{"response":{"docs":[{"id":"bcas_bcmss0837_1688","title":"Court filings concerning proposed changes to ADE monitoring and reporting responsibilities, districts' undisputed teacher retirement and health insurance damages, and ODM report, ''Racial Composition of the Certified Staff in the Secondary Schools and the Administrators in the Central Office of the North Little Rock School District (NLRSD)''","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["1999-02"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Arkansas. Department of Education","Office of Desegregation Monitoring (Little Rock, Ark.)","North Little Rock School District","Education--Arkansas","Education--Evaluation","Education--Economic aspects","Education--Finance","Educational law and legislation","Educational planning","Education and state","School management and organization","School employees","Education, Secondary","School administrators"],"dcterms_title":["Court filings concerning proposed changes to ADE monitoring and reporting responsibilities, districts' undisputed teacher retirement and health insurance damages, and ODM report, ''Racial Composition of the Certified Staff in the Secondary Schools and the Administrators in the Central Office of the North Little Rock School District (NLRSD)''"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1688"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["76 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"District Court, progress report on proposed changes to Arkansas Department of Education (ADE) monitoring and reporting responsibilities; District Court, motion for an order directing the State to distribute the districts' undisputed teacher retirement and health insurance damages; District Court, memorandum brief in support of the motion for an order directing the State to distribute the districts' undisputed teacher retirement and health insurance damages; District Court, notice of filing, Office of Desegregation Monitoring report, ''Racial Composition of the Certified Staff in the Secondary Schools and the Administrators in the Central Office of the North Little Rock School District (NLRSD)''; District Court, Arkansas Department of Education's (ADE's) response to the districts' motion for an order directing the State to distribute the districts' undisputed teacher retirement and health insurance damages; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool  The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.   STATE OF ARKANSAS OFFIC.KOF rim ATTORNEY GENERAL Mark Pryor Attorney General Ms. Ann Brown Office of Desegregation Monitoring 201 E. Markham, Suite 510 Little Rock, AR 72201 February 1, 1999 Re: little Rock School District v. Pulaski County Spedal School District No. 1, et~ LR-C-82-866 Dear Ms. Brown: RECEIVED FEB 2 1999 Oltl~i 0f  lllltGMIOll110~rroruNs Telephone: (501) 682-2007 Enclosed for your files and information, please find copy of the Progress Report on Proposed Changes to ADE Monitoring and Reporting Responsibilities. cj enclosure Sincerely Carol Robbins Secretary to T101othy G. Gauger Assistant Attorney General 200 Catlett-Prica Tower, 323 Center Street  Uttle Rock, Arkansas 72201-2610 -~--- Internet Website. http://www.ag.state.ar.us/ IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION RECEIVED rtB 2 1999 OfflCEOF OESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS PROGRESS REPORT ON PROPOSED CHANGES TO ADE MONITORING AND REPORTING RESPONSIBnITIES Pursuant to the Court's December 18, 1998 order, the Arkansas Department of Education submits this report on the progress made in developing proposed . changes to ADE' s monitoring and reporting responsibilities. After the issuance of ODM' s report on ADE' s monitoring, ADE, with the support of the State Board of Education, sought to meet with all parties to this action to discuss possible revisions to ADE' s monitoring and reporting requirements that would, among other things, address some of the concerns and criticisms contained in the ODM report. All the parties, including the Joshua and Knight intervenors, were invited and encouraged to participate in the process. As required by the Court, meetings between representatives of ADE and the parties have been documented and described in ADE' s monthly project management tools. The information contained in the monthly PMTs will not be repeated here. However, if the Court desires more detailed information about I - these meetings or would like to review meeting agendas, lists of participants, or correspondence between the parties related to these discussions, ADE will be happy to submit such information or documents to the Court for its review. To comply with the Court's December 18, 1998 order, ADE has prepared the attached Desegregation Monitoring and Assistance Progress Report. A draft of this report was shared with representatives of the parties for review and comment in January of 1999. The Report is intended to be a summary of the recommendations and comments made by the parties to date. As the Court will di.seem from reviewing the Report, the parties have focused their discussion on a plan that, among other things, (a) would provide for continued monitoring by ADE in six areas relevant to the Districts' desegregation efforts; (b) would provide for ADE analysis of selected data; and (c) would include ADE assistance to each District in areas such as staff development, curriculum alignment, and recruitment of minority teachers and administrators.  The attached Report is a work in progress. Many details will need to be discussed and refined by the parties before any proposed new monitoring and reporting plan can be submitted to this Court for approval. ADE intends to continue its meetings with the parties to discuss these issues so that a new monitoring and reporting plan can be presented to the Court as soon as practicable. 2 Respectfully Submitted, MARK PRYOR Attorney General Assistant Atto General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 (501) 682-2007 Attorneys for Arkansas Department of Education CERTIFICATE OF SERVICE I, Timothy Gauger, certify that on February 1, 1999, I caused a copy of the foregoing document to be served by U.S. mail, postage prepaid, on the following person(s) at the address(es) indicated: M. Samuel Jones, III Wright, Lindsey \u0026 Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Roe~ AR 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Roe~ AR 72201 Richard Roachell 401 W. Capitol, Suite 504 Little Rock, AR 72201  3 Christopher Heller Friday, Eldredge \u0026 Oark 2000 First Commercial Bldg. 400 W. Capitol Little Rock, AR 72201 Stephen W. Jones Jack, Lyon \u0026 Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Brown 201 E. Markham, Ste. 510 Little Rock, AR 72201 Desegregation Monitoring Prelimbuuy Progress Report-revised llllUUlrY 21, 1999 Arlwua Dq,art,nenl of Edllcation Desegregation Monitoring and Assistance Progress Report Arkansas Department of Education January 1999 NOTE: The following document summarizes the recommendations, written documents and comments made by district desegregation superintendents, specialized district staff, Office of Desegregation Monitoring, ADE staff and the parties in Pulaski County Desegregation Case. This preliminary progress report is a work in progress. It is intended to be disseminated among interested parties for discussion. comment, review and suggestions during the January 28, 1999 meeting. A revised'aiaft of the progress report shall be forwarded to all parties for review after administrative and Board review. 1 Arkansas Department of Education Desegregation Monitoring and Assistance Progress Report: Preliminazy Drqft-Revised Section I Goal The goal of the Desegregation Monitoring and Assistance is to ensure educational excellence and equity in the Pulaski County School Districts by monitoring, through the Arkansas Department of Education (ADE), the implementation of educational programs, aimed at satisfactorily remediating racial, academic, and achievement disparities. The proposed Monitoring Plan will revise the 1989 Monitoring Plan and formatting directives by eliminating unnecessary, or redundant provisions, reducing the data collection and submission burden on districts, and ensuring that districts remain accountable for commitments made to quality desegregated education. To ensure the integrity of the monitoring reports, the ADE will continue to use the Standards of Educational Evaluation. The Standards for Educational Evaluation define four attributes of sound evaluation: A B. C. D. Section Il The utility of the evaluation to the audience to be served in relation to the problems they face; The feasibility of the evaluation in terms of its efficient use of practical procedures; Propriety, which calls for fair treatment of participants in the evaluation and ethical use of evaluation procedures and findings; Accuracy, which calls for obtaining valid, reliable and objective findings and reporting justified conclusions and recommendations. Purpose Monitoring by the ADE will be closely related to the identified needs and priorities of the school districts so that monitoring becomes an integral part of the accountability function of quality schools and districts. In particular, monitoring will focus on efforts to raise the standard for student achievement and reduce achievement disparities. The monitoring indicators are divided into six sections that are important for a high-quality desegregated educational system: (1) achievement, (2) discipline, (J) staff development and technical assistance, (4) minority teacher recruitment and staffing, (5) financial resources/budget, and (6) racial balance in enr'ollments. The purpose of the monitoring is to provide the means for determining whether the process is meeting its goals: that is to determine how \"on target\" schools are by comparing achieved outcomes with intended ones. Section m Achievement All students will perf onn at grade level by the end of the fourth grade as measured by the State-mandated criterion referenced and nonn-ref erenced assessments. The ADE will analyze achievement on the basic battery of the norm-referenced test, annually and longitudinally. Trends in educational performance will also be provided. The ADE will analyze achievement on the criterion-referenced test annually and longitudinally to help schools determine the most critical areas of need. 2 The ADE will also analyze test scores to determine if racial academic disparities are being reduced. Results of the analysis shall be used by the ADE and schools to:  Increase student performance  Communicate current levels of student performance to school customers  Assist in the orchestration of School Improvement Plans  Focus on reducing achievement gaps between black and white students  Identify group strengths and weaknesses in content areas  Ensure that prescriptive instructional assistance matches student needs  Determine the number of students who reach the proficient level in Math and Reading  Guide decision making about ways to improve student performance. After testing each year, monitors will determine the following: 1. Are plans in place to address areas of academic deficiency? 2. Has the standard of adequate yearly progress been met? 3. Is there significant disparity in the scores of black and white students? 4. Are there more than 50% of the students achieving below grade level in mathematics and reading? 5. How does the school's achievement compare to the state average and to schools with similar demographics? 6. Is student achievement progressively improving? - - Note: Analysis q,fachievement data wi /I be conducted by the ADE and consultants hired by the ADE, -i Section IV Discipline/Disciplinary Disparity Schools shall be organized and operated in a manner that creates safe, secure schools which are most conducive to student learning. The ADE will: 1. 2. 3. 4. Section V Monitor the Annual Discipline Report Summary from each school district to determine if consequences, for the same offenses are consistently applied to black and white students Review the suspension and expulsion rates Examine each school's implementation of their Disciplinary Management Plans to ascertain whether goals and objectives are being met Make recommendations as needed based on educational research, theory and best practice. Staff Development/l'echnical Assistance (Ways the ADE might assist Districts in their efforts to improve academic achievement) The State is committed to assisting with staff development, preparation, and support of educators whose primary focus is on student learning and who possess the knowledge, skills and the commitment to teach to high academic standards. The State will, through the Smart Start and School Improvement Programs assist in the collaborative development of staff development programs that ensure that instructional delivery models are aligned to student needs, state standards, and assessments. The state will also provide staff development based on needs identified as a result of the monitoring process. The ADE will: 1. Monitor the district's evaluation component of staff development 2. Collaborate with the Office of Pupil Personnel in each district in sponsoring professional development aimed at reducing the disparity in minority suspensions and expulsions 3. Assist schools with analysis of assessment results and strategies for improved student perfonnance 4. Provide staff development on ways to recruit, retain and support teacher recruitment of minority teachers . - 5. 6. 7. 8. 9. Section VI Provide staff development to schools through the Smart Start Initiative Assist schools in the alignment of the curriculum with State standards and mandated assessments Provide staff development on researched-based and proven model in reducing achievement and disciplinary disparities with demographics similar to schools in Pulaski County Provide assistance in curriculum and assessment in the identified targeted areas Ensure that the monitoring reports are useful, succinct, readable and understandable, by assisting districts in the use of five essential steps: (1) disaggregation, (2) analyzation, (3) interpretation, (4) communication and (5) utilization of report findings. Recruitment of Minority Teachers 4 The quality of teachers is central to plans dedicated to improving student performance. The three districts in Pulaski County will need to recruit additional teachers, especially minority teachers due to retirement, and attrition. The ADE will remain committed to teacher recruitment through financial assistance for Minority Teacher Candidates, relevant job market information, and through the improvement of standards for teacher certification. The ADE will: 1. Maintain a current list of minority teachers and administrators who are seeking employment. This list should include certification areas, permanent addresses and phone numbers, and dates of availability 2. Review the number of minority teachers hired each year 3. Monitor the number of jobs offered to minority teachers 4. Examine recruitment plans and efforts such as the job fair participation 5. Assess racial balance in staffing by school and content/speciality areas 6. Disaggregate the percent of classes taught by teacher on a deficiency removal plan. - s Section VII Racial Balance in Enrollments The ADE will monitor to ensure that all students have access to a demanding curriculum, high quality instruction, and nourishing classrooms. The ADE will: 1. Monitor school enrollment for racial balance in accordance with court-approved desegregation plans outlined for each district. 2. Review the enrollment of minority students enrolled in advanced placement (AP) and special education programs 3. Evaluate the impact of interdistrict and intradistrict transfers on racial balance 4. Review the enrollment or participation of minority students in special clubs, teams, and activities 5. Analyze average daily attendance 6. Review the completion rate. Note: The ADE recognizes that the Revised Desegregation Plan for the Little Rock Pubic Schools (LRSD), does not require that every LRSD school be racially balance. Additionally, nothing in LRSD 's Revised Plan shall be construed as requiring a particular racial balance at every LRSD school or as obligating LRSD to recruit students to obtain a particular racial balance in every LRSD school. Section VIII Budget The monitoring of finances in the three school districts of Pulaski County will be the same as for all other school districts in the .state except for areas of the budget in which the districts receive financial support unique to the desegregation case. Also, monitoring done by the State in the financial area will be done from the standpoint of what the districts have agreed to do in their respective desegregation plans. Section IX Monitoring Process A The monitoring process shall be conducted to ensure effectiveness of court order remedies and will include site visitations, review of plans, review of statistical and administrative data as well as responses from school personilel, patrons and students. B C. D. 6 Monitoring teams shall be selected by the Director of the ADE. The team shall include ADE personnel and may include Intervenors, and other educational consultants as designated by the Director. Each district shall include in their school improvement plans appropriate objectives to achieve compliance with each court order related to the Agreement and recommendations made by the ADE. The ADE shall monitor annual school improvement plans to determine progress toward achieving educational goals. District plans should provide evidence of compliance with court orders and a process to ascertain progress. Continuous, independent, systematic monitoring and evaluation are processes necessary for assuring and demonstrating the quality of desegregated education. However, each school and district will be encouraged to conduct internal evaluations prior to monitoring by the ADE. No zysteni can achieve its potential and maintain a high level of service ifit does not constantly assess its performance, and modi fr its practices accordingly to ensure internal accountability. Section X Data Collection The ADE will: I . Collect, interpret, evaluate, and report the monitored data in a lucid, understandable manner so that the parties, the Court, the public, and ADE itself will have meaningful information that indicates the progress of desegregation, uncovers new or continuing problems, and points to needed changes 2. Collect, analyze, and interpret selected data annually for every school in Pulaski County 3. The ADE will produce two semiannual reports which are complementary to each other. The primary focus of each report will be achievement and selected monitoring indicators that impact student achievement 4. Examine the internal data collection and dissemination procedures annually with a view toward eliminating the duplicate collection of data throughout the monitoring process ,.~~ 5. Use the desegregation monitoring process to help the Pulaski County schools meet their desegregation commitments and improve student achievement . IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF VS. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL RECEIVED FEB 9 1999 OfflCEOF OESEGREGATIOM MOll1JIIIII MOTION FOR AN ORDER DIRECTING THE STATE DEFENDANTS INTER VENERS INTER VENERS TO DISTRIBUTE THE DISTRICTS' UNDISPUTED TEACHER RETIREMENT AND HEAL TH INSURANCE DAMAGES LRSD, NLRSD and PCS SD (the \"Districts\") for their Motion state: 1. The Districts have reached a compromise and settlement whereby PCS SD agrees to and does hereby withdraw opposition to the State's methodology for calculating the Districts' damages for teacher retirement and health insurance as set forth on the State's Revised Exhibit 504 filed January 19, 1999, subject to the modification set forth proposed in Districts' Briefin Response to ADE's Submission on the Issues of Teacher Retirement and Health Insurance filed August 19, 1998. Docket No. 3 18 7. The Districts' agreement is attached hereto as Exhibit A. 2. As a result of the Districts' compromise and settlement, there is no dispute that the Districts' are entitled to the damages as set forth in Revised Exhibit 504. Accordingly, the Districts' seek an immediate order directing the State to pay to the Districts the amounts shown on Revised - Exhibit 504. The State should be directed to make payment within ten days of entry of the Court's Order or to show cause why payment cannot be made within ten days. 1 3. The only remaining issue for the Court to resolve is whether the Districts' damages should be based on their actual teacher retirement and health insurance costs or the percentage of teacher retirement and health insurance costs paid by the State to other school districts. The State contends that the Districts' damages should be based on their actual costs. The Districts contend that their damages should be based on the percentage of teacher retirement and health insurance costs paid by the State to other school districts. This issue was the subject of the Districts' Brief in Response to ADE's Submission on the Issues of Teacher Retirement and Health Insurance filed August 19, 1998. Docket No. 3187. In addition to the reasons stated therein, the Districts' believe that Section II.F. of the 1989 Settlement Agreement requires that they be paid the same percentage of their teacher retirement and health insurance costs as the average for all school districts in the state. See - LRSD v. PCSSD, 148 F.3d 9556, 964 n.2 (8th Cir. 1998). 4. In addition to their damages as provided for on Revised Exhibit 504, the Districts should be awarded prejudgment interest. 5. The Districts' memorandum brief in support of this motion is hereby incorporated by reference. WHEREFORE, the Districts pray that the State immediately be ordered to pay the Districts the amounts set forth on Revised Exhibit 504 within ten days of entry of the Court's Order or to 1The Districts believe that Exhibit 504 should be revised a second time to reflect better information obtained by the Districts concerning their actual teacher retirement and health insurance costs. The Districts have presented this information to the State for consideration. The Districts reserve the right to present this issue to the Court if no agreement is reached with the State. However, this should not delay the Court's ruling on this Motion. The revised numbers now being proposed by the Districts would increase the Districts damages, and therefore, the State could be ordered to pay any additional damages at a later date. 2 show cause why payment cannot be made within ten days; that the Districts be awarded prejudgment interest on said amounts pursuant to 28 U.S . C.  1961 ; that they be awarded their costs and attorneys' fees expended herein and that they be awarded all other just and proper relief to which they may be entitled. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026 CLARK First Commercial Bldg., Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376-2011 B NOR TH LITTLE ROCK SCHOOL DISTRICT JACK, LYON \u0026 JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 F:IHOME\\FENDLEY\\LRSD\\des-tea-mot-dis.wpd 3 PULASKI COUNTY SPECIAL SCHOOL DISTRICT WRIGHT, LINDSEY \u0026 JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by hand-delivery on thi~day ofFebruary, 1999.  Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm First Federal Plaza 401 West Capitol, Suite 504 Little Rock, AR 7220 I Ms. Ann Brown Desegregation Monitor Heritage West Bldg., Suite 510 20 I East Markham Street Little Rock, AR 7220 I Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 F:IHOMEIFENDLEY\\LRSD\\des-tu-mot-dis.wpd Christopher Heller John C. Fendley, Jr. 4 AGREEMENT AMONG LITTLE ROCK SCHOOL DISTRICT, PULASKI COUNTY SPECIAL SCHOOL DISTRICT, NORTH LITTLE ROCK SCHOOL DISTRICT, JOSHUA INTERVENORS AND KNIGHT INTERVENORS REGARDING TEACHER RETIREMENT AND HEAL TH INSURANCE This Agreement among Little Rock School District (\"LRSD\"), Pulaski County Special School District (\"PCSDD\"), North Little Rock School District (NLRSD), Joshua Intervenors (\"Joshua\") and Knight Intervenors (\"Knight\") regarding teacher retirement and health insurance remedy (the \"Agreement\") is made and entered into on this 8th day of February, 1999. LRSD, PCSSD, NLRSD, Joshua, and Knight shall be collectively referred to as the \"Parties.\" LRSD, PCS SD and NLRSD shall be collectively referred to as the \"Districts.\" WHEREAS, the Parties disagree as to the correct method for calculating the three Pulaski County school districts' damages for the State of Arkansas' violation of the 1989 Settlement Agreement with regard to the teacher retirement and health insurance programs; and, WHEREAS, the Parties have determined that it is in the best interest of all of the Parties to reach a voluntary settlement of their disagreement; NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED: 1. That the Districts' collective damages for the State of Arkansas' violation of the 1989 Settlement Agreement with regard to the teacher retirement and health insurance programs shall be calculated pursuant to the methodology proposed by ADE as set forth in Court's Exhibit 504; 2. That the Parties shall submit to the Court within five (5) days of this Agreement final numbers for the 1996-97 and 1997-98 school years from which the Districts damages may be calculated using the methodology proposed by ADE as set forth in Court's Exhibit 504. The State should be ordered to pay those damages within fourteen days of this Agreement; 3. The State should be ordered to reimburse the district in future years on the same EXHIBIT \"A\" monthly schedule as equalization funding using prior year average participation numbers and current year State minimum required contribution numbers, with adjustments to be made in January and June based on current year actual participation numbers. The State should be ordered to make payments for the 1998-99 school year, within thirty days of this Agreement, as necessary to bring it into compliance with this paragraph. 4. That the total amount  of damages for the Districts as calculated according to the methodology set forth in court's Exhibit 504 shall be distributed each year as follows : 60% to LRSD, 30% to PCSSD and 10% to NLRSD; 5. That the amounts received by each district pursuant to paragraph 3 above shall 9e regarded as the actual amount of each district's teacher retirement and health insurance remedy. 6. This Settlement Agreement does not resolve the question of whether the State should be required to pay the districts 100% of each district's costs for teacher retirement and health insurance or the average percentage of actual costs received by other school districts in the State. That issue is ripe for adjudication by the Court. 7. That LRSD and PCS SD have entered into a separate agreement related to the Pooling Agreement and challenges to the Act 917 funding system which, in part, serves as consideration for this Agreement; 8. That LRSD and Knight have entered into a separate agreement related to teacher pay which, in part, serves as consideration for this Agreement. 9. That this Agreement may not be altered or modified except by written instrument executed by all Parties; and, 2 - - - ----- - - 10. That the Parties have authorized their respective attorneys to execute this Agreement on their behalf IN WITNESS WHEREOF, the undersigned have executed this Agreement this 8th day of February, 1999. Cnristopher Heller Attorney for LRSD Ste Jone~ Att( 'e : NL~f c{ /'. --r-+-'1.-_ v_L_-_--J _Y_ J;v ? .......,.= 1 J lvv. Walker \\ / ttorney for Joshua Intervenors 3 Richard Roachell Attorney for Knight + IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF vs. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL RECEi\\fED DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL FEB 9 1999 OFFICE 0~ DESEGREGATION MONITORING MEMORANDUM BRIEF IN SUPPORT OF MOTION FOR AN ORDER DIRECTING THE STATE DEFENDANTS INTER VENERS INTER VENERS TO DISTRIBUTE THE DISTRICTS' UNDISPUTED TEACHER RETIREMENT AND HEALTH INSURANCE DAMAGES I. Section H.F. of the 1989 Settlement Agreement. The Districts' agreement leaves this Court to decide whether the Districts' damages should be based on their actual teacher retirement and health insurance costs or the percentage of teacher retirement and health insurance costs paid by the State to other school districts. The State contends that the Districts' damages should be based on their actual costs. The Districts contend that their damages should be based on the percentage of teacher retirement and health insurance costs paid by the State to other school districts. This issue was the subject of the Districts' Brief in Response to ADE's Submission on the Issues of Teacher Retirement and Health Insurance filed August 19, 1998. Docket No. 3187. In addition to the reasons stated therein, the Districts' believe that Section II.F. of the 1989 Settlement Agreement requires that they be paid the same percentage of their teacher retirement and health insurance costs as the average for all school districts in the state. See LRSD v. PCSSD, 148 F.3d 9556, 964 n.2 (8111 Cir. 1998). Section II.F. of the 1989 Settlement Agreement provides: The State will not exclude the Districts from any compensatory education, early childhood development, or other funding programs or discriminate against them in the development of such programs or distribution of funds under any funding programs. (emphasis supplied). In affirming this Court's decision in this case, the Eighth Circuit noted, \"This provision may actually fit the present case better than Sections ILE. and ILL., which are the focus of the District Court's opinion and most of the parties arguments.\" Id. While the Eighth Circuit discussed Section II.F. in the liability context, this Court should consider Section II.F. in determining the appropriate remedy. The State's current method for funding the teacher retirement and health insurance programs results in the average school district in the state receiving approximately 106% of its teacher retirement and health insurance costs. Even so, the State proposes to pay the Districts only 100% of their actual teacher retirement and health insurance costs. To pay the districts less than the average amounts to discrimination in violation of Section II.F. Therefore, the Districts' damages should be based on the percentage of teacher retirement and health insurance costs paid by the State to other school districts. II. Prejudgment Interest. The Districts are further entitled to an equitable award to compensate them for the State's delay in paying the Districts' teacher retirement and health insurance costs. As the Eighth Circuit stated in affirming the grant of summary judgment on these issues, \"the districts are entitled to be held harmless against any adverse effect of the funding change.\" Id., 148 F.3d at 968 . The adverse effect on the Districts has manifested itself in many ways, including deprivation of funds -- or the use of 2 funds - to which they have been entitled since 1996. The Districts seek prejudgment interest as a matter of law and equity. The award of \"damages\" here is ancillary to the prospective relief of continued compliance by the State with its teacher retirement/medical insurance obligations under the Settlement Agreement. As such, there is no Eleventh Amendment bar to an award of prejudgment interest. Cf. Hutto v. Finney, 437 U.S. 678, 437 U.S . 678 (1978)(The Eleventh Amendment does not bar an award of attorney's fees ancillary to a grant of prospective relief). 