire. -Original Message- From:  MITCHELL. SADIE Sent: Thursday, June 28, 2001 9:29 AM To: LESLEY, BONNIE Subject RE: I panicked when I got here and saw all of the stuff from John. I am worried about Dr. James. I hope he will be able to handle all of this. Sadie Mitchell smmitch@lrsdadm.lrsd.k12.ar.us -Original MessageFrom: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:09 AM To: MITCHELL, SADIE Subject: RE: He was kind of angry that we are even attempting to respond to this stuff. He asked me what he needed to do to make sure everyone understands that we are not to play Mr. Walker's game. How ya doing today? -Original Message- From: MITCHEU, SADIE Sent: Thursday, June 28, 2001 9:18 AM To: LESLEY, BONNIE Subject: RE: :) Sadie Mitchell smmitch@lrsdadm.lrsd.k12.ar.us - __1!_8_ ------ - - --- - ------ --- - - -Original Message- From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:04 AM To: MITCHELL, SADIE; EGGLESTON, DEANA; GADBERRY, B~DY L.; STEWART, DONALD M.; BABBS, JUNIOUS; JAMES, KENNETH Cc: 'heller@fec.net' Subject: RE: I just spoke with Chris Heller, and he asked me to tell all of you that we are not going to make this information (copies of our invitations and documents sent to Mr.Walker or Ms. Springer) available to Mr. Walker. It is without exception stuff we have already sent to him:\"- He also asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. -Original Message- From: MITCHELL, SADIE Sent: Thursday, June 28, 2001 9:03 AM To: EGGLESTON, DEANA Cc: LESLEY, BONNIE; GADBERRY, BRADY L.; STEWART, DONALD M.; BABBS, JUNIOUS Subject: RE: Thank you Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us -Original Message- From: EGGLESTON, DEANA Sent: Thursday, June 28, 2001 8:38 AM To: MITCHELL, SADIE Cc: BABBS, JUNIOUS Subject: RE: Everyone sent the information when it was requested, however, I'm not sure if they have sent recent documents since his original request. I just spoke with Cly and he said to make the folders we have available to Joy on Monday as per \"her request, but for me to not to put the documents in any particular order (ie. date, subject, etc.) -  - ------  - .. ~.. . -- --- ---- .. -- - . ___ .. Deana -Original Message- From: MITCHELL, SADIE Sent: Thursday, June 28, 2001 8:41 AM To: LESLEY, BONNIE; STEWART, DONALD M.; GADBERRY, BRADY L.; BABBS, JUNIOUS; JAMES, KENNETH   Cc: EGGLESTON, DEANA Subject: Mr. Walker sent a fax requesting \"all invitations to Ms. Springer or Mr. Walker to meetings of any kind, as well as copies of any documents you have sent to them over the past three years. Also any document of whether Mr. Walker or Ms. Springer actually attended the meetings to which you invited them.\" I think we already sent this information to Mr. Babbs and he compiled it. Is this correct? Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 219 - - LESLEY, BONNIE From: LEASE, KATHY R. Sent: To: Tuesday, February 13, 2001 12:54 PM CARNINE, LESLIE V. Subject: FW: Test Pack Importance: High Dr. Carnine, What is the purpose of this? Am I missing something? Is Bonnie trying to eliminate her need to work with this department? We have some software that is licensed to this department. Eddie has been trying to get it loaded on her computer. My guess is that she needs it to work on her dissertation. She has not spoken to me about what her data needs are for her dissertation. Most doctoral candidates come in and visit with us about their data needs. We work with them, but they get data in an aggregate form, not individual students' information. I wish you would please tell me what role you want this department to play. I know the game that is being played. I am about to my wit's end with it. Kathy -Original Message--- From: JOHNSON, VIRGINIA Sent Tuesday, February 13, 200112:43 PM To: LEASE, KATHY R. Subject: FW: Test Pack -Original Message-  om: LESLEY, BONNIE nt; Monday, February 12, 2001 5:31 PM , o: RUFFINS, JOHN Cc: JOHNSON, VIRGINIA; McCOY, EDDIE; CLEAVER, VANESSA Subject RE: Test Pack Thanks so much, JOhn. -Original Message- From: RUFFINS, JOHN Sent; Monday, February 12, 2001 4:46 PM To: LESLEY, BONNIE Subject: RE: Test Pack I will come over and personally visit with Virginia and Eddie to access their data and program needs. -- -Original Message--From: LESLEY, BONNIE Sent Monday, February 12, 2001 2:40 PM To: RUFFINS, JOHN Subject Test Pack John, I am moving Eddie McCoy and Virginia Johnson out of the rooms designated for PRE and into the room where Vanessa Cleaver is. Both of them will have some program evaluation responsibilities and need to be able to access the SAT9 data, as well as other student data. How do I get those programs loaded onto their machines? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 19 ' LESLEY, BONNIE From: LEASE, KA THY R. Sent: To: Tuesday, February 13, 2001 5:36 PM CARNINE, LESLIE V. Subject: RE: Another thought Here's one more thought, then I'm burying this frustration. I wouldn't have knowt'i\" about what she is doing at all if Virginia hadn't forwarded me a copy of the message. I'm trapped in junior high!!! Can't somebody save me??? Kathy -Original Message-- From: CARNINE, LESLIE V. Sent: Tuesday, February 13, 2001 4:05 PM To: LEASE, KATHY R. Subject: RE: Another thought I can support but you do not want to hold the data ... You want free access. Give her all the access she wants or needs ... and then give her more. -Original Message- From: LEASE, KATHY R. Sent: Tuesday, February 13, 2001 12:56 PM To: CARNINE, LESLIE V. Subject: Another thought Is it possible to require Bonnie to work through me to get the data she needs? .She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can yo1:1 s1:1ppo1Tusor are weTon our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 5. Pulaski Little Rock, AR 72206 LESLEY, BONNIE From: LEASE, KATHY R. 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc. lrsd .k12.ar. us Sent: To: Tuesday, February 13, 2001 4:10 PM CARNINE, LESLIE V. Subject: RE: Another thought I totally agree with that. I want everyone to have access to the data at his or her fingertips. I just continue to be frustrated with the way she refuses to work with me. Kathy -- -Original Message--- From: CARNINE, LESUE V. Sent: Tuesday, February 13, 2001 4:05 PM To: LEASE, KATHY R. Subject: RE: Another thought \u0026amp; can support but you do not want to hold the data ... You want free access. Give her all the access she wants or needs ...  nd then give her more. --Original Message- From: LEASE, KATHY R. Sent: Tuesday, February 13, 2001 12:56 PM To: CARNINE, LESLIE V. Subject: Another thought 17 Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 LESLEY, BONNIE 501 -324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.k12.ar.us From: LEASE, KA THY R. Sent: To: Subject Tuesday, February 13, 2001 12:59 PM CARNINE, LESLIE V. Positions After Don's comment in Cabinet about not hiring people, I visited with him about the positions that I currently have advertised. He suggested that I visit with you about whether or not I can hire the people I need to do the assessment program. I am currently down to three employees. I don't think we can do assessment for 20,000 kids with that number. want to set up interviews this week, but I want your blessing! -- Thanks, Kathy Kathy Lease, Ed.D. a,-ssistant Superintendent 9'lanning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 LESLEY, BONNIE 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd. k 12 .ar. us From: LEASE, KA THY R. Sent: To: Subject: Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc. lrsd. kl 2.ar. us 18 From: To: Date: Dr. Faucette i'r/-}- Mrs. Hargis 17 November 2000 ....'  Subject: Exclusion of regular English students from Jennie Calder lecture I write to request a bit of information concerning the recent visit of Jennie Calder, a Robert Louis Stevenson scholar from Scotland, to Central as a part of the conference celebrating this great writer. It was my understanding, after our conversations last spring, that the event was in recognition of the universal appeal of a revered writer. Known and loved the world over, Stevenson is one of a -select group whose works attract readers from widely varying backgrounds, uniting people of all classes and condition in the appreciation of a gifted artist. I was excited about the opportunity Central students-including my own studentswould have to be--exposed to a world of exciting and enthusiastic research that would be especially significant for seniors. (Traditionally, the last year of high school English is dedicated to the exploration of the rich legacy of British literature.) I was disappointed  beyond belief to learn that none-not one--of my regular Engli~h students would be allowed to oenefit from tlie singular experience of having the chance to see and hear the visiting scholar. Only AP and pre-AP students were allowed to attend the Piesentation. In fact, most teachers of regular English classes only learned of the event when students began to ask why they were not allowed to attend the assembly that students in other classes were discussing at lunch. Limiting the experience to students in AP and pre-AP English classes meant that very few black students were allowed to attend. I am shocked and outraged that yet another singular educational opportunity has been reserved for the children of privilege. Because many of the privileged AP English students took advantage of the event to slip out of the building and skip the assembly, and because you wanted to supplement their numbers, you solicited the attendance of students from AP. science and history classes,   still denying access to students from regular English classes. If you really wanted to  impress Ms. Calder, having the Creative Writing Club presented would have done just  that. The knowledge that, at 287 members, the Creative Writing Club is the most active club at Central would impress any true scholar or teacher. One can only wonder why you, Mr. Howard, and the third floor English department all miss the significance of the fact that the club that most fully represents the student diversity in our building is a club centered around an academic endeavor, the study and practice of literature. Yes, this is quite an example you set for our students. Central, lvir. Howard, the English department, and you all had a chance to shine as this scholar brou~bt her enthusiasm to our large and diverse student body. Central, Mr. Howard, the English department, and you dropped the ball disastrously on this one. Rather than seizing the opportunity to be shining beacons by providing this opportunity 7tS I  I I   l ; . ~   .. for learning outside the traditional limitations of the classroom to all of our students, you have shown your true stripe. I thank you for the demonstration once again that, instead of a single unified English department, Central actually bas two:.the second floor contrining primarily regular English classes, and the privileged third-.floor home of AP English. I would now ask an additional bit of information. Please inform me in writing of your reasons for this -l~test instance of educational snobbery so that I might explain more accurately to my classes your dismissal of them as second-class students. - ....._ - -  -  Dr. Leslie Carnine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Dr. Carnine: Via Facsimile - 324-2146 December 16, 1998 Would you please ask Nir. James Washington, the District's ombudperson, to look into the complaint of Mr. \u0026amp; Mrs. Deodis Fleming regarding their concerns at Carver Magnet. You are probably not aware that this office has had.several complaints from other parents regarding the unfair treatment of black students at Carver. You should have received a letter from the Flemingsoutlining their concerns along with a response from Ms. Barksdale. Copies ofboth are enclosed for your convenience. . The Flemings believe that Ms. Barksdale is trying to excuse the reason for Ms. Ransom's exclusion of their son from participation by stating that he had behavior problems. In today's society, persons who discriminate usually attempt to establish legitimate reasons for their discriminatory actions. The reason given by Ms. Ransom, we believe, is pretextual. In other words, the reason that she has given is not legitimate. The Flemings were not previously advised that their son had behavior problems regarding his participation in Odyssey of the Mind. Moreover, they are not aware that their son has a behavior problem. Ms. Barksdale's commitment to establish an OM Guideline booklet is a step, I believe, in the right direction. However, I do not believe that she should wait until next year. That process should start immediately. Opportunity for discrimination evolves when there are no written guidelines or rules for participation in a particular activity. The person overseeing or administering the activity usually has the discretion to make rules as they go along. These rules usually favor their own personal interests. Moreover, these rules or guidelines usually change daily to fit a particular interest or situation. I am not sure why the Flemings chose not assist in the coaching of Odyssey's students as indicated by Ms. Barksdale; however, many of our children's parents are unable to participate in many of the schools activities because often they occur-when they are obliged to work and other commitments to meet the overall needs of their families. Page 2 - Letter to Dr. Carnine December 17, 1998 167 I have indicated to Mr. \u0026amp; rvirs. Fleming that I woulq be happy to sit down with 1vir. Washington, Ms. Mitchell, Ms. Barksdale, and any other persons tl,1-?-t they believe can help bring this matter to an amicable resolution. In fact, Mr. Washington may assume the role as the parent advocate, if the Flemings agree. I would, however, like to receive a report of his findings and resolution. Thank you for your attention to this request. JCS/ Enclosures cc: Mr. \u0026amp; Mrs. Deodis Fleming Ms. Diane Barksdale Ms. Sadie Mitchell Mr. James Washington Sincerely, Joy C. Springer Joshua Intervenors Via Facsimile - 324-2146 February 18, 1999 Ms. Sadie Iv.litchell Associate Superintendent for Student Services Little Rock School District 810 West Markham Little Rock, AR 7220 l Dear Ms. Mitchell: This office has received several calls regarding the selection process for the new football coach at J. A Fair High School. It is our information that the selection process has been changed to favor the selection of a particular coach for the position. In oraer to address tfie concerns that have been raised, would you please provide to me a copy of process being utilized by District officials for the selection of coaching positions including the selection criteria. If this information has changed from prior years, also please provide the process and criteria that was utilized in previous years. I have spoken with Mr. Gillespie regarding this matter and he has assured me that the only change in the process was that the selection committee did not meet on the school campus as it has done in previous years. I was, however, a bit concerned about the gender makeup of the selection committee for the Fair position. I voiced my concern to Mr. Gillespie that the committee was all males. I am available to discuss this matter with you and Mr. Gillespie at a mutually convenient time. Thank you for your attention to this request. JCS/ cc: Ivir. Ray Gillespie Sincerely, Joy C. Springer Joshua Intervenors Rudolph Howard . Principal, Central High School 1400 Park Street Little Rock, AR 72202 Dear Mr. Howard: Via Facsimile - 324-2308 March 17, 1999 lb't I am writing on behalf of Rev. \u0026amp; Ms. Bennie Horton and their son, Tariclc, to request a conference regarding his grades. As I review the revised desegregation plan, I can point to a number of areas including equal treatment, participation in honors and gifted classes, academic achievement, parental involvement etc. that are involved in these parents' concern. By copy ofUiis letter to the District's Ombudsperson, :tvir. James L. Washington, I am also putting him on notice of this concern and invite him to participate in the conference. I have spoken with Ms. Horton and she is available during her lunch hour to discuss this matter. Please let me hear from you. JCS/ cc: Rev. \u0026amp; Mrs. Bennie Horton Mr. James L. Washington Sincerely, Joy C. Springer Joshua Intervenors JOHN W. WALKER RALPH WASHINGTON 2\\-1ARK BUR1'rETTE AUSTIN PORTER, JR. Mr. James Washington Little Rock School District Office of Ombudsman 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: JOHN W. WALKER, P.A. ATIORNEY AT LAw 1723 BROADWAY L!ITLE ROCK, ARKANSAS 72206 'TELEPHONE(501) 374-3758 FA,'{ (501) 374-4187 Via Facsimile - 324-2213 October 14, 1999 KP./,puv1se AJ0. S 77{ /1)0, !1 I am writing to request that you look into the selection process for students participating on mock trial teams:at Central High School. We request that you obtain some background information regarding past composition by grade, race and gender and the current composition by grade, race and gender. This office has received a complaint that these teams are generally one race and favor . white students because their parents or other relatives are business professionals such as lawyers, judges, etc. Thank you for your attention to this matter. We further request a report of your findings with respect to this inquiry. By copy of this letter to Mr. Howard, :tv!r. Babbs and Dr. Carnine, I am also advising them of these allegations. JCS/ cc: Mr. Ruduloph Howard Mr. Junious Babbs Dr. Leslie Carnine a:rely,;'l - / ' cl::vKfl,/ / Joy C. Springer U .c::::1 On Behalf of Joshua 1vir. James Washington Ombudsperson Little Rock School District 810 West Markham Little Rock, AR 7220 I Dear Mr. Washington: Via Facsimile February 28, 2000 I am writing to request that you investigate the complaints of discrimination and retaliatory treatment by Mr. \u0026amp; Mrs. Eddy Harris Sr. against his son, Eddy Jr. by members of the staff at Oak Grove High School in the Pulaski County Special School District. For several years, Eddy Jr.w as a M to M student in tfie County. Eddy is currently a student in the Little Rock School District. I have previously requested that Mr. Billy Bowles, Assistant Superintendent for Desegregation, look into complaints of the Harrises. I am enclosing a CGpy of my request to .l\\!Ir. Bowles. Mr. Bowles assured me that he would conduct a thorough investigation and, thereafter, provide a report of his findings. I am enclosing a copy ofivir. Bowles' purported report of his findings. It is basically a one sentence conclusion. At least, I expected a report which enumerated all charges and a summary of his findings. I expected a more thorough report similar to the one that he and members of his staff conducted several years ago at Robinson High School where he noted findings, whether substantiated or unsubstantiated. The Harrises claim Eddy Harris Jr. was not allowed to participate on the football team for the last four or five games for.racial and/or retaliatory reasons, that Eddy Jr. was not selected to participate on the basket ball team for racial and/or retaliatory reasons and that Eddy Jr. re_ceived retaliatory treatment from his classroom teachers, in particular, Ms. Morrison, his English teacher. who gave him gave him an \"F\". The Harrises claim that Eddy's English grade for the semester is based, in part, upon assignments that he should not have been charged for because they had officially withdrew him from Pulaski County School District. Enclosed is the documentation from the Harrises. Also enclosed are copies of letters directed to or copied to Mr. Bowles regarding the claims of the Harrises. I also have several tape recordings of conferences with staff members that I will be happy to share with you. i\\lir. Bowles-was aware of these taped conferell(:es, but he-did not request a copy of either of them for his review. Mr. Bowles did not make single finding regarding his investigation nor did he address any of the points in this correspondence. In summary, the complaints of the Harrises are as follow: 1) failure of Eddy Jr. to participate in the remaining four or five games of the football season; 2) failure to Eddy Jr. to participate on the basketball team; and 3) the failing grade received by Eddy Jr. in English. 