1 Courts have awarded prejudgment interest in similar situations. For example, the Eighth Circuit has held that courts have the power to award prejudgment interest against state defendants under Title VII, notwithstanding that Title VII does not expressly authorize such awards. Winbush V. Iowa, 66 F.3d 1471, 1482-83 (8th Cir. 1995). Cf Reoppell V. Massachusetts, 936 F.2d 12 (1 st Cir.), cert. denied 502 U.S. 1004 (1991)(Eleventh Amendment does not bar award of prejudgment interest against state in action under Veteran's Reemployment Rights Act if, under normal litigation principles and rules of statutory construction, the district court could have been expected to allow prejudgment interest on underlying recovery; it was not necessary that the Act expressly sanction prejudgment interest). The equitable award of prejudgment interest is akin to the enhancement of attorneys' fees to compensate for delay in payment. Indeed, the Eighth Circuit in Winbush relied upon the attorneys' fee holding and rationale in Missouri v. Jenkins, 491 U.S . 274 (1989), in determining that prejudgment interest was proper in Title VII cases. The Jenkins holding and rationale also support 1 The \"no interest\" rule articulated by the Supreme Court in Library of Congress v. Shaw, 4 78 U.S. 310 (1986) is strictly limited to the sovereign immunity of the Federal Government. Missouri v. Jenkins, 491 U.S. 274, 109 S.Ct. 2463 (1989). 3 the request for prejudgment interest by the Districts in the present case. Indeed, in light of the Supreme Court's decision that adjustment of a fee award to account for delay in awarding fees is appropriate and not barred by the Eleventh Amendment, \"ot "},{"id":"bcas_bcmss0837_1697","title":"Court filings: District Court, emergency motion of the Joshua intervenors concerning the payment of attorneys' fees by the Little Rock School District (LRSD)","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)","Joshua Intervenors"],"dc_date":["1997-12-12"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Little Rock School District","Education--Arkansas","Education--Economic aspects","Educational law and legislation","Lawyers","Education--Evaluation","Educational planning","School management and organization"],"dcterms_title":["Court filings: District Court, emergency motion of the Joshua intervenors concerning the payment of attorneys' fees by the Little Rock School District (LRSD)"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1697"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["53 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  I  FILED U.S. DISTR ICT COURT IN THE UNITED STATES DISTRICT COtmTERN DISTRICT ARKANSAS EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION DEC 1 2 1997 LITTLE ROCK SCHOOL DISTRICT vs. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. NO. LR-C-82-866 RECEIVED DEC 1 5 1997 OFFICE OF DEFENDANTS INTERVENORS INTERVENOR Emergency Motion of ~~Wt{-hWNlmifHGrvenors Concerning The Payment of Attorneys' Fees by the LRSD The Joshua Intervenors respectfully move for the entry of an order providing for the payment of interim attorneys' fees by the LRSD to intervenors, periodically, in the manner described at the conclusion of this motion. The purpose of this motion is to ensure that the plaintiff class has adequate representation in the proceeding to consider the proposed, revised plan of the LRSD, and thereafter. This motion is based upon the accompanying memorandum and the following allegations: (1.) The LRSD has filed a motion, which this court has scheduled for a hearing beginning February 2, 1997, seeking approval of a \"Revised Desegregation and Education Plan.\" This plan is 16 pages in length. In contrast, the current plan of the LRSD is approximately 230 pages in length and the Interdistrict Plan is 64 pages in length. (2.) It is the stated purpose of the LRSD, in part, to have 1 / the Revised Plan \"supersede and extinguish\" the current LRSD Plan and the Interdistrict Plan. Revised Plan, at 1. (3.) The Revised Plan is in substantial part and in areas of critical importance merely an outline for a plan, rather than a plan that could be enforced by the court. For example: (a.) In 15 instances, in paragraphs II.B. through II.P, the words \"LRSD shall implement programs, policies, and\\or procedures,\" followed by a particular subject matter, appear. Revised Plan at 1-3. The \"programs, policies, and\\or procedures\" are not identified in the Plan. Compare Rule 65(d), Fed.R.Civ.Pro. (b . ) In Part V. of the Revised Plan, which deals with \"Student Achievement,\" the Plan specifies outcome goals for students in a way making it impossibe to determine the level of mastery intended. See Parts V.B.1.a. (at 8), V.B.2.a. (at 9-10), and V. B. 3. a. ( at 10) . (c.) In Part VII, the Revised Plan addresses a \"Compliance Program,\" without setting forth compliance standards. Revised Plan at 13. (4 . ) The Joshua Intervenors propounded written discovery requests to the LRSD concerning the Revised Plan. See copy of answers attached as exhibit A. One purpose of the discovery was to determine if the LRSD was willing to work with the Joshua Intervenors to render Part II. of the Plan, addressing \"Obligations,\" more specific. The LRSD made a nonresponsive answer to this query. Interrogatory 4 at 3. 2 /  (5.) One purpose of the discovery was to secure the identification of the underlying \"programs, policies and procedures\" which would appear to be determinative of the efficacy of the plan with regard to the plaintiff class. The answers to written discovery indicate that to a substantial degree, the underlying materials have not been identified. See Interrogatories 2, 18, 19, 20, 21, 22(i), 23, 27, 30. (6.) One purpose of the discovery was to identify the reason or reasons why in many instances the proposed plan did not identify the particular programs, policies or procedures to be implemented. The LRSD responded that \"LRSD believes, in order for the Revised Plan to be successful, the details related to implementation of the revised plan must be subject to modification without district court involvement.\" Interrogatory 3. In responding to an interrogatory about school construction, the LRSD again indicated its intent to have the power to define and redefine standards determinative of the value of the revised plan for the plaintiff class. Interrogatory 23. (7.) The LRSD seeks the approval of a new plan which is vague and standardless in many important respects, and designedly so, in a context in which the court and ODM have, over the years, found the performance of the agents of the LRSD in implementing the court-approved agreements to be deficient. See, for example, the court's statement to the LRSD school board members in March 1993; Mem. and Order, March 11 , 1996, at 8 (\"The LRSD has frequently exhibited indifference or outright recalcitrance 3 I  . ' towards its comitments and has been slow to implement many aspects of its agreements although some improvements have been made.''); Transcript June 23, 1995, at 34, 72, 87; July 6, 1995, at 123-24, 176-77, 241. (8.) In view of the foregoing allegations, it is reasonable to characterize the activities of the Joshua Intervenors in responding to the Revised Plan as protecting the extensive relief, previously agreed upon and approved by the courts. However, the relief sought in this motion is appropriate whether or not the court agrees with the foregoing position regarding the proposed Revised Plan. (9.) Assuming for the purposes of this motion the existence of the agreement on future fees found by this court in its Memorandum Opinion and Order, September 25, 1996, at 6-7, the agreement dealt with \"the life of the settlement plans ... \" (Chachkin); see also Mr. Heller (\"in our settlement plans\"). The activities of the Joshua Intervenors to date and in the future, with reference to the Revised Plan which would \"supersede and extinguish\" the LRSD and Interdistrict plans, are outside the parameters of the agreement found to exist by the court. Therefore, the Joshua Intervenors should be permitted to secure fees and costs for such work, and other work related to the Revised Plan, in accord with the standards last discussed by the Court of Appeals for the Eighth Circuit in Jenkins v. Missouri, 115 F.3d 554 (1997). (10.) Assuming for the purposes of this motion the existence 4 I' of the agreement on future fees found by this court in its Memorandum Opinion and Order, September 25, 1996, at 6-7, it is appropriate, in the totality of the circumstances of this case, to modify the agreement to delete the limitation on fee awards in the post-judgment phase of this case [see Appeal of the LRSD, 949 F.2d 253, 258 {8th Cir. 1991)], thereby restoring the applicability of the standard discussed in Jenkins v. Missouri. supra. The agreement will have been in force for seven years, during which an extraordinary amount of activity by the representatives of the Joshua Intervenors has been necessary, both in and out of court, much due to the deficient performance of the agents of the LRSD. This deficient performance has often been noted by this court, as evidenced by the examples cited above. See also Transcript, August 19, 1996, at 102. In addition, the continuation of the agreement will undermine the ability of the Joshua Intervenors to adequately represent the class. See the attached Affidavit of John W. Walker. (11.) Considerable work will be necessary in connection with the consideration of the Revised Plan, including responding to voluminous written discovery requests submitted by LRSD to intervenors' representatives. In addition, the LRSD proposal is for the Revised Plan to take effect eight months hence and to be in effect for at least three school years. {12.) This court has the authority to provide for an interim .award of fees and litigation costs, particularly when needed to protect the functioning of the private attorney general concept. 5 --- -- - -----  (13,) With regard to the hourly rates sought for the work of the representatives of the Joshua Intervenors, as noted in the prayer for relief below, see the following materials previously filed: John W. Walker -- Fee Petition, Nov. 21, 1995, Aff. of John w. Walker, at 1-7, 12-14; Supplemental Response of the Joshua Intervenors, Aug. 29, 1996, at 7 and Enclosure Two; Robert Pressman -- The Joshua Intervenors Motion for an Award of Attorneys' Fees (Sept. 1996), Sept. 27, 1996, Declaration of Robert Pressman and Attachments; Joy C. Springer -- Fee Petition, Nov. 21, 1995, Affidavit of Joy C. Springer, at 1-5, 19-20. WHEREFORE the Joshua Intervenors respectfully pray that the court enter an order: (a.) declaring that the work of the Joshua Intervenors' representatives concerning the Revised Plan is outside the scope of the agreement, previously found to exist by the court, limiting fee awards; (b.) declaring that the agreement of the Joshua Intervenors and the LRSD is modified, pursuant to the .court's authority to modify a consent decree, by eliminating the limitation on fee awards in the postjudgment stage of this case (with the understanding that the general standard governing fees at the postjudgment stage of a case will then apply); (c.) providing that the LRSD pay the Joshua Intervenors' representatives monthly their reasonable fees and costs, upon submission of adequate documentation, with the court available to rule on any portion of a request considered by the LRSD to be 6 outside the bounds normally governing fee awards; (d.) providing that the fees be paid at the following rates: John w. Walker ($ 250 per hour), Robert Pressman ($ 200 per hour), and Joy c. Springer($ 50 per hour); and (e) providing that the LRSD shall have the right to request the court to reconsider the procedure detailed in (c.) and (d.) after it has been in operation for 12 months; (f) providing such other and\\or different relief as the needs of justice may require. Robert Pressman MA 405900 22 Locust Avenue Lexington, MA 02173 617-862-1955 W. Walker AR 64046 W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing pleading was sent via United States mail on thi D e 1997 to all counsel of record and sent via counsel for LRSD. 7 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. RECEiVED DtL 1 5 1997 I, John W. Walker, a.ffiant herein, state under oath the following: FLED U.S. DISTRICT COURT EASTERN DISTrllCT ARKANSAS DEC 1 2 1997 JAMES W. McCORMACK, CLERK Bv: PLAINTIFF = -~ t:lEP.eLE1:111: DEFENDANTS INTERVENORS INTERVENORS 1. A majority of the cases being handled by my office are in the nature of civil rights litigation. 2. The clients in these cases are usually not fee paying clients whereby this office could on a regular basis bill them for our services. There are in such a practice unexpected losses, such as when the entire fee in the Judy Smith case was lost due to the bankruptcy of Harvest Foods. 3 Many of these cases are handled on a contingency fee basis thus causing the office to utilize a substantial amount of the fees collected on other cases to be a basis for support of these cases. 4. In the case ofLRSD, when the Eighth Circuit awarded fees to be paid in the case herein, a substantial amount was paid to the Legal Defense Fund (LDF) and to the estate of Wiley Branton, Sr. who had worked on this case for many years. Moreover, a substantial amount of the fee award was expended for expenses incurred in connection with the litigation herein. Furthermore, because of the taxing accounting method for purposes of making payments to the Internal Revenue Service (IRS), and the Department of Finance and Administration (DFA), large amounts of the Little Rock portion of the fee award were paid in that year or the next for federal and state income taxes. S. The costs of the representation of the class are enonnous and involve fees and costs to staff who monitor the case and who assist class members in their efforts to secure or retain rights believed by counsel to be afforded by the settlement. 6. The present scheduled hearing involves considerable preparation time including discovery, costs of extensive depositions from the two superintendents and five major level administrators and response to the substantial set of interrogatories propounded to the plaintiff class. This time and expense involvement comes during the period of the holidays, the end of the year, and the beginning of of the new year, when there is a need for attention, not only to legal presentation, but also to the overall business. It also comes at a time when the Pulaski County Special School District (PCSSD) is launching a serious attack upon the court approved settlement plan and is seeking to be declared unitary .. 7. In order to provide the court with insight into the plaintiff, LRSD's, tactic to overburden an already weakened office (no fees for more than $1,000,000.00 worth of work over a seven year period), the Friday firm proposes to take depositions of our representative simultaneously with our deposing the Superintendent and the staff. A response to that undertaking takes considerable time and effort. It distracts from inquiry into the plan. It also comes at a time when we still have our monitoring obligations which become more time consuming as the semester end approaches, based upon past experiences. Moreover, we are further handicapped because of the fact that we do not have the benefit of the usual Office of Desegregation Monitoring (ODM) reports for the past eighteen (18) months which would reflect the current or ongoing status of the LRSD's implementation of the desegregation plan. 8. The class stands to be adversely affected if our preparation for and participation in the February 2, 1998 hearing is not adequate. As it stands now, although the public belief is to the contrary, a fee drought for seven years from this case leaves us unable to meet the efforts of defense - counsel, supported by unregulated and unlimited funds, in an effort to defeat the very plan which they bugled in 1989 before the Court and the 8th Circuit. I have read the foregoing statements and they are true and correct to the best of my knowledge information and belief. SUBSCRIBED and SWORN before me this ~day of December, 1997.  ()fa a' Poivelx  Ex h; h,t A IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. vs. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PLAINTIFF LRSD'S ANSWERS TO PLAINTIFF:S DEFENDANTS INTERVENORS INTERVENORS THE JOSHUA INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LRSD'S MOTION FOR APPROVAL OF THE REVISED DESEGREGATION AND EDUCATION PLAN Plaintiff Little Rock School District (\"LRSD\") for its Answers to The Joshua Intervenors' First Set of Interrogatories and Requests for Production of Documents states: INTERROGATORY NO. 1: Please state the name, title, address and telephone number of each and every individual assisting in the preparation of the answers to these interrogatories. ANSWER: Objection. This inte~rogatory requests information which is privileged under the work product doctrine and/or the attorney-client privilege. Without waiving this objection, LRSD states that the following persons assisted in the preparation of these answers: Dr. Les Carnine, Christopher Heller and John c. Fendley, Jr. INTERROGATORY NO. 2: In 15 instances in paragraphs II. B. through II. P. of the proposed new plan, the words \"LRSD shall implement programs policies and/or procedures\" followed by a particular subject matter appear. Please identify separately for OEC5S97 7 each ot these 15 paragraphs all programs, policies and procedures  which you maintain ar~ currently implemented and are intended to be encompassed by the reference in the particular subparagraph of Pa~t II. of the proposed plan. In addition, please specify when the implementation of the particular program, policy or procedure began. Lastly, as to each sub-paragraph, please indicate whether work is underway to develop a particular program, policy or procedure to implement the obligation and, if so, describe generally the nature of the initiative(s) and the anticipated completion date(s).  ANSWER: Except as otherwise provided in LRSD' s Revised Desegregation and Education Plan (\"Revised Plan\"), the obligations set forth in Section II were not intended to encompass any particular implemented. program, policy and procedure currently being As stated in Section XI of the Revised Plan, the 1997-98 school year will be a transition year in preparation for implementation of the Revised Plan during the 1998-99 school year. During the transition year, LRSD will be evaluating current programs, policies and procedures and developing new programs, policies and procedures to be implemented in order to meet its obligations under the Revised Plan. Some of this work has already been completed and is contained in the work team reports submitted to the LRSD Board of Directors in August of this year. INTERROGATORY NO. 3: Please explain the reason(s) that the proposed plan does not include in the 15 instances referred to in Interrogatory No. 2, or in any instance, the identification of the 11-.\"\"'4..,._jo,I,._ 2  particular programs, policies and procedures to be implemented. (If LRSD believes that there is identification of a particular standard in one or more instances, please answer as to obligations where you agree that there is no identification of a particular standard or program). ANSWER: The Revised Plan includes specific programs, policies and/or procedures with regard to student assignments (Section III \u0026 IV), African-American academic achievement (Section V), equitable allocation of certified personnel (Section VI) and compliance (Section VII). With regard to the remaining obligations, LRSD believes that, in order for the Revised Plan to be successful, the details related to implementation of the Revised Plan must be subject to modification without district court involvement. LRSD firmly believes that flexibility is essential to instilling in the  qistrict a_ sense of responsibility and accountability. INTERROGATORY NO. 4: Would the system refuse to support adoption of the revised plan if the plan included the identification of particular programs, policies and/or procedures, or other steps, to implement the \"obligations\" identified in Part II? If so, explain the reason(s) for the system's position. ANSWER: The Revised Plan does identify particular programs, policies and/or procedures. See Answer to Interrogatory No. 3. INTERROGATORY NO. 5: Do you agree that as written, there would be compliance with the provisions of II.B. through II.P. of the proposed plan if the system implemented, as to the particular sub-paragraph, programs QI: policies QI: procedures regarding the ~11..a\\lonl~-- 3 I I I I \\  particular matter addressed in the paragraph. If the answer is negative, please explain the basis for the answer. ANSWER: Yes. INTERROGATORY NO. 6: As the plan is written, would the court have the authority, in the opinion of the LRSD, to hold a system official (s) (sic) in contempt of court for failure to implement a term of a particular policy of the district, which the LRSD views as encompassed by one of the sub-paragraphs in II.B. through II.P. of the plan, but which is not specified in the plan. If your answer is in the affirmative, please explain the basis f~r the answer. ANSWER: Objection. This interrogatory calls for the lega1 opinion of counsel for LRSD which is privileged under the attorneyclient privilege. Without waiving this objection, LRSD states that the district court would have authority to enforce the Revised Plan using its contempt power. INTERROGATORY NO. 7: As the plan is written, does any provision of paragraphs II.B. through II.P. of the plan require any action on the part of the LRSD if at a particular school there is substantial racial disparity, atypical in the LRSD system, in the numbers of black students suspended, the numbers of black males placed in special education classes, or the numbers of black students in the gifted and talented program. If the answer is affirmative, please identify the provision(s) which is the basis of the answer. 4 \\ ANSWER: Paragraphs G., H. and I. of Section II state LRSD's I obligations with regard to special education, student discipline and gifted and talented, respectively. Compliance with the~e paragraphs would require LRSD to investigate a racial disparity which varies substantially from what would be expected. INTERROGATORY NO. 8: Do you maintain that the .LRSD complies, currently, with each obligation set forth in Part II. of the plan. If not, please describe in detail the area(s) of noncompliance. ANSWER: The obligations set forth in Section II encompass the core obligations from LRSD' s current desegregation plan. LRSD maintains that it has substantially complied with its current desegregation plan. INTERROGATORY NO. 9: With respect to II.B. of the proposed plan, please identify as to each category of positions to which it applies, the proportion black in the relevant labor market and the source of this information, and the proportion black of the work force at present. ANSWER: LRSD intends to rely on federal EEOC statistics for Pulaski County, the State of Arkansas and the nation as a whole to determine the percentage of qualified African-Americans in the relevant labor market. With regard to the proportion of AfricanAmerican teachers and administrators, see Exhibits A, B and C attached. LRSD's noncertified personnel is 73.8% African-American. INTERROGATORY NO. 10: With respect to II.C. of the proposed plan, please identify as to each category of positions to which it applies, the meaning of the words \"the pool of candidates eligible 5 for promotion\", the proportion black in that pool and the source of  the information, and the proportion black of the persons employed in the category at present.  ANSWER: The \"pool of candidates eligible for promotion\" includes current employees who satisfy all eligibility requirements imposed by law or by the Board for a position. LRSD objects to identifying every position for which every employee is currently eligible for promotion as unduly burdensome. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 11: With respect to II.D. of the proposed plan, please identify the positions covered within the term \"certified personnel\" and provide as to each category the number of persons currently employed in the LRSD by race . ANSWER: \"Certified personnel\" are LRSD employees who must possess teaching or administrative certificates issued by the State of Arkansas in order to hold their position. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 12: With respect to II.E. of the proposed plan, please identify any category of certified personnel where the LRSD does not have the right to assign personnel for the good of the system and the basis of the limitation. ANSWER: See Articles XV through XVIII of the PN Agreement, attached hereto as Exhibit D, and the Arkansas Teacher Fair Dismissal Act. 6 \". INTERROGATORY NO. 13: With respect to II.H. of the proposed e plan, please describe in detail any specific initiative(s) in the LRSD a.t present, whether involving particular personnel, or standards, designed to guard against black students' receiving discipline for conduct for which white students are not disciplined, black students' receiving discipline for trivial matters, and/or black students' receiving more severe discipline than white students for similar conduct. ANSWER: LRSD expects all of its students, regardless of race or socioeconomic background, to comply with the Student Rights and Responsibilities Handbook. If a student fails to comply, the student will be disciplined as provided in the Handbook. Discipline information including the race of the student, the race of the administrator, the nature of the offense and the sanction imposed is compiled by the schools and maintained by LRSD. LRSD's Associate Superintendent for information in an attempt discrimination. Student Discipline reviews this to identify possible racial INTERROGATORY NO. 14: With respect to II.I. of the proposed plan, please define, with specificity, the word \"qualified,\" as it applies to each of the three areas discussed in the obligation; namely \"extracurricular activities\", \"advanced placement courses\", and \"gifted and talented\" programs. ANSWER: The phrase \"qualified African-American students\" means African-American students who satisfy the eligibility criteria for an activity or program. For many activities and 7  programs, there are eligibility criteria other than student interest. INTERROGATORY NO, 15: With respect to II.J. of the propos~d plan, does LRSD agree that as written the system would be in compliance with this provision if the system continued to implement any two programs with its federal Title I monies to improve the academic achievement of African-American students. If not, lease (sic) explain the basis for the disagreement. ANSWER: No. LRSD must also implement the programs, policies and/or procedures set forth in Section V of the Revised Plan. INTERROGATORY NO. 16: With respect to II.L. of the proposed plan, please define the terms \"equitable allocation,\" \"technological resources,\" and \"educational resources.\" Also, please identify any data source allowing a determination of whether these resources are equitably allocated to LRSD schools at present. ANSWER: The phrase \"equitable allocation\" means to allocate based on need and without bias or favoritism. The term \"technological resources\" means up-to-date computer and information technology. The term \"educational resources\" includes teachers, teacher aides, equipment and supplies. With regard to a data source for determing whether these resources are currently equitably allocated, see the technology work team report, the individual school profiles and the LRSD budget. INTERROGATORY NO. 17: With respect to II.M. of the proposed plan, please define the term \"equitable\" and identify the matters encompassed in the terms \"maintenance and repair.\" In addition, 8 ., . please identify any source of data available to -ascertain compliance with this obligation on a school-by-school basis. ANSWER: The term \"equitable\" means based on need and witho~t bias or favoritism. The terms \"maintenance and repair\" include the routine upkeep of the building and grounds and the repair or replacement of elements of the building and grounds which are no longer functional. LRSD maintains records which would indicate maintenance requests submitted by schools, the priority assigned to those requests and when and if those requests were acted upon. INTERROGATORY NO. 18: With respect to II.N. of the proposed plan, please identify any specific initiatives currently undertaken in the LRSD to ascertain whether or not guidance or counseling services provided to African-American students involve steering to a restricted range of courses and/or postsecondary educational opportunities. ANSWER: LRSD recognizes that African-American students are underrepresented in upper-level courses and has implemented strategies to address that issue. Specifically with regard to guidance and counseling services, LRSD has requested a National Science Foundation grant to fund training modeled after TESA and EQUALS to assist counselors in motivating African-American students to take the courses necessary to later be successful in upper-level science and math courses. INTERROGATORY NO. 19: With respect to II.O. of the proposed plan, does LRSD maintain that this subparagraph adds anything to 9 other obligations of the plan. If so, please describe with specificity what it adds. ANSWER: Yes. The obligations in Section II should be interpreted consistent with Paragraph o. INTERROGATORY NO. 20: With respect to II. P. of the proposed plan, please set forth the number of persons the LRSD plans to assign on a full-time basis to compliance/monitoring activities and the categories of positions to be staffed. In addition, please describe any steps to insure that the make-up of the staff includes a substantial number of African-American persons and any role which LRSD is willing to give the representative of the Joshua Intervenors in the selection of this staff. ANSWER: These decisions have not yet been made. INTERROGATORY NO. 21: With respect to III. A. 1. of the proposed plan, please identify any document , and any existing analysis stored in any other manner projecting school make-up by race if the steps described in this subparagraph are implemented. If any such data does not currently exist, please describe how such a projection could be done with data and resources available to the LRSO. ANSWER: LRSD is currently working with Edulog software to project school make-up under scenarios consistent with Section III of the Revised Plan. INTERROGATORY NO. 22: With respect to III. B. I.-5 of the proposed plan, please: (i) identify all written standards governing these transfers and (ii) describe any unwritten practices governing flllaN\"\"-1'\"711 ....... ,...._ 10 one or more of these transfers. (iii) In addition, please define the concepts of \"capacity limitations\" and \"reasonable requirement\" identifying any designations of schools capacities to be utilized. (iv) In addition, please explain the language \"a special need arising out of circumstances unique to a particular student\" by reference to the circumstances of youth receiving such transfers in 1997-98 and explain who does and who would decide that the requisite circumstances exist. (v) Lastly, please identify the numbers of students by race utilizing each category of such transfers in 1997-98. ANSWER: (i) No additional standards have been developed beyond what is contain in the Revised Plan. (ii) None. (iii) A school's capacity is a function of the physical plant and the educational programs being implemented at a school. At this time, LRSD is using the school capacity numbers attached hereto as Exhibit E. The \"reasonable requirements\" described in subparagraphs 1 through 5 of Section III.B. relate to procedural requirements which may be imposed by LRSD to ensure that student assignment occurs in a timely and efficient manner. ( iv) Special circumstances transfers as described by the Revised Plan are currently handled through an appeals committee composed of five members with individual members selected by the LRSD Board of Directors, the Biracial Committee, the PTA Council 11 and the Little Rock CTA. The committee reviews requests for transfers based on geographic isolation, racial isolation, medical hardship and other extenuating circumstances. This committee was established by the Tri-District plan and has been continued by LRSD under its current plan. (v) Records concerning transfers will be made available upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 23: With respect to III. E. of the proposed plan, please identify any potential sites for the school in west Little Rock, including any sites set forth in any study. In addition, please state whether the LRSD envisions the court's approving the site prior to its final approval. ANSWER: No potential site has been identified. Although LRSD anticipates keeping both the court and the parties informed about the site selection process, the site would not have to be approved by the court except as provided in Section IX.B. of the Revised Plan. INTERROGATORY NO. 24: With respect to IV.E. of the proposed plan, please describe any existing agreements, standards, and practices relating to cooperative efforts of the LRSD and PCSSD. ANSWER: See Interdistrict Desegregation Plan. INTERROGATORY NO. 25: With respect to V.B. and C. of the proposed plan, please (i) identify the author or authors of the provisions, committees and entities, designating the provision or provisions associated with each such author; ( ii) identify any document(s) providing further explanation of any provision(s) of r:--~Jooh.- 12  the proposal; (iii) regarding parts B.l.a., B.2.a., and B.J.a., I please identify any standards describing the level of competency envisioned in each instance and how it would be assessed; is developing the standards and the general timelines for that effort; and (iv) regarding these three parts of the plan, please state whether LRSD plans to have students satisfy a test requirement prior to moving to the next grade; if the matter is not decided, but such a requirement remains an option, please indicate. ANSWER: See curriculum work team report. INTE "},{"id":"bcas_bcmss0837_1685","title":"Court filings: District Court, Joshua intervenors' opposition to the Pulaski County Special School District (PCSSD) petition for release from federal court jurisdiction","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)","Joshua Intervenors"],"dc_date":["1997-12-02"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Pulaski County Special School District","Education--Arkansas","Education--Evaluation","Education and state","Educational law and legislation","Educational planning","School management and organization","School districts","School integration"],"dcterms_title":["Court filings: District Court, Joshua intervenors' opposition to the Pulaski County Special School District (PCSSD) petition for release from federal court jurisdiction"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1685"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["21 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  FILE6 U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. DEC 4 1gg7 [)gC O 2 1997 DEFENDANTS INT ERVEN ORS KATHERINE W. KNIGHT, ET AL. UJ:il~Of INTERVENORS ~ ION MONITORING The Joshua Intervenors' Opposition to the PCSSD Petition for Release From Federal court Jurisdiction A. Introduction The PCSSD has moved for a declaration of \"unitary status\" and the system's \"release from further court supervision.\" Petit., October 14, 1997, at 1. Subsequent to the filing of the motion,  _this court scheduled the matter for a hearing beginning on March 23, 1998. This memorandum discusses the standards applicable to the PCSSD motion and the showings made by the PCSSD regarding various elements of the system. In brief, the PCSSD errs with regard to the governing standards; moreover, if the district's presentation during the hearing mirrors the one made in the petition, the PCSSD will not be entitled to the relief sought. Indeed, the deficiencies of the Petition are such that it is appropriate to rescind the notice of a hearing and to deny the motion as was done in the case of a more detailed motion for termination of jurisdiction filed by the LRSD. See Mem. Opin. and 1 Order, Sept. 23, 1996, at 9-12. Consideration and resolution of the petition requires the parties and the court to address at least four areas: first, there is a need to designate the standards which identify both the areas of the system's operation to be evaluated and the criteria for the evaluations; second, there is a need to identify the extent (or degree) of compliance to be required in each area before jurisdiction is relinquished; third, there is a need to identify the party having the burden of proof to establish the requisite degree of compliance (or noncompliance); and fourth, there is a need to apply the foregoing principles. Intervenors' response addresses each area. A 14-page Attachment to this memorandum quotes many key elements of the desegregation plan of the PCSSD (April 1992) and the Interdistrict Plan {April 1992). These plans, we argue, rather than the so-called Green factors, as such, must be the focal point in the resolution of the PCSSD motion. To facilitate analysis of the issues presented by the petition, the Attachment clusters the provisions of the two plans by topic, rather than simply by page number. The Attachment is cited throughout this memorandum. The Joshua Intervenors argue below that the PCSSD has the burden of establishing a basis for the termination of supervision 2 in each area. However, ,intervenors do plan to undertake extensive discovery regarding compliance with the plans in the PCSSD. B. The Governing standards (1.) The Terms of the Plans Provide the Substantive standards for Evaluating the operation of the Pesso The PCCSD focuses upon the six areas mentioned by the supreme Court in Green v, county School Board, 391 u.s. 430, 435 (1968). See, for example, Petition at 4-5;  7-34. 1 In contrast, there is but a single, general reference to the Interdistrict Plan (Petit. at 7) and almost all of the small number of references to the 1992 PCSSD desegregation plan are in the form of terse assertions, without page citations. Ig. at 7, 9, 31, 33- 37; but see .ig. at 11 (single reference to page number in the plan). The citations to the significant provisions of the 1992 - PCSSD and Interdistrict Plans are obviously incomplete, as a reading of the Attachment shows. Moreover, the PCSSD approach is out of focus. Scores of rulings of the Court of Appeals for the Eighth Circuit and this court establish that the settlement plans, approved by this court by Order of May 1, 1992, must be the focal point in resolving the motion. 2 Intervenors next cite 1 In Green, the Supreme Court wrote in part: \"Racial identification of the system's schools was complete, extending not just to the composition of student bodies at the two schools but to every facet of school operations -- faculty, staff, transportation, extracurricular activities and facilities\" (at 435). 2 Indeed, the PCSSD recognizes this, in effect, by the very last part of its brief requesting this court to retain jurisdiction until \"enforcement of the Settlement Agreement\" is complete. Petit. at 44 n.5. See also LRSP y. PCSSD, 83 F.3d 1013, 1017, 1019 (8th Cir. 1996) (in appeal involving state payments 3 examples evidencing this aspect of \"the law of the case.\" In the oft-cited December 1990 opinion, the Court of Appeals directed this court to approve the \"settlement plans and settlement agreement as submitted by the parties.\" LRSP v. PCSSD, 921 F.2d 1371, 1376. The court stated that it was \"important for the settlement plans to be scrupulously adhered to ... \" (.i.g. at 1386) and alluded, similarly, to the parties' \"scrupulously and diligently carry[ing] out the settlement plans and the settlement agreement .... 11 .Ig. at 1394. Lastly, the court \"instructed\" this court \"to monitor closely the compliance of the parties with the settlement plans and the settlement agreement, [and] to take whatever action is appropriate, in its discretion, to ensure compliance with the plans and the agreement .... \" .Ig. at 1394, para. 8; emphasis added. The appellate court in 1991 set forth standards governing modifications to the settlement documents. It stated that \"[t]he 1989 settlement ... should indeed be a benchmark for the future path of this case.\" Appeal of Little Rock school District, 949 F.2d 253, 255; emphasis added. The court wrote that \"[t]he desegregation obligations undertaken in the 1989 plan are solemn and binding commitments. The essence and core of that plan should not be disturbed.\" I.g. at 256. Lastly, the court identified \"crucial\" \"elements of the 1989 plan\" \"with respect to which no retreat should be approved.\" .Ig. These include \"the agreed effort for workers' compensation claims and other matters, .court twice notes that PCSSD and LRSD .base their arguments on the terms of the Settlement Agreement). 4 to eliminate achievemel'}t disparity between the races\" and \"appropriate involvement of parents.\" .Ig. 3 Other pertinent guidance appears in the Court of Appeals' opinion concerning the PCSSD teacher strike issue. There, the court wrote that \"[t]he job of [this court] is to enforce the settlement agreement.\" Knight v. PCSSD, 112 F.3d 953, 954. The court added: \"Because this case has been settled, the settlement agreement becomes, in a sense, a particularization of federal law applicable to these parties.\" .Ig. at 955. Two examples from this court's many rulings support the Joshua Intervenors' contention that the court-approved settlement documents provide, with regard to substantive terms, the \"benchmark [at this stage] of this case.\" As previously noted, this court in a lengthy May, 1992 order, containing no reference to Green, approved the various desegregation plans, as modified.' The court's understanding of the significance of the plan provisions emerges from the following excerpt from that ruling. Special Education (PCSSD) .... While the Court approves the addition of new language regarding the relationship between social 3 It is noteworthy that the seven elements as set forth by the court are a combination of activities designed to attain an objective (or goal) and objectives\\goals. 'This action rendered the defendants subject to the possibility of a contempt sanction for the violation of a plan provision containing specific obligations. See Transcript of hearing of July 6, 1995, at 176-77 (court refers to then pending hearing on intervenors' motion to hold officials of the LRSD in contempt for plan violations). 5 deprivation and disproportionality in special education, the original language regarding long-range goals must remain in order for the Court to monitor progress toward the goal of reducing achievement disparity between the races and reducing over representation of black students in special education classes. [Order, 5-1-92 at 7-8] This court's decision of September 23, 1996, denying a similar motion of the LRSD \"to end federal court jurisdiction,\" is also noteworthy. The court first addressed an LRSD contention that its commitment to implement \"the desegregation plan\" was limited to a six year period, assuming adequate implementation. The court rejected this contention, noting that \"[t]he LRSD ... cites no provision that its duty to comply with the settlement plans ends after six years, and the Court cannot find such a provision in the settlement plans. 11 At 11.; emphasis added. This court then quoted the portion of the decision in Appeal of Little Rock School District setting forth the \"crucial\" elements of the settlements, 949 F.2d at 256, and described the predicate for any termination of federal court jurisdiction, as follows. The LRSD asserts in its pleadings that it has substantially complied with its desegregation goals. In order to end federal court jurisdiction, the LRSD must provide evidence that it has substantially complied with the aforementioned elements insofar as they obligate the LRSD. Reports of ODM and other evidence received in hearings in this matter reflect that the LRSD has fallen short of its goals with respect to many aspects of the plan. Instead of presenting substantial evidence of its compliance with its goals as set forth in the plan, the LRSD submits arguments that it has achieved unitary status because data from the LRSD compares favorably with data from other districts which have been declared unitary. The Court would be inclined to .agree with the LRSD with respect to many of these arguments if the LRSD were not contractually bound by the plan which it voluntarily adopted. 6 The Court has encouraged the parties to consider modifying those parts of the plan that are ineffective or unworkable. The court has provided the parties with the testimony of experts to assist in the modification process. Instead, the LRSD has used the testimony of these experts to ask the court to end court jurisdiction without first proceeding with plan modifications. The Court cannot so easily relieve the district of its contractual obligations, [At 11-12; emphasis added] These comments establish in this very context the centrality of the plan provisions to which the PCSSD voluntarily agreed. Three other arguments made by the PCSSD warrant responses. The PCSSD seems to argue that at this advanced stage of the remedial phase of the case, the parties and the court can return to the PCSSD's view of the scope of the liability findings as set forth by the Court of Appeals prior to the parties voluntarily agreements. Petit. at 2-3, 6-7. As intervenors have shown, this approach involves a head on collision with much law of the case at this and the appellate level. This court, we respectfully suggest, can not set aside the many rulings of the court of Appeals for the Eighth Circuit, necessary to adopt this approach. The PCSSD seems to argue that the fact that the Delaware case involved eight particular \"ancillary factors\" means that those factors are properly a focal point in this case. Petit. at 34. This approach is unsound. Relief regarding those factors was identified as necessary, and ordered, to support the desegregation remedy in the particular circumstances of that case. coalition to save our Children Y, Board of Education, 90 F.3d 752, 757, 769 (3rd cir. 1996). This case has its own  7 ,. decrees, entered largely by consent. The decisions of the court of appeals and this court establish, in accord with the general rule, that these decrees, in this case, provide the \"benchmark\" for measuring compliance by the officers and agents of the PCSSD. Finally, intervenors note other efforts to elevate substantive standards employed in other cases above the specific remedial steps and goals agreed to by the PCSSD in this litigation. Petit. at 1, 25, 31, 35-36, 38-41. However, none of these other cases involved a consent decree, much less one with the terms extant in this litigation. 2. The Degree of Compliance to Be Required in Each Area Prior to the court's Relinquishing Jurisdiction a. The Appropriate source of Legal Principles The parties, as has been noted, agreed in the PCSSD and - Interdistrict Plans to terms governing the operation of many aspects of the educational program afforded in the PCSSD. the parties' agreement also allowed \"[this court] to retain jurisdiction to oversee ... [the] implementation (of the agreements].\" LRSD, supra, 921 F.2d at 1390. The parties' agreements did not, however, address the standards and procedures for the termination of court jurisdiction in any particular area, including the standards delineating the degree or extent of compliance to be required in an area prior to the termination of jurisdiction. As to these matters not addressed in the agreements, it is the position of the Joshua Intervenors that the standards normally govern~ng the termination of jurisdiction in a particular area, described below, are applicable. 8 In the first place, there is no reason to believe that the plans provided for endless court jurisdiction. The system, as shown by the current motion, would not desire such jurisdiction. More significantly, by 1989 the courts had decided that perpetual jurisdiction would be inappropriate. For example, in Freeman v . Pitts, 118 L.Ed.2d 108, 132-33 (1992), the court described the 1976 decision in Pasadena city Board of Educ. v. Spangler, 427 U.S. 424. It noted the rationale of Spangler that a federal court in a school desegregation case has the discretion to order an incremental or partial withdrawal of its supervision and control. In resolving the teacher strike issue, the Court of Appeals identified the sources of law applicable in this case. Knight. supra, 112 F.3d at 954. The court referred to the settlement agreement, \"reasonable implication therefrom,\" and \"other applicable law.\" ,lg. Each of the latter sources of law supports the approach taken by intervenors. As the parties agreed to continued jurisdiction of the district court in traditional terms, 5 it is reasonable, absent explicit terms, to imply traditional terms to govern the court's exercise of that jurisdiction, when addressing the matter of termination of jurisdiction. With the parties silent on the matter, it seems eminently reasonable to draw upon the body of law normally utilized by courts considering the termination of jurisdiction, 5 compare Brown y. Board of Education, 349 u.s. 294, 299-301 (1955) with LRSD. supra, 921 F.2d at 1390. 9 namely, \"other applicable law.\"6 Two other factors buttress this approach. First, when the parties addressed the end of court supervision in some areas, they cited the principles set forth in Freeman y, Pitts. supra, a decision focusing on the termination of jurisdiction. See \"Stipulation for Order,\" Feb. 9, 1996. Second, when dealing with matters outside the substantive terms of t he agreements, the Court of Appeals has described this court's authority in traditional terms. LRSD y, PCSSD. supra, 921 F.2d at 1394, paras. 8., 9.; Appeal of LRSD. supra, 949 F.2d at 257 (nature of continuing jurisdiction), .ig. at 258 (standard for considering modifications). 7 6 These approaches reach the same result in different ways. In the first instance, intervenors suggest that the traditional concepts be viewed, by implication, as part of the agreement. In the second approach, intervenors argue, in effect, that the agreements are supreme as far as they go, with this court, which retains jurisdiction, supplementing the agreements, in areas not addressed, by reference to the traditional principles. See Restatement of contracts. second. sec. 204 (\"Supplying an omitted Essential Term\") (\"When the parties to a bargain sufficiently defined to be a contract have not agreed with respect to a term which is essential to a determination of their rights and duties, a term which is reasonable in the circumstances is supplied by the court.\") 7 See also LRSP y, PCSSP, 56 F.3d 904, 914 (8th Cir. 1995) (traditional standard employed in considering modification of LRSD plan); LRSP Y, Arkansas, Slip Opin., Oct. 14, 1997, at 3-5 (propriety of reliance on a federal statute, 42 u.s.c. Sec. 1988, as to the availability of 'a fee award, an area like this one, not addressed in the agreements between the PCSSD and other parties). 10 b. The standard for Evaluating the Degree of compliance The Supreme Court set forth the standard for evaluating the extent of compliance in a school district seeking release from court jurisdiction in Freeman v, Pitts. supra, 118 L.Ed.2d at 134-35. The Court wrote, in part (emphasis added): .... Among the factors which must inform the sound discretion of the court in ordering partial withdrawal are the following: whether there has been full and satisfactory compliance with the decree in those aspects of the system where supervision is to be withdrawn; .. [J  'The District court should address itself to whether the Board [hasJ complied in good faith with the desegregation decree since it was entered. and whether the vestiges of past discrimination [have] been eliminated to the extent practicable.' Board of Educ, of Oklahoma city v. Dowell, 498 U.S. ----(1991). see also Jenkins v, Missouri, 122 F.3d 588, 595-96 (8th cir. 1997) (quoting the foregoing portion of the Freeman decision); ,id. at 599 (\"As to the facilities factor, the district court found that certain court-ordered renovations remain to be completed. 959 F.Supp. at 1168. The district court did not err in requiring the terms of the court's decree to be completely fulfilled before relinquishing the ability to enforce compliance with the decree.\"); Pasadena city Board of Education y. Spangler. supra, 4271J.S. at 436, emphasis added (alluding to \"dispute as to the [district's] compliance with those portions of the plan specifying procedures for hiring and promoting teachers and administrators\"). The Joshua Intervenors relate these standards to the motion as follows. on the issue of degree of compliance, scrutiny must be given to two matters in each area addressed by the plans. 11 These are whether the ~CSSD has fully implemented, absent impossibility or the like, the various activities which it pledged to carry out to achieve objectives in that area .a.rul whether the configuration or make-up of students or staff, or the other target of the remedies, in that area, evidences achievement of the goals or objectives of the plans to the extent practicable. 3. The Burden of Proof Regarding Each Area In the Plans The matter of which party has the burden of proof regarding the areas of the system as to which the termination of court supervision is sought is another area not addressed by the parties' agreements. Based upon the same analysis, intervenors contend that the normal standards governing burden of proof in this phase of a school desegregation case apply. Under these standards, we submit, the PCSSD has the burden of proof to establish full compliance with the various steps set forth in the plans and to show that the plan goals have been fulfilled to the extent practicable. The general rule is that a school district has the burden of establishing the predicate for the termination of court jurisdiction in one or more areas of the case. Freeman v. Pitts, 118 L.Ed.2d 108, 137 (1992); 9 see also Wedo not suggest that these areas be viewed in isolation. The status of the activities is most important where the configuration of students or staff, as relevant, continues to reflect a racial pattern. '\"The school district bears the burden of showing that any current imbalance is not traceable, in a proximate way, to the prior violation.\" 12 United States Y, Fordice, 120 L.Ed.2d 575, 599 (1992) (higher education). 10 More generally, assignment of this burden to LRSD is consistent with the standards for allocation of the burden of proof set forth by the supreme Court in Keyes v. School District No. 1, 413 U.S. 189, 208-10 (1973). In Keyes, a school desegregation case in which segregation had not been required or permitted by state law, the Court identified instances in which Denver school authorities had the burden of proof. For example, proof of intentionally segregative actions in a substantial part of the system was held to establish a prima facie case that actions having a segregative effect in other parts of the system were also motivated by race. See 413 U.S. at 208-09. 11 The Court explained the basis for this rule as follows: \"This burden-shifting principle is not new or novel. There are no hard-and-fast standards governing the allocation of the burden of proof in every situation. The issue, rather, 'is merely a question of policy and fairness based on experience in the different situations.' 9 J. Wigmore, Evidence 2486, at 275 (3d Ed 1940).\" See 413 U.S. at 209. -The court then cited several situations in which considerations of \"policy and fairness\" had 10 \"Brown and its progeny, however, established that the burden of proof falls on the State, and not the aggrieved plaintiffs, to establish that it has dismantled its prior de jure segregated system. Brown II, 349 U.S. at 300. \" 11 \"In that circumstance, it is both fair and reasonable to require that the school authorities bear the burden of showing that their actions as to other segregated schools within the system were not also motivated by segregative intent.\" See 413 U.S. at 209. 13 been held to support a requirement that school authorities explain actions or conditions. See 413 U.S. at 209-10. Considerations of \"policy and fairness\" warrant allocating to PCSSD the burden of showing compliance with the terms of the settlement before the termination of the court's jurisdiction. The school district obviously has superior access to personnel and data, as well as greater resources, in. terms of personnel, to compile materials. The district's counsel, through its highest administrators, can request the lead personnel in each area to compile data and materials, if any there be, designed to show that the specified remedial steps have been undertaken and that goals have been attained to the extent practicable. This court seemingly adopted this approach when ruling on the earlier LRSD motion. It referred to the LRSD \"provid[ing] evidence that it has substantially complied and Order, May 1, 1992, at 11.  11 Mem. Opin. The PCCSD acknowledges having the burden of proof on the so-called Green factors. Petit. at 37. However, based upon its reading of the decision in the Delaware case, coalition to Saye Our Children. supra, the PCSSD argues that the burden of proof rests with the Joshua Intervenors as to any other areas where the relinquishment of jurisdiction is opposed. Petit. at 37-38. This argument is based upon an erroneous interpretation of the Delaware decision and again ignores the content of the courtapproved agreements in this case. The opinion in the coalition case discusses three areas of 14 district operations. These are the areas covered by the so-called Green factors (90 F.3d at 761-69, 776); eight so-called \"ancillary factors, as to which a \"1978 order of [the] court required the implementation of eight specific programs ancillary to the 9-3 pupil assignment plan\" (at 769-76); and \"certain performance disparities\" in the areas of achievement, special education and dropout rates, neither among the Green factors, nor covered \"in the ancillary relief order ... \".Ig. at 776. With regard to burden of proof as to termination of court supervision, the appellate court wrote: \"We emphasize that here we are not discussing the burden of proving compliance with the Green factors or the 1978 Order, as to which the school districts acknowledge bearing the evidentiary burden. Our discussion here, and our allocation of the burden of proof to [the Coalition] is limited to the issue of proving that the identified performance disparities are vestiges of de jure segregation.\" Ig. Thus, in the Coalition case, the court allocated the burden of proof to the plaintiffs only in areas not covered by a court order. Here, in contrast, the Joshua Intervenors' concerns, in their entirety, including as to achievement and special education, involve activities addressed in detail in the agreements, which the district has been ordered to implement, by reason of this court's approval of the plans. In sum, the Coalition decision is supportive of the intervenors' approach regarding burden of proof. 15 1 ' I i :1 c. Application of the Governing Standards to the Areas Addressed by the Plans, Including but Not Limited to Those Addressed in the Pesso Petition The Joshua Intervenors next discuss the various areas of the operation of the PCSSD which are addressed in the Petition. In keeping with the controlling legal standards, intervenors focus upon the specific activities which the PCSSD promised to undertake in the agreements, as well as th.e stated goals (objectives). Comments are made about the statistics presented (or not presented) in some instances. 12 Lastly, as appropriate, intervenors note distinguishing factors regarding the decisions cited by the PCSSD. 1. The Assignment of students. Including within Schools The PCSSD submits data on student enrollment, by school, - which is impressive, when considered in isolation. However, the system's showing in this area is incomplete for several reasons. 13 First. The petition is silent as to the plans of the PCSSD regarding student assignment, if supervision in this area is ended. One basis for jurisdiction to continue in an area is when this \"is necessary or practicable to achieve compliance with the 12 The PCSSD approach regarding statistical data varies. There is at times data by school; at times aggregated data, not showing the pattern by school; and at times no data. 13 Intervenors note ODM's conclusion, based upon its interpretation of the agreement, that in 1996-97, eight elementary schools and two secondary schools in the PCSSD \"[fell] outside the target for racial balance.\" see 1996-97 Erollment and Racial Balance in the LRSD and the PCSSD, ODM, Dec. 18, 1996, at 13, 14. 16 decree in other facets of the school system; -\" Freeman v. Pitts. supra, 118 L.Ed.2d at 135. Based upon the content of the plans, intervenors raise concerns infra about access to programs and the quality of school facilities available to class members. Intervenors and the court need to be informed about PCSSD's future plans for student assignment to know how they interact with these, and possibly other areas. 14 Second. The total failure of the petition to discuss the topic of the assignment of class members within schools is a major shortcoming. This issue is not the subject of either text, or statistics. In its 1990 decision, the Court of Appeals alluded to comments made by the intervenors' lead counsel, as follows: \"As one of the counsel for the Joshua Intervenors wisely remarked - during the oral argument, it is important which schools students attend, but it is also important what kind of education they receive after they get there. LRSD. supra, 921 F.2d at 1385. The PCSSD desegregation plan contains considerable content regarding assignment within schools. It addresses \"classroom racial balance\"; \"ability grouping,\" including its possible elimination; talented and gifted programs, including at the 14 In the Interdistrict Plan, the PCSSD agreed to cooperative efforts with the LRSD with regard to interdistrict schools (in both districts) and magnet schools (in the LRSD). Attach. at 11. The case file shows that the LRSD is not seeking the termination of jurisdiction at this time. The court and the intervenors need to know the PCSSD's future plans regarding the magnet and interdistrict schools, in particular, to assess the impact on the LRSD plan. The fact that three school districts joined in agreements may ~ead to the need to craft some special rules at the time when the limiting of the court's jurisdiction is proposed. 