77/ The treatment referenced above, we believe is due to racial and/or retaliatory treatment by Pulaski County School District officials. Please let me know if additional information or clarification is needed regarding this matter. Again, I am copying Mr. Junious Babbs to alert him of this egregious situation and to request that he also utilize his offices to assist in the amicable resolution of this matter. I would also appreciate a report of your findings. Thank you for your attention to this request. JCSt cc: Mr. \u0026amp; Mrs. Eddy Harris Sr. Mr. Billy Bowles Mr. Junious Babbs Ms. Ann Brown  Sincerely, Joy C. Springer Joshua Intervenors :Mr. James Washington Ombudsperson Little Rock School District 810 West Mark.ham Little Rock, AR 72201 Dear Mr. Washington: February 28, 2000 I am writing to request that you investigate the complaints of Mr. Reginald Abrams. I am taking the time to put this request in writing due to the egregious nature of the situation. Mr. Abrams' \"son is a Boys Scout at Cloverdale Middle School. Mr. Abrams complained to me regarding the treatment his son and other black Scouts received while attending the Boys Scout Council Area Banquet on last Thursday evening, February 24, 2000 at Ricks Armory. I have-asked Mr. Abrams to call you with the specific details of this experience. I must state, however, that based upon his communication to me, I do not believe that the Little Rock School District's commitment to inclusiveness and desegregation was demonstrated at this banquet. Upon information and belief, it appears that the black scouts roles at this activity were both demeaning and nonexistent. I must also question the expectations oflv!r. Lacour, the Scout Master, who tolerated this treatment and was reported to have said that he did not expect black parents to participate and thus be able to question the roles and participation of their children during particular scouting activities. Mr. Lacour needs to understand that the spirit of desegregation plan called for activities such as scouting and that \"scouting\" would be an opportunity for black students to have new experiences and be given opportunities to develop skills such as social and leadership skills, to new a few. May I suggest that you conduct an investigation into the scouting programs for the entire District and determine the roles of black students and whether similar situations have occurred. I believe that you should interview Mr. Lacour to determine the schools that he has been working with and the names of other scout masters in the area who work with Little Rock District students. I understand that Mr. Lacour's number is 758-1838 or pager 688-4533 . Mr. Abrams may be reached at 9700 Stardust Trail, Little Rock, AR 72209, telephone number 562-0348. Please let me hear from you regarding the result of your findings and your recommendations to ensure that similar situations do not occur in the future. Thank you for your attention to this request. I believe that it is important that ~fr. Junious Babbs receives a copy of this letter given his role to ensure compliance with desegregation. JCS/ cc: :tvir. Reginald Abrams l\\lir. Junious Babbs Sincerely, Joy C. Springer Joshua Intervenors JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Mr. Ray Gillespie Athletic Director Little Rock School District 8 l O West Markham Little Rock, AR 7220 l JOHN W. WALKER, P.A. ATTORNEY AT LAw 1723 BROADWAY UTILE ROCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile August 28; 2000 ...... Re: Southwest l\\:liddle School Dear Mr. Gillespie: 773 17l I am writing to request that you investigate the complaints of Mr. \u0026amp; Mrs. Michael Wesley regarding their son, Marquis, a student at Southwest Middle School. Mr. Wesley reports a very disturbing incident that occurred on Friday, August 24, 2000 at the school involving Coach Foote. In summary, Mr. Wesley reports that Coach Foote choked Marquis and has openly admitted doing so. The Wesleys are very upset about Coach Foote actions and request that \"he be dealt with\". We are available to meet with you, if additional information is needed. ncere~y '( h':-I ' Joy . Springe ,, On Behalf of Joshua lntervenors JCS/ JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Dr. Leslie Carnine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Dr. Carnine: JOHN W. WALKER, P.A. ATTORNEY AT LAw 1723 BROADWAY LITTLE ROCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile September 12, 2000 I am .vriting on behalf of Marcus Winston, a 9rh grade student at Parkview High School and similarly situated students in the Little .Rock District. Would you please direct my attention to the sec ti off ofthe District' s- student handbook which states that 9th grade students cannot participate in varsity team athletics. It is my understanding that the practice of the District in previous years has been to allow these students to participate on varsity teams. By copy of this letter to Mr. James Washington, I am also requesting that he investigate this matter. I recommend that he identify all 9th grade students at the senior high level to determine the number, race and gender of the students who are being adversely affected by unwritten directive. As I review t~e District's desegregation plan, I note in Section 2.6 of that plan that the District \"shall implement programs, policies and/or procedures designed to promote participation and to ensure that there are .no barriers to participation by qualified African Americans in extracurricular activities .... \" It appears that the District's refusal to allow 9rh grade students to participate in athletics at the varsity level is contrary to plan commitments. This new practice is neither promoting nor ensuring participation. Prior to invoking the process regarding compliance issues, I ask that Mr. Washington provide to this office a report of his preliminary findings. by September 20, 2000. Thank you for your attention to this matter. nin~ero/J~. ,_, . ~- \"44 \u0026lt;J= ; 9t~ ~ / Joy C. Sprin~er ~ ( On Behalf of Joshua Intervenors JCS/ cc: Mr. James Washington, Ombudsman Mr. Junious Babbs, Associate Superintendent Mr. Ray Gillespie, Althletic Director Ms. Ann Brown ?Jf JOHN W. WALKER RALPH WASHINGTON MARK BURNETIE SHAWN CHILDS Dr. Leslie V. Carnine Superintendent of Schools Little Rock School District 8 IO West Markham Little Rock, AR  7220 I JOHN W,,,WALKER, P.A . . _,,. ATI6RNEY AT Ll.w 1723 BROADWAY L!TILE ROCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile - 324-2146 October 10, 2000 Re: Duties of Ombudsman Dear Dr. Carnine: Yollf letter of October 5, 2000, in responseto my letter of October 3, 2000, was received by this office today. I look forward to receiving the other requested information. . With respect to the second instance, may I call your attention to a letter dated July 25, 2000 addressed to you from a Parkview parent, Bill Winston? A copy is attached for your convenience. According to Mr. Winston, you did not respond to his inquiry. On September 12, 2000, I spoke briefly with Mr. Gillespie about Mr. Winton's concerns. :tvfr. Gillespie reported to Mr. Winston and me that there existed documentation which communicated to all parents the District's position regarding 9th grade participation on varsity teams for the 2000-2001 school year. This information was requested for the parent through the Ombudsman. To date, this information has not been received. This complaint was subsequently assigned to Dr. Marion Lacey for handling. Dr. Lacey, Mr. Gillespie and I met on September 29, 2000 regarding Mr. Winston's concerns. I was assured by Dr. Lacey that she would provide a written response along with the previously requested information by the Ombudsman and myself By copy of this letter to Dr. Lacey, I hope that this will serve as a reminder that I wouid still like to have her letter and the requested information.  By copy ofthis letter to Mr. Washington, I hope that this also refreshes his memory regarding the requested information that was not shared with him or a parent after inquiry and request for it. Surely, these records do not fall in the category of confidentiality. Moreover, the District has had approximately thirty (30) days to provide the information. Thank you again for your response and consideration giveri to this inquiry. JCS! Enclosure  cc: Mr. Junious Babbs Mr. James w ashington Dr. Marion Lacey Mr. Ray Gillespie Ms. Ann Brown Mr. Gus Taylor 715 Sinferelv, 4~- (/,(L(( (:!, ' !zt:t~ My C. S prmger  . (J On Behalf of Joshua ..... SEP , 13 ! 00 . 7:48 FR NATIONWIDE July 25, 2000 Superintendent Les Carnine 810 W. Markham Little Rock. AR 72202 Superintendent Carnine, 501 223 1749 TO 93744187 Please be advised that I am attempting to contact you by letter, having been unsuccessful so far in getting you to call me back. ! have left several messages with your secretary requesting to speak to you concerning my oldest son, Demarcus Winston, a freshman .scheduled to attend Little Rock Parkview Arts and _Science Magnet High School this year. My lasr attempt to reach you was July 14, 2000 and I was told by your secretary that you were out of town and she would have you call me on Monday, July 24, 2000 upon your return. In any event, my concern involves the situation or status of 9th grade athletes being able to participate on the varsity level. I have spoken with the head football coach, Ernest Mcgee, and the head basketball coach, Al Flanagan, about this issue and they advised they were unclear-on-whether 9th graders could\"play with the varsity, but both were hoping they could. They encouraged me to voice my concerns to you hopefully before any decision is made . . I personally feel that my son would be penalized and held back in his development as an athlete if he were not allowed to play on the varsii:y level. The 9th graders who were good enough to play at the varsity level were allowed to do so last year and I have no idea and, as a concerned parent, have not been given an explanation of why my son would not be allowed to play this year. There is not an organized 9th grade league of competition as there is in the Pulaski County school district. Since the new format now moves 9th graders to Senior High (9-12), then he should be allowed to play. The coaches want him to play, his parents wanr him to play, but I am told that he may not be allowed to play. I would hope that you would consider that my son who is 6-6, 2001bs gets penalized ifhe is not allowed to play with the varsity and compete at the highest levd of competition. I am oguin asking you to discuss this issue with me and listen to my concerns. Sincerely, Mr. Bill Winston 775 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Mr. James Washington Ombudsman Little Rock School District 810 West Markham Little Rock, AR 7220 l Re: 9th grade Athletics Dear Mr. Washington: JOHN W. WALKER, P.A. ATIORNEY AT LAw 1723 BROADWAY LITTLE Rocx, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsimile - 324-2260 September 13, 2000 776 For y0ur information, I am attaching a copy of a letter- that was sent to Dr. Carnine by one of the concerned parents. It is my understanding that Dr. Carnine has not responded to the letter nor has he returned the parent's numerous teiephone calls. Also attached hereto is a list of other parents whose children stand to be adversely affected by the District unwritten rule regarding 9th grade athletics. Hopefully this information will assist you with your investigation. In speaking briefly with Mr. Gillespie on yesterday, he indicated that the District sent notices to parents regarding this matter. Would you also inquire about the notices that were sent to parents and share copies of same with this office. Finally, would you also check to see whether this issue was submitte~ to the Board for approval. .. I look forward to your preliminary report by September 20, 2000. Thank you for your cooperation. JCS/ (r:lyar ~(pnrig~~ On Behalf of Joshua SEP 13'00 7:48 FR NATIONWIDE 501 223 1749 TO 93744187 P . 02/03 776 July 25, 2000 Superin1endent Les Carnine 810 W. Markham Little Rock, AR 72202 Superintendent Carnine, Please be advised th.a! I am attempting to contact you by letter, having been unsuccessful so far in getting you to call me back. l have le.ft several messages with your secretary requesting to speak to you concerning my oldest son, Demarcus Winston, a freshman scheduled to attend Lirtle Rock Parkview Arts and Science Magnet High School this year. My last attempt to reach you was July 14, 2000 and l was told by your secretary that you were out of town and she would have you call me on Monday, July 24, 2000 upon your return. In any event, my concern involves the situaiion or status of 9th grade athletes being able to participate on the varsity level. I have spoken with the head football coach, Ernest Mcgee, and the head basketball coach, Al Flanagan, about this issue and they advised they w_ere unclear on whether 9th graders could play with the varsity, but both were hoping they could. They encouraged me to voice my concerns to you hopefully before any decision is made. I personally feel that my son would be penalized and held back in his development as an athlete ifhe were not allowed to play onthe varsity level. The 9th graders who were . good enough to play at the var.;ity level were allowed to do so last year and I have no idea and, as a concerned parent, have not been given an explanation of why my son would not be allowed to play this year. There is not an organized 9th grade league of competition as there is in the Pulaski County school district. Since the new fonnat now moves 9th graders to Senior High (9-12), then he should be allowed to play. The coaches want him to play, his parents want him to play, but I am told that he may not be allowed to play. I would hope that you would consider that my son who is 6-6, 200lbs gets penalized if he is not allowed to play with the varsity and compete at the highest level of competition. I am ago.in asking you to disc~ this issue with me and listen to my concerns. Sincerely, Mr. Bill Winston SEP 13'00 7:49 FR NATIONWIDE 501 223 1749 TO 93744187 Concerned Parents:  Bill and Tammy Winston (Demarcus Winston, Linle Rock Parlcview) Home Phone# (501)224-5138  Glenn and Karen Anderson (Jamaal Anderson. Little Rock Parkview) Home Phone# (501)224-2593  Lynn and Angie Smith (Nicholas Smith, Little Rock Parkview) Home Number Unknown  Brian and Tracey Salley (Trey Salley, Little Rock Parkview) Home Phone# (501)565-0947  William and Jean Givens (CaTravia Givens, Little Rock Central) Home Phone# (501)562-6882  Fred and Dorothy Blerlsoe (Fred Bledsoe, Jr., Little Rock Central) Home Phone# (501)562-566L  Eric Mcghee (Tori Mcghee, Linle Rock Central) Home Nwnber Unknown P.03/03 776 ** TOTAL PAGE.003 ** STEWART, DONALD M. - rom: LESLEY, BONNIE Sent: Tuesday, June 06, 2000 10:49 AM To: STEWART, DONALD M. Subject: RE: Desegregation Payments to Pulaski Co. Districts Thanks so much for this information. I am understanding it for the first time. -Original Message- Frorn: STEWART, DONALD M. Sent: Wednesday, May 24, 2000 4:17 PM To: CARNINE, LESLIE V. Cc: GADBERRY, BRADY L.; ANDERSON, VICTOR; MILHOLLEN, MARK; BABBS, JUNIOUS; MITCHELL, SADIE; LESLEY, BONNIE Subject: Desegregation Payments to Pulaski Co. Districts Attached to th is email is an Excel worksheet which calculates the total amount of funds received from the State by the three school districts in Pulaski County as a result of the Desegregation Settlement Agreement and various court orders. These calculations are based on the data from the 1999-2000 school year and do change slightly from year to year. In total payments the three districts in Pulaski County will receive approximately $39.5 M. in the 1999-2000 school year. This total is made up of funds for: Magnet School operation ($10.1), M-to-M transfer payments ($13 M), Magnet and M-to-M transportation ($5.9 M), Teacher Rel. \u0026amp; Health Ins. Reimburse. {$10.3 M), and Worker's Compensation Reimbursement ($.2 M). These payments are divided among the three Pulaski County Districts utilizing various methods and result in annual payments on behalf of district students to: LRSD ($19.86 M), NLRSD ($4.88 M), and PCSSD ($14.76 M). M-to-M Funding: Currently M-to-M transfer students are removed from the district enrollment prior to regular State Equalization Aid . computations. If these students were not being funded through the separate M-to-M funding mechanism they would be eligible for regular State Aid and would create approximately $8.5 M per year. LRSD is currently sending a larger number (1100) of M-to-M students than it receives (422) and also, through the pooling agreement, must pay to the PCSSD ($.4 M) for the education of M-to-M students. Because of these provisions, doing away with the M-to-M provision would actually result in an increase in aid to the LRSD of approximately ($1.2 M), while NLRSD wculd lose ($1 .3 M) and PCSSD would lose ($4.1 M). If all M-to-M transfers were returned to their home district, LRSO would be responsible for educating approximately 675 more students than it currently does. At the current rate of expense per student that would cost the district in excess of $4 M. Magnet Funding: Magnet funding is limited to students in the original stipulated magnet school, all located in LRSD. These students are included in the home district's enrollment count for equalization aid purposes. In addition to this funding source, the State is req uired to fund one half the cost of educating these students. This amount is calculated from MRC approved budget submissions and is paid directly to the LRSD on behalf of all students enrolled in those schools. The approved amount for the 1999-2000 school year is approximately ($10.1 M). The amount paid on behalf of each district's students is: 100 LRSD ($6.3 M), LRSD ($1.29 M), and PCSSD ($2.47 M). Magnet \u0026amp; M-to-M Transportation: ?77 The three districts in Pulaski County are currently paid one hundred percent of the costs of providing transportation for all Magnet and M-to-M students, including some expenses for getting these students to after school activities and events. The estimated costs for 1999-2000 is: LRSD ($3.41 M), NLRSD ($.57 M), and PCSSD ($1.94 M). If this funding sourc.e were eliminated there would be no resulting increase in Transportation Aid to the districts from regular State sources. The basic assumption would likely be that all of these cost would also end. Teacher Retirement \u0026amp; Health Insurance: During 1999-2000 the school districts in Pulaski County are projected to receive approximately ($10.28 M) to offset teacher retirement and health insurance costs. This number is somewhat stable but is effected by a number of factors and could change significantly from year to year. Under the present payment calculation any increase in the required contribution rate, (currently $114. per employee, per month and set by the State Board of Education) would result in a corresponding increase in funding to the Pulaski County Districts. The funding breakout by district is currently: LRSD ($6.17 M), NLRSD ($1 .02 M), and - PCSSD ($3.08 M). The cessa tion of these payments would result in a negative bottom line of the amounts received . No offsetting funds would exist and no method for significantly decreasing cost is available. Worker's Compensation: During 1999-2000 the school districts in Pulaski County will receive ($.19 M) to offset costs for providing Worker's Compensation coverage to district employees. These payment amounts by district are currently: LRSD ($.06 M). NLRSD ($.04 M), and PCSSD ($.09 M). Summary: If all special funding for desegregation programs and services were discontinued the ($39.5 M) estimated aid to the three Pulaski County School Districts from desegregation related funding sources would be offset by M-to-M students again being counted for regular State Equalization Aid. When that calculation is made the total aid loss would be app~oximately ($31 M) and by district would be: LRSD ($15.13M ). NLRSD ($4.21 M), and . PCSSD ($11 .66 M). The actual total aid loss to the LRSD budget would be increased by the amount paid directly to the District on behalf of students from the other districts attending Stipulated Magnet Schools. The additional amount would be approximately $3. 76 M but there would also be a decrease in the district's costs since the magnet students attending LRSD schools would by necessity either be reassigned to their home district or some other funding mechanism would need to be put in place. The total aid package is obviously a significant amount of funds and the abrupt loss of these funding sources would necessitate drastic changes in the way all the districts operate. A transition of several years may be necessary in order for the districts to work through the various changes that would be required. 