17 secondary level; \"honors and advanced placement courses\"; and \"advanced core curriculum courses.\" Attach. at 11-14. The plans provide for the gathering of data, the identification of any problems, and the crafting of solutions, if need be. Attach. at 6 I 12  We do not suggest that the PCSSD must provide a novel-length explanation of its implementation of the plan and the current configuration in each of these areas. However, to meet its burden, the PCSSD should be able to provide some statistical data, by school and race, as well as evidence of its carrying out of the specified activities. Citations to documents generated over time would often allow verification of the assertions made, if verification is possible. Failing such an approach in this and other areas, there is no guarantee that the plan provisions have been more than simply verbiage. 2. Transportation The resolution of this area must await resolution of the student assignment area. In the absence of information about future plans as to assignment to schools and data about access to enriched programs, one must speculate to address this area. 3. Personnel. Including Qualifications The Petition sets forth data regarding three areas. These are \"certified secondary staffing\" (by school but without a breakdown by category), \"principals and assistant principals\" (aggregate data), and \"central office.\" At 17-30. While the results cited are clear1y  positive in nature, they do not in view 18 . - of the full sweep of the commitments undertaken (Attachment at 9-10) warrant the relinquishment of jurisdiction. The existence of these commitments also distinguishes this case from others to which the PCSSD alludes. Petit. at 25. The PCSSD pledged that \"[a]enrollment levels of the organization will reflect a desegregated staff .... 11 Attach. at 9. The shortcomings in the PCSSD presentation are as follows: First. Data for certified staff should be provided by category, by school, so that it is possible to determine the extent to which black and white pupils are exposed to black faculty members, the staff members with whom students spend the majority of the school day. Second. The plan provides that the PCSSD \"shall staff each school with at least one minority administrator  11 Attach. at 10. The petition identifies, for 1996-97, 33 black principals and assistant principals and 37 schools. At 11-13, 27. Therefore, there is a need for a chart showing the number of administrators by school and by race to allow evaluation of the fulfillment of this objective. Third. The plan pledged efforts to desegregate several categories of staff, for which no data is now provided. These are \"support staff\"; the \"Special Education Department\"; \"facilitator\" in the Talented and Gifted Program; and \"coaches and band directors.\" Attach. at 9-10. Inclusion is important in each of these areas. For example, the support staff are often the first staff members to greet parents. Their make-up, therefore, 19 . - seems related to the central goal of promoting parental involvement. Data for these areas should allow a determination of whether there has been any progress over time. Fourth. The PCSSD made promises regarding staff qualifications, generally, and, in schools offering the compensatory program. The latter pledges were more specific. Attach. at 10. This area, an important one_ in a plan emphasizing educational quality and the narrowing of the achievement gap, is ignored. 4. co-curricular and Extracurricular Activities The PCSSD voluntarily agreed to more than three pages of provisions concerning these areas. Plan at 68-69, 76-77; ID Plan at 6; see also Attach. at 4-5. Under the law of the case, - citation to decisions dealing with systems without such commitments does not suffice to establish a basis for termination of the court's role. Intervenors note the following specific shortcomings in the presentation on this topic: First. The PCSSD has yet to submit the promised supplementation in the \"co-curricular\" realm. Petit. at 33. As the plan provides for a goal for each school (Attach. at 4), the data should be school-based. The providing of data for more than one year, as was done in the case of certified staff, will be necessary to permit a determination of whether any progress has been made over time. Should the data show \"minority underrepresentation\" in the past, the PCSSD should provide 20 ,. evidence that the affirmative steps promised by the plan (Attac "},{"id":"bcas_bcmss0837_1160","title":"Little Rock School District, Position Paper on Desegregation Obligations","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["Little Rock School District"],"dc_date":["1996-05-08"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Little Rock School District","Education--Arkansas","Educational law and legislation","School management and organization","School integration"],"dcterms_title":["Little Rock School District, Position Paper on Desegregation Obligations"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1160"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["documents (object genre)"],"dcterms_extent":["298 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nThe transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.\nI ' Little Rock School District Position Paper on Desegregation Obligations Table of Contents Executive Summary 1. Purpose of Position Paper 2. Background 3. Response Groupings and Definitions of Tenns 4. Results of Audit and Interviews 5. Position on 'Not Begun' Items 6. Internal Enhancements 7. Conclusions May 8, 1996 This report was prepared by the LRSD administrative team of Brady Gadberry, Sterling Ingram, Dr. Ed Jackson, Deana Keathley, Dr. Patty Kohler, Dr. Russ Mayo, Leon Modeste, Ken Savage, and Marvin Schwartz. 1 3 4 8 11 13 15 16 Little Rock School District, 810 West Markham, Little Rock, AR 72201 #501-324-2000 IN THE UNITED STATES DISTRICT COURT FILED sw EASTERN DISTRICT OF ARKANSAS ~ WESTERN DIVISION U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS LITTLE ROCK SCHOOL DISTRICT v. LR-C-82-866 JAMES W McCORMACK, CLERK By: PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL -------,---- DE P. CLERK DEFENDANTS INT ERVEN ORS INTERVENORS SPECIAL STATUS REPORT For its special status report, the Little Rock School District states: 1. The Little Rock School District has recently reviewed the status of its compliance with its desegregation obligations and determined that the district is in substantial compliance with those obligations. The attached \"Little Rock School District Position Paper On Desegregation Obligations\" describes the process used by LRSD to determine its compliance and reports the conclusion that LRSD has implemented 96.3 percent of its desegregation obligations. Respectfully submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026amp; CLARK 2000 First Commercial Bldg. 400 West Capitol Street Little Rock, AR 72201 (501) 376-2011 r1.stopher Helle Bar No. 81083 CERTIFICATE OF SERVICE I certify that a copy of the foregoing Special Status Report has been served on the following by depositing copy of same in the United States mail on this 8th day of May, 1996: Mr. John Walker JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 3400 Capitol Towers Capitol \u0026amp; Broadway Streets Little Rock, AR 72201 Mr. Richard Roachell Roachell and Streett First Federal Plaza 401 West Capitol, Suite 504 Little Rock, AR 72201 Ms. Ann Brown - HAND DELIVERED Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 2 LITTLE ROCK SCHOOL DISTRICT POSITION p APER ON OESEGREGA TION OBLIGA TIONS EXECUTIVE SUMMARY FINDINGS  THE DISTRICT IS IN SUBSTANTIAL COMPLIANCE WITH ITS DESEGREGATION OBLIGATIONS. THIS IS BASED ON IMPLEMENTATION OF 96.3% OF ITS OBLIGATIONS.  SOME OF THE GOALS OF THE PLAN HA VE NOT BEEN ACHIEVED AND ARE NOT LIKELY TO BE ACHIEVED TIIROUGH THE CURRENT OBLIGATIONS. RECOMMENDATIONS  RECOGNITION OF THE DISTRICT'S SUBSTANTIAL COMPLIANCE SHOULD BE MADE BY THE COURT.  OBLIGATIONS WHERE SUBSTANTIAL COMPLIANCE HAS BEEN ACHIEVED SHOULD BE RELEASED FROM COURT SUPERVISION.  OBLIGATIONS WHICH DO NOT MEET THE NEEDS OF STUDENTS SHOULD BE REVISED.  REVISED OBLIGATIONS SHOULD BE MODELED ON ACTION ITEMS IN THE RECENTLY COMPLETED STRATEGIC PLAN. Page 1 LITTLE ROCK SCHOOL DISTRICT 1. PURPOSE OF POSITION PAPER  Assess District's performance m meeting desegregation obligations.  Inform the public of status of these accomplishments.  Prove good faith effort in achieving substantial compliance. 2. BACKGROUND  The District has accepted desegregation obligations as a binding contract.  Desegregation obligations are reviewed through regular updates of the Program Budget Document.  A LRSD obligations audit identified more than 2,000 items and published the listing as the Abbreviated Summary. Scan sheets were developed for each item and completed by District staff.  Compilation of scan sheet responses provided the overall status for this report. 3. RESPONSE GROUPINGS AND DEFINITION OF TERMS  Responses to the scan sheets were grouped to match program names.  Responses within each program name were sorted to identify total items in compliance and items not yet begun. Page2 POSITION PAPER ON DESEGREGATION OBLIGATIONS 4. RESULTS OF AUDIT AND INTERVIEWS  Final assessment of the audit showed substantial compliance with all desegregation obligations. This is based on implementation of 96.3% of those items.  The interview process allowed comprehensive review of all evidence supporting implementation of obligations. 5. PosmoN ON NoT BEGUN ITEMS  Obligations identified as Not Begun reveal barriers to effective implementation such as unrealistic expectations.  The obligations modification process lags behind current implementation plans. 6. INTERNAL ENHANCEMENTS  An automated PBD will show new patterns of completion, allowing assessment of obligations by individual items and by schools.  The automated process increases overall accountability toward fulfillment of the obligations. LITTLE RocK SCHOOL D1sTR1cT POSITION PAPER ON DESEGREGATION OBLIGATIONS 1. Purpose of Position Paper The daily operation of the Little Rock School District is centered on providing the public with the highest quality education available in Arkansas and the nation. With an October 1995 enrollment of 24,922 students and the employment of . 3,513 people, the tasks required to provide that quality education are quite numerous. Effective coordination of those tasks and public accountability for their implementation are some of the criteria by which the District should be measured. The numerous obligations approved for the District by the 8th Circuit Court of Appeals have resulted in a lengthy and highly detailed document containing more than 2,000 obligations or specific tasks. Additionally, the LRSD Desegregation Plan is one of several plans approved by the Court for Pulaski County public school districts. The District commits significant personnel and financial resources to implementation and reporting of desegregation obligations. Some of these resources could be used more effectively to meet student educational needs. The primary purpose of this position paper is to assess District progress in meeting desegregation obligations. Secondary purposes of this position paper follow in logical sequence. To assure accountability by the District in response to desegregation obligations, this paper will identify the status of those accomplishments. It will show which Page3 obligations the District has fully or partially accomplished, and it will show the results from those actions. The overall intent of this paper is to prove a good faith response by the LRSD to the complex task of meeting desegregation obligations. Further, this paper will address those obligations which the District has not fulfilled, and it will give an account for those nonaccomplishments. In some cases, an appropriate response to the obligation was not possible. In other cases, a response was possible but not attempted because circumstances made the effort unfeasible. Finally, this paper will provide an update on District efforts to meet reasonable obligations where progress is lacking. More specifically, the overall intent of this paper is to prove a good faith response by the LRSD to the complex task of meeting desegregation requirements. It is the goal of the LRSD to meet the educational needs of all its students. In the process of meeting those needs, the District seeks to achieve unitary status or release from Court jurisdiction. We believe an objective reading of this position paper will advance that effort and better serve the interests of Little Rock students and all citizens of the community. LITTLE RocK SCHOOL D1sTR1cT POSITION PAPER ON DESEGREGATION OBLIGATIONS 2. Background The desegregation obligations currently in place for the LRSD have evolved from legal actions and court supervision of Pulaski County school districts that began in the early 1980s. These obligations derive from the consent decrees the District has entered into with several parties, including:  North Little Rock School District  Pulaski County Special School District  Knight Intervenors  Joshua Intervenors  State of Arkansas (no longer current) In 1993, an audit of desegregation obligations was undertaken by LRSD attorneys at the Friday Law Firm. After review by District management, the obligations listing was filed with the court. The District's response to all desegregation obligations has been to accept them as a binding contract. As a whole, this imposes a weighty burden on the District. Finances for instructional programs have been diverted toward legal fees, and an administrative capacity for the development of creative instruction has been dissipated in time spent in the legal process or in preparation of desegregation-related documents. These impositions have limited the District's ability to meet the needs of a diverse student population. A reporting process used by the District to update the Court on progress Page4 toward obligations is key to the assessment and conclusions reached in this position paper. This process is the Program Budget Document (PBD). An explanation of the development and implementation of the PBD will help identify the reporting burden and the tendency for duplication imposed by the system. The PBD was developed to monitor progress on all obligations. The document identifies every obligation relating to the case and provides essential information to track relevant activity. The District's response to the desegregation obligations has been to accept them as a binding contract. The PBD is updated quarterly with information provided by the primary leaders to reflect progress. However, many items on the PBD are repeated yearly or are part of a continuous process. These can include items such as principals writing school profiles or District Equity Monitors visiting schools. Such items are never completed in themselves, but reports are required within the year to show how much of the task has been accomplished. Conversely, some items are maintained on the PBD and addressed even after they have been completed. (This weakness in the PBD design has been corrected in the new automated version. See Section 7. Internal Enhancements). LITTLE RocK SCHOOL D1sTRICT The LRSD process for reporting to the Court is centered on updates of the obligations and activities contained in the PBD. One barrier to the PBD reporting process, however, is the lack of a quantifiable assessment which clearly shows how well the District has done in meeting all its obligations. The original version of the PBD did not provide a numerical or percentage summary. As a preliminary step toward overall assessment, the District began a comprehensive review in mid 1995 to identify every distinct obligation. The Abbreviated Summary, as the project came to be known, involved cross referencing items from the PBD and all legal documents. The audit identified 2,098 distinct obligations. A refining of the list yielded a final count of 2,008 obligations. Further, the Abbreviated Summary identified numerous inconsistencies such as POSITION PAPER ON DESEGREGATION OBLIGATIONS duplicative obligations (See Figure 1. Examples of Duplication among Desegregation Obligations) and obligations being implemented for which no legal reference could be located. Additionally, numerous legal documents had made separate contributions to the obligations by this time, each introducing additional requirements. Legal Documents Influencing Obligations  8th Circuit Court Orders  District Court Orders  lnterdistrict Plan  LRSD Desegregation Plan  Settlement Agreement  Stipulations  McClellan Plan  Henderson Plan  Court Transcripts  Exhibit  June 5, 1992 Monitoring Report Figure 1. Examples of Duplication among Desegregation Obligations Subject Abbreviated Text Original Legal ID#, Document Incentive 1. Make recommendations to the Board LR Deseg. Plan 1783 School 2. Make staff recommendations LR Deseg. Plan 1788 Staffing 3. Make staff recommendations for LR Deseg. Plan 1789 employment to the Board M-to-M 1. Develop recruitment plan with PCSSD for lnterdistrict Plan 1481 Transfers M-to-M transfers 2. Parties to promote M-to-M transfers lnterdistrict Plan 3154 1. ID numbers for obligations refer to listings in the Abbreviated Summary. Page 5 LITTLE ROCK SCHOOL DISTRICT POSITION PAPER ON DESEGREGATION OBLIGA TIONS The assessment process chosen for the task was for the LRSD Division of Planning Research and Evaluation (PRE) to develop computer scan sheets relating to the status and evidence of all obligations. (See Figure 2. Obligations Scan Sheet) In 1995, a process was begun in which primary leaders answered six concise questions and sent the sheets back to PRE for compiling of responses. The scan sheets asked direct questions and gave multiple choice answers. The Primary Leaders had to identify if their obligations were a) not begun, b) completed, c) completed periodically, or d) continuous/never completed (See Figure 3. Response Categories for Scan Sheet Survey of Obligations). To assure accountability, they also had to identify the specific location where evidence concerning the obligation was kept and who was responsible for that evidence. The assessment process continued with a 1996 follow-up survey to address items that had been recently added as well as allow a figur~ 2. Obli'gatiof'ls Scan Sheet Questions relating to the evidence available for the above named obligation. 1. What is the status of the obligation? A) Not begun (If answer is A, do not complete the rest of the form.) B) Completed (ff answer is B, go to question # 2.) C) Completed Periodically (ff answer is C, go to question #3.) D) Continuous/Never Completed (ff answer is 0, go ta question #3.) 2. In what school year was the obligation completed? A) Priorto1992-93 (If answer is A, goto question # 4.) B) 1992-93 (ff answer is B, go to question# 4.) C) 1993-94 (ff answer is C, go ta question # 4.) D) 1994-95 (ff answer is D, go to question# 4.) 3. If the obligation is on-going, in what school year was the obligation first accomplished? A) Prior to 1992-93 B) 1992-93 C) 1993-94 D) 1994-95 4. In what form does the primary evidence for this obligation exist? A) Pamphlet or Publication B) Written Evaluation, Survey or Summary Report C) Bill or Requisition 0) Document (written agenda, sign--in sheet, notice of meeting, invnation, etc.) E) No evidence exists (ff answer is E, do not complete the rest of the form\nhowever. explain why in AREA 2 an the back of this sheet.) 5. Location where primary evidence concerning this obligation is kept: A) School B) District Offices, LRSD Annex, IRC, Student Assignment C) Plant Services, Procuremen~ Food Services, Safety \u0026amp; Security, Transportation D) Adult Education 6. Who is the keeper of the primary evidence? A) Primary Leader B) Secondary Leader C) Person Responsible Signature: _ _ _ _ _________ Date: _ _____ _ Page6 I (!) 0@  j ' @. J.@\n,J@)  ,@  A . : ,, 0 , @_ .  ,@  ~t .@, ... ~ . \"',.   @    .A .! ., B . ~ (E) I l'J 1 j   (i) -1 IV I  i  I  m I (!)  .  I '(r) LITTLE ROCK SCHOOL DISTRICT second reporting on items previously identified as \"not begun.\" The processing of scan sheets gave the District a clear and comprehensive understanding of the degree of compliance it had achieved regarding the identified obligations. The scan sheets gave the District a clear understanding of the degree of compliance it had achieved regarding the identified obligations. Progress since 1993 has resulted from the improved tracking accuracy of the original PBD. A recent upgrade to a computerized PBD process will further improve its accuracy. The audit of obligations and scan sheet surveys represent other distinct improvements in the District's overall response to desegregation obligations. POSITION PAPER ON DESEGREGATION OBLIGATIONS Figure 3. Response Categories for Scan Sheet Survey of Obligations CO - Completed. Items done once which need no repeating. Example: Motion granted for construction of cafeteria at Chicot Elementary. ID #1177, Court Order, 4/30.!93, Pg. 1 CP - Completed Periodically. Items which have repetitive schedules within fixed time frames. Example: Establish a summer school program. ID #1208, lnterdistrict Plan, 4129193, Pg. 13 NC - Continuous/Never Completed. Items which require on-going implementation. Example: Monitor the Desegregation Plan. ID #0936, LR Plan, 4129192, Pg. 28 NB - Not Begun. Items which have not been addressed. Example: Plan new junior high school construction. tD #1326, LR Plan, 4129192, Pg. 129 Page7 LITTLE RocK SCHOOL D1sTRICT POSITION p APER ON DESEGREGATION OBLIGATIONS 3. Response Groupings and Definition of Terms To fully understand the information reflected on the scan sheets and to communicate those results to the public in a precise manner, certain groupings of responses were made. This process included three broad steps, summarized below and detailed in the remaining sections of this report. 1 The status of individual obligations were identified on the scan sheets as CO CP NC, or NB. , , 2 All obligations were categorized as CO orNB. 3 Overall response to desegregation requirements was identified as Substantial Compliance (SC). The process began by grouping the scan sheet responses into PBD Program Areas. In this manner, thousands of individual obligations and strategies were brought together under distinct program names. The process then gave abbreviated titles to the distinct categories of response as shown on the scan sheets. These abbreviations are presented in Figure 3, and examples of obligations for each category are provided. An additional category is represented with the letter A. This group includes obligations which were identified after the 1995 scan sheet survey. Examples of A items include: Pages  Restore Gifted Coordinator to Budget, ID #5144,Court Transcript, 716/95, Pg. J  Court Requires Long-Range Facilities Plan, JD #5127, Court Order, 2/8195, Pg. 2 All A items have been addressed in the follow up survey of February 1996, and their tally is included in the final results. As represented in Figure 4. Obligation Status - Grouping Process, the grouping process condensed five categories of responses into three. Each category represents total responses for that status and does not relate to specific programs or activities. For example, responses marked \"completed\" include those which are addressed periodically and those which are continuous/never completed or cyclical. These items are considered completed because the District has met all possible requirements for their fulfillment during the time frame or cycle. Final grouping of the responses culminated in the two categories, Completed (CO) or Not Begun {NB), represented in the next section of this report. In this manner, the District has been able to provide the most direct presentation of its substantial compliance with desegregation obligations. To assure the most accurate reporting possible, the District identified the legal definitions of the categories of response and other terms used when describing desegregation obligations. Many LITTLE RocK ScHooL D1sTR1CT of these terms have had their original meanings transformed through usage by the media, the public, and by educators who did not fully understand them in the proper context. As a legal document, however, the Plan requires a strict and consistent interpretation. POSITION PAPER ON DESEGREGATION OBLIGATIONS The following items are key terms2 in understanding desegregation obligations and the District's response.  Obligation - a legal requirement that constrains to a course of action, an imperative for specific action. An 2 Definitions for terms were paraphrased from Black's Law Dictionary, 6th Edition, 1991. Initial Survey Figure 4. Obligation Status - Grouping Process Response Grouping Page9 Results of Follow-up Preliminary Surveys Follow-up Survey Legend A Added after Initial Survey CO Completed CP Completed Periodically NC Never Completed/Continuous NB Not Begun SC Substantial Compliance L1TTLE RocK SCHOOL D1sTRICT   obligation is something one is bound to do. It leaves no room for negotiation, compromise, or alternative. Example: LRSD will pay an increase of $52,604.09 in the ODM budget. ID #4113 . Court Order. 418194, Pg. J Recommendation - something which is offered or suggested as a favored action. A recommendation is worthy of acceptance, but there are no constraints upon its action. Recommendation refers to an action which is advisory in nature rather than one having a binding effect. Example: The following full time positions are recommended for each Incentive School. (20 positions are listed, including classroom teachers, counselors, etc.) LR Desegregation Plan. Incentive School Section, 4/2192, Pg. 190 Substantial Compliance: conformity with the essential requirements in fulfilling formal or official obligations of a contract or a statute. Being in substantial compliance means that you have done substantially all you were required to do to fulfill the obligation. The concept of \"substantial compliance\" is the primary assessment criteria for this report. Example: Establish six thematic interdistrict schools, ID #1479, lnterd1str1ct Plan, 4/29/92, Pg. 3  Good Faith Effort - an effort based on an honest belief, the absence of malice, and the absence of the design to   Page 10 POSITION PAPER ON DESEGREGATION OBLIGATIONS defraud or seek advantage. Example: Provide Homework Hotlines. JD #1918, LR Desegregation Plan, 4/2/92, Pg. 180 Completion - something which is fully realized, which possesses all necessary parts. Completion means an action has been brought to an end or to an intended condition. With desired results achieved, no further action is necessary. Example: Install Rockefeller Elementary Heat/AC. ID # 1350, Monitoring Report, 615/92. Pg. 43 On-Going Obligations - certain items identified as obligations which need to be repeated on a regular basis. These \"on-going obligations\" can not be totally completed because further action is necessary throughout the term of the desegregation plans. The District considers itself in compliance with these items if it fulfills the necessary action within each scheduled reporting period. These items are represented in the CP ( completed periodically) or the NC (never completed) groups. Example: Maintain all school facilities for safe/operable condition. ID #950, LR Desegregation Plan, ,l/2/9192, Pg. J 29 LITTLE RocK ScHOOL D1sTRICT Results of the preliminary surveys showed the District m substantial compliance with its desegregation requirements. This was based on initial findings which showed implementation of 97. 5% of obligations. The need for evidence of compliance with obligations led to a final round of interviews. The intent of the interviews was to gain proof in addition to the scan sheets that all information was accurate. Interviews were conducted with all primary and secondary leaders and all persons responsible for implementation of the obligations. Evidence of all activities was reviewed by committees, and a new and more specific assessment was obtained. As illustrated in Figure 5. Results of the Interview Audit, the final number of obligations became 1,753. This was achieved by the removal of additional duplicates, recommendations, goals, and items which were identified as not obligations. The District is in substantial compliance with its desegregation requirements based on 96.3% implementation of its obligations. Of that group of 1,753 obligations, 96.3% or 1,689 were identified as being in substantial compliance. Partial compliance Page 11 POSITION p APER ON OESEGREGA TION OBLIGATIONS was achieved in 1.1 % or 19 obligations, and only 45 obligations or 2.6% of the total remained as Not Begun items. LITTLE ROCK SCHOOL DISTRICT POSITION PAPER ON DESEGREGATION OBLIGATIONS Figure 5. Results of Interview Audit ORIGINALLY IDENTIFIED OBLIGATIONS 2008 REVIEWED - NOT OBLIGATIONS 12 DUPLICATE OBLIGATIONS 224 RECOMMENDATIONS 9 GOALS 10 NET OBLIGATIONS AFTER AUDIT-~17~5\"\"!\"\"3 RELEASED FROM COURT SUPERVISION SUBSTANTIAL COMPLIANCE COMPLETED ON-GOING PARTIAL COMPLIANCE NOT BEGUN SUBSTANTIAL COMPLIANCE PARTIAL COMPLIANCE NOT BEGUN PARTIAL COMPLIANCE 1% 203 52 429 1005 19 45 1753 1689 19 45 1753 NOT BEGUN 3% SUBSTANTIAL COMPLIANCE 96% Page 12 11 .6% 3.0% } 24.5% 57.3% 1.1% 2.6% 100.0% 96.3% 1.1% 2.6% 100.0% 96.3% Substantial Compliance LITTLE ROCK SCHOOL DISTRICT POSITION p APER ON DESEGREGATION OBLIGA TI0NS 5. Position on 'Not Begun' Items As previously stated in this report , the District has identified desegregation obligations with a 'Not Begun' status. Analysis of those obligations showed that in some cases, the premise upon which the obligations were based was found to be flawed. In other areas, obligations were shown to be dependent on numerous factors outside the District's control. Accountability for the 'Not Begun' obligations is best represented through the following broad categories.  Conditional Obligation: These items are dependent on external factors which have not been met, such as partnership relations with other organizations, receipt of grant funds, or other conditions outside District control. Example: Two obligations under the Library Media section of the Interdistrict Plan and cross referenced in the LRSD Desegregation Plan call for Utilization of TV Technology and Implement Utilization of Cable Channel 19. (m #1033, Interdistrict Plan, Pg. 34, 4129192) The Plan states these obligations will be done \"if funded by a federal Star grant.\" The grant was not funded, therefore, the obligations were not begun.  Unrealistic Expectation: These items are unfeasible or do not generate a sufficient return to justify the effort of implementation. This decision is based on District experience in the field and is a realistic response to items developed Page 13 as part of a 'wish list' by framers of the obligations. Example: The Incentive School Support Section of the LRSD Plan requires the District to meet at homes with groups of parents. cm #2049, LRSD Desegregation Plan, Pg. 210, 4/29/92) The District has found the effort to locate and coordinate a home-based meeting of parents is a time consuming and laborious process. This obligation does not address the reality that people must be invited into a home. They can not be mandated to offer that hospitality.  Changed by Court Order: Changes in the LRSD Desegregation Plan by the Court, such as rulings from the bench and Court orders, have not been reflected as revised the language in the Plan. Example: Numerous items within the Focused Activity section of the LRSD Desegregation Plan have been superseded or redefined by a May 1, 1992 Court Order.  