101 STEWART, DONALD M. - om: Sent: To: Subject: BABBS, JUNIOUS Thursday, April 19, 2001 9:19 AM STEWART, DONALD M. FW: LRSD Biracial Committee Request 77! Thanks for agreeing to give him a call. You will find his number listed in an earlier mailing attached. Will stay in touch. Junious C Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District -Original Message- From: EGGLESTON, DEANA Sent: Wednesday. April 18, 2001 1:51 PM To: BABBS. JUNIOUS Subject: FW: LRSD Biracial Committee Request FYI -Original Message- From: STEWART, DONALD M. Sent: Wednesday, April 18, 2001 2:01 PM To: EGGLESTON, DEANA Subject: RE: LRSD Biracial Committee Request The reason we do not have an estimated completion date on Romine is that we have just started the preliminary design work on that project and until we know exactly what we are going to do we can't guess when it will be complete. I don't know who needs to talk to this person but if Junious want it to be me, let me know. - -----Original Message---- F rorn: EGGLESTON, DEANA Sent: Wednesday, April 18, 2001 10:06 AM To: STEWART, DONALD M.; GADBERRY, BRADY L. Cc: BABBS, JUNIOUS Subject: LRSD Biracial Committee Request We held the April meeting of the LRSD Biracial Committee last night. Delaney Fleming (Joshua's representative) was questioning why the Romine project had no start/ est. completion date on the handout that Don provided. FYI - Delaney has questioned the district's committment to Romine and the \"poor conditions\" of the Romine bldg. many times. Mr. Babbs said that he would check into the projected start dates and have one of you telephone Mr. Fleming. His # is 224-0630. Mr. Fleming's address is 9505 Cerelle, Little Rock, AR 72205 (in Romine's zone). Babbs is out today, however, he wanted me to pass this info along to you. Deana Deana M. Eggleston Student Registration Office (501) 324-2408 dmeggle@stuasn.lrsd.k12.ar.us 37 '/ 1/7 STEWART, Db_NALDM.: \" __ . --___ .''i:\u0026gt;- __ ... . . :c;;. \u0026gt;.:: From: LEASE, KATHY R. Sent: Wednesday, April 25, 2001 2:32 PM To: MILHOLLEN, MARK Cc: STEWART, DONALD M. Subject: Leave Accountability Report Importance: High Mark, I just received the June to March Leave Accountability Report. The names of all those people that we discussed earlier are still on the report. One of my concerns is that they do not have access to their leave information because it was all sent to my department. Another concern is that, again, it looks like there are more people in PRE that there really are. Interestingly enough, Regina Moore got changed to PRE since she is now Karen Broadnax' secretary. The following list of folks do not work in PRE: Mona Briggs, Karen Broadnax, Virg inia Johnson, Shirley Lewis Eddie McCoy, Regina Moore, Rosalyn Summerville. The people who do work for me are the following: Eula Yvette Dillingham, Irma Truett, Charlotte Marks, Malinda Allen , Paulette Denson, and Ed Williams. Thanks for your help in straightening this out. It concerns me that the PRE staff list has not been accurate the whole time I've been here. I'm afraid that it presents a distorted picture of staffing for this department. If there is anything that you need me to do, please let me know. Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd .k12.ar.us Sent: Tuesday, May 22, 2001 1:01 PM To: WELCH, JANE Cc: LESLEY, BONNIE Subject: RE: Plato Communication grade I did not know that Central was offering a PLATO Communications course. I am going to research my email from last year. Seemingly there was a question about it then either at Central or Hall. -Original Message- From: WELCH, JANE Sent: Tuesday, May 22, 2001 12:15 PM To: LESLEY, BONNIE Cc: GREEN,CAROL Subject: Plato Communication grade I have been given a grade in the Plato Lab for Larts-/communication. We do not have a number assigned for communication. How do I key this grade without an identifying number? Jane Welch, Registrar-Central High school LESLEY, BONNIE From: Sent: To: Cc: Subject: LESLEY, BONNIE Friday, May 25, 2001 4:14 PM BERRY, DEBORAH; BLAYLOCK, ANN; FULLERTON, JAMES; HUDSON, ELOUISE; Larry Buck; MARIAN LACEY; MOSBY, JIMMY; PATTERSON, DAVID; ROUSSEAU, NANCY; SAIN, LLOYD DAVIS, SUZI; AUSTIN, LINDA Middle School Evaluation I understand that you all got \"assigned\" the middle school program evaluation yesterday. Probably most of the stuff you  eed is in the Compliance Report or the Interim Report. I am attaching both for your information. They are long, so you ay want to look at what you need before you print them. I am not at all sure that you need to spend much time on that assignment. Let me check with the superintendent before you do a lot. I know you have many other things on your plate right now. ~ 1 A Final Compliance Report-001 ... Compliance Report, Feb. 2000.d ... Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/ 324-0567 (fax) 358 STEWART,\" DONALD M. From: LESLEY, BONNIE Sent: Wednesday, June 07, 2000 11 :31 AM To: CARNINE, LESLIE V.; ANDERSON, VICTOR; BABBS, JUNIOUS; MITCHELL, SADIE; STEWART, DONALD M.; GADBERRY, BRADY L. Subject: FW: AP fyi --Original Message- From: Clay Fendley [SMTP:FENDLEY@fec.net1 Sent: Wednesday, June 07, 2000 11 :13 AM To: BALESLE@IRC.LRSD.K12.AR.US Subject: AP I have received and reviewed you memo on AP enrollment. It looks great! As you know, there will be concern that we are simply lowering the standards so more kids can get into the courses. To counter this perception, it would be nice to show an increased number and/or percentage of students passing the AP exam. For this reason, I would support either requiring them to take the exam or offering some incentive for doing so. 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AO 72A (Rev.8/82) ECEIVED JUL -8 2002 OFF!CF. OF EGREGATIOH MONITORING u.sfo,{b~cRRT IN THE UNITED STATES DISTRICT CO\"fltffERN DISTRICT ARKANSAS EASTERN DISTRICT OF ARKANSAS JUL Q 1 2002 LITTLE ROCK DIVISION LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ORDER DEFENDANTS INTER VEN ORS INTER VEN ORS Pending is Plaintiffs Motion for a Protective Order and for Emergency Hearing. For the time being, Plaintiff's request for a protective Order against Joshua, or anyone acting on their behalf, is GRANTED. The deadline for exchanging exhibits and witnesses was set on May 15, 2002, for June 21 , 2002. At the request of lawyers for LRSD and Joshua, the deadline was orally extended until 5:00 p.m. on Monday, June 24, 2002. It appears, from the documents attached to Plaintiffs Motion, that Joshua's FOI request was submitted on June 26, two days after the deadline for exchanging exhibits and the names of witnesses. Even assuming the FOI can be used in addition to the Federal Rules of Civil Procedure by a party to litigation, it appears quite certain that this request was not timely. It is my impression, from a quick review of the law, that the great weight of authority precludes a party from using the FOi as a supplement to the discovery rules of the Federal Rules 6 1 1 A072A {Rev.8/82) of Civil Procedure; but, be that as it may, this particular request appears to be manifestly out of time. I note in passing that many, if not most, of the documents requested in the FOI request are not pertinent to the three remaining issues in this case. Accordingly, the LRSD is relieved of any duty to respond to the FOI request by Joshua. If Joshua wants a hearing on this issue, it should file a response to Plaintiff's Motion forthwith, and request a hearing--if such a request is made, a hearing will be set as soon as practicable. IT IS SO ORDERED. DA TED this I 9-:f day of July, 2002. UNITED sT ATESDISTc JUDGE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE 1/V!Tb:(oE 58 AND/OR~7~ F9R CP r,;, , ~ ..,___ GY _ - - '\" _ f_t:___ I -2- IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKJ COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL MEMORANDUM BRIEF IN SUPPORT OF PLAINTIFF'S MOTION IN LIMINE RELEVANCE GENERALLY RECEIVED JUL - 8 2002 OFACEOF DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTER VEN ORS INTER VEN ORS The LRSD moves to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors pursuant to Fed. R. Evid. 401 , 402 and 403 . The ultimate issue before this Court is whether noncompliance with the Revised Plan casts doubt on the Board's intent to comply with the Constitution in the future absent court supervision. See Cody v. Hillard, 139 F.3d 1197, 1199 (8th Cir. 1998). Noncompliance that the Board knew nothing about has no bearing on this issue and is irrelevant. See Fed. R. Evid. 401. Section 1983 Liability Standard The issue before this Court is analogous to the issue of whether a governmental entity may be held liable under 42 U.S.C.  1983 for the unconstitutional conduct of its employees. Respondeat superior is not a permissible theory for holding a governmental entity liable for the unconstitutional acts of its employees. Monell v. Department of Social Services, 436 U.S. 658, 690, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978). Instead, a governmental entity is liable under 1983 when \"a policy, statement, ordinance, regulation or decision officially adopted and promulgated - by that body's officers\" can be causally related to the allegedly unconstitutional conduct of its employees. Id. Liability may also be based on \"constitutional deprivations visited pursuant to governmental custom even though such a custom has not received formal approval through the body's official decision-making channels.\" Id. at 690- 91, 98 S.Ct. 2018. See Ryan v. Board of Police Commissioners of the City of St. Louis, 96 F.3d 1076, 1084 (8th Cir.1996). In Ware v. Jackson County, 150 F.3d 873 (8th Cir.1998), the Eighth Circuit explained that: Official policy involves 'a deliberate choice to follow a course of action * * * made from among various alternatives' by an official who [is determined by state law to have] the final authority to establish governmental policy.\" Jane Doe A, 901 F.2d at 645. Alternatively, \"custom or usage\" is demonstrated by: (1) The existence of a continuing, widespread, persistent pattern of unconstitutional misconduct by the governmental entity's employees; (2) Deliberate indifference to or tacit authorization of such conduct by the governmental entity's policymaking officials after notice to the officials of that misconduct; and (3) Th[ e] plaintiff['s] injur[y] by acts pursuant to the governmental entity's custom, i.e., (proof] that the custom was the moving force behind the constitutional violation. Ware, 150 F.3d at 880 (citations omitted) (emphasis supplied). \"(I]naction or laxness can constitute government custom if it is permanent and well settled.\" Tilson v. Forrest City Police Dept., 28 F.3d 802, 807 (8th Cir.1994) (citation omitted). - \"Such a government custom of laxness or inaction must be the moving force behind the constitutional violation.\" Id. \"To establish a city's liability based on its failure to prevent misconduct by employees, the plaintiff must show that city officials bad knowledge of prior incidents of police misconduct and deliberately failed to take remedial action.\" Andrews v. Fowler, 98 F.3d 1069, 1075 (8th Cir.1996) (emphasis supplied). In the context of the present case, the Board is the \"final authority\" in making District policy. During the term of the Revised Plan, the Board adopted and/or re-adopted clear, unambiguous policies indicating its intent to comply with the Revised Plan, federal civil rights statutes and the Constitution. See CX 719. Thus, to cast doubt on the Board's intent to comply with the Constitution in the future, Joshua must establish a \"custom or practice\" of failing to remedy noncompliance with the Revised Plan. This requires that Joshua show \"that [the Board] had knowledge of prior incidents of [noncompliance] and deliberately failed to take remedial 2 action.\" Andrews, 98 F.3d at 1075. Accordingly, incidents of noncompliance of which the Board did not have knowledge are irrelevant. See Fed. R. Evid. 401. Joshua may argue that the District failed to adequately train or supervise its employees who were violating the Revised Plan. It is true that a governmental body may also be held accountable under certain circumstances based on a failure to adequately train and supervise employees. City of Canton v. Harris, 489 U.S . 378, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989). In Andrews, the Eighth Circuit summarized these circumstances related to a city police force. The court stated: A city also may be liable for deficient policies regarding hiring and training police officers where (1) the city's hiring and training practices are inadequate; (2) the city was deliberately indifferent to the rights of others in adopting them, such that the failure to train reflects a deliberate or conscious choice by a municipality; and (3) an alleged deficiency in the city's hiring or training procedures actually caused the plaintiffs injury. It is necessary to show \"that in light of the duties assigned to specific officers or employees the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, the policymakers of the city can reasonably be said to have been deliberately indifferent to the need.\" In other words, the plaintiff must demonstrate that the city \"had notice that its procedures were inadequate and likely to result in a violation of constitutional rights.\" Andrews, 98 F.3d at 1076 (citations omitted) (emphasis supplied). In the context of the present case, Joshua must establish that the Board \"had notice that its procedures were inadequate and likely to result in a violation of [the Revised Plan.].\" Id. It is simple common sense that the Board cannot be on \"notice that its procedures were inadequate\" if the Board was unaware of the noncompliance resulting from the alleged procedural inadequacy. Therefore, Joshua must at a minimum show that the Board had knowledge of noncompliance with the Revised Plan in order to cast doubt on the Board's intent to comply with the Constitution in the future absent court supervision. The Revised Plan Requiring Joshua to show, at a minimum, that the Board had knowledge of noncompliance about which they complain is consistent with the Revised Plan. As a part of the 3 Revised Plan, Joshua and the LRSD agreed to a process for raising and resolving compliance issues. Revised Plan  8 outlined a three step process for resolving compliance issues. First, the issue would be brought to the attention of the District. If the parties were unable to reach an agreement, the issue would be submitted to ODM for facilitation. Finally, the issue would be presented to the Court for resolution. During the term of the Revised Plan, all compliance issues raised by Joshua were resolved without the need for facilitation by ODM or resolution by the Court. See Final Report, p. 166. Consistent with Revised Plan  8, the Board expected Joshua to bring to its attention any substantial compliance issues. To facilitate Joshua's monitoring of the District's compliance, the Board agreed in advance to pay Joshua to monitor the LRSD's compliance with the Revised Plan, and Joshua billed the LRSD for monitoring the LRSD's Compliance. See Exhibits 7 and 8 to Plaintiffs Memorandum Brief in Support of Motion for an Immediate Declaration of Unitary Status. Therefore, Joshua cannot be heard to complain that requiring it to show that the Board had knowledge of noncompliance is inconsistent with the Revised Plan. Conclusion The parties knew there would be compliance issues, and for that reason, agreed to Revised Plan 8. Thus, real question before this Court is not whether there was noncompliance, but how the Board responded to noncompliance. The Board had no opportunity to respond to noncompliance of which it was unaware. Thus, noncompliance that was not brought to the Board's attention is irrelevant and should be excluded pursuant to Fed. R. Evid. 401, 402 and 403 . 4 Respectfully Submitted, LITTLE ROCK SCHOOL DISTRJCT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE \u0026amp; CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501 - 011 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by mail on July 2, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. 1 723 Broadway Little Rock, AR 72201 (via hand-delivery) Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 5 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 A072A (Rev.8/82) I O!INO~ NOl!VU3YD3S3Q d030WO zooz s- 1nr u.fo!k~QAr ... , :\\ ;~l'\\~U ::JJi \\i :.il .J :I g EASn fiN Ol6i/ii1CT MH\u0026lt;AN IN THE UNITED STATES DISTRICT COURT JUL O 2 z SA EASTERN DISTRICT OF ARKANSAS 002 LITTLE ROCK DIVISION LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEIVED MRS. LORENE JOSHUA, ET AL. KA THERINE KNIGHT, ET AL. JUL - 8 2002 OFACEOF DESEGREGATION MONITORING ORDER DEFENDANTS INTERVENORS INTERVENORS On July 1, 2002, I entered an Order (docket no. 3611) granting LRSD's request for a protective order to the extent that LRSD was relieved of its duty to respond to Joshua's FOI requests, which appeared to be untimely under the May 15, 2002 Scheduling Order (docket no. 3600). However, I permitted Joshua's counsel the opportunity to file a written response to LRSD's Motion for Protective Order and for Emergency Hearing and to request a hearing ifhe deemed it necessary. This morning, I received Joshua's counsel's July 1, 2002 letter, a copy of which is attached to this Order. In that letter, Joshua's counsel requests me to rescind my July 1 Order, allow him an opportunity to file a written response to LRSD's Motion, and \"then allow either party to request a hearing.\" This Order responds to the various points raised by Joshua's counsel in his July 1 letter. First, my July 1 Order admittedly was entered in \"haste\" because LRSD's motion papers declared an \"emergency\" and made it clear that July 1, 2002, was the deadline for it to produce A072A {Rev.8/82) documents pursuant to Joshua's FOI requests. Furthermore, in LRSD's Brief in Support of Motion for Protective Order and Emergency Hearing, its counsel pointed out that Ark. Code Ann.  25-19-104 provides a \"potential criminal penalty (of thirty days in jail) which could flow from the LRSD's failure to respond within three days [to Joshua's FOI requests] .\" This time of year, jails in Arkansas are particularly uncomfortable. Therefore, I hastened to enter my Order before 5 :00 p.m. on July 1, lest I place someone in jeopardy of being hauled off in chains. I want to assure counsel for Joshua that, in entering that Order, I was not \"vexed\" with counsel--somewhat or otherwise. I appreciate counsel for Joshua clarifying that the FOi requests were filed in connection with his ongoing monitoring ofLRSD under the 1998 Revised Desegregation and Education Plan (the \"Revised Plan\"). This important point apparently was not communicated to LRSD, which understandably construed the FOI requests as seeking documents that Joshua intended to use in connection with the upcoming evidentiary hearing which commences on July 22, 2002. J.n LRSD v. PCSSD, 921 F.2d 1371 , 1386 (8th Cir. 1990), Judge Arnold made it clear that, in approving the 1989 global settlement of this case, the Court placed \"a great deal of weight\" on the fact that \"the parties have all agreed to continued monitoring,\" which the Court found to be \"essential.\" Likewise, Exhibit B to the Revised Plan makes it clear that Joshua's counsel will continue his monitoring of the LRSD's implementation of its desegregation obligations. By clarifying that Joshua is seeking the documents described in its FOI requests in connection with its continuing monitoring duties, and not for use in the July 22 hearing, I believe counsel should be able to work out a satisfactory schedule for the production of the requested documents. As an aside, I believe that counsel for both sides have more than enough to do in preparing for the -2- AO 72A (Rev.8/82) upcoming five days of evidentiary hearings beginning on July 22, and should not to have to concern themselves with the collection and production of a large volume of documents related to Joshua 's ongoing monitoring function. It appears to me the production of those documents can and should be delayed until after the completion of the evidentiary hearings that begin in less than three weeks. In conclusion, my July 1 Order will remain in effect until after the evidentiary hearing unless counsel for Joshua can convince me that there is a need for the production of the documents described in the FOI requests before the July 22 hearing. Counsel for Joshua is allowed until and including July 8, 2002, to file a response to LRSD's Motion for Protective Order and for Emergency Hearing. LRSD can submit a short reply by 5:00 p.m. on Thursday, July 11 , 2002. Thereafter, if either party requests a hearing on that Motion, the Court will likely conduct one. IT IS SO ORDE~,- DATED this 1 ~ day of July, 2002. W~R-~ UNITED STATES DISTRICT mDGE -3- JUL . 1.2002 5:55PM JOHN W WALKER PA JOHN W. WALKER, P.A. JOH.,.