On Appeal: The District is involved in an appeal process to the 8th Circuit Court of Appeals regarding an obligation. In this instance, the obligation is not appropriately aligned with contemporary events. Example: A Court Order currently under appeal states that the LRSD will reimburse PCSSD $167,113 within 60 days of the order. cm #4111, Court order, Pg. 3, 3/16194) LITTLE RocK SCHOOL D1sTRICT  Improperly Reported: Errors in reporting were discovered as a result of of the desegregation obligations scan sheets and audit. Example: An item erroneously reported as NB requires the LRSD to develop or enhance site-based management at designated schools. (ID #0501 , LRSD Desegregation Plan, Pg. 42, 4/29/92) The obligation is being implemented through staff development for principals, revision of District procedures, and enhanced principal accountability for programs. The implementation is being addressed through the Strategic Planning Action Team 8 and will continue through the 1996-97 school year.  Not Begun: These are obligations which the District has not yet implemented. The District recognizes the validity of these obligations and intends to comply with them. Example: An obligation addressing the Incentive School Latin Program calls for the District to evaluate the elementary Latin Program. (ID #2021, LRSD Desegregation Plan, Pg. 164, 4/29/92) This will be done as soon as possible. Similarly, an obligation requires the District to form a media coalition that involves a series of meetings between the superintendents of the three school districts and representatives of the local media. cm #1555, Interdistrict Plan, Pg. 3, 4129/92) Scheduling for these meetings is currently being arranged. POSITION p APER ON OESEGREGA TION OBLIGA TIONS Page 14 LITTLE RocK ScHOOL D1sTR1cT POSITION PAPER ON DESEGREGATION OBLIGATIONS 6. Internal Enhancements The LRSD has completed a revision of the Program Budget Document (PBD) reporting process which will provide information in greater detail and with instant computer access. The computerized PBD will greatly enhance the District's ability to track on-going compliance with obligations. Staff inservice is underway for the recently designed program automation, which is expected to be implemented in the spring of 1996. An automated computer linkage will allow primary leaders to access the system and input directly to the LRSD mainframe AS400 system. Information will address activities done toward the fulfillment of obligations. The automation replaces a manual system where computer diskettes were submitted quarterly and updated reports printed. Another improvement in the system is the automated program's ability to identify responses to single items by individual schools and across the District. This will allow school-by-school reports on specific obligations, an option not previously available. If questioned about a specific obligation, the District has immediate access to its status at each setting. The system will also show patterns of completion and allow deactivation and storage of completed obligations. PBD automation will control the publishing of updates and changes to the obligations, thereby avoiding errors resulting from changing text or phrasing of obligations. Page 15 LITTLE RocK ScHooL D1sTR1cT Major accomplishments such as the identification of obligations and the implementation of a strategic planning process show the District is doing a good job of meeting its desegregation obligations. A 96.3% level of implementation affirms that achievement. The District should be recognized for its accomplishments and certain items should be released from further court supervision. The District should\"be recognize'd 'folits ' accomplishments and i. r  certain 'items released from 'further court supeNision. The District is accountable for its response to desegregation obligations, a response represented in this report. But it should not be held accountable for all of the goals of the Plan, some of which have proved to be unobtainable in this district or any other district in the country. The desegregation plans of the District have resulted in significant desegregation accomplishments. As we near the end of the six-year life of those plans, however, it is apparent that in some ways they have outlived their usefulness. The recently completed Strategic Plan, developed as a result of significant community input and involvement, should be used to guide decisions about LRSD's future. POSITION PAPER ON DESEGREGATION OBLIGATIONS Page 16\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n\u003cdcterms_creator\u003eLittle Rock School District\u003c/dcterms_creator\u003e\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_1759","title":"Court filings regarding scheduling letter, Arkansas Department of Education (ADE), Joshua intervenors', Knight intervenors', and Pulaski County Special School District's (PCSSD's) responses to court order, Office of Desegregation Management (ODM) report, and ADE project management tool.","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2004-03-17/2004-03-31"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Education--Arkansas","Arkansas. Department of Education","School districts","Pulaski County Special School District","Office of Desegregation Monitoring (Little Rock, Ark.)","Project management","Lawyers"],"dcterms_title":["Court filings regarding scheduling letter, Arkansas Department of Education (ADE), Joshua intervenors', Knight intervenors', and Pulaski County Special School District's (PCSSD's) responses to court order, Office of Desegregation Management (ODM) report, and ADE project management tool."],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1759"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["83 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\u003c?xml version=\"1.0\" encoding=\"utf-8\"?\u003e\n\u003citems type=\"array\"\u003e  \u003citem\u003e   \n\n   \n\n   \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n   \n\n\n   \n\n   \n\n\n   \n\n   \n\n\n\n\n\n\n\n\n\n   \n\n \n\n \n\n \n\n\n   \n\n   \n\n   \n\n\n   \n\n  \n\n   \n\n\n   \n\n  \n\n   \n\n\n   \n\n \n\n\u003cdcterms_description type=\"array\"\u003e   \n\n\u003cdcterms_description\u003eCourt filings: District Court, three orders; Court of Appeals scheduling letter; District Court, response to court order by separate defendant Arkansas Department of Education (ADE); District Court, response to court order by Knight intervenors; District Court, Joshua intervenors' response to the Court's March 17, 2004, order; District Court, Pulaski County Special School District's (PCSSD's) response to order; District Court, supplement to response to Court order by separate defendant Arkansas Department of Education (ADE); District Court, NLRSD response to Court's March 17, 2004, order; District Court, notice of filing, Office of Desegregation Management report, ''The Little Rock School District's (LRSD's) implementation of the Court's compliance remedy''; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool    This transcript was create using Optical Character Recognition (OCR) and may contain some errors.    \\ \\ RECE i ~ED FILED tUt AR J. \" l'!fv1.lQ 4, U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS OFF!::: '.' '.' DESEGREr.mr IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS ~AME MAR 1 ?. 2004 LITTLE ROCK DIVISION y: ___ \"=~v.u~~~~ LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DNIHOllNOW NOllV~31:W3S30 :lO 33H:l0 DEFENDANTS INTERVENORS INTERVENORS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ~OOl 8 I ~vw ORDER Lawyers for the parties will please provide the following information: 1. Do you or any member of your firm represent anyone who is now or has been employed by the Office of Desegregation Monitoring (\"employee\" is to be construed broadly regardless of job description)? 2. The dates of any such attorney-client relationship. 3. Whether you deem it proper for a lawyer representing a party in this case to represent an employee of the ODM. 4. If you deem it proper, please explain your position in exact and plenary detail, with citations of authority. 5. If you deem it improper, please explain your position in exact and plenary detail, with citations of authority. \"Attorney-client,\" \"representation,\" and \"consultation\" are to be construed broadly. As an example, a telephone conversation during which the employee seeks to employ a lawyer, or seeks - legal advice of any nature, whether or not it is related to an ODM matter ( even on a one-time - basis) is \"representation.\" A would-be client who talks with a lawyer falls within the definitions above. \"[W]ould-be clients are virtually indistinguishable from 'actual ' clients during the period in which a relationship is under consideration ... \"1 If, for example, a person calls a lawyer, describes a car wreck, and asks, \"has the statute of limitations run\" and the lawyer answers with a definitive, monosyllabic, \"yes,\" this is sufficient to establish an attorney-client relationship for that brief period of time. Generally, see also the Law of Lawyering, Volume 1,  1.6: I 03 and 1.6: 105. Your response to this order must be filed by noon on Friday, March 26, 2004. IT IS SO ORDERED this _/2Tlt,arch, 2004. d,, UN' ~J/r!;;UDGE WM. R. WILSON, JR. 1Law of Lawyering, Volume 1,  1.6:115 at 168.17. ~srRl5!4,~ D o1srR1cr couRr IN THE UNITED ST ATES DISTRICT COURT MAR f B AR!vws,4,s EASTERN DISTRICT OF ARKANSAS JAMt:s VV 2004 LITTLE ROCK DIVISION .By;  MccoRMAc K, CLt:Rk LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ORDER I. In response to an Order, entered yesterday (March 17, 2004) Mr. John W. Walker, one of Joshua Intervenor' s lawyers, has fax ed a letter to me today, a copy of which is attached to this Order as Exhibit A. 2. Among several other things Mr. Walker states, \"we do not represent any member of the ODM staff present or past as far as we know. I add the 'as far as we know caveat' (sic) because we may not know all of the employees present and past of ODM.\" 3. Let's take a look at the record. On October 15, 2002, Joshua Intervenors' lawyers filed a pleading entitled \"The Joshua Intervenors ' Motion for Relief Concerning the ODM Budget\" (Doc. No. 3686). The first paragraph of this pleading reads as follows: It has come to the attention of the Joshua Intervenors that this court is in the process of reducing the ODM staff and budget. A member of the ODM staff affected by staff and budget reductions planned by the court has contacted counsel for these intervenors with regard to her legal rights (emphasis added). 841 4. Then, ten days later (on October 25, 2002), Joshua Intervenors' lawyers filed yet another pleading entitled \"The Joshua Intervenors' Motion to Stay Reduction of ODM Staff' (Doc. No. 3691), with the following first paragraph: On or about October 14, 2002, Intervenors' counsel learned from an African American staff member of ODM, Ms. Linda Bryant, that she had been given notice of termination as an ODM staff member effective on or about October 15, 2001 . Ms. Bryant conveyed to counsel her understanding that her termination was attributable to a directive or requirement of this court. ( emphasis added) 5. The quotes in the two paragraphs above appear to establish beyond peradventure that Joshua Intervenors' lawyers represented an employee of the ODM in October of 2002 . Furthermore, the Order entered yesterday makes it clear that this is exactly the type of information to be disclosed. 6. The March 18, 2004 letter asserts that Joshua Intervenors ' lawyers do not know the identity of past or present ODM employees. I do not want to practice law for any party, but I believe that, if I were in this situation as a lawyer, I would call or write the ODM and get a complete list of these employees. 7. I have reviewed the Order entered yesterday again -- after receiving the fax letter from Joshua Intervenors' lawyers today -- and I must immodestly admit that I believe it is a model of clarity. It can be faulted, if it is to be faulted at all, for redundancy; but I intentionally made it longer than I normally would so that it would not be misunderstood. 8. Joshua Intervenors' lawyers should carefully check their memories and records to determine if they represent, or have represented, any other employees of the ODM ( other than Ms. Bryant). Likewise, counsel for the other parties should do the same. Once this is done, 2 counsel for each party should proceed to prepare a pleading which will comply with the remainder of yesterday's Order. r--1-f IT IS SO ORDERED t~is Ji day of March, 2004. 3 !))~ fl_UuJ,v_ UNifED STATES DISTRICT JUDGE WM. R. W ILSON, JR. MAR.18.2004 10:19AM JOHN W WALKER PA JOHN W WALKER SHAWN CHILDS JOHN W. WALKER, P.A. ATroRNEY AT LAW 1723 BRoADWAY 1rrrLE RoCK, ARKANSAS 72206 TELE!\u0026gt;SONE (501) 374-3758 FAX (501) 874-4187 March 18, 2004 The Honorable William R. Wilson, Jr. 423 U.S. Post Office \u0026amp; Courthouse 600 W. Capitol Ave. Little Rock, Arkansas 72201 Re: LRSD v. PCSSD Dear Judge Wilson: NO.498 OF COUNSEL ROBERT MclIENRY, P.A. . DONNA J. McP.ENR'f 8210 HE!IDERSON RoAO L1'rrLE RoCK, .AJlxt.NS . .'J! 72210 P!!ONll: (601) 372-342/i  F,IA (501) 372-3428 EMAIL: =-hinuyd@swbell.uet RECEIVED MAR 1 8 2004 (j'm . R : Wilson, Jr E i- District Judge   of Arkansas I am writing to provide the Court a preliminary report in reply to the Order herein dated March 17, 2004. The Order appears to invite, if not require, a responsive pleading. By this letter I am requesting further instruction as to the form the expected final response should take.  With respect to question one (1 ), I have spoken with the other attorneys associated with me, including those not in my firm as such, and inform the Court that the answer we provide is that we do not represent any me!!).j:i_~r of the ODM staff present or past~ far as we k.now. I add the \"as fu as we know cave ~t\" because we may not know all of the employees present and past of ODM. There was 9. period when I believe ODM employed certain e;,,,.-perts and there may have been some part-time or temporary employees hired from time to time by ODM. With respect to the other questions I do not believe them to applicable in view of the answer to proffered question number one, Moreover, questions three through five invite, if not direct, responses to any imaginary hypothetical situation. I therefore cannot provide an answer to a question which I do not fully comprehend and which is not before me in an actual case. I do wish and intend to reply to the Court, however. Accordingly, I request clarification regarding me last three questions. In making the above report I recall that Judge Susan Webber Wright observed that ODM was not represented by counsel at which point she invited me to begin the questioning of ODM. The position that we took at the hearing on behalf of Joshua was consistent with OD M's and contrary to LRSD's. The hearing about which I speak involve extensive inquiries into LRSD's budgeting process and th.at occurred some seven or eight years ago. I deemed it proper men., as I do now, to reply to the Court. Our position was that LRSD was not meeting its budgeting obligations, ODM staff presented expert testimony to that point which I generally elicii:ed and LRSD opposed it. MAR.18.2004 10=19AM Page Two March 18, 2004 JOHN W WALKER PA N0.498 This is our best understanding of how to reply to the Courr' s Order but if our understanding is incomplete, I respectfully request further guidance from the Court for the Joshua counsel. JWW:lp cc: All Other Counsel (fax only) The Honorable J. Thomas Ray R~spectli;llY su)imitte'7, ;~~ 1-rD/ ~'7l t/i John W. Walker \"Li TO: DATE: FAXCOVERSHEET - UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS Telephone: 501-604-5140 Fax Number; 501-604 5149 Chris Heller 376-2147 Sam Jones 376-9442 Steve Jones 375-1027 John Walker 374-4187 Robert Pressman 781 -862-1955 Timothy Gauger 682-2591 . Mark Hagemeier 682-2591 Ann Marshall 371-0100 Mark Burnette 375-1940 \"3. / B- O'f c~ e,u~~./, ~ .:~ ;;-~ There are__ pages, including this Cover Sheet, being sent by this facsimile transmission. MESSAGE SENT BY: ~/--- ?Z-rrr-- Office of Judge Wm. R. Wi on, Jr .. U.S. District Court 600 West Capitol, Room 423 Little Rock, Arkansas 72201 Matt Morgan, LRSD Law Clerk 501-604-5141 FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS IN THE UNITED STATES DISTRICT COURT MAR 1 8 2004 EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION JAMES W. McCORMACK CLER' By: ' I 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. MAR 1 9 2004 OFFICE OF DESEGREGATION MONITORING ORDER PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Pending is separate Defendant Arkansas Department of Education's Motion to Withdraw Counsel and For Substitution of Counsel (Doc. No. 3839). Separate Defendant Arkansas Department of Education requests that Mr. Dennis Hansen be withdrawn as counsel since he is no longer actively participating in the day-to-day litigation at the Attorney General's Office. Defendant requests that Mr. Mark Hagemeier be substituted as counsel of record. For good cause shown, separate Defendant Arkansas Department of Education's Motion to Withdraw Counsel and For Substitution of Counsel is GRANTED.  (7--r;,::. IT IS SO ORDERED this / 0 day of March, 2004. 842 DEP CLER: UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT - rlAEL E. GANS Clerk of Court Mr. Will Bond BOND \u0026amp; O'BRIEN 602 W. Main Street Jacksonville, AR 72076 THOMAS F. EAGLETON COURT HOUSE ROOM 24.329 111 S. 10TH STREET ST. LOUIS, MISSOURI 63102 March 18, 2004 VOICE 1314) 244-2400 FAX (314) 244-2780 www.ca8 .uscourts.gov RECEuVED MAR 2 ;- 2004 OFFICE OF DESEGREGATION MONITORING Re: 03-3088 Re: 03-3404 Greg Bollen vs. Lorene Joshua Pulaski Cty . School vs. Greg Bollen Dear Counsel: The court has decided that they will hear this appeal via telephone conference sometime in May. The exact date will be determined at a later time . If you have any conflicts during the month of May, please bring them to our attention at your earliest convenience. If you have any questions regarding this matter, please contact me. tab cc : John W. Walker Rickey H. Hicks Robert Pressman Clayton Roy Blackstock Mark Burnett M. Samuel Jones III Sam Jones Scott Smith Christopher JoH~ellne . Stephen w. Jones Ann Marshall Timothy Gauger Sincerel Trish Calendar Coordinator District Court/Agency Case Number(s) : 4:82-CV-866 WRW RECEIVED MAR 2 3 2004 OFFICE OF DESEGREGATION MONITORING Mark A. Hagemeier Assistant Attorney General M. SamuelJones,III Wright, Lindsey \u0026amp; Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 THE ATTORNEY GENERAL STATE OF ARKANSAS MIKE BEEBE March 22, 2004 Direct dial: (501) 682-3643 E-mail: mark.hagemeier@ag.state.ar.us Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 Stephen W. Jones Jack, Lyon \u0026amp; Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Marshall Office of Desegregation Monitoring 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Re: Little Rock School District v. Pulaski County Special School District, et al. USDC No. LR-C-82-866 Dear Counselors and Ms. Marshall: Please find enclosed the Response to Court Order by Separate Defendant Arkansas Department of Education which we filed today. 323 Center Street Suite 200  Little Rock, Arkansas 72201 (501) 682-2007  FAX (501) 682-2591 Internet Website http://www.ag.state.ar.us/ Page 2 of2 March 22, 2004 MAH Enclosures Very truly yours, ~ ~~y Assistant Attorney General UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. RESPONSE TO COURT ORDER BY SEPARATE DEFENDANT ARKANSAS DEPARTMENT OF EDUCATION PLAINTIFF DEFENDANTS Separate Defendant Arkansas Department of Education, by and through its attorneys, Attorney General Mike Beebe and Assistant Attorney Mark A. Hagemeier, for its Response to Court Order dated March 17, 2004, state: 1. Ms. Ann Marshall of the Office of Desegregation Monitoring (\"ODM\") - supplied the Office of the Attorney General with a list of past and present employees. 2. Undersigned has circulated this list of past and present ODM employees to attorneys within the Office of the Attorney General who have worked on this matter. 3. Tim Gauger, Dennis Hansen, and Mark Hagemeier have never represented a past or present employee of ODM. By: Respectfully Submitted, MIKE BEEBE Attorney General MARK A. HAG IER, #9 Assistant Atto:; en:l 323 Center Street, Suite 200 Little Rock, AR 72201-2610 (501) 682-3643 ---- ----- -------------------- - CERTIFICATE OF SERVICE I, Mark A. Hagemeier, Assistant Attorney General, do hereby certify that I have served the foregoing by depositing a copy in the United States Mail, postage prepaid, this ;}-;). day of March 2004, addressed to: Stephen W. Jones Jack, Lyon \u0026amp; Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings LLP 200 W. Capitol, Suite 2300 Little Rock, AR 72201-3699 Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 John W. Walker John Walker, P.A. 1 723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 Mark A. Hageer 2 Rec Er 67ED MITCHELL, BLACKSTOCK, BARNES, WAGONER, IVERS AND SNEDDON, PLLC MA\\ 2 ~1 2004 Dr:S'\" OFFICE OF EUGENE R. WARREN (1909-1980) MICHAEL W. MITCHELL* CLAYTON R. BLACKSTOCK** MARCIA BARNES JACK WAGONER III DAVID IVERS EMILY SNEDDON MARK BURNETTE OLIVER HAHN Mr. SamuelJones,III Wright, Lindsey \u0026amp; Jennings 200 W. Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. l 723 Broadway Little Rock, AR 72201 Ms. Ann Marshall One Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 7220 l ATIORNEYS 1010 WEST THIRD STREET LITTLE ROCK, ARKANSAS 72201 (501) 378-7870 www .mbbwi.com Writer's e-mail: mburnette@mbbwi.com March 25, 2004 1: i:Gl1EG11T:O:, ?.lDi'fTDR!W~ MAILING ADDRESS P.O . BOX 1510 LITTLE ROCK, AR 72203-1510 TELEFAX 501-375-1940 *CERTIFIED IN CIVIL TRIAL ADVOCACY BY NATIONAL BOARD OF TRIAL ADVOCACY ** ALSO LICENSED IN TEXAS Mark Arnold Hagemeier Arkansas Attorney General's Office Catlett-Prien Tower Building 323 Center Street, Suite 200 Little Rock, AR 72201 Mr. Christopher Heller Friday, Eldrege \u0026amp; Clark 400 W. Capitol, Ste. 2000 Little Rock, AR 72201 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 W. Capitol, Ste. 3400 Little Rock, AR 72201 Re: Little Rock School District v. PCSSD, et. al. U.S.D.C. No. 4:82CV00866WRW Ms. Marshail and Gentlemen: I enclose herein a file-marked copy of a Response to Court Order by Knight Intervenors. MTB/dm Encl. Very truly yours, Mark T. Burnette IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. 4:82CV00866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. FILED U.S. o:::~;:_ ICT COURT EASTER:, C,::;:,:..1..:-;- K-;.KANSAS MAR 2 5 2004 JAMES W. McCOri.:.,,.\\SK, CLERK By:.---------;:;-=-;~;-;; C:::? CLERK PLAINTIFF DEFENDANT INTER VEN ORS INTER VEN ORS RESPONSE TO COURT ORDER BY KNIGHT INTERVENORS Come the Knight Intervenors, by and through their undersigned counsel, and for their response to the Court's Order of March 17, 2004, state: 1. Undersigned counsel obtained a roster of ODM employees and distributed the roster to all current attorneys in this firm. 2. No attorney client relationship has existed between any of the listed employees of ODM and an attorney in this firm. It may also be worth noting that Emily Sneddon, a partner in this firm, was employed as a law clerk in the office of the Honorable Susan Webber Wright during a period when Judge Wright presided over this case. Ms. Sneddon does not participate in the case in her current position. Respectfully submitted, Clayton Blackstock Mark Burnette MITCHELL,BLACKSTOCK, BARNES WAGONER, IVERS \u0026amp; SNEDDON, PLLC 1010 West Third P. 0. Box 1510 Little Rock, AR 72203-1510 (501) 378-7870 By: 72:lMfl~/1/Yldtv Mark Burnette N # 88078 Certificate of Service A true and accurate copy of the foregoing has been mailed to the following by U.S. Mail, postage paid, on this.24\"\" day of March, 2004: ,;f.at?I Mr. 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 Ms. Ann Marshall One Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mark Arnold Hagemeier Arkansas Attorney General's Office Catlett-Prien Tower Building 323 Center Street, Suite 200 Little Rock, AR 72201 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 W. Capitol, Suite 2000 Little Rock, AR 72201 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 W. Capitol , Suite 3400 Little Rock, AR 72201 By: 2?kJ,/3trA21d/ Mirk Burnette BAR NO. 88078 R.ECEjVED MAR 2 9 2004 OFFICE OF - ESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS FILED U.S. DI STRICT COURT EASTERN  : STRICT ARKANSAS MAR 2 6 2004 WESTERN DIVISION JAMES W. McCORMACK, CLERK LITTLE ROCK SCHOOL DISTRICT By: ________ __,= PLAINTIFF DEP CLERK V. CASE NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. DEFENDANTS INTERVENORS INTERVENORS JOSHUA INTERVENORS' RESPONSE TO THE COURT'S MARCH 17, 2004 ORDER Mrs. Lorene Joshua, et al. (\"Joshua\"), Intervenors herein, by their undersigned attorneys, submit this JOSHUA INTERVENORS' RESPONSE To THE COURT'S MARCH 17, 2004 ORDER and state the following: FACTS On October 15, 2002, Joshua filed a pleading entitled \"The Joshua Intervenors ' Motion for Relief Concerning the ODM1 Budget.\" Paragraph 1 of that pleading stated, \"It has come to the attention of the Joshua Intervenors that this court (sic) is in the process of reducing the ODM staff and budget. A member of the ODM staff affected by staff and budget reductions planned by the court (sic) has contacted counsel for these intervenors with regard to her legal rights.\" Oct. I 5, 2002 Mot. for Relief Concerning the ODM Budget, 1. The \"member of the ODM staff' referred to in that pleading is Linda Bryant (\"Ms. Bryant\"). Joshua did not file its pleading to seek individual relief for Ms. Bryant. Joshua' s sole purpose for filing the pleading was to gain access to documents and other materials so that 1 ODM is the Office of Desegregation Monitoring created by the United States Court of Appeals for the Eighth Circuit in 1990. Little Rock Sch. Dist. v. Pulaski County Special Sch. Dist. o. 1, 921 F.2d 1371 , 1388 (8th Cir. 1990). Joshua could \"make recommendations concerning or objections regarding the ODM budget and elements thereof, prior to their implementation.\" Oct. 15, 2002 Mot. for Relief Concerning the ODM Budget ~~ 5(a), 5(b); see also Oct. 15, 2002 Mem. Concerning the ODM Budget. On October 16, 2002, the Court denied Joshua's motion without prejudice, holding it was premature. Oct. 16, 2002 Order. On October 25, 2002, Joshua filed a pleading entitled, \"The Joshua Intervenor's (sic) Motion to Stay Reduction of ODM Staff.\" Paragraph 1 of that pleading stated, \"On or about October 14, 2002, Intervenors' counsel learned from an African American staff member of ODM, Ms. Linda Bryant, that she had been given notice of termination as an ODM staff member effective on or about October 15, 2002. Ms. Bryant conveyed to counsel her understanding that her termination was attributable to a directive or requirement of this Court.\" Oct. 25, 2002 Mot. to Stay Reduction of ODM Staff~ 1. Again, the purpose of this particular pleading was not to seek individual relief for Ms. Bryant, rather, Joshua simply wanted the opportunity to provide its input into the budget of the ODM prior to the Court ordering a reduction of its budget. Oct. 25, 2002 Mot. to Stay Reduction of ODM Staff at 2. Holding that the motion for a stay was moot, the Court denied Joshua's motion the same day Joshua filed it. Oct. 25, 2002 Order. On March 17, 2004, the Court entered an order requesting each party's attorneys to answer the following questions: (1) Do you or any member of your firm represent anyone who is now or has been employed by the Office of Desegregation Monitoring (\"employee is to be construed broadly regardless of job description)?\"; (2) The Dates of any such attorney-client relationship; (3) Whether you deem it proper for a lawyer representing a party in this case to represent an employee of the ODM; (4) If you deem it proper, please explain your position in 2 exact and plenary detail, with citations of authority; (5) If you deem it improper, please explain your position in exact and plenary detail, with citations of authority.\" Mar. 17, 2004 Order. APPLICABLE LAW Before answering the Court's inquiries, a discussion of the applicable law is appropriate. On May 1, 1980, the United States District Court for the Eastern and Western Districts of Arkansas adopted the Model Federal Rules of Disciplinary Enforcement, codified at the Appendix to the Rules of the United States District Court for the Eastern and Western Districts of Arkansas. Rule IV.B of the Model Federal Rules of Disciplinary Enforcement provides in relevant part, \" .. . The Code of Professional Responsibility or Rules of Professional Conduct adopted by this Court is the Code of Professional Responsibility or Rules of Professional Conduct adopted by the highest court of the state in which this Court sits, as amended from time to time by that state court, except as otherwise provided by specific Rule of this Court after consideration of comments by representatives of bar associations within the state.\" In 1985, the Supreme Court of Arkansas adopted the American Bar Association 's Model Rules of Professional Conduct as the State of Arkansas's code of professional responsibility. Jones v. Clinton, 36 F. Supp.2d 1119, 1132 n.19 (E.D. Ark. 1999) (citing In re Arkansas Bar Ass ' n, 287 Ark. 495, 702 S.W.2d 326 (1985)). Thus, the Arkansas Model Rules of Professional Conduct is the starting point for analyzing the ethical duties of lawyers practicing before this Court. Model Fed. R. of Disciplinary Enforcement IV.B . In order to determine a lawyer's authority and responsibility, principles of substantive lav.r external to the .. 1odel Rules of Professional Conduct determine whether a client-la,.vyer relationship exists. Scope, Model R. of Profl Conduct~ 3. Most of the duties flowing from the client-lawyer relationship attach only after the client has requested the lawyer to render legal ,., .) - services and the lawyer has agreed to do so. See id. (emphasis added). But there are some duties, such as that of confidentiality under Rule 1.62 , that may attach when the lawyer agrees to consider whether a client-lawyer relationship shall be established. See id. Whether a clientlawyer relationship exists for any specific purpose can depend on the circumstances and may be a question of fact. See id; see also Cortinez v. Supreme Ct. Comm. on Profl Conduct, 332 Ark. 455, 464, 966 S.W.2d 251 (1998). The attorney-client relationship is not simply the casual assistance of a member of the bar, but is an intimate process of consultation and planning which culminates in a state of trust and confidence between the client and his attorney. Clements v. State, 306 Ark. 596, 607, 608, 817 S.W.2d 194 (1991) (citing Smith v. Superior Ct. of Los Angeles, 440 P.2d 65 (Cal. 1968); McKinnon v. State, 526 P.2d 18 (Ak. 1974); People v. Davis, 449 N.E2d 237 (Ill. App. Ct. 1983); In re Welfare of M.R.S., 400 N.W.2d 147 (Minn. Ct. App. 1987)). 2 The text of Rule 1.6 provides: Rule 1.6. Confidentiality of information. (a) A lawyer shall not reveal information relating to representation of a client unless the client consents after consultation, except for disclosures that are impliedly authorized in order to carry out the representation, and except as stated in paragraph (b ). (b) A lawyer may reveal such information to the extent the lawyer reasonably believes necessary: ( 1) to prevent the client from committing a criminal act; or (2) to establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and the client, to establish a defense to a criminal charge or civil claim against the !a,.,,yer based upon conduct in which the client was involved, or to respond to allegations in any proceeding concerning the lawyer's representation of the client. (c) Neither this Rule nor Rule 1.8(b) nor Rule l.16(d) prevents the lawyer from giving notice of the fact of withdrawal, and the lawyer may also withdraw or disaffirm any opinion, document, affirmation or the like. 4 The relationship is not dependent only an express agreement, it may be implied on the part of an attorney who acts in behalf of his client in pursuance of a request by the latter. Sexton v. Supreme Ct. Comm. on Profl Conduct, 295 Ark. 141 , 147 (747 S.W.2d 94 (1988) (Hays \u0026amp; Glaze, JJ., dissenting) (citing Hirsch Bros. \u0026amp; Co. v. R.E. Kennington Co., 124 So. 344 (Miss. 1929); 88 A.LR. 1; 7A C.J.S.  169). Although the Model Rules are silent on the subject, the Supreme Com1 of Arkansas has stated that attorneys remain obligated to avoid any \"appearance of impropriety.\" Arkansas Att'y Gen. Op. No. 2002-347 (citing Saline Mem'l Hosp. v. Berry, 321 Ark. 588, 906 S.W.2d 297 (1995); Burnette v. Moman, 303 Ark. 150, 794 S.W.2d _145 (1990)). Joshua will now turn to answering the Court's questions. I. JOSHUA'S ATTORNEY'S \"REPRESENTATION\" OF MS. BRYANT On or about October 14, 2002, Ms. Bryant informed Joshua's attorney that her employment with the ODM was about to be terminated and sought counsel regarding her legal rights. Oct. 15, 2002 Mot. for Relief Concerning the ODM Budget 1 1; Oct. 25 , 2002 Mot. to Stay Reduction of ODM Staff 1 1. When Ms. Bryant communicated her desire to have Joshua's attorney explain her legal rights to her, at that specific moment the duty of confidentiality codified in Model R. of Pro fl Conduct 1.6 was triggered. Scope, Model R. of Prof 1 Conduct 1 3. Upon learning where Ms. Bryant worked and what relief she was seeking, Joshua's attorney told her in unambiguous terms that he could not represent her and that she needed to look elsewhere Lu ublain representation. Joshua's attorney did not rendef any substantive advice, such as informing her of the statute of limitations or the remedies available to her or what administrative measures she had to take prior to obtaining judicial relief. 5 In fact, Joshua's attorney strictly followed Model R. of Profl Conduct 4.33 and gave Ms. Bryant no advice other than to find another attorney. Model R. of Profs Conduct 4.3 cmt. (comparing Rule 4.3 to American Bar Association rule DR 7-104(A)(2) and stating that a lawyer shall not give advice to a person who is not represented by a lawyer, other than the advice to secure counsel). Because Joshua's attorney declined to represent Ms. Bryant and offered no substantive legal advice in the course of declining the representation, most of the other duties flowing from the client-lawyer relationship did not attach. Scope, Model R. of Prof! Conduct ,r 3 (stating \"most of the duties flowing from the client-lawyer relationship attach only after the client has requested the lawyer to render legal services and the lawyer has agreed to do so\") (emphasis added). Had Ms. Bryant communicated information to Joshua's attorney that was materially adverse to another party in this case (which she most certainly did not), it is arguable that Joshua's attorney would be barred from using that information by Model Rules 1.6 and l.7(b). Rule 1.7(b) provides, \"A lawyer shall not represent a client if the representation of that client may be materially limited by the lawyer's responsibilities to another client or to a third person, or by the lawyer's own interests.\" In the instant case, nothing Ms. Bryant told Joshua's attorney could be reasonably construed to be adverse to the Joshua Intervenors or perhaps more importantly, to the ODM. The ODM is not a party to this case. In fact, Joshua and ODM's interests and efforts are often congruent in that Joshua and the ODM have a duty to monitor the 3 The text of Rule 4.3 provides: Rule 4.3. Dealing with unrepresented person. In dealing on behalf of a client with a person who is not represented by counsel, a lawyer shall not state or imply that the lawyer is disinterested. When the lawyer knows or reasonably should know that the unrepresented person misunderstands the lawyer's role in the matter, the lawyer shall make reasonable efforts to correct the misunderstanding. 6 - school districts ' compliance with their desegregation obligations. Little Rock Sch. Dist. v. Pulaski County Special Sch. Dist. o. 1. 921 F.2d 1371 , 1388 (8th Cir. 1990) (holding, \"As indicated above, this does not mean that the parties will be free of supervision or monitoring. Quite the contrary: a necessary condition of our holding that the plans are not facially unconstitutional is that the parties' compliance with them will be carefully monitored. As we shall make clear at the conclusion of this opinion, when we set out the directions to be followed by the District Comi on remand, the office previously known as the Office of the Metropolitan Supervisor will be reconstituted as the Office of Desegregation Monitoring, to be headed by a Monitor appointed by the District Court, with such additional personnel as the District Court shall deem appropriate\"). In 1978 or 1979, Joshua's attorney was plaintiffs' counsel  in a federal class action discrimination lawsuit against First National Bank in a case styled Raymond Smith v. First Nat'! Bank. Ms. Bryant was a member of the plaintiffs' class, but was not a named plaintiff or class representative. This representation lasted approximately two years and terminated prior to the filing of the instant case and nearly a decade prior to the OD M's creation. Thus, in answer to the Court's first query, Joshua's attorney owes a Rule 1.6 duty of confidentiality to Ms. Bryant stemming from her seeking his legal advice and his declining to give it in connection with her employment with the ODM, because an attorney-client relationship between Ms. Bryant and Joshua's attorney formed for the period in which Ms. Bryant sought legal advice from Joshua's attorney. Scope, Model R. of Profl Conduct~ 3. That relationship, however, terminated when Joshua's attorney declined to represent Ms. Bryant, and that termination relieved Joshua's attorney of most of the duties that typically flow from an attorney-client relationship. See id. Joshua's attorney also owes a duty of confidentiality to Ms. 7 Bryant based on her membership in the class of plaintiffs in the Ravmond Smith case. That attorney-client relationship terminated over twenty years ago and preceded the filing of this case and the creation of the ODM. II. THE DATES OF JOSHUA'S ATTORNEY'S \"ATTORNEY-CLIENT RELATIONSHIP\" Joshua's attorney's representation of Ms. Bryant in the Raymond Smith lasted from 1978 or 1979 until 1980 or 1981. Ms. Bryant's fleeting attorney-client relationship with Joshua's attorney in connection with her employment with the ODM occurred on or about October 14. 2002. The relationship terminated on that same date. III. THE PROPRIETY OF REPRESENTING AN EMPLOYEE OF THE ODM This question is difficult to answer given the hypothetical nature in which it is posed. In essence, the Court is seeking an advisory opinion from the attorneys in this case. While the Court has the discretion to do this, exercising that discretion raises the same issues for the attorneys as the Court itself would face were the attorneys to seek an advisory opinion from the Court. An advisory opinion is one rendered when no justiciable case or controversy exists. Flast v. Cohen, 392 U.S. 93, 95 (1968). Under Article III, courts are required to \"avoid issuing advisory opinions based upon hypothetical situations.\" Briggs v. Ohio Elections Comm'n 61 F.3d 487, 493 (6th Cir. 1995). A court's judgment \"must resolve a real and substantial controversy admitting of specific relief through a decree of a conclusive character, as distinguished from an opinion advising what th .. 1\"'\\\" \\\"O\"lrl ho \"pen,, h\" pothetic\u0026lt;\u0026gt;l cet of .::ark\" prPicer 'I l\\Te,,,lrirlr 4')') TT Q io.;; LI.QI (107\u0026lt;;) \\. J.J. ..... J.'-4'1' 'I' 1,,t.J.'-6. V .._,\\A. J.\\A.J.J J..1.1,..1.\\A.._, 1;...,.,._,. J..._,.1.-.14 .4, ',f' .1.\".1..1.J.\"-I ,;,..,,;,.., .._.,  ._,,_,_,,_,, I \\ /I _,, Determining whether an opinion would be advisory is interrelated with the question of whether there exists a case or controversy. State of Ohio ex rel. Celebrezze v. United States Dep't of 8 Transp. 766 F.2d 228, 232 (6th Cir. 1985). The requirements of standing, ripeness, and mootness guard against the issuing of advisory opinions. See id. With that said, Joshua will answer the question based on the factual predicate set forth in Sections I and II of this pleading. Because Joshua's attorney declined to represent Ms. Bryant in connection with her employment with the ODM and in so doing fastidiously avoided rendering any substantive legal advice, the ephemeral attorney-client relationship created and terminated on October 14, 2002 does not conflict with any duties Joshua's attorney owes to any party in this case, another client, or Joshua's attorney's own interests. Model R. Profl Conduct l.7(b). This is so because the brief encounter between Ms. Bryant and Joshua's attorney contained none of the elements that attend the conventional, substantive attorney-client relationship. Clements v. State. 306 Ark. 596, 607, 608, 817 S.W.2d 194 (1991). Thus, under this particular set of facts, there was and is nothing improper vis-a-vis the instant case about Joshua's counsel meeting with Ms. Bryant on October 14, 2002, listening to her request for representation, and declining to provide that representation. Likewise, Ms. Bryant's status a class member in the Raymond Smith does nothing to compromise Joshua's attorney's duties to any party in this case, another client, or Joshua's attorney's own interests. Model R. Profl Conduct l.7(b). This is so because that representation started and ended prior to the filing of the instant case and prior to the ODM's creation. Moreover, that representation did not involve any of the parties or issues in this case. Therefore, that former representation in light of this case was also proper. There are countless scenarios under which an attorney for a pa1iy in this case could be approached by an employee of the ODM seeking representation in myriad areas of the law, therefore, Joshua cannot opine on the propriety of representing an employee of the ODM in 9 representation and did not offer Ms. Bryant any substantive legal advice. Declining the - representation terminated the attorney-client relationship, thereby eliminating any potential conflict Joshua's attorney might have with another client, a third party, or any party to this case. Model R. ofProf'l Conduct l.16(a)(l), l.7(b).  Joshua's attorney's representation of Ms. Bryant in the Raymond Smith does not create a conflict because it started and ended prior to this case being filed. Joshua hopes it has answered the questions put to it by the Court in a satisfactory manner. Respectfully submitted, ~ ~ ,tp- ToM LU. John W. Walker Ark. Sup. Ct. Reg. No. 64046 John W. Walker, P.A. 1723 Broadway Street Little Rock, Arkansas 72206-1250 Telephone (501) 374-3758 Facsimile(501)374-4187 Robert Pressman Mass. Bar No. 405900 Attorney at Law 22 Locust Avenue Lexington, Massachusetts 02421-5817 Telephone (781) 862-1955 not only that associate, but with the entire firm at least until the associate declines to answer the question or declines the representation. Scope, Model R. of Pro fl Conduct 13 . 11 every conceivable context different from the specific facts involving Ms. Bryant and Joshua's attomey4. Those are the only facts before the attorneys in this case per the plain language of the Court's March 18, 2004 Order. Mar. 18, 2004 Order 11 3-5. Given that, Joshua is inclined to follow the pattern of federal appellate courts and decline to answer anything more than the specific question put before it. Joshua's misgivings notwithstanding, in order to comply as fully as possible with the Cami's directives of March 17 and 18, 2004, Joshua can say that as a general matter, if a current ODM employee sought representation from Joshua's counsel, it would probably be prudent to decline that representation so as not to raise the specter of conflict with the intervenors. Model R. of Profl Conduct 1.7(b). On the other hand, if a former employee of the ODM sought representation for a matter unrelated to that person's employment with the ODM and unconnected from that facts and paiiies in this case, that representation probably could be undertaken. CONCLUSION An abbreviated attorney-client relationship between Ms. Bryant and Joshua's attorney began and ended on or about October 14, 2002 only because Ms. Bryant sought legal advice from Joshua's attorney. Scope, Model R. of Profl Conduct 1 3. Joshua's attorney declined the representation and did not offer Ms. Bryant any substantive legal advice. Declining the representation terminated the attorney-client relationship, thereby eliminating any potential 4 For example, Messrs. Jones and Mr. Heller work for large, full-service law firms with numerous partners, associates, and support staff. Presumably, any of their partners or associates could be approached by an employee of the ODM seeking advice on anything from domestic relations, tax, probate, or any other legal issue. Theoretically, that employee could approach a newly hired associate in a social setting, ask the associate for an opinion about something completely unrelated to the ODM or this case, and establish an attorney-client relationship with not only that associate, but with the entire firm at least until the associate declines to answer the question or declines the representation. Scope, Model R. of Profl Conduct 13. CERTIFICATE OF SERVICE We, the undersigned attorneys for l'virs. Lorene Joshua et al., Intervenors herein, hereby certify that a true and correct copy of the foregoinfi JOSHUA INTERVENORS' RESPONSE TO THE COURT'S MARCH 17, 2004 has been served this 261 1 day of March, 2004, by mailing a copy by First Class United States Mail to : Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Avenue Little Rock, Arkansas 72201-3493 Stephen W Jones Jack, Lyon \u0026amp; Jones, P.A. 425 West Capitol Avenue, Suite 3400 Little Rock, Arkansas 72201-3472 M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings LLP 200 West Capitol Avenue, Suite 2300 Little Rock, Arkansas 72201-3699 Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers \u0026amp; Sneddon 1010 West Third Street Little Rock, Arkansas 72201-2039 Ann Marshall Office of Desegregation Monitoring One Union National Plaza 124 West Capitol Avenue, Suite 1895 Little Rock, Arkansas 72201-3714 Dennis R Hansen Chief Deputy Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201-2610 J,9tuYW. Walker  Ko-bert Pressman 12 P.3 CERTIFICATE OF SERVICE We, the undersigned attorneys for Mrs. Lorene Joshua et al., Intervenors herein, hereby certify that a true and correct copy of the foregointf JOSHUA INTERVENORS' RESPONSE To THE COURT'S MARCH 17, 2004 has been served this 26 day of March, 2004, by mailing a copy by First Class United States Mail to: Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Avenue Little Rock. Arkansas 72201-3493 Stephen W. Jones Jack, Lyon \u0026amp; Jones, P.A. 425 West Capitol Avenue, Suite 3400 Little Rock, Arkansas 72201-3472 M.SamuelJones,m Wright, Lindsey \u0026amp; Jennings LLP 200 West Capitol Avenue, Suite 2300 Little Rock, Arkansas 72201-3699 Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers \u0026amp; Sneddon 1010 West Third Street Little Rock, Arkansas 72201-2039 Ann Marshall Office of Desegregation Monitoring One Union National Plaza 124 West Capitol Avenue, Suite 1895 Little Rock, Arkansas 72201-3714 Dennis R Hansen Chief Deputy Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201-2610 John W. Walker Robert Pressman 12 JOHN W. WALKER SHAWN CHILDS Christopher Heller JOHN W. WALKER, P.A. ATIORNEY AT LAW 1 723 BROADWAY LITILE R OCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 March 26, 2004 FRIDAY, ELDREDGE \u0026amp; CLARK 2000 Regions Center 400 West Capitol Avenue Little Rock, Arkansas 72201-3493 RECEIVED MAR 2 9 2004 OFFICE /JF DESEGREGATiOU MO~{lf Cfi/NG OF COUNSEL ROBERT McHENRY, P.A. . DONNA J. McHENRY 8210 HENDERSON RO . .\\D LITTLE ROCK, ARKANSAS 72210 PHONE: (501) 372-3425  FAX (501) 372-3428 E~WL: mchenryd@swbell.net RE: Little Rock Sch. Dist v. Pulaski County Special Sch. Dist. No. 1, et al. In The United States District Court Eastern District of Arkansas Western Division Case Number 4:82CV00866 WRW/JTR Dear Mr. Heller: Enclosed please find a file marked copy of JOSHlJA TNTERVENORS' RESPONSE To TI-lE COURT'S MARCI-I 17, 2004 ORDER. Please telephone me if you have any questions, comments, or concerns. Thank you for your attention to this matter. TC Enclosures (1 ) Cc Robert Pressman Mark Burnett Stephen W. Jones M. Samuel Jones, III Dennis R. Hansen Ann Marshall IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. 4:82CV00866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PCSSD'S RESPONSE TO ORDER RECEIVED MAR 2 9 2004 OFFICE OF DESEGREGATIOrJ f:10 NITORING PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS The PCSSD, by counsel, will address the five numbered paragraphs in the Court's Order of March 17, 2004, seriatim. 1. No. However, in approximately 1987, Gene Jones was the assistant superintendent for instruction in the PCSSD and the District's representative on the Magnet Review Committee which was then in its nascent stage. Mr. Gene Jones recalls that undersigned counsel helped prepare him for testimony on one occasion concerning Magnet Review Committee issues during that time period. 2. While undersigned counsel does not believe that the foregoing described episode arose to an attorney-client relationship, even as broadly construed, the episode occurred some time during 1987. Of course, this event predated the formation of the ODM by several years and predates Mr. Gene Jones' employment with the ODM by many years . 3. No. 487697-v1 4. Not applicable. 5. The ODM is an \"arm of the court\" and plays a special role in this institutional reform litigation. Accordingly, and especially if school counsel made a conscious decision to represent an employee of the ODM, then other parties could make a cogent argument that the school counsel is disqualified from further representation in the school case because he or she has effectively chosen to represent an employee of an entity directly connected to and originally created by this Court. (See generally Model Rule 1.7). From time to time in the past, one or more of the parties have sought to utilize either the reports of the ODM or testimony from ODM employees to make a point or further their position in these proceedings. Particularly under these unique circumstances, such representation as described in the Court's order should be avoided. Because the monitoring or recommendations made by the ODM can in fact influence the practices of a school district, or could have an affect upon the practices, presentations or positions of any party to this case, then discretion would seem to behoove that such representation be eschewed. Stated another way, if an employee of the ODM was represented by counsel to one of the parties in this case, and particularly if that employee was in a position to influence monitoring outcomes or recommendations to be made by the ODM, and if that counsel had an interest in either the monitoring outcomes or recommendations, then the representation of that ODM employee could present the appearance of impropriety. Particularly since the ODM occupies a high profile position, and presuming that the ODM desires to foster and maintain the trust of the public, any doubt about the representation should be resolved against accepting it. 487697-v1 2 This reasoning seems consistent with certain principles the Arkansas Supreme Court reaffirmed in First American Carriers, Inc. vs. Kroger Company, 302 Ark. 86, 787 S.W.2d 1669 (1990) . In that case, the Court reminded the legal profession that avoiding the \"appearance of impropriety\" was still part of the rules governing attorneys as established by prior decisions of the Supreme Court even though the previous ABA Code of Professional Responsibility had, by then, been replaced by the Model Rules of Professional Conduct. As the Court explained: While Canon 9 is not expressly adopted by the Model Rules, the principle applies because its meaning pervades the Rules and embodies their spirit. It is included in what the preamble to the Rules refers to as \"moral and ethical considerations\" that should guide lawyers who have \"special responsibility for the quality of justice\". Another difficulty could arise as respects the budget of the ODM. The Court routinely refers the proposed annual budget to counsel for all of the parties for comment. If one of the lawyers in this case was representing one of the employees of the ODM, then there would be at least a tension between that representation and certain budget issues, including the proposed compensation for that employee or, particularly as this case \"winds down\", issues such as a reduction in force for the ODM or a curtailment of duties and responsibilities. While such developments might be to the financial interest of one or more of the parties to this case, those issues would likely conflict with the employees' own self interest. Another potential issue presents itself as respects the attorney-client privilege. (Please see the Law of Lawyering, Volume 1,  1.6: 103 @ page 137). It is conceivable that an attorney representing an employee of the ODM could acquire information useful to his \"school 487697-v1 3 client\" in this case. However, even if that information might have otherwise been discoverable through routine means, the fact that the attorney acquired it from his or her ODM client would likely (if not certainly) cause the privilege to attach thereby likely precluding the attorney from using the information that would otherwise be useful to his school client. The problem presented in this example is palpable. Id.@ 1.6:115@ 168.16 Another potential example suggests itself in these circumstances. For instance, the ODM client might confide to the attorney something like \"School District Xis fudging on the numbers it is reporting to the ODM, but don't tell anybody.\" While the attorney might very well have ultimately figured out such a circumstance, and used it to his or her advantage in this case, the fact that he or she initially received the information in an obviously privileged communication is at best problematic. Since the information confided likely does not rise to - the level of a \"crime\" or \"fraud\" as discussed in the Code, (assuming the fudging is a product of sloppiness rather than intent) then more likely than not the attorney cannot use the information to the advantage of his school case client presumably to that client's detriment. See, for instance, the Law of Lawyering,  1.6: 105@ 148.2. As discussed generally in the Law of Lawyering, Id. @ 1. 6: 115 @ 168 .17, the examples given above could arise even in the context of a \"one shot\" consultation to which the privilege would attach, however briefly. Accordingly, it would appear to be clearly prudent to even avoid the potential circumstance of establishing an attorney-client relationship, however fleeting, by simply declining to discuss with any ODM employee any issue that could lead to the formation of the relationship. 487697-v1 4 Respectfully submitted, WRIGHT, LINDSEY \u0026amp; JENNINGS LLP 200 West Capitol Avenue, Suite 2300 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 By~ CERTIFICATE OF SERVICE On March 26, 2004, a copy of the foregoing was served via facsimile and U.S . mail on each of the following : Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 487697-v1 5 Mr. Mark A. Hagemeier Assistant Attorney General Arkansas Attorney General's Office 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, Arkansas 72201 Mr. Clayton Blackstock Mr. Mark Burnett 1010 W. Third Street Little Rock, AR 72201 Judge J. Thomas Ray U.S. District Courthouse 600 West Capitol Avenue, Suite 149 Little Rock, Arkansas 72201 487697-v1 Mr. Robert Pressman 22 Locust A venue Lexington, Massachusetts 02173 6 EDWARD L. WRIGHT (1903 - 1977) ROBERT S. LINDSEY (1913-1991 ) ALSTON JENNJNGS WRIGHT, LINDSEY \u0026amp; JENNINGS LLP ATTORNEYS AT LAW (1917 -2004 ) ISAAC A. SCOTT , JR . JOHN G. LILE GORDON S. RATHER, JR. MARTIN G. GILBERT ROGER A. GLASGOW C. DOUGLAS BUFORD , JR . PATRICK J. GOSS ALSTON JENNINGS. JR . JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J, MULDROW N.M. NORTON CHARLES C. PRICE CHARLEST. COLEMAN JAMES J. GLOVER EDWIN L. LOWTHER, JR . WALTER E. MAY GREGORY T. JONES BETTINA E. BROWNSTEIN WALTER McSPADOEN JOHN O. DAVIS JUDY SIMMONS HENRY VIA HAND DELIVERY The Honorable Wm. R. Wilson, Jr. U.S. District Courthouse 600 West Capitol Avenue, Suite 423 Little Rock, Arkansas 72201 200 WEST CAPITOL A VENUE SUITE 2300 LITTLE ROCK , ARKANSAS 72201 - 3699 (501) 371 -0808 FAX (501) 376-9442 www . wlj .com OF COUNSEL RONALD A. MAY BRUCE R. LINDSEY JAMES R. VAN DOVER GREGORY S. MUZINGO .. Writer ' s Direct Dial No . S0l -212 - 1273 mjones@wlj .com March 26, 2004 KIMBERLY WOOD TUCKER RAY F. COX. JR . TROY A. PRICE PATRICIA SIEVERS HARRIS KATHRYN A. PRYOR J. MARK DAVI S CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J. SALLINGS WILLIAM STUART JACKSON MICHAEL 0 . BARNES STEPHEN R. LANCASTER JUDY ROBINSON WILBER KYLER . WILSON C. TAD BOHANNON KRISTI M. MOODY J. CHARLES DOUGHERTY M. SEAN HATCH J. ANDREW VINES JUSTIN T. ALLEN MICHELLE M. KAEMMERLING SCOTT ANDREW IRBY PATRICK D, WILSON REGINA A. SPAULDING MARY ELIZABETH ELDRIDGE BLAKES . RUTHERFORD PAUL D. MORRIS  LicaJ.Wtnpncticeb!JiJrrtMUnitiedSutes Patent UJd Tndi:rwrk Offic.e 0 J..icauf tn pnctk:e in M\",cbipn only MAR 2 ~l 2004 OFFICE OF DESEGREt:rnTIOM MONITOR!N0 Re: Little Rock School District v. Pulaski County Special School District; et al. USDC Docket No.: 4:82CV00866WRW Dear Judge Wilson: Enclosed is a courtesy copy of the PCSSD response to the Court's order of March 17, 2004. Because of the Court's impending deadline, copies of being faxed to all counsel in this case as well. MSJ:ao Encls. cc/w/encls.: 488399-vl Cordially yours, WRIGHT, 6 Honorable J. Thomas Ray (via hand delivery) Mr. Robert Pressman (via facsimile and U.S. Mail) All Counsel of Record (via facsimile and U.S. Mail) THE ATTORNEY GENERAL STATE OF ARKANSAS MIKE BEEBE , MAR Z : 2004 Mark A. Hagemeier Assistant Attorney General Direct dial: (501) 682-3643 E-mail: mark.hagemeier@ag.state.ar.us M. SamuelJones,III Wright, Lindsey \u0026amp; Jennings 2000 NationsBank Bldg. 200 W. Capitol Little Rock, AR 72201 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 March 26, 2004 Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 Stephen W. Jones Jack, Lyon \u0026amp; Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Ann Marshall Office of Desegregation Monitoring 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Re: Little Rock School District v. Pulaski County Special School District, et al. USDC No. LR-C-82-866 Dear Counselors and Ms. Marshall: Please find enclosed AD E's Supplemental Response to the Court's Order of March 17, 2004 that we filed today. 323 Center Street  Suite 200  Little Rock, Arkansas 72201 (501) 682-2007  FAX (501) 682-2591 Internet Website  http://www.ag.state.ar.us/ Page 2 of 2 March 26, 2004 MAH Enclosure Very truly yours, Y1~-~ ~ MARK.A. HAGEr Assistant Attorney General UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT v. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. MAP 1- r 2004 PLAINTIFF DEFENDANTS SUPPLEMENT TO RESPONSE TO COURT ORDER BY SEP ARA TE DEFENDANT ARKANSAS DEPARTMENT OF EDUCATION Comes now Separate Defendant Arkansas Department of Education (\"ADE\"), by and through its attorneys, Attorney General Mike Beebe and Assistant Attorney Mark A. Hagemeier, and for its supplement to its Response to Court Order dated March 17, 2004, states: ADE is and was unable to respond definitively to questions 3, 4, and 5 of the Court's Order dated March 17, 2004. ADE believes it lacks sufficient specific facts regarding any particular attorney-client relationship to respond definitively to these three questions. It appears from the Court's questions that the principal concern is that, if there was an attorney-client relationship between an attorney in the case and an employee of ODM, could confidential information have been divulged by that employee to that attorney. If during the attorney-client relationship the ODM employee divulged information to the attorney concerning ODM's or the Court's opinion or contemplated course of action on a subject relevant to this desegregation litigation, then ADE would certainly contend this was improper or, at the very least, created an appearance of impropriety. However, if the attorney-client relationship had nothing to do with this desegregation litigation and if no confidential information was disclosed, then ADE might conclude the relationship was proper. It appears to ADE that there could be circumstances where an attorney-client relationship between an employee of ODM, which is an arm of the Court, and a lawyer or a member of lawyer's firm representing a party in this case could be appropriate. For example, if an ODM employee requested services for an adoption, a will, or a criminal matter from one of these lawyers or their firm, ADE would not think this attorney-client relationship improper. ADE can also imagine, however, various situations that would run the gamut between these two extremes that might create an appearance of impropriety that the Court would want the ODM and its employees to avoid. In conclusion, separate defendant would want to know many more facts before it could opine on whether any particular relationship between an employee of ODM and an attorney in this case was improper or not. By: Respectfully Submitted, MIKE BEEBE Attorney General R, #94127 Assistant Attorney Ge ral 323 Center Street, Suite 200 Little Rock, AR 72201-2610 (501) 682-3643 2 CERTIFICATE OF SERVICE I, Mark A. Hagemeier, Assistant Attorney General, do hereby certify that I have served the foregoing by depositing a copy in the United States Mail, postage prepaid, this ;;)b day of March 2004, addressed to : Stephen W. Jones Jack, Lyon \u0026amp; Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings LLP 200 W. Capitol, Suite 2300 Little Rock, AR 72201 -3699 Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 MarkA. ~eier 3 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF vs. NO. LR-C-82-866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. DEFENDANTS LORENE JOSHUA, et al. KA THERINE KNIGHT, et al. INTERVENORS INTERVENORS RESPONSE TO COURT'S MARCH 17, 2004 ORDER Comes the law firm of Jack, Lyon \u0026amp; Jones, P.A. , counsel for the North Little Rock School District (\"NLRSD\") and in response to the Court's Order of March 17, 2004 states as follows: 1. The law fi rm of Jack, Lyon \u0026amp; Jones, P.A. has co nducted a conflicts search regarding its representation of those individuals listed by Ms. Ann Marshall as having worked for the Office of Desegreation Monitoring in the email of March 19, 2004 from Ms. Ann Marshall , copy attached as Exhibit 1. 2. Jack, Lyon \u0026amp; Jones, P.A. has not represented any of the individuals listed in Exhibit 1. 