~ W. WALKER SHAWN CHILDS Honorable Judge William R Wilson United States District Judge 600 West Capitol, Suite 423 Little Rock. AR 72201 ATToRNEY AT LAW 1723 BROADWAY L1TrLE RoCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 Via Facsinule - 604-5149 July 1, 2002 Re: Case No. 4:82CV0866WRW/JTR LRSD v. PCSSD Dear Judge Wtlson: NO .521 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 liEND81!SOl'I RoAD Ltmz Rocr, ~ 72210 l'HON\u0026amp;: (501) 372-3425  J\u0026lt;'AX (501) 372-3428 r.!MA!r..: mchonry,i@awbGll.not - I received your order dated July 1, 2002 after 5:30 p.m. when I returned to the office from a trial before the Honorable George Howard, Jr., USA v. Dennis Wtlliams and Joe Bryant I am surprised that the Court ruled on the matter before I had an opportunity to reply to it. I note, however, that the Court provides that opportunity to reply post hoc by the filing of a motion and requesting a hearing. The apparent premise of the Order is that the requested FOIA documents are intended for use at the trial on July 22, 2002. Moreover, the Court seems so_mewhat vexed ~el. I believe the Court would not be ~ were I to have had a reasonable time in which to respond and to make the follo'Wing explanation. Joshua has been monitoring the District's record of compliance since the entry of the original Decree. In that role, we constantly receive concerns from class members about race related matters in each of the three Districts. We first seek to get the District's infonnation by letter. When that fails, we make a request under FOIA. The District usually responds to our letter requests unless a hearing like the one set for July 22 is approaching. Our monitoring was contemplated by the 8th Circuit and the Settlement Agreements herein. The Court has not been involved with respect to our monitoring unless the District claimed some prejudice in its trial preparation. BetWeen 1998 and June 2001, there was not a single hearing before the Court on any matter involving LRSD that was initiated by Joshua Furthermore, the Office of Desegregation Monitoring and Joshua have obtained information from the District in the same manner for years. The Court has reacted in haste to a matter which is not, and will not be before it. The reaction is seen in the Court's conclusion that the requested information \"appears quite certainn to JUL. 1.2002 5:55PM JOHN W WALKER PA NO.521 P.3/3 be \"not timely\". The Court seems persuaded that we did not meet the deadline for exchanging exlnoits and names of witnesses. We each did so. Mr. Heller's office delivered bis exhibits to us at the close of business on June 24, 2002 and we returned our witness list and exhibits to Mr. Heller by his own courier. We agree with the Court's comments that the requests are pot pertinent to the three rernainine issues in this case as the case relates to the District's compliance as of March 15, 2001. That does not mean, however, that Joshua's monitoring ended upon the filing of the report by the District on March 15, 2001. For the foregoing reasons, I request the Court to simply rescind its Order, afford us a reasonable reply time and then allow either party an opportunity to request a hearing thereon.. In that way, the burden of proof would be upon the moving party on the issue rather than having Joshua in the position ofbeing the moving party. For the information of the Court and the other parties, a criminal jury trial in which I am counsel before Judge Howard is expected to last at least through July 8, 2002. Thank you for your attention to this matter. JWW:js cc: All Counsel of Record Clerk of the Court IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION RECEIVED JUL 8 2002 OFACEOF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS NOTICE OF FILING In accordance with the Court's Order of December 10, 1993, the Arkansas Department of Education hereby gives notice of the filing of AD E's Project Management Tool for June 2002. Respectfully Submitted, MARK PRYOR Attorney General DENNIS R. HANSEN,# 97225 Deputy Attorney General 323 Center Street, Suite 300 Little Rock, Arkansas 72201 (501) 682-2586 Attorney for Arkansas Department of Education CERTIFICATE OF SERVICE I, Dennis R. Hansen, certify that on July 2, 2002, I caused the foregoing document to be served by depositing a copy in the United States mail, postage prepaid, addressed to each of the following: Mr. M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings 200 W. Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1 723 Broadway Little Rock, AR 72201 Mr. Richard Roachell Attorney at Law P.O. Box 17388 Little Rock, AR 72222-7388 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 W. Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 W. Capitol, Suite 3400 Little Rock, AR 72201 Ms. Ann Marshall One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Lt~ Dennis R. Hansen IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL PLAINTIFFS V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE W. KNIGHT, ET AL INTERVENORS ADE'S PROJECT MANAGEMENT TOOL In compliance with the Court's Order of December 10, 1993, the Arkansas Department of Education (ADE) submits the following Project Management Tool to the parties and the Court. This document describes the progress the ADE has made since March 15, 1994, in complying with provisions of the Implementation Plan and itemizes the ADE's progress against timelines presented in the Plan. - IMPLEMENTATION PHASE ACTIVITY I. FINANCIAL OBLIGATIONS A. Use the previous year's three quarter average daily membership to calculate MFPA (State Equalization) for the current school year. 1. Projected Ending Date Last day of each month, August - June. 2. Actual as of June 28, 2002 Based on the information available at)v1ay j _t 2002,;frie ADE calculated the Equalization Funding for FY 01/02, iUbj'eb(to periodic adJustrr.i'knis: B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June. A072A (Rev.8/82) ECEIVED JUL - 8 2002 OFFICE OF ESEGREGATION MONITORING FIL~e EAS ~ S. 1~~ RT IN THE UNITED STATES DISTRICT COURT T RN'2Ji 1 ~NSA EASTERN DISTRICT OF ARKANSAS JUL - 5 2002 LITTLE ROCK DIVISION LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ORDER DEFENDANTS INTER VEN ORS INTERVENORS On July 3, 2002, LRSD filed a Motion in Limine and Supporting Memorandum Brief arguing that: (1) because Joshua's witness list fails to comply with the Court's May 15, 2002 Order, Joshua should be required, on or before 5 :30 p.m. on July 10, 2002, to identify the date and time each of their witnesses will be called, to identify the issues on which each witness is expected to testify and to provide a detailed statement of the witnesses' expected testimony on each issue; (2) certain Joshua exhibits should be excluded because they have not been provided to LRSD as required by the Court's May 15 Order; (3) Joshua should not be allowed to call Sadie Mitchell and Junious Babb, because, in earlier evidentiary hearings, Joshua's counsel has called and examined both of them on student achievement, guidance counseling, and advanced placement courses; (4) various Joshua exhibits should be excluded because, on their face, they do not directly relate to the three remaining issues of advanced placement courses, guidance counseling, and extracurricular activities; (5) any testimony from Jim Mosby and Jody Carter related to their recent removal as principals of Southwest Middle School and McClellan High 6 1 6 A072A (Rev.8/82) School should be excluded under Fed. R. Evid. 401 , 402, and 403; (6) Joshua's failure to identify any witnesses or exhibits for use in their \"thirty minutes of true rebuttal\" prevents them from presenting any rebuttal testimony at 8:30 a.m. on July 22, 2002; and (7) Joshua Exhibits 767- 776 and 791 should be excluded under Fed. R. Evid. 801-804, 401-403, and 901. The schedule for LRSD and Joshua submitting their exhibits and witness lists to the Court on July 9 and the commencement of evidentiary hearings on July 22 necessitates an expedited response from Joshua to LRSD's Motion in Limine. Therefore, Joshua must file their response to LRSD's Motion in Limine no later than 2:00 p.m. on Monday, July 8, 2002, and serve other counsel by fax at or before that time. Thereafter, the Court will promptly decide the merits of LRSD's Motion in Limine. Since time is of the essence, this Order will be faxed to counsel of record as soon as it is entered. IT IS SO ORDERED. 11f DA TED this f day of July, 2002. UNITED STATESDlSTRIC DG THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITH RULE 58 AND/OR 7~ ON 7/6/0'6 gy_O-c~,-_=-_..~,a.-- -2- ---- -- RECEIVED .- - -- 'JUL 1 O 2002 OFACEOF DESEGREGATION MONITORING - . ; /:JLt:::,o .. - E.A.s,f;p. Dtsr g;;;. IN THE UNITED STATES DISTRICT QOURT Noisr~;g~ uRr EASTERN DISTRICT OF ARKANSAS JUL OB KA.ivsAs WESTERN_DIVISION JAMs W 2002 By:  MccoR MACK LITTLE ROCK SCHOOL DISTRICT V. NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO.I , ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL JOSHUA INTERVENORS' RESPONSE TO THE LRSD 1. Joshua Intervenors ' Witness List , CLERK p.1,,1\u0026lt;,\u0026lt;Dl.A ,,...._.u. F [f::RK DEFENDANTS INTER VEN ORS INTER VEN ORS The Joshua Intervenors maintain that their witness list generally parallels the list submitted by the LRSD, by identifying the topics of witness testimony. For example, the LRSD can maintain that the summary of the testimony of Dr. Leslie (for 6 hours) \"provide[s] a detailed statement of the witnesses' expected testimony on each issue\" only on a \"tongue in cheek\" basis.  The Joshua Intervenors face two problems in preparing a witness list, which the LRSD does not face. The LRSD has ready access to all of its witnesses, who are its employees. In contrast, none of Intervenors ' witnesses are employees.1 Moreover, at least 11 oflntervenors' witnesses are subject to the direction of the LRSD. These are witnesses number 1-3, 5, 7, 14-15, 18-19, 23, and 26 on the Intervenors ' list. Nevertheless, the Joshua Intervenors will submit a supplemental witness list by 5 :00 p.m. on 1Doctors Roberts and Ross are experts designated by Intervenors. -1- July 10, 2002. 2. Asserted Failure to Provide Exhibits The LRSD complains about the failure to provide exhibits identified by the numbers 793, 794, 799, 800 and 801. Each exhibit is an LRSD document(s) . . Some are voluminous. By this objection, the LRSD is simply seeking to frustrate the Joshua Intervenors' effort to present the position of the class in a reasonable manner. Exhibit 801, \"LRSD Quarterly Status Reports,\" was the subject of testimony during the earlier hearings. These reports contain information regarding enrollment in advanced courses, as well as the extent to which students succeed. 3. Testimony by Sadie Mitchell and Junious Babbs These associate superintendents served on the LRSD compliance committee during the implementation of the revised plan and have had responsibility for the areas of guidance counseling and extracurricular activities. LRSD plans to offer lengthy testimony by Ms. Mitchell (two hours). The Joshua Intervenors, in contrast, propose to question each administrator for approximately 10 minutes. In this light, it is appropriate to allow Joshua Intervenors to proceed with the testimony, with the LRSD having the right to object to a question as repetitive. 4. Various Exhibits Assertedly Not Relevant to Issues to be Heard The exhibits deal with the following issues: advance placement: 754, 801-802 guidance and counseling: 780, 786-789 extracurricular activities: 746 (lumped statistics), 771, 773 , 775 rebuttal: 743,747,749, 750,755 , 757,758,759,760,762,763 , 764,779, 785 will not be offered: 752, 756, 761, 777, 778, 779, 782, 783 , 784 -2- 5. Testimony from Jim Mosbv and Jodv Carter The Joshua Intervenors do not plan to question Messrs. Mosby and Carter regarding \"their recent removal as principals.\" 6. Rebuttal The Joshua Intervenors will present rebuttal testimony by ODM Monitors Ann Marshall and Gene Jones. They will address the LRSD's testimony at the earlier hearing, which asserted compliance with Section 2. 7 .1 of the revised plan. 7. Joshua Exhibits 767-776. 791 These letters written by Ms. Springer are offered to show notice to the district of various problems. Counsel for Joshua Intervenors intends to explore at the hearing what if any investigation and other responsive actions were undertaken by the LRSD, after receipt of the letters. The LRSD pledged to implement programs, policies and procedures to insure non-discriminatory access to extracurricular activities. Its administrators ' responses to the letters is therefore relevant. The Joshua Intervenors should have the opportunity to seek the authentication of pages 2 and 3 of Exhibit 791 , dealing with guidance, by the testimony of Junious Babbs and Sadie Mitchell. 8. Relevance Generally The LRSD's efforts \"to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors ... \" [Motion in Limine at 3] and to rely on Section 1983 entity liability standards [Memorandum Brief in Support of Plaintiffs Motion in Limine] is flawed. These gambits ignore the law of the case, and, more particularly, multiple promises, throughout the plan, to implement various activities without regard to whether or not non-compliance was called to the attention of the Board. See, e.g., Revised ,., -.)- Plan Sections 2.5, 2.7, 2.7.1, 2.12.1, 6, and 11. As emphasized in Joshua Intervenors ' response of May 30, 2002, the Court of Appeals has held and reiterated that the terms of settlement agreements in this case provide the standards for measuring the performance of the school districts, here the LRSD. [Memorandum at 47] The Revised Plan does not identify Section 1983 entity liability principles as the standard for evaluating compliance with its terms. Rather, it calls, inter alia, for adoption of various programs, policies, and procedures, their implementation, and monitoring to identify problems and provide a basis for remedial actions. School Board members are not LRSD employees, their commitment is for less than full-time. Manifestly, the plan envisions implementation activities by administrators and other - elements of the work force, without qualification in terms of notice to the school board. Joshua Intervenors ' proof will be consistent with this fran1ework. There will likely be questioning on the adoption of programs, policies, and procedures (largely the domain of the school board). There will be questioning of implementation, or the lack thereof (largely the domain offulltime employees). The effort to exclude evidence, wholesale, is without merit. Robert Pressman, Mass Bar No. 405900 22 Locust A venue Lexington, MA 02421 (781) 862-1955 Respectfully submitted, John -W. Walker, AR Bar No. 64046 JQHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501) 374-4187 (Fax) -4- CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has/been senTby fax and U.S. Mail, postage prepaid to the following counsel ofrecord, on this ,?~ day of l-,, 1,  ----:-2002: -r:;:-- 'I // I Mr. Clay Fendley Mr. Dennis l'l. H en  FRIDAY, ELDREDGE \u0026amp; CLARK Office of the Attorney General 400 W. Capitol, Suite 2200 323 Center Street Little Rock, Arkansas 72201 200 Tower Building Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Little Rock, Arkansas 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Richard Roachell ROACHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 I / Joen W. Walker -5- J VHl'i W WHLKt.t-\u0026lt; t-' H N0 . 571 JOHN W. WALKER, P.A. Attorney at Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 Fax (501) 374-4187 FAX TRANSMISSION COVER SHEET Date: July 8, 2002 To: Ms. Ann Brawn Marshall Fax: 371-0100 Re: LRSD v. PCSSD, et al. Sender: Jolm W. Walker P. l/6 YOU SHOULD RECEIVE [ _ (including cover sheer)] PAGE(S), INCLUDING THIS COVER SHEET. IF YOU DO NOT RECEIVE ALL THE PAGES, PLEASE CALL \"\u0026lt;(501) 374-3758'\u0026gt;\" The information conr.a.ined uu:his fucsimile message is atto111ey privileged and confidential information intended only fur the use of the individual or entity named aoove. !f the reader of this m~sagc is not the intended recipient, or me emp1oyee or agent responsible to deliver it fo the inrended recipient, you are hereby notified that any dissemination, distribution or copying of this communicttion Is strictly prohibited. If you have received this communication in error, please immediate notify us by telephone, and return the original message to us at the above address via the U.S. Postal Service. Thank you. R CEIVED IN THE UNITED STATES DISTRICT COURTu.folb~cPuRT EASTERN DISTRICT OF AR.KANSAS EASTERN DISTRICT ARKANSAS LITTLE ROCK DIVISION JUL 0 9 2002 J L 11 2002 OFFICE OF OESEG EGATION MONITORING A072A (Rev.8/82) LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. I, ET AL. MRS. LORENE JOSHUA, ET AL. KA THERINE KNIGHT, ET AL. ORDER DEFENDANTS INTERVENORS INTER VEN ORS Earlier today, United States Magistrate Judge Tom Ray conducted a hearing to receive the parties ' pre-marked exhibits, exhibit lists, witness lists, and witness statements as provided for in paragraph 5 of my May 15, 2002 Scheduling Order. In addition, at my request, Judge Ray also addressed several housekeeping matters associated with the hearing that I have scheduled for 8 :30 a.m. on Friday, July 12, 2002, on LRSD's Motion In Limine. I have now reviewed the transcript of the hearing before Judge Ray, and want to reiterate several points covered during that hearing. First, the evidentiary hearing that is scheduled to commence before me at 8:30 a.m. on July 22, 2002, is limited to testimony and other evidence relevant to LRSD's alleged failure to substantially comply with its obligations in three specific areas of the Revised Plan: (1) advanced placement courses ( 2.6 and 2.6.2); (2) extracurricular activities ( 2.6); and (3) guidance A072A (Rev.8/82) counseling ( 2.6.1 and 2.11.1 ). The only other evidence the Court will receive during the July 22 hearing will be limited to: (a) LRSD's obligation of good faith( 2.1), but only as that obligation specifically relates to these three things: advanced placement courses, extracurricular activities, and guidance counseling; and (b) LRSD's obligations regarding African-American students' achievement ( 2.7), but only as that obligation specifically relates to these three things: advanced placement courses, guidance counseling, and extracurricular activities. 1 Second, after reviewing Joshua's witness list and witness statements, it appears to me that some or all of the anticipated testimony of a number of their witnesses falls outside the scope of the July 22 evidentiary hearing, as defined above, and as defined earlier by Judge Wright, and by my Order of May 9. I assume these potential problems will be cured by the supplemental witness lists and statements that Joshua and LRSD will file by 5:00 p.m. tomorrow. In connection with those supplemental witness lists and statements, I expect both sides to comply fully with each and every requirement of paragraph 3 of my May 15 Scheduling Order. Third, I want to reiterate that I will be continuing the practice followed by Judge Wright of allocating and keeping time for each side during the July 22 hearing. As my May 15 Scheduling Order makes clear, Joshua and LRSD are each allocated twenty hours to present their cases. Each side should keep this overall time constraint in mind in calling and examining their witnesses. Absent compelling circumstances, I do not intend to give either side more than their allocated twenty hours. 11 am mindful that Joshua also will be allowed thirty minutes at the beginning of the July 22 hearing to call Ann Marshall and Gene Jones as rebuttal witnesses on the three issues tried to conclusion during the earlier evidentiary hearings before Judge Wright: (1) good faith; (2) African-American student achievement; and (3) student discipline. -2- A072A (Rev.8/82) Finally, I have reviewed the so-called \"rebuttal exhibits\" that Joshua intends to introduce during the rebuttal testimony of Ann Marshall and Gene Jones. Many of these rebuttal exhibits appear to be documents that were available and could have, and, if they wanted them in evidence, should have, been introduced by Joshua in their case in chief. During the July 12 hearing, Joshua's counsel should be prepared to address how those exhibits constitute true rebuttal documents. The lawyers for the parties, especially the lawyers for LRSD and Joshua, should have someone watching their fax machines commencing no later than 8:30 a.m. this Thursday, July 11. It is possible that I will enter an Order early Thursday morning in response to filings made by these parties Wednesday afternoon. The Order may require additional work before the hearing scheduled for 8:30 a.m. this Friday, July12. IT IS SO ORDERED#. DATED this qr aay of July, 2002. UNITED STATES DISTRIC'i'JUDGE -3- FAX COVER SHEET UNITED STATES DISTRICT COURT Eastern District of Arkansas JAester,'1 Division Telephone 501-604-5140 Fax Number 501-604-5149 TO: Chris Heller \u0026amp; Clay Fendley Sam Jones . 