3. Mr. Gene Jones was previously the Assistant Superintendent for Instruction for the NLRSD during the pendency of this litigation and while Jack, Lyon \u0026amp; Jones , P.A. was representing the NLRSD. However, Jack, Lyon \u0026amp; Jones, P.A. has never represented Mr. Jones individually. 4. In addition , all attorneys at Jack, Lyon \u0026amp; Jones, P.A. have been asked if they have any memory of any conversation with one of the listed individuals regarding any legal matter regardless of how casual the discussion. No attorney has any present memory of any such discussion occurring . By: 2 Respectfully Submitted , pN \u0026amp; JONES, P.A. --- NW. JONES, #7 -083 425 West Capitol Avenu Suite 3400 Little Rock, Arkansas 72201 (501) 375-1122 \"Ann Marshall\" \u0026lt;asbrown@aristotle.ne t\u0026gt; 03/19/2004 11 : 19 AM To: \u0026lt;sjones@jlj .com\u0026gt; cc: Subject: FW: judge wilson's order Hello , Steve. Below are the e-mail exchanges I ' ve had with Chris and Sam re Judge Wilson ' s most recen o rders . I don ' t want to leave you out . At the very bottom is the list of those individuals who have worked for ODM, to the best of our knowledge. Als o , as I pointed out , all of us have at one time worked for ADE, LRSD, NLRSD , or PCSSD . Please let me know if you need any further information, and I ' l l be glad to do what I can. Ann -----Original Message----- From: Ann Marshall [m3ilt o :asbrown@aristotle . net} Sent : Friday , March 19, 20 0 4 10:47 AM To: Chris Heller Cc: mjones@wlj . com Subject : RE : judge wilson ' s order Sam , below is the lis t I sent Chris yesterday. For both of yo u , Chris and Sam , the complete name o f t he person whose last name I couldn ' t recall is Theresa Bradley, who wo rked as a receptionist in the Office of the Metropolitan Supervisor . The name in the list below that reads \"Jackie Bates \" is actually \"Ja c kie Banks , \" who was also a receptionist and is deceased . In reply to your que s tion this morning , Sam, about Gene Jon es ' previous position: he was re ti red when I hired him in 1995. He had mos t recently been assis ta n t supe rin t endent for instruction in the NLRSD. Befor e that , he was dire c t o r o f secondary education and assistant superintende n t for instruction in PCSSD. He was also an associate director for instru c t ion at ADE and once director of t he Metropolitan Education Servi ces Center As a matter of fa c , every employee of t his o ffice , including me, at one time worked for ei t her ADE , PCSSD, LRSD, or NLRSD . Hope this info helps . I f you need more, just holler . Ann -----Original Me s sage -- - -- From: Chris Hel l e r [mailt~ : HELLER@fec .net] Sent : Thursday, March Jo , L004 6 :42 PM To: Alan Bryan; Ale;,:andra l r rah ; Amanda Ros e ; Angelia Chamberlin; Donald Ba con; J.C . Bake r; Darin 8a1.ron ; Tom Baxt e r; Bryan Duke; Robert Beac h ; Joe Bell; Paul Benha m; Bra ndon Ha rrison ; Lee Brown ; Bruce Tidwell ; Larry Bur~s ; Jim Buttry; Carol1n Wall a ce; Jim Clark; Allison Cornwell; Kevin Cra s s ; Coleman Wes:brou~ ; Qsrar Davis; Betty Demory; Walter Ebel; John Echol s ; Byron Ei sema n; r~: -~ Sardne r; Greg Mc Kee; Dave Graf; Will Gri f f in ; Jame s Ha rr is ; C~r:s H~l ler; Jason Hendren ; Dan Herrington; Fra n Hic ~man ; J o seph Hurst ; ~i-- ~ Hut chison; Jonann Con iglio ; Jamie J ones ; Joseph McKay; Jeff Moo r e ; Joey Nichols ; John Peiserich ; jpmsec ; James Smith ; Jay Taylor ; Kimber l y Dickerson ; Khayyam Eddings ; Karen Halbert; Kristen Rowlands; ScotL ~a~~~ste r ; H. T . Larzelere ; Chris Lawson ; Tom Leg ge tt ; Harry Li ght ; ' .. y:, ~\"' .\"o:!nson; Lindsey Mit c ham; Lois Dundee; Diane Mackey ; Phil Ma l c om; Mar - ~~ s~it h; Michelle At or; Marvin Childers; EXHIBIT ii Martin Kasten ; Mike Moore; Michael Moyers; Elizabeth Murray; Wyck Nisbet; Jane Oberste; Ellen Owens ; William PATTON ; Cliff Plunkett ; Ryan Bowman; Robert Smith; Shep RUSSELL ; James Saxton; Steven Brooks; Sarah Cotton; Robert Shafer ; James Simpson; Sam Macheak ; Laura Smith ; Carla Spainhour ; William Sutton; Tim Ezell; Tonia Jones; Scott Tucker ; Fred URSERY; William Waddell ; Guy Wade ; Dewey Watson ; David Wilson ; Wayne Young Cc: fendleyl@alltel . net ; asbrown@aristotle . net Subject : judge wilson ' s order lawyers - judge wilson has required that all lawyers in the pulaski county school desegregation case answer , among others , the fo l lowing question : \"do you or any member of your firm represent anyone who is now or has been employed by the office of desegregation monitoring ( ' employee ' is to be construed broadly regardless of job description ' )? \" the current and forrmer odm employees i ' ve identified so far are : ann marshall (formerly ann brown) , gene jones, horace smith , polly ramer , margie powell , linda ~ryant, connie hickman, bob morgan , bill mooney , skip marshall , melissa gulden , arma hart , jackie bates and prentice dupins . in o r der to properly respond to j. wilson ' s order, i need to know about any communication with any of these people regarding any legal matter , whether or not you believe it amounted to \"representation \" . thanks . ch CERTIFICATE OF SERVICE I, Stephen W. Jones, doe hereby certify that I have served the foregoing by depositing a copy in the United States Mail, postage prepaid , this 26th day of March, 2004, addressed to the following : Mark A. Hagmemeier Assistant Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201 -2610 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72201 Ann Brown Marshall ODM One Union National Plaza 124 West Capitol , Suite 1895 3 Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201 -3493 M. Samuel Jones, Ill Wright, Lindsey, \u0026amp; Jennings 200 W. Capitol , Suite 2300 Little Rock, AR 72201 -3493 Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 JACK, L YoN\u0026amp; JoNEs,P.A. HiECEi~VfED Offices I n: Conway, Arkansas Nashville, Tennessee Mark A. Hagmemeier Assistant Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201-2610 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72201 Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 ATTORNEYS AT LAW 3400 TCBY TOWER 425 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201 (501) 375- 1122 Telecopier (501) 375-1 027 March 26, 2004 Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 M. Samuel Jones, Ill Wright, Lindsey, \u0026amp; Jennings 200 W. Capitol , Suite 2300 Little Rock, AR 72201 -3493 Mark Burnette Attorney at Law 1010 W. 3rd Little Rock, AR 72201 RE: Little Rock School District v. Pulaski County Special School District, et al. U.S.D.C. No. LR-C-82-866 Gentlemen and Ms. Marshall: MAR 2 f: 2004 Enclosed please find North Little Rock School District's Response to the March 17, 2004 Court Order which is being filed with the Court today. SWJ:tl Enclosure Sincerely, ~9~ MAR 3 0 2004 JAMES W. l\\.!ic:COf~L :.\\CK, CLERK By- -------,=--- DEP CLER!( THE LITTLE ROCK SCHOOL DISTRICT'S IMPLEMENTATION OF THE COURT'S COMPLIANCE REMEDY Ann S. Marshall Federal Monitor March 30, 2004 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Gene Jones Associate Monitor UNITED STATES DISTRICT COURT EASTERN DISTRlCT OF ARKAl'fSAS JAMES W. McCORMACK, CLERK WESTERN DIVISION By: OEP CLERK LITTLE ROCK SCHOOL DISTRICT vs. PULASKI COUNTY SPECIAL SCHOOL DISTRlCT NO. 1, et aL MRS. LORENE JOSHUA, et aL KATHERINE K.i~GHT, et aL 4:82CV00866 RECEIVED MAR 01 2004 . OFFICE OF DESEGREGATION MONITORING ORDER PLAINTIFF DEFENDAl~S INTERVENORS INTERVENORS On March 17, 2004 I entered an order directing the lawyers to provide information and give me opinions with respect to representation, or potential representation, of members of the ODM by lawyers representing a party in this lawsuit. It appears that each party agrees that it would be improper, in almost all instances, for a party to represent a member of the ODM Accordingly, the parties and their lawyers are directed to notify the Court immediately if a lawyer for a party undertakes to represent a member of the ODM briefly or for the long haul. \"Representation\" is to be construed broadly as is set forth in the order ofMarch 17, 2004. Incidentally, judges are prohibited from rendering \"advisory\" opinions; on th~ other hand lawyers probably spend ninety percent of their time rendering advisory opinions to their clients and courts.  r_lr IT IS SO ORDERED this ti day of March, 2004. United States District Judge 852 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al DEFENDANTS 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 the ADE's Project Management Tool for March 2004. Respectfully Submitted, cottSmith, #92251 Attorney, Arkansas Department of 'Education #4 Capitol Mall, Room 404-A Little Rock, AR 72201 501-682-422 7 CERTIFICATE OF SERVICE I, Scott Smith, certify that on March 31, 2004, 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. SamuelJones, III Wright, Lindsey \u0026amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1 723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes Wagoner, Ivers \u0026amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Ms. Ann Marshall One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 TOM COURTWAY Interim Director State Board of Education JoNell Caldwell, Chair Little Rock Shelby Hillman, Vice Chair Carlisle Sherry Burrow Jonesboro Luke Gordy Van Buren Calvin King Marianna A Lawson s'Ponvi ii e MaryJane Rebick Lillie Rock Diane Tatum Pine Bluff Jeanna Westmoreland 4.rkadelphia Arkansas Department of Education #4 Capitol Mall, Little Rock, AR 72201-1071 501-682-4475 March 31, 2004 Mr. M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers \u0026amp; Sneddon P. 0 . Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Ms. Ann Marshall One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 http:/ /arkedu.state.ar.us RECEIVED APR - 1 2004 . OFFICE OF DESEGREGATION MONITORING RE: Little Rock School District v. Pulaski County Special School District, et al. US. District Court No. 4:82-CV-866 Dear Gentlemen and Ms. Marshall: Per an agreement with the Attorney General's Office, I am filing the Arkansas Department of Education's Project Management Tool for the month of March 2004 in the above-referenced case. If you have any questions, please feel free to contact me at your convenience. General Counsel Arkansas Department of Education SS:law cc: Mark Hagemeier UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al DEFENDANTS 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 the ADE's Project Management Tool for March 2004. Respectfully Submitted, , - ( ~ ( ' I M4\u0026lt; Jt,;j-t,_ cottSmith, #92251 Attorney, Arkansas Department of :Education #4 Capitol Mall, Room 404-A Little Rock, AR 72201 501-682-4227 CERTIFICATE OF SERVICE - I, Scott Smith, certify that on March 31, 2004, 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 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes Wagoner, Ivers \u0026amp; Sneddon P. 0 . Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Ms. Ann Marshall One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 ------------ ---------------~ 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 March 31, 2004 Based on the information available at February 29, 2004, the ADE calculated the Equalization Funding for FY 03/04, subject to periodic adjustments. B. Include all Magnet students in the resident District's average daily membership for calculation. 1 . Projected Ending Date Last day of each month, August - June.    This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.\u003c/dcterms_description\u003e\n   \n\n\u003c/dcterms_description\u003e   \n\n  \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n  \n\n  \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n   \n\n   \n\n   \n\n\n\n\n\n   \n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n   \n\n\u003c/item\u003e\n\u003c/items\u003e"},{"id":"bcas_bcmss0837_1767","title":"Court filings regarding Arkansas Department of Education (ADE) project management tools, Little Rock School District (LRSD) filing quarterly update, and Office of Desegregation Management (ODM) report.","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2005-01/2005-03"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Education--Arkansas","Arkansas. Department of Education","Project management","Little Rock School District","School districts","Office of Desegregation Monitoring (Little Rock, Ark.)","Education--Evaluation","African Americans--Education","Education--Curricula"],"dcterms_title":["Court filings regarding Arkansas Department of Education (ADE) project management tools, Little Rock School District (LRSD) filing quarterly update, and Office of Desegregation Management (ODM) report."],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1767"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["58 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\u003c?xml version=\"1.0\" encoding=\"utf-8\"?\u003e\n\u003citems type=\"array\"\u003e  \u003citem\u003e   \n\n   \n\n   \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n   \n\n\n   \n\n   \n\n\n   \n\n   \n\n\n\n\n\n\n\n\n\n\n\n\n   \n\n \n\n \n\n \n\n\n   \n\n   \n\n   \n\n\n   \n\n  \n\n   \n\n\n   \n\n  \n\n   \n\n\n   \n\n \n\n\u003cdcterms_description type=\"array\"\u003e   \n\n\u003cdcterms_description\u003eCourt filings: District Court, two notices of filing, Arkansas Department of Education (ADE) project management tools; District Court, Little Rock School District's (LRSD's) notice of filing quarterly update; District Court, notice of filing, Office of Desegregation Management report, \"\"Update of Discipline Sanctions and Compensatory Programs Aimed at Dropout Prevention in the NLRSD\"\"; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool    This transcript was create using Optical Character Recognition (OCR) and may contain some errors.    ,. Arkansas DEPARTMENT OF EDUCATION 4 STATE CAPITOL MAU.  UTTLE ROCK, ARKANSAS 72201-1071  (501) 682-4475  http://arkedu.state.ar.us Dr. Kenneth James, Director of Education Jan~ary 28, 2005 Mr.M. SamuelJones,ill Wright, Lindsey \u0026amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers \u0026amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 JAN 2005 OFFIC[ OF DESEGREGMlOil ;110NITORING Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 RE: Little Rock School District v. Pulaski County Special School District, et al. U.S. District Court No. 4:82-CV-866 WRW Dear Gentlemen: Per an agreement with the Attorney General's Office, I am filing the Arkansas Department of Education's Project Management Tool for the month of January 2005 in the above-referenced case. If you have any questions, please feel free to contact me at your convenience. Sie7~o. ~~-rk General Counsel Arkansas Department of Education SS:law cc: Mark Hagemeier STATE BOARD OF EDUCATION: Chair - JoNell Caldwell, Little Rock Vice Chair - Jeanna Westmoreland, Arkadelphia Members: Sherry Burrow, Jonesboro  Shelby Hillman, Carlisle  Calvin King, Marianna  Randy Lawson, Bentonville MaryJane Rebick, Little Rock  Diane Tatum, Pine Bluff  Naccaman Williams, Johnson An Equal Opportunity Employer UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DNISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 WRW 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 the ADE's Project Management Tool for January 2005. Respectfully Submitted, tt Smith, Bar # 92251 General Counsel, Arkansas Department of Education #4 Capitol Mall, Room 404-A Little Rock, AR 72201 1501-682-4227 CERTIFICATE OF SERVICE I, Scott Smith, certify that on January 28, 2005, 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 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes Wagoner, Ivers \u0026amp; Sneddon P. 0 . Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Arkansas  DEPARTMENT OF EDUCATION 4 STATE CAPITOL MAU  UTILE ROCK. ARKANSAS 72201-1071  (501) 682-4475  http://arkedu.state.ar.us Dr. Kenneth James, Director of Education February 28, 2005 Mr. M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers \u0026amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 I/ ' ,') 1 - ~ 05 I . . l. RE: Little Rock School District v. Pulaski County Special School District, et al. U.S. District Court No. 4:82-CV-866 WRW Dear Gentlemen: Per an agreement with the Attorney General's Office, I am filing the Arkansas Department of Education's Project Management Tool for the month of February 2005 in the above-referenced case. If you have any questions, please feel free to contact me at your convenience. ~3~~ General Counsel Arkansas Department of Education SS:law cc: Mark Hagemeier -ATE BOARD OF EDUCATION: Chair -JoNell Caldwell, Little Rock  Vice Chair -Jeanna Westmoreland, Arkadelphia Members: Sherry Burrow, Jonesboro  Shelby Hillman, Carlisle  Calvin King, Marianna  Randy Lawson, Bentonville MaryJane Rebick, Little Rock  Diane Tatum, Pine Bluff  Naccaman Williams, Johnson An Equal Opportunity Employer UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DNISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 WRW 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 the ADE's Project Management Tool for February 2005. Scott Smith, Bar # 92251 General Counsel, Arkansas Department of Education #4 Capitol Mall, Room 404-A Little Rock, AR 72201 501-682-4227 CERTIFICATE OF SERVICE I, Scott Smith, certify that on February 28, 2005, 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 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1 723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes Wagoner, Ivers \u0026amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 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 WRW 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 February 28, 2005 Based on the information availabl~ at January 31, 2005, the .ADE .calculated the State Foundation Funding for F,Y 04/05, subject to periodic adjustments. B. Include all Magnet students in the resident District's average daily membership for calculation. 1. Projected Ending Date Last day of each month, August - June. IN THE UNITED ST A TES DISTRICT COURi: (, '. ?ii7-j EASTERN DISTRICT OF ARKA:t-f,~ ~-\u0026lt; - __ ,..,,  WESTERN DIVISION  C .t,._   ' \u0026lt;\u0026gt; LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL DEFENDANTS MAR ? 2005 MRS. LORENE JOSHUA, ET AL INTERVENORS OFFI F KA THERINE KNIGHT, ET AL DES GREGATIO!l [,,ONITORING LRSD'S NOTICE OF FILING OUARTERL Y UPDATE INTER VEN ORS Little Rock School District (\"LRSD\") for its Notice ofFiling Quarterly Update dated March 1, 2005 states: 1. The attached document is the second quarterly written update by the Little Rock School District and its Planning, Research, and Evaluation Department. It has been provided to the Joshua Intervenors and the Office of Desegregation Monitoring in accordance with the District Court's 2004 Compliance Remedy (Memorandum Opinion of June 30, 2004). 2. LRSD is filing this Quarterly Update so that the Court may be aware of the compliance work done by LRSD to comply with the Court's Memorandum Opinion of June 30, 2004. WHEREFORE, the LRSD submits its Quarterly Update as required by the Court. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026amp; CLARK Christopher Heller (#81083) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) 376-2011 BY:~k CopherHcler CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on the 1st day of March, 2005 : Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Nations Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Judge J. Thomas Ray U. S. District Courthouse 600 West Capitol Avenue, Suite 149 Little Rock, AR 72201 2 Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Tim Gauger Mr. Mark A. Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Mr. Clayton Blackstock Mr. Mark Burnett 1010 W. Third Street Little Rock, AR 72201 istopherHeller Little Rock School District (LRSD) QUARTERLY UPDATE to Office of Desegregation Monitoring (ODM) and Joshua March 1, 2005 MAR 2 2005 OFFICtOF DESEGREGAT/Oi'J ;,:ONITORING LITTLE ROCK SCHOOL DISTRJCT, PLAINTIFF V. PULASKI COUNTY SPECIAL SCHOOL DISTRJCT NO.1 ET AL., DEFENDANTS MRS. LORENE JOSHUA, ET AL., INTERVENORS KATHERJNE KNIGHT, ET AL., INTERVENORS Planning, Research, and Evaluation (PRE) Little Rock School District 3001 South Pulaski Little Rock, AR 72206 Page I of 18 Introduction This is the second quarterly written update by the Little Rock School District (LRSD) and its Planning, Research, and Evaluation (PRE) Department, submitted in accordance with the District Court's 2004 Compliance Remedy (Memorandum Opinion of June 30, 2004, pp. 61-67). The organization of this report is that of the Compliance Remedy: A. \"LRSD must promptly hire a highly trained team of professionals to reinvigorate PRE.\" B. \"The first task PRE must perform is to devise a comprehensive program assessment process\". which \"must be deeply embedded as a permanent part of LRSD's curriculum and instruction program.\" C. \"During each of the next two academic school years (2004-05 and 2005-06), LRSD must hire one or more outside consultants to prepare four ( 4) formal step 2 evaluations.\" D. \"PRE must (1) oversee the preparation of all eight of these step 2 evaluations; (2) work closely with Dr. Ross and any other outside consultants ... and (3) provide the outside consultants with any and all requested assistance and support ... \" E. Evaluations will contain numbers and grade levels of teachers and administrators who contributed data, recommended program changes necessary for improved academic achievement by African-American students, and brief explanations of how each change will increase a program's effectiveness. F. \" . .. PRE must notify the ODM and Joshua in writing of the names of those eight programs. In addition, after PRE and Dr. Ross have formulated a comprehensive program assessment process and reduced it to a final draft, PRE must provide a copy to the ODM and Joshua at least thirty days before it is presented to the Board for approval . . . by December 31, 2004.\" G. PRE must submit quarterly written updates on the status of the . . . four step 2 program evaluations . .. during the 2004-05 school year and the four step 2 program evaluations that will be prepared during the 2005-06 school year . . . to ODM and Joshua on December 1, March 1, June 1, and September 1. .. \" H. (ODM's responsibilities.] I. [Joshua's responsibilities.] J. Four step 2 program evaluations due to the Court October 1, 2005 and four more due October 1, 2006. K. Compliance Report due October 15, 2006. L. [This Compliance Remedy supersedes earlier one.] Page 2 of 18 Status as of March 1, 2005 A. Hire a highly trained team of professionals. LRSD hired a highly trained team of professionals in 2004 and reported its action in the first quarterly written update, December 1, 2004. This team has continued its duties as described below, in this second quarterly written update. B. Devise and embed a comprehensive program assessment process. At its December 16, 2004 session, LRSD Board of Directors approved the comprehensive program assessment process devised by PRE. The final draft was in Appendix B of the first quarterly written update. C. Hire outside consultant(s) to prepare four formal step 2 evaluations. Credentials of Drs. Catterall and Ross were in this section and Appendix C of the first quarterly written update. Both agreed to prepare step 2 evaluations of LRSD programs. Their progress is described below in Section D. D. PRE (1) oversees the preparation of the step 2 evaluations, (2) works closely with Drs. Ross and Catterall, and (3) assists them. PRE continued discussions with Dr. Steven Ross of step 2 evaluation designs for thethree LRSD programs which he will conduct, reported December 1, 2004-Compass Learning (CL), Reading Recovery (RR), and Smart/Thrive (S/f). By January 14, PRE and Dr. Ross agreed on evaluation designs, whose descriptions are in the appendix of this second quarterly written update. Negotiations also continued in Janua,ry with Dr. James Catterall regarding evaluation of YearRound Education (YRE), the fourth step 2 evaluation for 2004-2005. Its design, too, is in the appendix of this second quarterly written update. At the monthly Leadership Team (school principals) meeting, on January 19, PRE staff alerted LRSD principals about the four evaluations and answered their questions. At the February 16 Leadership Team session, Dr. Ross and his team described designs of his three evaluations and answered questions. After his presentation to the principals on February 16, Dr. Ross and his team met with PRE, each program director, and two other outside experts (Drs. Linda Dorn and Gail Weems, both of UALR's College of Education). During these discussions, ODM officials and counsel for Joshua Intervenors provided feedback and assisted with the final design of data collection instruments. Page 3 of 18 PRE has established four evaluation teams, led by PRE members and composed of people with skills and experiences appropriate to their respective evaluations. Parent and teacher representatives are also members of these teams, whose first formal meeting was arranged for February 24. Dr. DeJarnette will lead the evaluation of Compass Learning; Ms. Malcolm, Smart/Thrive; Dr. Williams, Year-Round Education; and Mr. Wohlleb, Reading Recovery. Members' names and results of that meeting will appear in the third written quarterly update, due June I. E. Evaluation will have (1) numbers and grade levels of teachers and administrators who submit data for evaluations, (2) recommended program changes necessary for improved achievement by African-American students, and (3) succinct explanations of how each change will increase its respective program's effectiveness. Designs of the evaluations, furnished in the appendix to this report, will include 1) records of the teachers and administrators who furnish data, opinions and guidance, and their grade levels and positions; 2) data in addition to race/ethnicity and test scores that will enable the evaluators to find reasons for differences in academic achievement and recommend changes; 3) bases for explanations of how these other factors impact on academic achievement and how program changes will bring about improved academic achievement. F. Delivery of names of programs to be evaluated and the comprehensive program assessment process to ODM and Joshua. Names of the four programs evaluated during 2004-2005 and the process were delivered before they were due last year and so reported in the first written quarterly update. G. PRE must submit quarterly written updates on the status of step 2 evaluations. PRE submitted its first written quarterly update on December I, 2004. PRE submits this one on or before March 1, 2005 and will submit its third by June 1, 2005. Page 4 of 18 Appendix C. Designs of Step 2 Evaluations of2004-2005 Reading Recovery (RR) Compass Leaming (CL) Smart/Thrive (SIT) Year-Round Education (YRE) Evaluation Schedule 2004-2005 Page 5 of 18 Reading Recovery Program Description RR is one of the eight literacy programs, interventions, and/or models used by various LRSD schools. Restricted to the first grade, it provides systematically designed, individual tutoring to students identified as having the highest need for supplemental support. LRSD funds are used to support the RR Program. Currently, 17 elementary schools are implementing RR: Number of Reading Percent African- Percent Recovery Number of Number of American Free/Reduced School Teachers Teachers Students Students Lunch Students Booker 4 55 496 53 63 Carver 2 43 496 52 53 Chicot 3 44 536 73 86 Dodd I 27 261 54 69 Franklin 2 35 387 96 94 Geyer Springs I 23 299 88 81 Gibbs 2 30 310 53 44 Meadowcliff I 24 349 78 85 Mitchell I 22 156 96 92 Otter Creek 1 31 511 60 56 Rightsell 1 25 262 100 88 Wakefield 2 29 451 78 92 Watson 1 34 456 96 93 Williams 2 36 461 52 34 Wilson 1 27 285 89 92 RR Evaluation Questions and Design A mixed-methods design will address the research questions as follows: Primary Evaluation Question: 1. Has the RR program been effective in improving and remediating the academic achievement of African-American (AA) students? A. Whole School Sample: A treatment-control school, pretest-posttest design will be employed in Grades 1-3. The analysis will control for pretest, gender, ethnicity, and SES. The analysis will possibly examine (a) all 17 schools relative to the entire district elementary-school database or (b) a stratified random sample of RR schools relative to matched control schools. Pretests: DRA or DIBELS (whichever has the more usable database), adm inistered in Kindergarten. Page 6 of 18 Posttests: 2004-05 Iowa Test of Basic Skills (ITBS) Reading and Math Subtests. B. RR Subsample: Within each of the RR schools, first- to third-grade students who participated in RR as first graders will be identified and their achievement gains compared to predicted scores based on school status (RR vs. non-RR), and student pretest, gender, ethnicity, and SES. Supplemental (Qualitative/Step 2) Evaluation Questions: 1. What are the quality and level of implementation of RR at the 17 schools implementing it in 2004-05? RR teachers will be interviewed by phone. First-grade teachers and other grade-level teachers will be surveyed. Observations of RR sessions will be at a sample of schools. A minimum of IO observations will be conducted. To the extent resources are available, an attempt will be made to observe at all 17 sites. 2. What is the level of participation in RR by AA students relative to other ethnic groups at the school? Student records/archival data for 2003-04 and 2004-05 will be analyzed. 3. What is the progress demonstrated by AA and other student participants in RR in improving achievement, as demonstrated on program-specific measures? What percent of students are \"discontinued\" or \"not discontinued\"? RR teachers will be asked to complete \"Achievement Profiles\" (to be developed) for each 2004-05 RR student. The Achievement Profiles will be one-page forms designed to require only a few minutes to complete. Procedures will be written through consultation with PRE and RR experts in LRSD. 4. What are the perceptions of RR teachers regarding RR program implementation, impacts, strengths, and weaknesses? The RR teacher interview will directly address this question. 5. What are the perceptions of non-RR first-grade teachers and other teachers in the schools regarding RR program implementation, impacts, strengths, and weaknesses? The RR School Teacher survey will address this question via closed-ended and open-ended items. Respondents will identify their status by grade and role. 6. What are the perceptions of parents/guardians of RR students regarding program impacts, strengths, and weaknesses? A RR Parent survey will be conducted via a questionnaire including closed- and open-ended items. Page 7 of 18 Summary of RR Data Sources and Participants by Evaluation Question Evaluation Question I Participants Data Sources Primarv Question I . What are the effects of  All grades 1-3 students  DRA or DIBELS (pretest participation in RR on AA at 17 RR schools and in K) student achievement? other elementary  2004-05 !TBS Reading schools and Math subtests  RR student participants (posttest in grades 1-3) within above samples Step 2 Questions 1. What is the quality and level  All RR teachers  RR Teacher Phone of implementation of RR at the  All teachers at RR Interview 17 schools implementing it in schools  RR School Teacher 2004-05? Survey (faculty meeting)  RR Achievement Profiles  One-hour RR Tutoring Observation (min. of 10 schools) 2. What is the level of  All RR schools  School records/archival participation in RR by AA data students relative to other ethnic groups by school? 