376-2147 376-9442 3i5-1027 221-3331 374-4187 682- 2591 371-0100 Stevejones Richard Roachell John Walker Dennis Hanson Anne Marshaii DATE: There are _\"f.J pages, including this Cover Sheet, being sent by this facsimile transmission. Z:0/10 3rnrl MESSAGE SENT BY: Office of Judge Wm. R. Wiison, J; U.S. District Court 600 West Capitol, Room 423 Little Ro,..,~ \"R 7,,0, ~,, I \"-\"-J ~ ,, t RECEIVED JUL 1 5 2002  OFFICEOF ESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT V. NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICTNO.l, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL JOSHUA INTERVENORS' WITNESS LIST DEFENDANTS INTER VEN ORS INTERVENORS The Joshua Intervenors submit their witness list in response to the Court's several directives regarding these matters. Joshua is presenting below a summary of the testimony in some detail of each witness it will call on direct. Joshua is presenting a table of the name of each witness, the expected time each witness will take on direct examination and the approximate time of the appearance of each witness. The times of the appearances of each witness are presented taking into account an equal an1ount of cross examination time by the plaintiff. Possible times for lunch breaks are included. In presenting the matter in this manner, we do not intend to offend the Court by suggesting the exact times of breaks and/or for lunch, nor do wish to offend the Court by presenting this document in this fashion. The manner in which we present it will provide the Court and the parties a timeline of expected testimonial events and provide easy and ready reference to each forthcoming event. We expect our case in chief to be approximately 11 hours (660 minutes). We expect to use the remaining time for either cross examination or for rebuttal (up to two hours). -1- SADIE MITCHELL: The issues Sadie Mitchell will address are extra-curricular activities and guidance counseling. Her respective testimony is that Joshua raised issues of disparate treatment with respect to extra-curricular activities for which she or some subordinate made responses. She will address examples such as discrimination in 9th grade athletics, band, scouts, choir, mock trial, quiz bowl, cheerleaders and the activities wherein participation by race is reflected in the various student yearbooks. She will also address the complaints regarding student honors and efforts to improve minority paiiicipation in AP and honors type activities particularly at Central and Hall High Schools. She will also relate to the inadequacy of data collection regarding extra-cunicular activities and the decision to aggregate rather than disaggregate activity data. She will confirm that aggregation of the data presents a false picture of activity participation in the respective schools which include all the secondary schools. She will also address the failme rates in advanced placement courses as reflected in the Quarterly Reports previously discussed before Judge Wright. JUNIOUS BABBS: Junious Babbs will address the identification of particular athletic programs and other activities with limited African American participation and plans for remediation, review of each school's annual guidance report to identify areas of limited service to African American students such as a) course enrollment facilitating access to stronger higher education opportunities; b) access to financial aid; and c) course enrollment to help to facilitate graduation. He will also address his investigation into the participation and inequities thereof of minority students in AP courses and the passing and failure rates related thereto. MS. SHARON BROOKS: Ms. Sharon Brooks will testify regarding her placement of -2- elementary school African American boys without utilization of counseling services for a period of two months. She will address failure to provide a teacher and a counselor for those boys, whom she separated from the girls. DR. MICHAEL FAUCETTE: Dr. Michael Faucette, a teacher at Central High School, will discuss in detail the problems with the administration of advanced placement courses, the racial effect of the placements, the manner in which the placements are made, how the placements tend to favor one group of children over another, the problems with scheduling and how those scheduling decisions interact with other decisions of placement and counseling; participation in extra-curricular activities; the favor given to white students at Central high School; the disparate effect of AP courses with respect to teaching, awards, and other oppo1iunities; and he will discuss the issue of the District's good faith compliance. MS. PAM MERCER: Ms. Pam Mercer, an African American parent, will discuss the District's good faith establishment and administration of AP courses at Central High School, the exclusion of African American students therefrom, the privileges extended by AP teachers and activities sponsors to white students, counseling of students for placement in AP courses and the racial atmosphere which exists within AP classes. She will discuss her membership on the Activities Advisory Board for the school district and her dissatisfaction with its efforts. CRYSTAL MERCER: Crystal Mercer will discuss her dissatisfaction with guidance counseling services with respect to the following areas: access to financial aid and course enrollment facilitating access to stronger higher educational oppo1iunities. JASON MERCER: Jason Mercer will discuss his dissatisfaction with the District's efforts to ensure more African American student participation in AP courses. He will also discuss content ., -.)- of Exhibit 797. D.J. THAMES and A VIS THAMES: D.J. Thames, student at Fair High School and Avis Thames, his mother. Their testimony will cover their dissatisfaction with the District's efforts to ensure fair participation in extra-curricular activities such as football. ROMONA HORTON: RomonaHorton,parentof students at Central High School and Forest Heights Jr. High School will testify regarding her dissatisfaction with the District's efforts to encourage her children's participation and retention in Pre AP and AP courses at their respective schools. She will also testify regarding her dissatisfaction with counseling services with respect to her children's success in the classes, access to financial aid and course emollment facilitating access to stronger higher educational opportunities. In addition to testimony regarding dissatisfaction with her children's participation in AP, she will also address the use of racial slurs by an AP teacher. She will also discuss the District's response to her complaints. JODIE CARTER: Jodie Carter will discuss special problems with AP classes in the school district as a whole and at McClellan High School in particular. He will specifically relate to the manner in which courses are constituted at the various schools. The problem with staffing the classes and in filling the classes at the various schools. He will discuss his understanding of guidance counseling as it relates to AP placement, participation in extra-curricular activities and the District's good faith. He will specifically relate to problems that he has observed regarding school board members' support of AP classes, guidance counseling and extra-curricular activities. He will discuss the issue ofracial placement and how the counseling system has worked in his observation at the school district over time. This necessarily will include the varying levels of support provided by the central administration with respect to AP courses, guidance counseling and extra-curricular -4- activities at McClellan in comparison to Parkview and Central High School. MS. DOROTHY MCDONALD: Ms. Dorothy McDonald will discuss counseling in general and at McClellan High School in particular. She will discuss the way counseling has a more negative impact on African Americans than white students at McClellan High School and as she understands it to be at other schools based upon her meetings with JoEvelyn Elston and other persons who oversee and administer the other counseling progran1s. MS. CASSANDRA NORMAN: Ms. Cassandra Norman, Principal at J.A. Fair High School will discuss counseling services, placement in pre AP and AP classes at both the middle and Jr. High school and high school and how those courses differ from similar courses at Central and Parkview High Schools. She will discuss AP class sizes, expenditures, teacher turnover and the support of school administrators for her school with respect to these issues. She will address issues regarding counseling within Fair and the problems with a counselor that she had whodid not address the issues in equitable way regarding African American students. CHRIS PAYNE: Chris Payne a former student at J.A. Fair High School will discuss race discrimination in extra-curricular activities. His efforts to participate in the Quiz Bowl at Fair, counseling that he received at Fair while he was there, and the fact that he did not feel that he was fairly treated with respect to those subjects. MR. KENNETH MOORE: Mr. Kenneth Moore will discuss extra-curricular activities, counseling and good faith compliance. His testimony will relate to his experiences at Hall and Fair High Schools and how counseling works at those schools to the detriment of African American students with respect to their participation in extra-curricular activities and with respect to their AP type placements. -5- MR. RAY GILLESPIE: Mr. Ray Gillespie will discuss his role with respect to overseeing the athletic extra-curricular programs and activities and assisting in the monitoring of school programs at the direction of Les Carnine to ostensibly assure eliminating racial discrimination. He will testify regarding the lack of suppo1i that he received in his efforts to achieve equity and his conclusion that African American students and staff are treated differently with respect to these subject areas in comparison to similarly situated white persons. MR. JIMMY MOSBY: Mr. Jimmy Mosby will discuss guidance counseling, extra-curricular activities and pre AP courses during his tenure at Hall High School and at Southwest Middle School. He will address the District's lack of support with respect to pre AP and cow1seling. MS. SUE STRICKLAND: Ms. Sue Strickland will address guidance and counseling programs, AP courses, class sizes of AP courses, pupil teacher ratio, criteria for placement into the programs or the lack thereof or the rationale therefore and the board's good faith. Ms. Strickland will also address the lack of truthfulness by Superintendent Carnine with respect to communication with the school board. DR. KA THERINE MITCHELL: Dr. Katherine Mitchell will address guidance and counseling programs, AP courses, class sizes of AP courses, pupil teacher ratio, criteria for placement into the programs or the lack thereof or the rationale therefore and the board's good faith. DR. MICHAEL DAUGHTERY: Dr.Michael Daughtery will address guidance and counseling programs, AP courses, class sizes of AP courses, pupil teacher ratio, criteria for placement into the programs or the lack thereof or the rationale therefore and the board's good faith. He will discuss his efforts to understand the necessity for relating counseling to AP and pre AP placement, monitoring counseling programs and AP programs and his efforts to have AP programs -6- to become more inclusive for minority students. He will discuss how students can be expected to succeed in AP courses in middle and high schools if they haven't been taught and properly counseled in the earlier grades. DR. TERRENCE ROBERTS: Dr. Tenence Roberts is a District Consultant regarding desegregation activities. He will address the necessity for there to be a correlation between guidance counseling and placement in AP courses. He will discuss the manner in which he has been used by the District to train teachers with respect to these subjects in particular and other subjects in general in Little Rock. Counsel is endeavoring to have him available on either July 23 rd or July 24th . He lives in California and travel arrangements have not been made. DR. STEVEN ROSS: Dr. Steven Ross will testify about the District's good faith compliance, AP courses. He will also discuss the need for criteria for placement and whether all students may be qualified in the absence of standards for placement in AP courses without earlier foundations and specific training. MS. ETHEL DUNBAR: Ms. Ethel Dunbar, Principal at Franklin Elementary School will discuss elementary good faith compliance, gifted and talented courses, guidance cotmseling and the assistance received with respect to these issues from the Division of Instruction. REBUTTAL Name Date of Testimony Approximate Time Minutes Ann Marshall 7/22/02 8:30 - 9:00 a.m. 15 Gene Jones 7/22/02 15 -7- DIRECT EXAMINATION Name Date of Testimony Approximate Time Minutes Sadie Mitchell 7/22/02 9:30 a.m. 30 Junious Babbs 7/22/02 10:30 a.m. 30 Sharon Brooks 7/22/02 11 :30 a.m. 15 7/22/02 Lunch 12-1:00 p.m. 60 Dr. Michael Faucette 7/22/02 1:00 p.m. 90 Pam Mercer 7/22/02 4:00 p.m. 30 Crystal Mercer 7/22/02 5: 00 p.m. 10 Jason Mercer 7/22/02 5:20 p.m. 15 D .J. Thames/ A vis Thames 7/22/02 6:30 p.m. 15 Romona Horton 7/23/02 8:30 a.m. 30 Jodie Carter 7/23/02 9:30 a.m 120 7/23/02 Lunch 12- 1 :00 p.m. 60 Dorothy McDonald 7/23/02 2:30 p.m. 15 Cassandra Norman 7/23/02 3:00 p.m. 45 Chris Payne 7/23/02 4:30 p.m. 10 Kenneth Moore 7/23/02 4:50 p.m. 15 Ray Gillespie 7/23/02 5:20 p.m. 15 Jimmy Mosby 7/24/02 8:30 a.m. 15 Sue Strickland 7/24/02 9:00 a.m. 10 Dr. Katherine Mitchell 7/24/02 9:20 a.m. 10 Dr. Michael Daughtery 7/24/02 9:40 a.m. 30 Dr. Terrence Roberts 7/24/02 10:40 a.m. 30 -8- Dr. Steven Ross 7/24/02 Ms. Ethel Dunbar 7/24/02 Robert Pressman, Mass Bar No. 405900 22 Locust A venue Lexington, MA 02421 (781 ) 862-1955 11 :40 a.m. 1:45 p.m. Respectfully submitted, ,,,-,, Jdhn W. Walker, AR Bar No. 64046 vJOHN W. WALKER, P.A. 1 723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501) 374-4187 (Fax) -9- 30 30 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been sent by fax and U.S. Mail, postage prepaid to the following counsel of record, on this 10th day of July, 2002: Mr. Clay Fendley FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Arkansas 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Richard Roachell ROACHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 I . ,,('(;~~--/:.,/ J,ohn W. Walker . RiCEIVED JUL 1 5 2002 OFACEOF - SEGREGATION MONITORING J:JL 1 O 2~:;, JAMES W r, :,..c .. IN THE UNITED STATES DISTRICT CO   .- ., -ORMACK, CLERK EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. CASE NO. 4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. 1v1RS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. JOSHUA lNTERVENORS' SUPPLEMENT AL WITNESS LIST PLAINTIFF DEFENDANTS INTER VENO RS INTER VENO RS Joshua filed its Witness List earlier today. Inadvertently omitted was the name of Ms. Pat Watson, Counselor at Hall High School. Her name is being submitted as a witness who will address the District 's counseling programs, her instructions as to how they are to be implemented and how they are in fact implemented at Hall High School. She will address the counseling role for placement into Pre-AP, AP and Honors courses and she will relate to the counseling with respect to scholarships and other opportunities as well as course enrollment . Her testimony will take approximately 15 minutes. We urge to allow us to use her testimony on either the 23 rd or 241h if we are making substantial progress and have additional time we have not used in our case and chief. Otherwise her testimony will that of Ms. Ethel Dunbar on July 24th at approximately 3:00 p.m. Respectfully submitted, Robert Pressman - MA Bar No. 405900 22 Locust Avenue Lexington, MA 02421 (781) 862-1 955 \"'John W o.-64046 JOHNW. WALKER, PA 1723 Broadway Little Rock, AR 72206 501-374-3758 501-374-4187 (fax) CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing Motion has been sent to all counsel of record via United States mail postage prepaid on 1~10'11 ~-ay of ~uly , 2092. \\ Ml , ! I ' / -~ / \";c' L}/ -' / . ~ /Ar~-;/ tz~-tt i \\, RECEIVED FILED U,S, DISTRICT COURT EASTE~N DISTRICT ARKANSAS JUL 1,2 2002 IN THE UNITED STA TES DISTRICT COURT JUL 1 0 2002 OFACE OF DESEGREGATION MONITORING EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF vs. , 4:82CV00866-WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1., et al MRS. LORENE JOSHUA, et al KATHERINE KNIGHT, et al ORDER DEFENDANTS INTERVENORS INTERVENORS Attached is a copy of the transcript of the telephone conference held yesterday afternoon. The directions in this transcript are the orders of the Court. - ord.LRSDI IT IS SO ORDERED this 10th day of July, 2002. THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE VV!TH RULE 58 AND/OR 7~ FRCP oN_!Jd__O-Od::'BY -,~~----'-~=-  1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 - 25 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, V . No. 4:82CV00866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al., Little Rock, Arkansas July 9, 2002 4:45 P.M. Defendants, MRS. LOREN JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., APPEARANCES: Intervenors. TELEPHONE CONFERENCE BEFORE THE HONORABLE WILLIAM R. WILSON United States District Judge. For the Plaintiff: CHRISTOPHER J. HELLER, ESQ. Friday, Eldredge \u0026amp; Clark Regions Center, Suite 2000 400 West Capitol Avenue Little Rock, Arkansas 72201 For the Defendant: (No appearance. ) Carolyn S. Fant United States Court Reporter 1 1 For Joshua Intervenors: ROBERT PRESSMAN, ESQ. John Walker, P.A. 2 1723 Broadway 3 4 Little Rock, Arkansas 72206 Proceedings reported by machine stenography; transcript 5 prepared by computer . 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carolyn S. Fant United States Court Reporter 2 1 2 P R O C E E D I N G S THE COURT: All right, we're having a telephone 3 3 conference hearing this afternoon on the record in Little Rock 4 School District against Pulaski County, et al. It's 5 LR-C-82-866. This conference is regarding a letter that was 6 just hand delivered to me dated July 9 from Mr. Walker and Mr. 7 Pressman. It shows a copy to Mr. Heller. I am going to 8 notify by letter in the morning other lawyers of this 9 telephone conference so that they can order a transcript of 10 this hearing if they want to from Ms. Fant. But in any event, 11 I want to address this letter, and I will just start with the 12 first paragraph. Apparently Joshua got Exhibits 793 and 801 13 over to Judge Ray's courtroom deputy, Ms. Swanson, this 14 afternoon as was directed by Judge Ray this morning. By the 15 way, Judge Ray is here in my conference room. But I 16 understand there are other exhibits that have not been brought 17 over for marking, which are 794, 799 and 800 and I'm puzzled. 18 What's the problem with them, Mr. Pressman? 19 MR. PRESSMAN: One of the exhibits is five 20 yearbooks, and we were told that we could pick up the year- 21 books at five different high schools. 22 23 THE COURT: Okay. MR. PRESSMAN: And take them away to copy. And Mr. 24 Walker wasn't here. I didn't know how to handle that. 25 THE COURT: Okay, I will give you -- 794 and 799 and Carolyn s. Fant United States Court Reporter 1 800 I will give you until 2:00 p.m. tomorrow to do what's 2 necessary to have them delivered to Ms. Swanson by 2:00 p.m. 3 All right, are there other exhibits that we need to 4 address? 5 6 7 8 9 10 MR. PRESSMAN: No, I don't think so. THE COURT: All right, let's look at paragraph 1 of the letter; that he and Judge Wilson are apprised of the following position: \"One, we want to reserve for rebuttal that part of our 20 hours which we do not utilize in our case in chief.\" I'll, of course, allow you to reserve a certain 4 11 amount of time for rebuttal. I will remind you again that I'm 12 big on true rebuttal, not just more evidence that could have 13 been introduced during your case in chief. And I wouldn't 14 allow you, for example, to put on five hours of testimony and 15 reserve 15. What do you want? About an hour or two hours for 16 rebuttal, Mr. Pressman? 17 MR. PRESSMAN: That was -- that was -- that's what 18 Mr. Walker told me. He has handled this. 19 THE COURT: Is Mr. Walker there with you? 20 21 22 23 MR. PRESSMAN: No, he's at the courthouse. THE COURT: Well, I will give you two hours for rebuttal and you notify me by 2:00 p .m. tomorrow by fax -Judge Ray and me both by fax and the other parties if you want 24 more than two hours reserved for rebuttal. I'm not inclined 25 to reserve much more than that, but I will give you an Carolyn S. Fant United States Court Reporter 1 2 3 4 5 6 7 8 9 opportunity to address that. If you haven't addressed it by 2:00 p.m., I will assume that two hours is satisfactory with you. Now the next sentence in paragraph 1 I find quite disturbing. It says, and I quote: \"We'll attempt to provide a more specific response regarding rebuttal time in our supplemental document regarding our witnesses.\" Now, I entered this order in May directing the identity of witnesses and detailed statements with respect to 5 10 what they were going to say, and that order was not met. The 11 12 13 14 15 16 17 requirements of that order were not met. Judge Ray today extended that until 5:00 p.m. tomorrow. As I understand, Mr. Walker was in the courtroom part of the time, at least, but I'm not sure I understand what \"attempt\" -- why you use \"attempt\" rather than say \"we will comply.\" If you will look  at the title of that document that I entered back in May or those two documents, the word \"Order\" is there, not 18 suggestion. 19 And so would you address .that, what the problem is 20 with that, not getting that detailed statement or just 21 attempting to do it? 22 23 24 25 MR. PRESSMAN: I have not been involved in the development of the facts regarding these three areas. I was asked to do this hearing because Mr. Walker was not available. THE COURT: Well, of course, he knew well in advance Carolyn S. Fant United States Court Reporter 1 2 3 4 5 6 7 8 of the trial before Judge Howard he was going to have it and he's had since May to meet those directions. You need to get him tonight and tell him that I'm going to take a very dim look at an attempt rather than a full compliance by 5:00 p.m. tomorrow. Will you pass that message on to him specifically? MR. PRESSMAN: Yes. THE COURT: All right, I appreciate it very much. In paragraph number 2, I'm going to solve that 9  problem real quickly. Just assume that the other side will 10 take as long for cross-examination as you take for direct and 11 we'll worry about whether I ask questions or not. That won't 12 13 14 15 count against you, of course, so that should make it very easy. Any problems with that? MR. PRESSMAN: I will just we'll comply. I just 16 wish to say that I think that attorneys -- it's proper to 17 inform the Court if you feel that the Court's orders are 18 unreasonable, and that was the reaction that we had to these 19 orders about timing. 20 21 THE COURT: What's unreasonable about it? MR. PRESSMAN: Because these things just can't be, 22 you know, determined with that degree of precision. 6 23 24 25 THE COURT: Well, you know, of course, judges across the country are doing this regularly. I know one judge from -- district judge in Chicago who is now in the last couple of Carolyn S. Fant United States Court Reporter 1 years been promoted to the Seventh Circuit who runs two stop 2 watches, and they count objections against your time if you 3 don't win them, so I don't think that's unreasonable at all. 4 So I'm directing that you comply with it . And, like I say, 5 just give your time for direct examination and assume the 6 other side is going to take the exact same amount of time for 7 cross so you can calculate it. 8 Now I will say this, and I hesitate to say it 9 because I don't want to sound like I will give too much 7 10 leeway. You have a total amount of time here so if you want to 11 go 30 minutes on a witness that you estimated at 20 and take 12 13 14 it off another witness, that's all right. The total amount of time, that is the main thing. However, I'm not going to allow taking much more than your estimated time because what will 15 happen we'll get down to the end and you say, \"I have the most 16 crucial witness I've got in the whole case and I don't have 17 any time to put them on . \" So you'll have to stick pretty 18 close to your projected time . So that issue has been 19 resolved. 20 On the next page, the last page, the second page: 21 \"Last, we want to again point out we do not have the same 22 ability as the LRSD to control the order in which our 23 witnesses will appear. We are not dealing with persons who 24 25 are our employees.\" I'll cure the problem right now. Subpoena your witnesses for 8:15 on July the 22nd. Have them Carolyn S. Fant United States Court Reporter 1 all there . I will get them in the courtroom, swear them in, 2 and tell them to either stay at the courthouse or be where 8 3 they can be reached by telephone so you can get them there. I 4 will take that burden off your back, Mr. Pressman. 5 Hello? 6 7 8 9 10 11 fees? 12 13 MR. PRESSMAN: Yes. THE COURT: Doesn't that solve it? MR. PRESSMAN: Okay . Yes, it solves it. THE COURT: All right. MR. PRESSMAN: I guess we have to pay them witness THE COURT: I would assume. It's very unlikely -- if the exhibits are not over 14 here by 2 : 00 p . m. tomorrow that we have designated, it's very 15 unlikely I will allow their use at the trial. 16 Are there any other issues that we can resolve at 17 this point? If not, I'm going to sign off. 18 19 Honor. 20 21 MR. HELLER: We haven't seen that letter, Your THE COURT: Who's speaking? MR. HELLER: I'm sorry. This is Chris Heller. But 22 it sounds like the issues have been covered and we certainly 23 don't have any other issues at this point. 24 25 THE COURT: All right. How about you, Mr . Pressman? MR. PRESSMAN: No, I don't have any other issues, Carolyn S. Fant United States Court Reporter 9 1 but I think that Your Honor's approach doesn't account for the 2 3 4 5 6 7 different kind of practice that Mr. Walker has from a large law firm that has a school system as a client. THE COURT: In what respect does it not account for it. What specifically? MR. PRESSMAN: Because there aren't the same resources available. Mr. Walker is a unique resource in 8 Arkansas. People are constantly calling him from all over the 9 10 11 12 13 14 state every day about their civil rights problems. His time is called upon from scores of different directions. He has a lot of pressures on his time. He does the best he can within that context, and it's not as easy to comply with these kinds of directives for him as it is for a large law firm. THE COURT: Well, you know, I practiced for many 15 years as a solo practitioner in a small firm and judges 16 imposed these burdens on me regularly, and I just figured that 17 I had to double up. Of course, I was a mere street lawyer, 18 but I would suspect I probably got as much or half as much 19 again number of phone calls as Mr. Walker gets during the day, 20 so he's had since May to do this. This is a major trial. I 21 don't believe he has a more major trial. You are here, so it 22 23 24 looks to me like, Mr. Pressman, since you're one of the counsel of record you may need to stay hooked in here real tight and make sure the deadlines are met. I want you to 25 convey this to Mr. Walker very distinctly. I am not going to Carolyn S. Fant United States Court Reporter 10 1 treat him differently than I treat other lawyers. Lawyers in 2 big firms -- I happen to have had the happy experience of 3 being in a big firm myself for over two and a half years in 4 the litigation department, and the lawyers are -- each one has 5 an extremely busy practice. Now we all have a tendency when 6 we are not in one of the big firms to say, \"Oh, they've got a 7 hundred or 80 lawyers up there,\" but unfortunately each of the 8 80 or 70 lawyers has -- they are as busy as a solo 9 practitioner. They have their own solo practice, in effect. 10 I have been there, done that, and I used to get, \"You're at a 11 big firm. You\"ve got five partners that can do this, that or 12 the other.\" So I am distinctly unimpressed with that 13 position. I appreciate your expressing it and I'm glad you 14 did because it gives me an opportunity to make it clear that 15 I'm going to hold Mr. Walker to the same standard that I'm 16 going to hold the lawyers representing the other parties. 17 Everybody is going to be treated equally. 18 Is there anything else that we can bring up? I will 19 be happy to hear anything else; an objection, a complaint, 20 whatever else. I'm in a rulifying and commenting mood. 21 MR. HELLER: Your Honor, we don't have anything. 22 THE COURT: Mr. Pressman? 23 MR. PRESSMAN: No. I mean, I just basically 24 disagree with your positions but that's -- you're the Judge. 25 THE COURT: Mr. Pressman, you know, at least half of Carolyn S. Fant United States Court Reporter 11 1 the lawyers in every case I have disagree with my position and 2 that's one of the wonderful reasons that we have an Eighth 3 Circuit in case I don't do right. But I do appreciate your 4 comments. I take them into consideration. I just I don't 5 agree with your position and particularly not that I should 6 treat Mr. Walker differently than I should another lawyer. I 7 would consider that a very, very bad thing if I did that to 8 any lawyer . 9 All right. There being nothing else that I hear 10 from the lawyers, I want to thank you all for taking this call 11 on short notice and you go have a good evening to the extent 12 you can after my rulings. 13 MR. HELLER: Thank you, Your Honor. 14 MR. PRESSMAN: All right . Thanks. 15 16 17 18 19 20 21 22 23 24 25 (At 5:00 p.m., the above-entitled proceedings were adjourned. ) C E R T I F I C A T E I, Carolyn S. Fant, Official Court Reporter, do hereby certify that the foregoing is a true and correct transcript of proceedings in ~e above-ent Carolyn S. Fant United States Court Reporter IN THE UNITED ST A TES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKl COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KA THERINE KNIGHT, ET AL PLAINTIFF'S REVISED WITNESS LIST FOR THE JULY 22, 2002 HEARING RECEIVED JUL 1 l 2002 OFFICE OF DESEGREGATION MONITORING PLAINTIFF DEFENDANTS INTER VEN ORS INTER VEN ORS Plaintiff Little Rock School District (\"LRSD\") hereby identifies the following witnesses to be called at the July 22 , 2002 hearing and provides a detailed statement of their expected testimon y: 1. Dr. Bonnie Lesley. Dr. Lesley will testify on Wednesday, July 24, 2002, from I :00 p.m. until 4:00 p.m. regarding the District's compliance with Revised Plan 2.6 (as it relates to advanced placement courses) and Revised Plan  2.6.1 and 2.6.2. Dr. Lesley is the Associate Superintendent for Curriculum and Instruction for the District. Dr. Lesley will testify that the District's efforts to increase African-American enrollment in advanced placement courses and to ensure their success in those courses begins as soon as they enter the District. In this regard, Dr. Lesley will review the latest results from the K-2 reading assessments (the third year of the program 's implementation and the third year of testing data); describe a recent study Page I of 8 conducted by a team in her Division on the academic effects of participation by AfricanAmerican students in the District's pre-kindergarten program for students now in grades K-8 versus the scores of African-American students who did not participate; describe the new grants that have been awarded to several elementary schools to support their school improvement efforts, especially in reading/writing literacy; discuss the results of the State Benchmark examinations for grades 4, 6, and 8 (if available by the hearing date); discuss the District's new writing curriculum for PreK-12 (which will be ready by the time school starts in fall 2002), its goals related to improved student achievement at all levels, and how it is aligned with the State's curriculum standards and the knowledge/skills required to perform well on the ACT. Dr. Lesley will also discuss efforts undertaken by the District specifically at the secondary level and the results achieved by the District so far. In particular, she will summarize the results of two studies related to the District 's advanced courses at the secondary level; discuss the section on \"Advanced Placement Courses\" on p. 36 of the Compliance Report of March 2001-the summary of activities that resulted in the improved enrollments; describe the District's partnership with the Southern Regional Education Board in the implementation of the \"High Schools that Work\" framework for high school reform, especially the emphasis on all students taking a rigorous program of study, including college preparatory courses in the core areas; describe the trend/research for high schools to admit more and more non-traditional students to advanced courses and the benefits derived from those changes in practice, including improved test results, improved ACT scores, improved performance in college, etc.; review the NAACP's \"Call for Action in Education,\" and compare the NAACP's recommendations to the District's efforts; and describe a study that she conducted on class size at the middle and high school Page 2 of 8 - - ---- levels, including the percentage of small classes that are advanced classes and the percentage of African-Americans who were enrolled in all classes under 20. Dr. Lesley will also update her testimony from November 2001 related to how she sees the District continuing to improve in the next several years. The District's efforts must also be consistent with the requirements of the new federal \"No Child Left Behind\" legislation. Accordingly, Dr. Lesley will explain the District's plan for implementing these new requirements and responding to the new accountability requirements, including the support for low-performing schools. During her testimony, Dr. Lesley will also address the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Dr. Lesley may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. 2. Dr. Marian Lacey. Dr. Lacey will testify on Thursday, July 25, 2002, from 10:00 a.m. until 11 :00 a.m. regarding the District's compliance with Revised Plan 2.6 (as it relates to extracurricular activities) and Revised Plan 2.6.3. Dr. Lacey is the Assistant Superintendent for Secondary Schools for the District. Dr. Lacey will testify that the Board adopted policies JB, JBA, JBA-R, JJ, JJ-R, JJIA, JJIB, JJIB-Rl, JJIB-R2, and JJIB-R3 in order to comply with Revised Plan  2.6; that the District increased participation in extracurricular activities 76 percent in the 1998-99 school year and another 26 percent in the 1999-2000 school years; that 62 percent of African-American students participated in extracurricular activities during the 1999-2000 school year; that the number of African-American students participating in co-curricular activities increased 9 percent in the 1998-99 school year and an additional 30 percent in the I 999-2000 school year; that a 1999-2000 parent survey indicated that 90 percent of African-American parents and 93 percent of African-American teachers thought that activities Page 3 of 8 were open to all students; that the SIP program has helped increase African-American participation in activities; that transportation is provided for all extracurricular activities; that the Activities Advisory Board has begun functioning; that the District has hired Danny Fletcher, an African-American, as Fine Arts Director; and that she is not aware of any barriers to participation by African-Americans in extracurricular activities. During her testimony, Dr. Lacey will also address the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Dr. Lacey may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. 3. Jo Evelyn Elston. Ms. Elston will testify on Thursday, July 25, 2002, from I :00 p.m. to 2:00 p.m. regarding the District's compliance with Revised Plan  2.11 and 2.11.1 . Ms. Elston is Director of Pupil Services for the District. She will testify that during the term of the Revised Plan the District adopted policies JB, JBA and JLD; that counselors assist students with their educational, social, personal and career development; that each school conducts a needs assessment every three years and develops a school-based guidance plan; that the District has developed a comprehensive guidance program plan for both the elementary and secondary level; that counselors prepare monthly reports on their progress in implementing the guidance plan; that counselors are to keep a daily log of students counseled; that counselors have been instructed to encourage students to take pre-AP and AP courses; that counselors have attempted to ensure equity in honors, awards and scholarships; that counselors regularly prepare newsletters to notify students of scholarsh.ip opportunities, ACT preparation courses, etc.; that counselors provide all students with a written graduation plan; that secondary counselors prepare annual reports; that her office monitors both the monthly reports and annual reports prepared by counselors; that the Page 4 of 8 data on enrollment in pre-AP and AP courses, scholarships and honor graduates suggests that the counselors are doing a good job; that a 1999-2000 parent survey indicates that counselors are doing a good job; that the Safe School Health Students grant has allowed the Pupil Services Department to provide additional services to students; and that she is not aware of any systemic racial discrimination in the provision of guidance and counseling services. During her testimony, Ms. Elston will also address the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Ms. Elston may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. 4. Sadie Mitchell. Ms. Mitchell will testify from 3:00 p.m. to 4:00 p.m. on Thursday, July 25, 2002, regarding the District's compliance with Revised Plan  2.6, 2.6 .2, 2. 6.3, 2.11 and 2.11 .1. Ms. Mitchell is the Associate Superintendent for School Services for the - District. She will testify that the District has adopted the Total Quality Management philosophy and the principles underlying that philosophy; that the District has been awarded Quality Interest Award and Quality Commitment Award; that Campus Leadership Teams play an important role in school improvement; that the District has provided extensive training to make Campus Leadership Teams successful; that each school develops a school improvement plan each year, focusing on improving achievement in literacy and math; and that an important part of the District's strategy for improving achievement of African-American students is encouraging more African-American student to enroll in more rigorous academic courses. During her testimony, Ms. Mitchell will also address the District's good faith commitment to comply with the Constitution even ifno longer monitored by the Court. Ms. Mitchell may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. Page 5 of 8 5. Dr. Ken James. Dr. James will testify on Thursday, July 25, 2002, from 5:00 p.m. until 5:30 p.m. regarding the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Dr. James is the current Superintendent of the District and has held that position for one year. Dr. James will testify that he supports and intends to follow District policies which require compliance with the Constitution and federal civil rights statutes. Dr. James will also discuss the District's partnership with the Southern Regional Education Board, its implementation of the \"High Schools that Work\" framework for high school reform and the importance of students taking a rigorous program of study. Dr. James may also offer testimony responsive to evidence offered by the Joshua lntervenors during their case. 6. Baker Kurrus. Mr. Kurrus will testify on Friday, July 26, 2002, from 9:00 a.m. - until 10:00 a.m. regarding the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Mr. Kurrus is President of the District's Board of Directors. Mr. Kurrus will testify that the Board adopted and/or re-adopted policies during the term of the Revised Plan requiring compliance with the Revised Plan, Constitution and federal civil rights statutes; that every policy was adopted after being read at a prior Board meeting; that the Board fully expected the administration to comply with its policies requiring compliance with the Revised Plan; that the administration reported to the Board that it was complying with the Revised Plan; that a representative of the Joshua Intervenors was permitted to address the Board whenever requested; that in the 1998-1999 school year, the Board had 23 meetings and no representative of the Joshua lntervenors addressed the Board; that during the 1999-2000 school year, the Board had 20 meetings and a representative of the Joshua Intervenors appeared on July Page 6 of 8 22, 1999 and November 10, 1999; that at the July 22, 1999 meeting, attorney John Walker raised only general concerns; that the Board understood that the Superintendent worked with the Joshua Intervenors to address those concerns; that on November 10, 1999, attorney John Walker appeared to support parents and community members opposed to the closing of Mitchell Elementary School; that the Board agreed not to close Mitchell Elementary School; that during the 2000-2001 school year, the Board had 27 meetings, and the minutes reflect that Joy Springer appeared on behalfofthe Joshua Intervenors on January 25, 2001; that on that date Ms. Springer stated that improvements had been made, that there were still some issues to be addressed and that the Joshua Intervenors were hoping to work with administrators and the Board to address those issues; that the Board understood that the administration attempted to work with the Joshua lntervenors to resolve those issues; that the Board expected the Joshua Intervenors to raise in a - timely manner any compliance issues which could jeopardize the District obtaining unitary status, either with the Board or pursuant to Revised Plan  8; that the Board agreed to pay the Joshua Intervenors in advance to ensure Joshua's ability to monitor the District's compliance; that Joshua billed the District for monitoring, and the District paid those bills; that the Board never had any evidence presented to it that the District had not substantially complied with the Revised Plan; and that the Board adopted the Covenant to demonstrate and memorialize its good faith commitment to the Revised Plan and the Constitution in the future. Mr. Kurrus may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. Page 7 of 8 Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE \u0026amp; CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376-2011 BY!fjflzt1~- C. Fendley,Jr. CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by U.S. mail or as otherwise indicated on July 10, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. I 723 Broadway Little Rock, AR 72201 (hand-delivery) Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 F \\HOME\\FENDLEY\\l..RSD 2001 \\dcs-uniwy-wimcss-list- 7-22-02-revised.wpd Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 J~\u0026lt;=.F'endCley, fr -~ Page 8 of 8 RECEIVED UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS u r-:,S~ll; RRT EASTERN DISTRICT ARKANSAS 600 W. CAPITOL, ROOM 423 JUL 1 5 2002 OfFICE OF DESEGREGATION MONITORING LITTLE ROCK, ARKANSAS 72201-3325 (501) 604-5140 BILL WILSON JUDGE Mr. Christopher Heller Mr. Clay Fendley Facsimile (501) 604-5149 July 11, 2002 LETTER-ORDER BY FAX Mr. John Walker 400 West Capitol Avenue, Suite 400 Little Rock, AR 72201 1723 South Broadway Little Rock, AR 72206 Mr. Samuel Jones, Ill 200 West Capitol, Suite 2200 Little Rock, AR 72201 Mr. Richard W. Roachell 11 800 Pleasant Ridge Road Little Rock, AR 72222 Mr. Dennis Hansen 111 Center Street, Suite l 200 Little Rock, AR 72201 Re: Little Rock School District v. Pulaski County Special School, et al. 4:82CV00866 Dear Counsel: The filings yesterday appear to meet most of the requirements of paragraph 3 of the May 15 order. Joshua does need to file -- today -- a detailed statement of the expected testimony of their two rebuttal witnesses. It appears that Joshua has provided the exhibits referenced in LRSD's Motion in Limine. Joshua's filing of July 8 indicates that the testimony of Ms. Mitchell and Mr. Babbs will not be duplicative -- and the questioning of each witness will only be for ten minutes. It appears that Joshua has removed some of the \"rebuttal\" exhibits listed earlier. I will take a look-see at the other exhibits at the hearing which commences at 8:30 in the morning, unless LRSD concedes that Joshua's response renders those remaining relevant for rebuttal. LRSD v. Pulaski County School District July 11, 2002 Page Two Joshua indicates, in its July 8 pleading, that it does not intend to question Messrs. Mosby and Carter regarding their recent removal as principals. As long as the questioning of these two witnesses (as well as all the other witnesses) relates only to the three remaining issues, there should be no problem. Back to Joshua's two rebuttal witnesses. LRSD argues that they can't provide true rebuttal testimony, but I cannot rule on this point until I see the detailed summary of their expected testimony -- which, as noted above -- must be filed today. Turning now to Joshua Exhibit 767-776, 791 (Ms. Springer's letters). First off, let me state that I will not apply Monell in this case. That 1978 case, involving a Section 1983 complaint, is not applicable in school desegregation cases, in my view. The LRSD's objection to my ruling on this point is denied, and its exception is saved. I now quote from Joshua's July 8 filing with respect to these exhibits: The Joshua intervener should have the opportunity to seek the authentication of pages 2 and 3 of Exhibit 791, dealing with guidance, by the testimony of Junious Babbs and Sadie Mitchell . I will have to be more fully advised in the premises, during the hearing in the morning, as to the exact meaning of the above-quoted paragraph. Joshua's July 8 filing also indicates that these exhibits are offered to show \"notice.\" I assume that this means that Joshua is not offering them to prove truth of the contents. If this is correct, it removes the statements from the definition of hearsay, and I must turn to the question of whether \"notice\", in this manner, is admissible, and, if so, under what theory. In view of my ruling, above, on Monell, I see no reason to go further with respect to LRSD's \"relevance generally.\" I can't put my finger on the objection right now, but, as I recall, LRSD objected to Joshua's designation of LRSD's exhibits as Joshua's exhibits too. If I recall the objection correctly, it is overruled, and LRSD's exception is saved. While courthouse lore is often contrary to established law, it has been the practice of trial lawyers in this state, since the mind of man and woman runneth not to the contrary, to designate the other party's exhibits as their own. LRSD contends (again, as I recall it) that this designation is contrary to some provision in the May LRSD v. Pulaski County School District July 11, 2002 Page Three l 5 order. If that order prohibited this specific designation, I'm going to ignore that particular portion of the order (in this context). If there are other issues that should be addressed in the morning, I would be much obliged if the parties would send Judge Ray and me a fax today identifying those issues. Thank you. ci!il~ Wm. R. Wilson, Jr. cc: The Honorable J. Thomas Ray Original to the Clerk of the Court RECEIVED 9N1110llNOW NOllYD3\\193S30 JUL 1 s 2002 United States District Court ~033wo --::aor--______EA_ ST_ER_N_ __ DlSTIU~rr _ ARI\u0026lt;ANSAS ZOOZ 8 1 1nr - OFACEOF T TTT: r: Rnr'f(Fcltm~~SION rnE ii.R~Ilg~~OM~E~~cr EAST~r1f.Pc1STAICT ARK'lTNSAs ~~~jl:I JUL 1\"' 1 2002 LASKI COUNTY SPECIAL SCHOOL DISTRICT, et a!.MES W McCORMACK, CLERK CASE NIBvffiER: 4 : 82CV008, ,_..,.,. 1--:- . B~: DEP. C[ERKI --  TnO~L'\\S R..~Y Christopner Eelle:::-, et al. Sam Jones, et a1. u!v\" 9, ?QQ? \\ ~a'fi,1.yn Fant \\ FsF Swapsol! . - - x~ 7-~-i;: - ' :x ~~b ~ I I ::x '/ Yip I I ex 'JtP \\ \\ \\ I \\ ~ 4S \\ \\ \\ I \\ I ex 1 5,) I ( I I I ex '757 I l I I I ex 153 I \\ I I I 1 cxt~ I ) \\ \\ \\ ~,si; I I I I . . $:~~;ot;;,ff'g;_\\vc.~ ~o' l~-r1'14\"~ ~ Tu-14-eo r ~ ~ -/2, ~ ~-a {~ ~qo) (-~ ~ 0'1-;;;i...q-ot ~ _,, ~\u0026lt;;J.\u0026amp;,.._ . hw--,.._-ft ~ H-% tL,v/., ~,~-t ~7-.J.-O ;,' . /07) I t-~ ~ I I - I le -oo ~~ ~ ~ 'To \\~~ I c;__ - mi:iJ_ cue~ 03 -01 -o 1 0 . 1-l T ~ 0-,ui_ /14 w....;t cf.d_-fa, C:3-07-D( (l.f:/)..'i/11-f .f'(i/4 ; I It,, ::..n,._d.J.. clLW D 7-b--ul (rfJr.ri - -le l liJ(),\\J. (h.ti_ - ~ ~ D7-11p-ot {. g~ 1 (-r,,..\u0026amp;.l I.,~ o\u0026lt;o-~g--01 c,:o\u0026lt;:sa..-f'r\u0026lt;- F H~ ~ -fc o-r,J2.-n4,..;,2 ,~ ~ ~I ( P. tq;;\u0026gt;. tL.d /q 3 \\ u cv ~ :J ;o United States District Court ________E_ AS_TE_RN __ DtSTIUCT OF --:::-=:ARKAN==-~SA~S _______ I T TTTJ 'C' Barz DIVISION [T ROCK SCF.OOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECL~L SCHOOL DISTRICT, et al. CASE NlJ11BER: 4: 8 2CVOO! J:-iHO~L\u0026gt;\\S RAY I ..._,...Ch:-   11 al  1-- r1.stopne= J::ie_ er, et . Sam jones, et al . .!u!v' 9, 2002 l.aTI,1yn Fant I w;; Swapson ex 7 rsr; '!- '1-0 ~ -~ cl.t:rfu- oq-.).q-oo ~ ~ ~ ~ / K~ -~ IU:P~ ;;Jboo-O~ CR _57) I I ~ -riutJ- d,i.,# 10 - 3-00 ~ ~, e~ ~ ~ k - ~ ~ -'Alt ~1--~ ( A @J I 0 l I\\ I I I I ( - h\\._~  Q -I~ ~ I 3 - if I  I rJ.-.,J. Ca:~ c.~ 1q ') I .f\\ - ;.. United States District Court -----------=EA:..:..::.S.;::.;:TE=RN_ __ DtSTIUCT OF ARKANSAS  I TTTT ,:- Rory --;:;D~[V~IS~I07-;\"N~-------- [T ROCK SCP.COL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE IBJMBER: 4: 82CVOOl T\"\"'nfmL-\\S RAY 1-- 1-- Chriscophe-:- Eeller, et al. Sam Jones, et: al. Ju!v\" 9, 2002 \\t'arcilyn Fane \\ :acf'\"\" 5 . . . . - -   ~--~v  wapson \\cx'Y7(p \\ \\ \\ \\ \\~ ~ Ofv-07-06 ~ ~ il\u0026gt;~1  ex 117 I I I I 1e~ /k ~:;;~-OI United States District Court -----= ______ E_AS_TE_R_N __ D1STR.ICT OF -~ARK.!~!\\N:7SA~S ______ _ - I TTTJ ,:- :gnrx DIVISION ITTLE ROCK SCROOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE N\"'illvffiER: 4: 82CVOO! Ju!v\" 9, 2002 I \\ \\ ex 1ero  I I ...-.... ......... Christopher Eeller, et al. I. t:\"a'fp1 yn F an_t I,__ Kathv s~apson I I I I (-;y...r,i,__,t ~ 09-3o-CO - ~ c=r-c..,, __ -/TJ ~ -ak h{Jz;,/.4- t..,\\ ~ I I I I I I I I I I I I I I I I I I I I I I I I \\ \\ I I I I \\ I ~  1 - ~~ Ct4\u0026lt;M..e. - I ~v-Q_ e,o ~d-'7t j ~ ~ 68-04--Cfq ~ ~ rn~ I] United States District Court ~-------E_A_ST_ER_N ___ D1Sn.ICT OF --=::-::ARK.!::::!\\N:::-:S-;-A_S ______ _ - I TTTT -c- pnry DIVISION .ITTLE ROCK SCHOOL DISTRICT I. 'ULASKI COUNTY SPECL~L SCHOOL DISTRICT, et al. , rnfmL~S RAY I I ........, __ Christopher Eeller, et al. mtv\" 9, 2002 \\.t\"a'fl\u0026gt;1.yn Fant I I I I I I I I EXHIBIT LIST CASE NIBvIBER: 4: 82CVOQ. ~  I . I United States District Court ________ EA_ST_ER_N __ D!STRICT OF_~ARKAN==SA;.:;....S ______ _ - I TT.,..J\"\" :gnrK D[VISION ~ITTLE ROCK SCP.COL DISTRICT EXHIBIT LIST V. PULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE NillvIBER: 4: 82CV0C 1:--THOK!\\.S RAY \\ 'chr'i';;opher Heller, e't al. \\ 7a:j;nes, et: al. ex \u0026lt;lO / I I I -pG.A.k~..J ~ ~ ~ ~1~ I l ~, 7_;);).-:,btl~ 7-~-557'6 United States District Court ___. ,..___ _____EA _S_TE_RN __ DlSTRlCT OF --=-::-ARKAN~_;;,.;.SA~S _______ - I TTTJ, ROCK DIVISION CTTLE ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE NUMBER: 4: s2cvooc T\"\"'fiim-L'\\S RAY \\ 'chr':i';;opher Heller, et al. I ~-~nes, et al. J,....u .1. \" 'v\" 9, 2002 1--\"+ F 1---  1.,ar.9.1.yn an~ Kathv \u0026lt;;wapson ex?; / 3 ~-1-0;).. J!.P.W f-lciB.,Zv().(.d' -~ =-t-14 -t-u~1 9~J~ooo (,--;;i ct- 01qq1,;1. -j-T) /-;).f-0111,;iq. I I J/.d-,0--0 ro ;1.1esc/~ ~ t -c) -DICfl :\u0026gt;.~ I -)f-ol C/ '1~) I I rf..R.. SJ) ~~\"--\" ~~\"'\u0026lt;..LO- t/-l';;l - !'119- 'd{JO() {1--~-K-o/CjCJQ;, ~ /~)(-cJ/19(:;q) 1 I I I I 1:- ~ \"'4'.P / '\\,U,VTI\\J/ ~t:\u0026lt;19 _ g 17 \\ \\ \\ \\ \\ P~~vt- ~Cll.Ad   1 I I I . l ~-4 . iqqq(l-~-DI . United States District Court ~-------EA_ST_E_RN ___ DIS'TRICT OF _-::-:-:'-ARKAN~-:-:-SA_S ______ _ - I TTTT -c- BOrK DIVISION LTTLE ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE NUMBER: 4:s2cvoo1: J:-iHOI:La\\S RA.Y I ~i-;;opher Heller, et al. I ~-'j;nes, et al. Ju!v' 9, 2002 l.ra'fp1.yn Fant I w~ Swapsop United States District Court __________EA_ ST_E_RN_ __ DISTIUCT OF -~ARK.!~~~SA_S_ _______ - I TTTJ i:- BOrK DIVISION :TTLE ROCK SCP.COL DISTRICT EXHIBIT LIST JLASKI COUNTY SPECL~L SCHOOL DISTRICT, et al. CASE NlJrvfBER: 4:82CV008 Ju!v\" 9, 2002 \\ :C-a~'lyn Fan~ I w~ Swanson ex Mo I \\ex '6ltq \\ ~~ i;-D I I I I I I I I I I I I I I I I I - I I I I \\ \\ I I I I I I 11--R..SD ~Z\u0026gt; -ot ~~ ~ e  (1-:).\u0026lt;;i\"'-oJo3~ --fo f-:\u0026gt;-f-6)031./7) l'J'l'L . :/S~ Ct -:\u0026gt;-i ..... Q d-0 iJL/::;;. 71\u0026gt; I- d-\u0026lt;t-Od-() c.;9) United States District Court __________EA_ ST_ER_N_ __ DlSTRlCT OF --=::=:ARKAN~~SA~S _______ - r TTT'J ,:- B/\"\\rT\u0026lt;\" D1VISION ITTLE ROCK SCHOOL DISTRICT EXHIBIT LIST lTLASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE N\"'U1v1BER: 4: 82CV001: r:-'fRO!:-LA.S RAY I 'chr'i';;opher Heller, et al. I s:;j';;'nes, ec al. .ru!v' 9, 2002 l.'.Ca'fp1.y:n F~n.t I FsF Swanson ~ sr;;-\\ ~g, I ! ! I I Im vT ~..-. DI ( t -- -;;;.. f_ o){Jb{i.  --/-\u0026lt;iJ /-\";;).f-c~O\u0026amp;:J/';;}. I 1, '\\ I~ ~  ~ P~ \\ c?.06 r - ').Do ::i. (r --;}. F '-0 ::i. o~ 'gC/7zJ I-';) ?-o~t) 77;) ex g Go I I . I 1~ ~ -  ,~ ~o~ ex '6l, ( \\ ) \\ \\ \\ \\ ~ tJ HD -1 f ' b -~;;J- 6'/-3'{ -r,, 7~ ';,;;). _,;11d 1 \\ ( \\ \\ \\ \\ t\u0026lt;.. itL,tr ~ vth~::2. ( 1 cx ~ (,)- \\ . I ~J;;;ff:LI 1 g ..-- l-0, ~ (7- -;; - [;l/l/D lD 7 - ;;;-;;) - X q, 6 3 I . / I I I I ~ ' 7  ~If!!_ ( c).COC  i~4 I \\ I I I 1~ ~7-~-m1/fe7-?2-w1J United States District Court --------E-ASTE-RN ---DISTRICT OF ARKANSAS I TTII 't\" BOrK DIVISION [T~ ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al . CASE NUMJ3ER: 4: 82CVOOE .i-:-firo-t-Lt\\.S RAY \\ 'chr'i;;opher Heller, et: al.. \\ ~~nes, et al. Ju!v' 9, 2002 luTI,1yn F.ant I wF Swapson I I I -I I I I I I .. - I I \\ I I I I I I I ex I I I I I I I I -I I I I I I I I I I I  I I I I I RECEIVED - JUL 2 .. 2 2002 OFACEOF DESEGREGATION MONITORING u.fo lbf cPuRT IN THE UNITED STATES DISTRICT CO~ERN DISTRICT ARKANSAS EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION JUL 1 8 2002 JAMES W McCORMACK, CLERK By: ----~D::-:E\"\"'P.\"\"\"c\"\"\"'Le=A-R LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTER VEN ORS KA THERINE KNIGHT, ET AL. INTER VEN ORS ORDER 1. My May 15, 2002 Order read, in part, as follows: 4. In addition to exchanging exhibit lists, each party must exchange pre-marked exhibits on or before June 21 , 2002. Any exhibit that is not pre-marked and exchanged on or before June 21 , 2002, will not be received into evidence during the July 22 hearing, absent highly unusual circumstances. (Emphasis added.) 2. In a letter dated July 16, 2002, Mr. Walker enclosed seven proposed rebuttal exhibits. I will deal with them one by one. 3. CX 599 has been previously identified by Joshua and, absent a specific objection, will be admitted. 4. A Bonnie Lesley July 27, 2001 e-mail to Ms. Anne Brown (Marshall) was not - - - - - ----- - - - - -- - - - - - identified and marked prior to the June 21 deadline, and will be excluded. 5. A copy of the cover sheet for the Office of Desegregation Monitoring, which is entitled \"Report on the Little Rock School District's Preparations for Implementation of its Revised Desegregation and Education Plan,\" dated August 11, 1999. I assume, but do not know, that Joshua plans to introduce the entire report, although nothing but the cover sheet was provided in the letter. In any event, it violates the deadline set forth above and will be excluded. 6. Ms. Bonnie Lesley's February 21, 2000 letter to Ms. Anne Brown regarding \"recent LRSD publications.\" It will be excluded for the same reason.  7. A letter dated April 13, 2000, from Ms. Anne S. Brown to Dr. Bonnie Lesley acknowledging receipt of Ms. Lesley's February 21 , 2000 letter and attachments. It will be excluded. 8. Ann Brown's April 25,200 memo to Bonnie Lesley regarding \"feedback on LRSD Curriculum Documents.\" It will be excluded. 9. The Office of Desegregation Monitoring's October 26, 1999 \"Achievement Disparity Between The Races In The Little Rock School District.\" This will be excluded. 10. In the last paragraph beginning on the first page of Mr. Heller's July 17 letter, he requests that Mr. Walker be required to identify, by page and line number, the testimony of Dr. Lesley, which renders the rebuttal testimony of Ms. Marshall and Mr. Jones necessary. This is a fair request, and I normally would require it if time were not so short. I do note that Mr. Walker has only thirty minutes, total, for rebuttal. 11 . In the first full paragraph of Mr. Heller's letter dated July 17, 2002, which begins, \"in its Motion in Limine ... \" LRSD objects to the reading into evidence portions of the -2- depositions of certain Board members. With the exception of Dr. Karen Mitchell's testimony at lines 13-23 on page 27, all of remaining designated deposition testimony relates exclusively to the issues of academic achievement and program evaluations which are not among the issues which will be addressed during the hearing beginning on July 22. The objection is sustained. 12. In view of the sustaining of the objection, in the next preceding paragraph, the remainder of Mr. Heller's letter is moot. IT IS so ORDERErH DATED this / B day of July, 2002. -3- THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WlTf: ~UL7 58 ANO/OR 79(a) FRCP ' 7//9/tJ~ ~ 07/18/2002 11:16 5016045149 PAGE 02 RECEJVED JUL 2 -2 2002 OFFICE OF DESEGREGATION MONITORING FILJ:D : U.S. DISTRl~COURT  EASTERN DISTRICT ARKANSAS JUL 1 8 2002 STATE OF ARKANSAS JAMES W McCORMACK, CLERK OFFICE OF THE ATTORNEY GENEME----=..,,_.,.;._ oJiliP~ Deputy Attorney G\u0026lt;m~l Civil Department Direct dial: (BOI) 682,2586 Mark Pryor Attorney General R~~tr,s July 17, 2002 ... _,,~ The Honorable William R. Wilson . J. a~j (U?\"'w:U;_ ~1:~~ Jr. United States District Court ~nO ~~~ '(/ uE.t. ~~sx;~~~~g~e 600 West Capitol, Suite 423 11) : ~ Little Rock, AR 72201 RE: Little Rock School District v. Pulaski County Special School District, et al. Case No. 4:82CV0866WRW/JTR Dear Judge Wilson: oiC  ~ \"f!:11-(0)- eneral, counsel for the Arkansas Department of Education in the above-referenced matter, es ec y request that we be excus from the final evidentiary hearing on the Little Rock School Distnct s otlon or m ary tatus set to begin on Monday, July 22, 2002. The presentation of evidence by Joshua and the Little Rock School District on the remaining issues does not appear to require our attendance at the hearing and we do not intend to examine witnesses or otherwise participate. Thank you for your consideration of the foregoing. c=~~ DENNIS R. HANSEN Deputy Attorney General DRH/km cc: The Honorable J. Thomas Ray Mr. Christopher Heller Mr. SamuelJones,III Mr. Richard W. Roachell Mr. John Walker Ms. Ann Marshall Mr. Steve Jones Original to the Clerk of the Court 323 Center Street  Suite 200  Little Rock, Arkansas 72201 (501) 682-2007  FAX (501) 682-8084 Internet Website http://www.ag.state.ar.us/ Q :\\Civi1\\DenniaHldeeeg\\2002\\Con-espondcnce\\judgeltt07-l 7 .doc JUL.19.2002 10:36AM Ja-!N W W~KER P A N0.732 P.2 na:\\;flVEu - JUL 2 2 2002 OFFIC~ OF n ,:.:( .l! '/1\"~\"  \"\" I~IO NITORING JOffNW. WAt,Klm . SHAWN CH1LD8 Honorable William R. Wilson United States District Jlldge 600 W. Capitol Suite 149 Little Rock. AR 12201 JoHNW. WALKER,P.A. u Ff LS::D .s. DISTR1\u0026lt;!'rcou M:TOBNXT kt LAW EASTERN DISTRICT RT 1723 B'RoADWAY ARKAN SAS Lrm\u0026amp;Rocx,ARKANSAB 72206 JUL 1 9 2002 TELEPS'ONE (501) 374-3758 FAX (501) 814-4187 JA_M~~q5M , Sy, -,~~aw;..~,~C~LERK~ . T MOcHFECNORUYN PiE.AL. , _ DONNAJ. ~y VI.a Facsbnile: 604--5149 July 19, 2002  8210 HIMl'l!SON BoAD 14:rrt,\u0026amp; Roc:x. ~ 7l!l!l0 PROm: (501) 11n-3426  Fax (501) 372,M28 EliWl-~bell.net 7 l -- ct_..\u0026lt;!L ,. h , . ~))4 \"~ f l)f il)UI-~  ~ dra'I' ~lA lA'L  ~ \u0026lt;J r ) i: CA V\\11 L  _A _1t ,i.,VII\\ ~ ,-A,1/~p ))\\f I , ~,t.\u0026amp;_ ~;;-.;, ,, u9--1 ) _,d.Jfo/'f .A ~ !-+Iv'' \u0026gt;;f/i u C~----aJfl--\\ ~f~i,ll 1 ~l ..,_;;,a,Lv--' i),L{ . ~{' ~'':' 1:,,t--\u0026amp; 1#..\"' v-.\u0026lt;1-Y,~J:v ~1,\u0026lt;, I ,. -~--;\";j))}-tL ffed: ,e-. Y:,. i,..1L '10   1i '\\ tJ,'.Jl.-.- if J?,1 ,uA-a.t.--.;(,~{# ~ '?r.,,/,'P-\" v\" Ct ~ 1'.-c11~u~ Dear Judge Wilsoll! \\,Vw-,.-v' .,/4A, J;-{,t,Jul- \\,~A.A. ~t.U: '  IJ\"'\"t/' One of the witnesses that we listed Ms. Ethel Dunbar~ Principal of Franklin ElementarY  , pit.Q.,,( School has been subpoenaed for the 8,30. July 22, 2002 hearing as directed by the Court. She ;,(c.' (J)l)-M has called me to ask excuse from being present at 8:30 due to State Department of Education }- business at that time. She is scheduled to appear 8$ a witness on Wednesday. I see no probleui n~ L\\. in haVing hor appear on Wednesday other th8n your order. Toe District, l llll1 sure, will alao C'- \"')'. want her exoused if it is also possible. I am therefore writing to request tha1 she be allowed to ., v\"  l..f report on Wedneoda}' momlng, July 24, 2002. ralh\u0026lt;:r than July 22. 2002. ~, \"\"'; Thank you for whatever consideration you may give regarding this request. JWW:lp cc; Honorable J, Thomas Ray Mr, Chris Heller Ms, Ethel Dun.bar 10/10 39'i1d 51,rs RECEIVED JUL 2 2 2002 OFACE OF DESEGREGATION MONITORING UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 600 W. CAPITOL, ROOM 423 LITTLE ROCK, ARKANSAS 72201-3325 (501) 604-5140 BILL WILSON JUDGE Mr. Dennis Hansen Deputy Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201 Facsimile (501) 604-5149 July 19, 2002 BY FAX FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS JUL 1 9 2002 ~~~~ RE: Little Rock School District v. Pulaski County Special School, et al. 4:82CV00866WRW / JTR Dear Mr. Hansen: You may be excused from next week's evidentiary hearing in this case a t - your discretion. cc: The Honorable J. Thomas Ray All Counsel of Record Original to the Clerk Wm. R. Wilson, Jr. RECEIVED Fii ;:~ u ~--.. , EAsrMRsN ?;,ftt1ff co URT ' ARKANSAS f JUL 3 0 2002 IN THE UNITED STATES DISTRICT COURT . JUL 1 r 2~n2 l a_ OFFICEOF 90ESEGREGATION MONITORING EASTE~I;:~c6ii s~NS~:MES w. McCORMACK, CLERK LITTLE ROCK SCHOOL DISTRICT V. NO.-4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO.I, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL MOTION FOR RECONSIDERATION DEP CLE~K PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The Joshua Intervenors respectfully request the Court to reconsider its Order of July 18, 2002 which was faxed to us at the end of the business day, yesterday, July 18, 2002. On the day before, July 1 7, 2002, plaintiffs counsel filed a letter with the Comi by fax, also at the end of the business day, wherein counsel made several objections citing authority for one. The Joshua Intervenors were not afforded an opportunity to respond prior to the Court's Order. The Joshua Intervenors, therefore, object to the Court's entry of an Order on a disputed matter without their having been afforded a reasonable response time to the plaintiffs motion. We note that there are only 30 minutes of rebuttal testimony and evidence at issue here. Joshua notes that the positions of the Office of Desegregation Monitoring (ODM) have been considered vital in the previous deliberations during fact finding proceedings. In the past, the Court Itself has invited the ODM to state its findings on matters which it had monitored. That has been the established procedure in this case for its duration. Joshua counsel acknowledges that the transition from one judge to another will result in some changes in the administration of a case; but Joshua believes that it is fundamental that the role of the ODM be preserved not only in operation but in presentation of the facts which it learns during its monitoring. Joshua proceeds now to address the reasons for the motion herein. 1) Joshua communication with Ms. Ann Marshall before June 21 , 2002 and even since then has been difficult due to personal circumstances of Ms. Marshall. Ms. Marshall's personal situation constitutes \"highly unusual circumstances.\" 2) The Leslie e-mail of July 27, 2001 to Ms. Marshall is a document which the Distiict has had for some time. There is no unfair prejudice to the plaintiff for it to be used by Ms. Marshall during her testimony. We submit that the Court's ruling should be reconsidered because it simply identifies ODM documents. 3) The Court excludes the ODM \"Report on the Little Rock School Districts Preparation for Implementation of its Revised Desegregation and Education Report.\" We note that this report is already a pait of the Court's record. It was filed when it was prepared. Please note the file mark of August 1 1, 1999. The cover sheet was submitted simply for reference by Joshua because the Court already has the entire report. I presume, but apologize for presuming, that the Court was aware that this report was already a pait of the record. [See Par. 5, infra.] 4) The Bonnie Leslie letter of February 21 , 2000 has also been excluded by the Court. We object to the Court's ruling for the reason, supra. The District contends that ODM participated in the evaluations that it made. The letter of February 21, 2000 shows that Leslie invited \"feedback for improvement\" or questions regarding the certain curriculum documents rather than for \"evaluations.\" We request that we at least be allowed to proffer the document with a note that Ms. Marshall may surely testify about the contents therein. 5) The Court excluded the ODM Report of August 26, 1999. This, too, has been filed as a matter of record in this case since August 26, 1999. It is not a new exhibit. The Court has had this exhibit before it now for almost three years. I ask the Court to reconsider its exclusionary ruling because the effect of it is to remove an admitted document from the record. [Underlining added for emphasis.] 6) Finally, with respect to the identified testimony of school board members, the Court precludes all but the testimony of Dr. Mitchell at lines 13-27 on p. 27. We feel that the Court should reconsider this ruling because an issue of good faith is also raised with respect to the issues which were before the Court in the first proceeding. For example, Dr. Carnine testified regarding the subjects in issue. His credibility was a clear issue. Dr. Mitchell and Ms. Strickland were asked questions regarding Dr. Carnine's truthfulness to them as board members. We are entitled to show that either they did not consider him credible or that they would falsify a response themselves rather than give a statement of their experiences with Carnine regarding Carnine's truthfulness. Carnine's truthfulness goes to the District's good faith and to the integrity of the evidence recited in the reports prepared under Carnine's supervision in March of 2000 and 2001. Also, please note, Judge Wilson, that the school board members depositions were taken after we had basically concluded our case on those issues before the Court. We could not have presented it during our case-in-chief because it was not then available. Furthermore, the depositions were before the Court as exhibits before the June 21, 2002 deadline for filing exhibits. The cited lines relate to the issue of good faith with respect to good faith, discipline, student achievement and program evaluations. In conclusion, the Joshua Intervenors respectfully request the Court to reconsider its Order and to modify it accordingly. Joshua also requests that if the Court is inclined to make an instantaneous ruling on a motion by the District that the Cow1 afford Joshua reasonable time to respond before entering an Order. Robert Pressman, Mass Bar 22 Locust A venue Lexington, MA 02421 (781) 862-1955 . r, AR Bar No. 64046 ' JOHNW. WALK.ER, P.A. 1 723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501) 374-4187 (Fax) Rickey Hicks, AR Bar No. 89235 Rickey Hicks, P.A. 1 723 Broadway Little Rock, Arkansas 72206 (501) 3 7 4-3758 (501) 374-4187 (Fax) CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoin/ ~.ha been \"},:,lf and U.S. Mail, postage prepaid to the following counsel ofrecord, on this day of I  , 2002: I Mr. Clay Fendley Mr. Dennis R. Hansen FRlDAY, ELDREDGE \u0026amp; CLARK Office of the Attorney General 400 W. Capitol, Suite 2200 323 Center Street Little Rock, Arkansas 72201 200 Tower Building Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Sam Jones \\\\TRJGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Little Rock, Arkansas 72201 rvir. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Richard Roachell ROA CHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 JUL 2 2 2002 A OFACEOF  DESEGREGATION MONITORING UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, vs. * * * * PULASKI COUNTY SPECIAL SCHOOL * .I)ISTRICTNO. 1, et al., * Defendants, * MRS. LOREN JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors, * * * * * * 4:82CV00866 ORDER u.fo1{fm~cRRr EASTERN DISTRICT ARKANSAS JUL 1 :e 2002 i;,~~-1-r I have reviewed Joshua's motion for reconsideration of the July 18, 2002 order excluding - certain documents Joshua recently identified as exhibits for use with their rebuttal witnesses. First, Joshua points out that the Court entered its order without allowing Joshua an opportunity to respond to LRSD's letter requesting the exclusion of those exhibits. While the Court normally allows opposing counsel an opportunity to respond to an issue before ruling, in this case Joshua had clearly violated the Court's May 15, 2002 Scheduling Order that explicitly required Joshua to identify all exhibits they intended to use during the July 22, 2002 hearing -- on or before June 21 , 2002. In light of that undisputed fact, which was the basis for my exclusion of those proposed exhibits, I saw ( and see) no reason for allowing Joshua an opportunity to respond. Second, Joshua points out that a number of the documents have previously been filed in the record. I was fully aware of that fact at the time I entered my order. However, merely because a - --- - - - - - ---- - ---- document has been filed in the record does not excuse Joshua from complying with the May 15 Scheduling Order. It explicitly required them to pre-mark and exchange with opposing counselall exhibits that it intended to use during the July 22 hearing. Under Joshua's interpretation of the May 15 Scheduling Order, they would be permitted to use, as rebuttal exhibits, any of the thousands upon thousands of documents that have been filed in this case during the last two or three years without identifying and exchange those documents with opposing counsel (marked as exhibits) -- as required by this order. Finally, in connection with the excluded deposition testimony, Joshua has construed the remaining issue of \"good faith\" in far too broad a context. The only good faith issue that remains to be tried in this case is LRSD's substantial compliance with its obligations regarding extracurricular activities, advance placement courses, and guidance counseling. To the extent that Joshua desired to use this deposition testimony, which was known to them before the conclusion of the November 19, 2001 hearing, Joshua should have submitted that testimony as part of its case in chief. Since the trial date is upon us, if either side files a motion, at this late hour, an instantaneous ruling is likely if the motion or request is patently meritorious, as it was in this case. For both parties: The chute is about to open -- get your best hold. IT IS SO ORDERED. Dated this 19th day of July, 2002. THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE o';~9J~J.~; ~~~,o:~ 2 U/f!i;{ [~ U. S. DISTRICT JU~~ UNITED STATES MAGISTRA TE JUDGE J 600 WEST CAPITOL R  THOMAS RAY , OOM 149 LITTLE ROCK, ARKANSAS 72201 PHONE: (501) 604-5230 FAX: (501) 604-5237 FACSIMILE FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS JUL 2 2 2002 RECEIVED JUL 2 3 2002 omcEoF DESEGREGATION MONITORING UNITED STATES MAGISTRATE JUDGE J. THOMAS RAY 600 WEST CAPITOL, ROOM 149 LITTLE ROCK, ARKANSAS 72201 PHONE: (501) 604-5230 FAX: (501) 604-5237 FACSIMILE FROM: \\,..I ~ ,_r\\ - ~ '\\! N't\\ . \\'\\. ~ ' :s Q(\\ FAX No: ~7 4 - L\\ \\ 'o7 / \"3 7lo-2\\47 DA7E: ~ \"'-\\Q 2\\/ 200 2 RECEIVED JUL 2 3 2002 OFRCEOF DESEGREGATION MONITORING RE: ~ ~\\~ '2..2. \\\\~r\\\"A \\..~bb \"' ~ '-s s.:h  No. Ac. ezcv O0 7 _ 2. 7 - D L-- J s,~ PAGES: {ji_JJ,/\\. ~~: } ~vn1.12 J N-'/;\" ~ ,zf:;u- lf!J,V; O-A,J) ~I\\ 1), ~ /_,M-.(,;_p f-t\u0026amp;.w-J!{ 1M.e_ u,_/,,c6i (\\_ ~~ i~!J)_ 1 ~ ,vy\u0026amp;,.~r (a~ tt%/J  ,~A.Vi.,i,\"-'i.t..J J,f.#.,T waf k lJ.bl} tf--l-L/v4J / ,u. ' ~ 1 ,y-JrJ-i {}/wv1.-' 06V1.,l7f-fQ1::;1 . ri 1~. ~ l\u0026lt;.c ~i!l l,vll~ X C : \\../.C1' / ~ 4--(/--r,~ f\u0026lt;-J-,t 1 UNITED STATES MAGISTRATE JUDGE J. THOMAS RAY 600 WEST CAPITOL, ROOM 149 LITTLE ROCK, ARKANSAS 72201 PHONE: (501) 604-5230 FAX: (501) 604-5237 FACSIMILE RECEIVED FROM: 'N~-\"- 'v-J :\\s ~ JUL 2 3 2002 OFACEOF DESEGREGATION MONITORING -FAX ;:.o, 0\\ 4- 4\\~7 / ~llo-Z I '\\7 RE: ~ ::--~ - ?~;- F\"!L %fR1 g,srR,~ D IN THE UNITED STATES DISTRICT CO~T ,srR,cr ~/!:J EASTERN DISTRICT OF ARKANSA~. JUL 2 3 2i sAs WESTERN DIVISION s;MEs w M 'OJ2  ccoRMAc K, CLERK LITTLE ROCK SCHOOL DISTRICT PL V. LR-C-82-866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL RECEIVED JUL 2 5 2002 OFFICE OF DESEGREGATION MONITORING PLAINTIFF'S WITNESS LIST FOR THE JULY 22, 2002 HEARING AS REVISED JULY 23, 2002 DEFENDANTS INTERVENORS INTER VEN ORS Plaintiff Little Rock School District (\"LRSD\") hereby identifies the following witnesses to be called at the July 22, 2002 hearing and provides a detailed statement of their expected testimony: 1. Dr. Bonnie Lesley. Dr. Lesley will testify on Wednesday, July 24, 2002, from I :00 p.m. until 4:00 p.m. regarding the District's compliance with Revised Plan  2.6 (as it relates to advanced placement courses) and Revised Plan  2.6.1 and 2.6.2. Dr. Lesley is the Associate Superintendent for Curriculum and Instruction for the District. Dr. Lesley will testify that the District's efforts to increase African-American emollment in advanced placement courses and to ensure their success in those courses begins as soon as they enter the District. In this regard, Dr. Lesley will review the latest results from the K-2 reading assessments (the third year of the program's implementation and the third year of testing data); describe a recent study conducted by Page 1 of 7 a team in her Division on the academic effects of participation by African-American students in the District's pre-kindergarten program for students now in grades K-8 versus the scores of AfricanAmerican students who did not participate; discuss the District's new writing curriculum for PreK- 12 (which will be ready by the time school starts in fall 2002), its goals related to improved student achievement at all levels, and how it is aligned with the State's curriculum standards and the knowledge/skills required to perform well on the ACT. Dr. Lesley will also discuss efforts undertaken by the District specifically at the secondary level and the results achieved by the District so far. In particular, she will summarize the results of two studies related to the District's advanced courses at the secondary level; discuss the section on \"Advanced Placement Courses\" on p. 36 of the Compliance Report of March 2001 - the summary of activities that resulted in the improved enrollments; especially the emphasis on all students taking a rigorous program of study, including college preparatory courses in the core areas; describe the trend/research for high schools to admit more and more non-traditional students to advanced courses and the benefits derived from those changes in practice, including improved test results, improved ACT scores, improved performance in college, etc.; review the NAACP's \"Call for Action in Education,\" and compare the NAACP's recommendations to the District's efforts; and describe a study that she conducted on class size at the middle and high school levels, including the percentage of small classes that are advanced classes and the percentage of African-Americans who were enrolled in all classes under 20. During her testimony, Dr. Lesley will also address the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Dr. Lesley may also offer other testimony responsive to evidence offered by the Joshua Intervenors during their case. Page 2 of 7 2. Dr. Marian Lacey. Dr. Lacey will testify on Thursday, July 25, 2002, from 10:00 a.m. until 11 :00 a.m. regarding the District's compliance with Revised Plan  2.6 (as it relates to extracurricular activities) and Revised Plan  2.6.3. Dr. Lacey is the Assistant Superintendent for Secondary Schools for the District. Dr. Lacey will testify that the Board adopted policies JB, IBA, IBA-R, JJ, JJ-R, JJIA, JJIB, JJIB-Rl , JJIB-R2, and JJIB-R3 in order to comply with Revised Plan  2.6; that the District increased participation in extracurricular activities 76 percent in the 1998-99 school year and another 26 percent in the 1999-2000 school years; that 62 percent of AfricanAmerican students participated in extracurricular activities during the 1999-2000 school year; that the number of African-American students participating in co-curricular activities increased 9 percent in the 1998-99 school year and an additional 30 percent in the 1999-2000 school year; that a 1999- 2000 parent survey indicated that 90 percent of African-American parents and 93 percent of African- - American teachers thought that activities were open to all students; that the SIP program has helped increase African-American participation in activities; that transportation is provided for all extracurricular activities; that the District has hired Danny Fletcher, an African-American, as Fine Arts Director; and that she is not aware of any barriers to participation by African-Americans in extracurricular activities. During her testimony, Dr. Lacey will also address the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Dr. Lacey may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. 3. Jo Evelyn Elston. Ms. Elston will testify on Thursday, July 25, 2002, from 1 :00 p.m. to 2:00 p.m. regarding the District's compliance with Revised Plan  2.11 and 2.11.1 . Ms. Elston is Director of Pupil Services for the District. She will testify that during the term of the Revised Plan the District adopted policies JB, IBA and JLD; that counselors assist students with Page 3 of 7 their educational, social, personal and career development; that each school conducts a needs assessment every three years and develops a school-based guidance plan; that the District has developed a comprehensive guidance program plan for both the elementary and secondary level; that counselors prepare monthly reports on their progress in implementing the guidance plan; that counselors are to keep a daily log of students counseled; that counselors have been instructed to encourage students to take pre-AP and AP courses; that counselors have attempted to ensure equity in honors, awards and scholarships; that counselors regularly prepare newsletters to notify students of scholarship opportunities, ACT preparation courses, etc.; that counselors provide all students with a written graduation plan; that secondary counselors prepare annual reports; that her office monitors both the monthly reports and annual reports prepared by counselors; that the data on enrollment in pre-AP and AP courses, scholarships and honor graduates suggests that the counselors are doing a - good job; that a 1999-2000 parent survey indicates that counselors are doing a good job; that the Safe School Health Students grant has allowed the Pupil Services Department to provide additional services to students; and that she is not aware of any systemic racial discrimination in the provision of guidance and counseling services. During her testimony, Ms. Elston will also address the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Ms. Elston may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. 4. Sadie Mitchell. Ms. Mitchell will testify from 3:00 p.m. to 4:00 p.m. on Thursday, July 25, 2002, regarding the District's compliance with Revised Plan  2.6, 2.6.2, 2.6.3, 2.11 and 2.11. 1. Ms. Mitchell is the Associate Superintendent for School Services for the District. Ms. Page 4 of 7 Mitchell may offer testimony responsive to evidence offered by the Joshua Intervenors during their case. 5. Baker Kurrus. Mr. Kurrus will testify on Friday, July 26, 2002, from 9:00 a.m. until 10:00 a.m. regarding the District's good faith commitment to comply with the Constitution even if no longer monitored by the Court. Mr. Kurrus is President of the District's Board of Directors. Mr. Kurrus will testify that the Board adopted and/or re-adopted policies during the term of the Revised Plan requiring compliance with the Revised Plan requirements regarding guidance counseling, extracurricular activities and advanced placement courses, that every policy was adopted after being read at a prior Board meeting; that the Board fully expected the administration to comply with its policies requiring compliance with the Revised Plan requirements regarding guidance counseling, extracurricular activities and advanced placement courses; that the administration reported to the Board that it was complying with the Revised Plan requirements regarding guidance counseling, extracurricular activities and advanced placement courses; that a representative of the Joshua Jntervenors was permitted to address the Board whenever requested; that in the 1998-1999 school year, the Board had 23 meetings and no representative of the Joshua Jntervenors addressed the Board; that during the 1999-2000 school year, the Board had 20 meetings and a representative of the Joshua Jntervenors appeared on July 22, 1999 and November 10, 1999; that at the July 22, 1999 meeting, attorney John Walker raised only general concerns; that the Board understood that the Superintendent worked with the Joshua Intervenors to address those concerns; that on November 10, 1999, attorney John Walker appeared to support parents and community members opposed to the closing of Mitchell Elementary School; that the Board agreed not to close Mitchell Elementary School; that during the 2000-2001 school year, the Board had 27 meetings, and the minutes reflect Page 5 of 7 that Joy Springer appeared on behalf of the Joshua Intervenors on January 25, 2001; that on that date Ms. Springer stated that improvements had been made, that there were still some issues to be addressed and that the Joshua Intervenors were hoping to work with administrators and the Board to address those issues; that the Board understood that the administration attempted to work with the Joshua Intervenors to resolve those issues; that the Board expected the Joshua Intervenors to raise in a timely manner any compliance issues which could jeopardize the District obtaining unitary status, either with the Board or pursuant to Revised Plan  8; that the Board agreed to pay the Joshua Intervenors in advance to ensure Joshua's ability to monitor the District's compliance; that Joshua billed the District for monitoring, and the District paid those bills; that the Board never had any evidence presented to it that the District had not substantially complied with the Revised Plan requirements regarding guidance counseling, extracurricular activities and advanced placement - courses; and that the Board adopted the Covenant to demonstrate and memorialize its good faith commitment to the Revised Plan requirements regarding guidance counseling, extracurricular activities and advanced placement courses and the Constitution in the future. Mr. Kurrus may also offer testimony responsive to evidence offered by the Joshua Intervenors during their case. Respectfully    This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. 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