3. What is the progress  All RR teachers  RR Achievement Profile demonstrated by RR students in improving achievement, as demonstrated on program-specific measures? What percentage of students are \"discontinued\" or \"not discontinued\"? 4. What are the perceptions of  All RR teachers  RR Teacher Interview RR teachers re: RR program implementation, impacts, strengths, and weaknesses? 5. What are the perceptions of  All RR school teachers  RR School Teacher regular first-grade teachers and Survey (disaggregated by other teachers re: RR program I st grade vs. other grades) implementation, impacts, strengths, and weaknesses? 6. What are the perceptions of  Parents of RR students  RR Parent Survey parents/guardians of RR students re: program impacts, strengths, and weaknesses? Page 8 of 18 Compass Learning Program Description Compass Learning (CL) is a computer-based program designed to develop students' skills in reading, writing, and spelling. Additional purposes are to support teacher management of student performance, personalize instruction, and connect communities of learners. The themebased lessons and activities provided by CL take a cross-curricular approach and offer a \"real world\" context for learning. The Compass Management system assessment is either automatic or customizable. Technology Specialists assist classroom teachers with any technology question or need. In the 2004-05 school year, 21 LRSD elementary schools, two middle schools, and the Accelerated Learning Center (high school) utilize CL programs: Percent Percent Number Number African- Free/Reduced of of American Lunch Schools Teachers Students Students Students Bale Elementary 27 319 82 88 Booker Elementary 55 605 53 63 Brady Elementary 28 318 78 80 Carver Elementarv 43 496 52 53 Chicot Elementary 44 536 73 86 Fair Park Elementarv 19 187 75 73 Forrest Park Elementary 25 361 20 14 Franklin Elementary 35 387 96 94 Fulbright Elementary 38 554 26 17 Geyer Springs Elementary . 23 299 88 81 Gibbs Elementary 30 310 53 44 Mabelvale Elementary 25 257 80 88 McDermott Elementary 26 406 62 88 Mitchell Elementary 22 156 96 92 Otter Creek Elementary 31 511 60 56 Rightsell Elementary 25 262 100 88 Rockefeller Elementary 35 453 67 66 Stephens Elementary 39 499 95 91 Wakefield Elementary 29 451 78 92 Williams Elementary 36 461 52 34 Cloverdale Middle School 59 682 82 66 Henderson Middle School 60 630 82 70 Accelerated Leaming Center 14 178 92 15 Page 9 of 18 CL Evaluation Questions and Design A mixed-methods design will be employed to address the research questions as follows: Primary Evaluation Question: 1. What are the effects of participation in CL on the achievement of African-American (AA) students? A. Quasi-experimental design: Due to the insufficient sample size and unique nature of the high school (n = 1), the quasi-experimental analysis will be conducted with the elementary (n = 21 schools) and middle (n = 2) school samples only. A descriptive examination (see below) of test scores for the high school will also be conducted to determine trends and patterns at that site. Specifically, the quasi-experimental design will compare CL elementary and middle schools to other schools in the district, most likely by multiple-regression analyses in which the dependent variable is posttest (2004-05) scores (Arkansas Benchmarks in grades 3-8, and Iowa Test of Basic Skills in grades K-8) and covariates are pretest (pre-program) test scores, gender, ethnicity, and SES. Pretests: Iowa Test of Basic Skills (ITBS) (for grades K-8), Arkansas Benchmarks (for grades 4-8) Posttests: 2004-05 ITBS Reading and Math Subtests (for grades 1-8); Arkansas Benchmarks (for grades 3-8). B. Descriptive design: For the one high school using CL,. whole-grade pretest and posttest means on Arkansas Benchmarks, ITBS, Grade 11 Literacy Exam, and Algebra I and Geometry End-of-Course (EoC) exams will be compared to district norms. The purpose will be to assess absolute and relative performance as possible correlates of CL implementation. Supplemental (Qualitative/Step 2) Evaluation Questions: 1. What are the quality, nature, and level of implementation of CL at the 24 schools implementing the program in 2004-05? Phone interviews will be conducted with (a) the LRSD CL Coordinator and (b) a sample of IO school Technology Specialists (the I high school, the 2 middle schools, and a random sample of 7/21 elementary schools). All teachers at the 24 schools will be surveyed so that site-specific data regarding implementation will be available. Observations of CL laboratory sessions will be conducted at a sample of JO schools (the I high school, the 2 middle schools, and 7 of 21 elementary schools). At half of the observed schools (n = 5), a brief (20-minute) student focus group (n = 5 to 7 students) will be conducted to ascertain students' perspectives on their experiences in using CL (nature of activities, usefulness, enjoyment, etc. ). 2. What is the level of participation in CL by AA students relative to other ethnic groups at the schools involved? Page 10 of 18 Student records/archival data for 2003-04 and 2004-05 will be analyzed. 3. What are the perceptions of teachers and Technology Specialists regarding CL program implementation, impacts, strengths, and weaknesses? This question will be addressed via the Technology Specialist Interview and closed-ended and open-ended items on the CL Teacher Survey. 4. What are the perceptions of parents/guardians of CL students regarding program impacts, strengths, and weaknesses? A CL Parent survey will be conducted to address this question via a questionnaire including closed- and open-ended items. Page 11 of 18 Summary of CL Instruments and Participants by Evaluation Question Evaluation Question Particioants Data Sources Primarv Question 1. What are the effects of  Students at 23 CL  ITBS as pretest for Grades K-9 participation in CL on the elementary and middle  Arkansas Benchmarks as posttest achievement of AA students? schools and comparison for 3-8) schools  2004-05 ITBS Reading and Math  Whole grade-level means subtests (grades 1-9 posttests) at the CL high school.  2004-05 Grade 11 Literacy Exam ( as posttest)  2004-05 Algebra I and Geometry EoC Exams (as posttest) Steo 2 Questions 1. What are the quality,  All CL school teachers  CL Teacher Survey (faculty nature, and level of  10 Technology Specialists meeting) implementation of CL at the (1 high school, 2 middle  Technology Specialist Phone 21 schools implementing the schools, and 7 randomly Interview program in 2004-05? selected elementary  District CL Program Coordinator schools) Phone Interview  District CL Program  Two-hour CL Laboratory Coordinator Observations (10 schools: 1 high  5 student focus groups ( 1 school, 2 middle schools, 7 high school, 1 middle randomly selected elementary school, 3 elementary schools) schools)  20-min. Student Focus Groups (n = 5-7 students), one each at 5 of the IO observation schools 2. Whatisthelevelof  All CL schools  School records/archival data participation in CL by AA students relative to other ethnic groups at the schools concerned? 3. What are the perceptions of  All CL school teachers  CL Teacher Survey teachers and Technology  10 Technology Specialists  Technology Specialist Interview Specialists regarding CL program implementation, impacts, strengths, and weaknesses? 4. What are the perceptions of  Parents of CL students  CL Parent Survey parents/guardians of CL students regarding program impacts, strengths, and weaknesses? Page 12 of 18 Smart/Thrive Programs Program Description The Smart/Thrive (Sff) program was designed as an intervention for 8th - and 9th -grade AfricanAmerican students who are lacking the knowledge, skills, and/or confidence required for success in Algebra I. S/T currently (2004-2005) engages approximately 10 percent of the total AfricanAmerican student population enrolled in Algebra I classes. During the 2003-2004 academic year, 264 students participated, studying pre-algebra for two weeks during the summer (Smart Program) and 10 Saturdays across the school year (Thrive Program). Various local grants have funded this program since 1999. Currently, SIT serves students from all eight LRSD middle schools: Percent Percent African- Free/Reduced Number of Number of American Lunch Middle Schools Teachers Students Students Students Cloverdale 59 682 82 86 Dunbar 58 747 61 57 Forest Heights 59 688 77 62 Henderson 60 630 82 70 Mablevale 57 634 81 75 Mann 64 873 52 37 Pulaski Heights 57 708 57 47 Southwest 55 493 94 87 srr Evaluation Questions and Design A mixed-methods design will be employed to address the research questions as follows: Primary Evaluation Question: 1. Have the srr programs been effective in improving and remediating the academic achievement of African-American (AA) students?  A treatment (2 levels)-control student, pretest-posttest design will control for pretest, gender, ethnicity, and SES. Three types of Algebra I students will be compared depending on their program enrollment: 1. No program 11. Smart program only 111. Both Smart and Thrive programs  Pretests: 2002-2003 and 2003-2004 6th and 8th grade Benchmark tests. Page 13 of 18  Posttests: 2004-05 (ITBS) Math Subtests; Algebra I EoC Supplemental (Qualitative/Step 2) Evaluation Questions: 1. What is the level of participation in Smart and Thrive by AA students? Student records/archival data of 2003-04 and 2004-05 will be analyzed. In addition to descriptive information, levels of participation will be gathered as a potential variable for the student achievement analyses. 2. What instructional strategies are used during the tutoring sessions? Approximately five random observation visits will be conducted during the Saturday Thrive Program sessions in 2005. 3. What are the perceptions of SIT Tutors regarding program impacts, strengths, and weaknesses? A questionnaire will be administered to SIT Tutors. 4. What are the perceptions of Algebra I teachers regarding program impacts, strengths, and weaknesses? A questionnaire will be administered to Algebra I teachers. 5. What are the perceptions of participating students regarding program impacts, strengths, and weaknesses of SIT? A questionnaire will be administered to student participants. A sample of them will also be selected to participate in approximately 3 - 5 student focus groups, each comprised of approximately 5 students. 6. What are the perceptions of parents/ guardians of SIT students regarding program impacts, strengths, and weaknesses? An SIT parent survey will be conducted to address this question via a questionnaire including closed- and open-ended items. Page 14 of 18 Summary of Sff Data Sources and Participants by Evaluation Question Evaluation Question Participants Data Sources Primary Question 1. What are the effects of  All 8th and 9th grade  2003-2004 benchmark participation in the Smart Algebra I students  2004-05 ITBS Math and/or Thrive Programs on subtests; Algebra I EoC AA student achievement? Suoolemental Questions I. What is the level of  All program participants  School records/archival participation in Smart and data Thrive bv AA students? 2. What instructional  SIT teachers and students  Observations of tutoring strategies are used during the sessions tutoring sessions? 3. What are the perceptions of  All SIT Tutors  SIT Tutor Questionnaire SIT Tutors regarding program impacts, strengths, and weaknesses? 4. What are the perceptions of  All Algebra I teachers  Algebra I Teacher Algebra I teachers regarding Questionnaire program impacts, strengths, and weaknesses? 5. What are the perceptions of  Program participants  SIT Student Questionnaire participating students  Focus Groups regarding program impacts, strengths, and weaknesses? 6. What are the perceptions of  Parents of SIT students  SIT Parent Questionnaire parents/guardians of SIT students regarding program impacts, strengths, and weaknesses? Page 15 of 18 Year-Round Education Programs Program Description Year-Round Education (YRE) rearranges instruction and vacations so that they occur throughout the year, for more continuous learning and frequent breaks. YRE has emerged nationally as a way to educate all students better, regardless of ethnic backgrounds, social strata, or academic performance. LRSD's design is a single-track, 45-10 calendar where all students and teachers in the school are in class or on vacation at the same time. (The \"45-1 O\" means 45 days in a quarter, then IO days of intersession/vacation. Intersession is a five-day program and attendance 1s voluntary.) Currently, five elementary schools are implementing YRE: Percent of Percent Students Eligible for Elementary Number of Number of African- Free/Reduced Schools Teachers Students American Lunches Cloverdale 26 360 77 89 Mablevale 25 257 80 88 Mitchell 22 156 96 92 Stephens 39 499 95 90 Woodruff 21 235 91 86 YRE Evaluation Questions and Design Primary Evaluation Question: I. Has the Year-Round Education (YRE) Program effectively improved and remediated the academic achievement of African-American (AA) students? Whole-school sample: In a treatment vs. control school, pretest vs. posttest design, the analysis will control for pretest scores, gender, ethnicity, and family income (eligibility for free or reduced lunch program). Subsample: Within each YRE school, evaluators will compare achievement gains of students who participate in intersession to predicted gains (based on category of school, pretest scores, gender, ethnicity, and family income). Supplemental (Qualitative/Step 2) Evaluation Questions: 1. What are the quality and level of implementation of intersession instructional strategies? 2. What are the quality and level of implementation of instructional strategies during regular session? Page 16 of 18 I  Evaluators will interview YRE teachers by phone and observe YRE classrooms (during both the regular session and intersession). 3. What is the level of participation in YRE Programs by AA students relative to other ethnic groups at the school? Student records/archival data for 2003-04 and 2004-05 will be analyzed. 4. What are the perceptions of YRE teachers regarding program impacts, strengths, and weaknesses? The YRE teacher interview and the YRE teacher survey will address this question via both closed- and open-ended items. 5. What are the perceptions of participating students regarding program impacts, strengths, and weaknesses? Evaluators will administer a survey to YRE program participants. 6. What are the perceptions of parents/guardians of YRE students regarding program impacts, strengths, and weaknesses? A Parent survey will address this question via a questionnaire including both closed- and open-ended items. Page 17 of 18 ... Summary of YRE Data Sources and Participants by Evaluation Question Evaluation Question Participants Data Sources Primary Question: 1. What are the effects of YRE All grades at YRE schools and other Benchmark and ITBS participation on achievement of AA elementary schools. Year Round students? Education intersession student participants within above samples. Suoo/emental (Step 2) Questions: 1. What are the quality and level All YRE teachers Teacher phone of implementation of intersession interview instructional strategies? 2. What are the quality and level of Selected teachers and students Classroom observations implementation of instructional strategies during regular session? 3. What is the level of All YRE schools School records/archival participation in YRE Programs by data AA students relative to other ethnic groups? 4. What are the perceptions of All YRE teachers YRE teacher interview Year Round Education teachers and survey regarding program impacts, strengths, and weaknesses? 5. What are the perceptions of YRE students grades 4 and 5 YRE student survey participating students regarding program impacts, strengths, and weaknesses? 6. What are the perceptions of Parents of YRE students YRE parent survey parents/guardians of YRE students regarding program impacts, strengths, and weaknesses? Page 18 of 18 I  I I I I I I I I I I I I I FILED U.S. O!ST'\u0026lt;iCT COURT EASTERN DiSTi'\u0026lt;1CT ARKANSAS MAR 1 8 2005 UPDATE OF DISCIPLINE SANCTIONS AND J~~ES W. McC8KMACK, CLERK COMPENSATORY PROGRAMS AIMED AT DROPO~ PREVENTION '.)::? c~::R.t\u0026lt; IN THE NORTH LITTLE ROCK SCHOOL DISTRICT March 18, 2005 Office of Desegregation Monitoring United States District Court Little Rock, Arkansas Margie L. Powell Monitor Arkansas DEPARTMENT OF EDUCATION 4 STATE CAPITOL MALL , unu: ROCK, ARKANSAS 72201-1071 , (501) 682-4475  http://arkedu.state.ar.us Dr. Kenneth James, Director of Education March 31, 2005 Mr. M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings 200 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes, Wagoner, Ivers \u0026amp; Sneddon P. 0. Box 1510 Little Rock, AR 72?03-1510 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 RE: Little Rock School District v. Pulaski County Special School District, et al. US. District Court No. 4:82-CV-866 WRW Dear Gentlemen: Per an agreement with the Attorney General's Office, I am filing the Arkansas Department of Education's Project Management Tool for the month of March 2005 in the above-referenced case. If you have any questions, please feel free to contact me at your convenience. Sincerely, _g~~ General Counsel Arkansas Department of Education SS:law cc: Mark Hagemeier ATE BOARD OF EDUCATION: Chair - JoNell Caldwell, Little Rock  Vice Chair - Jeanna Westmoreland, Arkadelphia Members: Sherry Burrow, Jonesboro  Shelby Hillman, Carlisle  Calvin King, Marianna  Randy Lawson, Bentonville MaryJane Rebick, Little Rock  Diane Tatum, Pine Bluff  Naccaman Williams, Johnson An Equal Opportunity Employer UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 WRW 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 the ADE's Project Management Tool for March 2005. Respectfully Submitted, ScottSmitir,13ar # 92251 General Counsel, Arkansas Department of Education #4 Capitol Mall, Room 404-A Little Rock, AR 72201 501-682-4227 CERTIFICATE OF SERVICE I, Scott Smith, certify that on March 31 , 2005, 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 West Capitol, Suite 2000 Little Rock, AR 72201 Mr. John W. Walker John Walker, P.A. 1 723 Broadway Little Rock, AR 72201 Mr. Mark Burnette Mitchell, Blackstock, Barnes Wagoner? Ivers \u0026amp; Sneddon P. 0. Box 1510 Little Rock, AR 72203-15 l 0 Mr. Christopher Heller Friday, Eldredge \u0026amp; Clark 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 Mr. Stephen W. Jones Jack, Lyon \u0026amp; Jones 425 West Capitol, Suite 3400 Little Rock, AR 72201 Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Scott Smith     This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.\u003c/dcterms_description\u003e\n   \n\n\u003c/dcterms_description\u003e   \n\n  \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n  \n\n  \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n   \n\n   \n\n   \n\n\n\n\n\n   \n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n   \n\n\u003c/item\u003e\n\u003c/items\u003e"},{"id":"bcas_bcmss0837_308","title":"Compliance correspondence","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["2001-03/2001-07"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","Education--Arkansas","School administrators","Educational planning","Education--Evaluation","Educational law and legislation","Educational statistics"],"dcterms_title":["Compliance correspondence"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/308"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["correspondence"],"dcterms_extent":["192 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\ne  *- GADBERRY, BRADY L. From: Sent\nTo: Subject: CARMINE, LESLIE V. Friday, March 02, 2001 12:45 PM LESLEY. BONNIE\nBABBS, JUNIOUS\nSTEWART DONALD M  GADBERRY. BRADY L.\nMITCHELL. SADIE ' FW: Mathematics program evaluation Original Message From: Sent: To: Cc Subjecfc LESLEY, BONNIE Thursday, Mardl 01, 2001 1:25 PM CA^NE^ LEtS V ^bBERRY, BRADY L\nSTEWART, DONALD M. r^athematics program evaluation We have yet another sflrifiUfi problem concerning program evaluation, Ooew^w^ contains numarous erws of facf and anerpretetion-ao many that i1 is going to taxa me a tot of ame to 2- The District is paying Virginia Johnson full-time to do the math/science evaluation for NSF and what Nunnprv hac \"T? '1 fVirginia has done and submitted to NSK We ^n Mt Into a l o^M^usion Interpretations of the project! And we are terribly vulnerable to justified criticisr^ we say two ^^reri? . .dP Dennis and I wrote for the Compliance Report-so if Nunnery's reoort is submitted and It dMsn't Jive with the Compliance Report, we are going to look like fools again submitted and 4. The Nunnery report makes many of the same errors that PRE made originally It devoid of context\nit is incomplete in its data analysis\nthe Interoretations are nor infnr wrtten is nt^at all aligned with the reports that Virginia NSF 3. etc. is incomplete in its data analysis\nthe Interpretations are not mform^^bniTiatwTare District decide to spend yet more money on the NSF evaluation? esoeciallv t. neversuppos^ Bdo. .epaU evaluallop cTmSae^S hare or jS rSrSnSS Sb? iteTOF rfp^lL *iaveh,ent as b a,adoral cdor, information in one place. Why in the world are we allowina to continue decision-making the one person who can help the District avoid these embarrassing w^i^hdtoi^TT ''D' xpensive problems? The two meetings of the Research Committee have been scheduled absolutely could not attenrf-which happened as well in the scheduled meetings with Steve Ross I do not t that all these inci'dents are ^incidento^^ s=bdulS mtrngsStevl R^^  indication of what we are going to get with the other reports-then we don't just have one oroblem have multiple problems. I am VERY wearv of trvino to clean un the mecc uuhen we rriHrr4 r -------iP*i__ __ place. Itiple weary trying toclean up mess ^rn w^didn^ to hav?one in toe^t It makes NO sense to me, given the last year's events, to allow Kathy Lease to continue overseeino the orooram evaluation reouirements for this riiKthrt That le ,h., i h,o _______r-rZ J.l Z  2.\" Program I ra w *M wiiww ixaoiy bcci3w Lw wUliUllUC UVciScG e^luation requirements district. is why I have removed Virginia Johnson from PRE OFTI^A VA/lfn \\/in A* A A a.Uikt! I U.^. _______a a.*.. . * 'uL , , mar is wny i nave removed Virginia Johnson from PRE and moved her into the office with Vanwsa. ^d that is why I have assigned Eddie McCoy to do the ESL evaluation for this school year At least StSoffier^oS SpoS accePteble quality and do not contradict what we havi SvI%Tre,!^mmeX'inn \u0026lt;his. Otherwise, I would just let it go. You have my concerns. You I lavo iiiy I owi III I loriQowOn. Below is a list of errors that I identified in the report from just one quick read-through 1. First sentence\nThe grant began in 1998-99, not 1997-98 not'2?^Athynn^?dL^^^^^ ?.''o,^''''' performance in mathematics and science\" are not something we dreamed upbut required in the NSF program evaluation iak?hoS,tot\u0026amp;oS \" 854. Lots Of capitalization and punctuation errors. 5. Tkis dra^l uses 190 as ike baseline for SATS ficopss. Tho cdhipliancs reporf used f 55T-Sfisince il was iln year before we began to implement changes 6. Disaggregation is unclear, is it \"white\" or is it \"non-black\" scores that are reported'? a M??nDDDnDT?I ' ' * sutints themselves changel n^'^mcSr WAroHid,r science scores tell us anything since that test is in no way aligned with the 12 Achievement gap scores are not as easy to interpret on the SAT9 as they are on the Benchmark Al-sn iftr..i \u0026amp; aS science and math that are outlined and analyzed in the Compliance Report Those are the courses that should be examined. Near the end of the first paragraph ' -----------------  . A? 'J? -^Sebra I in Sth grade faifed the cou'rse.\" Our very'high^t achievinqVfadente are wha?so'^vll^] \" tt^at concYusion ^thouf a^^^ rVi laloU9Var 1 we have so far any is a gross error. He states that \"relatively large \"district is providing increasingly equitable access to Algebra 1.\" Well thats true but it is n or S^atiS ***  GeomeS and either 4ai!?LVonSis^j^he'Co''4 \"\"\" The f\u0026lt;evise\u0026lt;i Desegregation Plan-is the title of another section of the paper f 5,  G^I'Sation 2.6-the one having to do with access to and success in advanced, g/t, and AP courses^e programs that are outlined are for the most part remedial-implemented to ensure success in regular-level courses not to ensure access to or success in advanced courses, necessarily. The interpretation is all wrongX Sm and rSpTfanceWpoS\"^ achievement in this area. All those programs, etc. are outlinXthe '?  rekrence t^olicy IG as being the one allowing dual-credit courses. That is an error Policy IG has to do with curriculum adoption. There is another policy and set of regs having to do with college enrollment (IHOTA and WCDA- writer apparently had no understanding of the University Studies courses as our best examole of the PP\u0026lt;^\u0026lt;jnity to earn coIImc credit while still in high school. All that information is in the Compliance Report. *2 2.6.1. which is the section on teacher/counselor training having to ao will  ff*' fond in the Compliance Report. Are you seeing the pattern here Pf 'ofo fais paper the stuff that we have already described and analyzed in the Compliance Report? 20. 1 he writer attempted to analyze increased enrollment in AP math and science-hut aoain had no data and nn .which is the section on teacher/counselor training having to do with .rrfr,rmaHr,r, analyzc^incre^ed enrollment in AP math and science-but again had no data and no information about the many actions taken to accomplish what we have. What we have done for remediation. An w^at we have done. including most of the prMrams that he erroneously listed under the advanced course section 22. It seems to me that if he wants to evaluation Section 2.71 that a desnrintinn nf th^ now ifhe description of the new assessments would be ap^ropnate, as well as a discussion of the Quality Index, the ACTAAP accountability requirements, etc. None of ^t is 23. Obligation 2.8. This section is pitifulagain because the writer did not understand the wunyoMun i D. , Hio ,s piuiui-again oecause the writer did not understand the program or what we have done have1)X a^bfg failure of which have been wonderfully suc^ssful, and others of which most part, student 24. This section also falls to include in the analysis all of several other partnerships. 25. Now, here's the clincher\nUnder \"Findings and Conclusions,\" the writer states that \"For the most di outi^mes in Mathematics (sc) and Science (sic) did not change substantially between 1997 and 2001 m! profound finding on one measurement alone-the SAT9. No ^nchmark data. No ALT data? No CRT date of t^he tremendous increases in course enrollments, participation, etc., etc.,, etc. VJe have paid big 'P'^' 'f'\" fo \u0026gt;0 Po whatever ho has done, and now to Nunnery to declare that we tha\\1\u0026lt;wkrat/Sl^^e^ate^at we^have*^ absolutely wrong And we are continuing to pay staff to work on the NSF reporf for LRSD students\" noi Inn^aragraph about the'implementation dip,\" one of the phrases that I've heard Kathy use a lot of fim^. The fact of the matter is that we did NOT have an implementation dip. Fourth grade went up A LOT in the first year of implementationif we look at the one test that is best aligned with what we are doingthe Benchmark SAT9 declines are NOT due to implementation dips. They are due to the fact that the SAT9 does not correlate with the wmculum framework or the new curriculum and assessments we are using. Goodness! 27. The discussion about achievement gaps is based upon the same flaws in information and understanding. 86dLunX,'^n \"? 2?^ '\"' draining program-and the feet is that we have tons of also have an assessment of the oTamTkTImplementation. We also have an assessment of the quality of teacher implementation of the new curriculum-again in the Compliance Report. Vn dSRod Whdt wo hsd or for infinrmafion rwi fha tflOSe d3t3 tO N^^^d Kathy never analysis of what went wrong last year). One of 30. The Recommendations section is nothing but shallow-but then oiven what th^ writer knouu th.- ...__ . c^ld we ex^ We have some critical issJes that should ^e^ to arfo even s^ed some o^em already this school year based on our own analysis of what went wrong last vear) One of the basics in program evaluation is to derive the recommendations for improved^Kdafe^lh^te the program staff who can shed light on interpretations and on identifying what went wrong or what ' P0\"ay hink about this stuff ail the tiriie, and so d\u0026lt;^ Dwn^nlj w do^Xs^ W^^va ewry right to be outraged that people without any direct Information, with giant gaps of information without observation of knowledge of what we are doing and why. without infixmation about NSF wrthout anv ^empt to find out what we kriTO would deem it even possible to make judgments about the work about what the outcomes mean, or what should happen next. For goodness sake! * coounne worn, aoomwnattne the Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski UtOe Rock, Arkansas 72206 SO1/324-2131 501/324-0567 (fax) GADBERRY, BRADY L. From: Sent: To: Subject: CARNINE, LESLIE V. Friday, March 02, 2001 12:31 PM GADBERRY, BRADY L\nSTEWART, DONALD M. I , I W I hB.y W I V vr~il \\ I , Ivll FW\nCentral High School Parking and/or Baseball Field K  3lwa^ thrTO side to the story but this Is going to go public and there will be a lot of finger not be a good Kme to visit with Baldwin Shell about the logistics of the Central renovation. That could then determine the number of portables and feasibility of the faculty parking and the other issues. Original Message From: Sent: To: Cc Subject HOWARD, RUDOLPH Wednesday, February 28. 2001 S\n39 PM EATON, DOUGLAS LACEY, MARIAN G.\nGADBERRY, BRADY L\nCARNINE, LESLIE V. Central High School Parking anq/or Baseball Reid We keep going \"around and around\" in an effort to avoid the issue. det^ine whethw or not the district was going to support the building of a baseball field SPMifically.how mu^ was the district going to contnbute in order to match what the baseball boosters(Mr.Yancey) would contribute. After waitmn fnr a rmuhnn Inr nu^r 9 mnr.ke 1 _____t.___r,___ . '.. y'*!) waiting fora mating for over 2 months. I receive this memo ffom DouT^O^^^^ already been covered. Specifically, the issue about the parking lot and the portables. wouW give up the teacher parking lot in order to accommodate the portables. WE ARE NOT AGREEABLE TO GIVING UP ANY ADDITlOl^L SPACE ON THE PRACTICE FIELD. additional space for portables, but you ner tell us how many portables that n^ded. Therefore, we can never determine if the space on the parking lot and/or the space around uenvai is adequate or not. 875013744137 WALKER LAW FIRM 050 P02 JUL 24 01 11:20 GADBERRY, BRADY L From: Sent: To: Subject: CARNINE, LESLIE V. Friday, March 02, 2001 12:45 PM LESLEY, BONNIE: BABBS. JUNIOUS\nSTEWART, DONALD M.\nGADBERRY, BRADY L\nMITCHELL, SADIE FW: Mathematics program evaluation I understand your concern and there are some issues that should be discussed but this no more serious than the errors found in the NSF evaluation grant that we sent to the visiting team. I am sorry but I hope the other Associates can be objective. Original Message From: Sent: To: Cc Subject: LESLEY, BONNIE hiursaay, March 01, 2001 1:25 PM BAB8S, JUNIOUS, MITCHELL, SADIE\nGADBERRY, BRADY L\nSTEWART, DONALD M. CARNINE, LESUE V. Mathematics program evaluation We have yet another serious problem concerning program evaluation. I received on Monday afternoon a copy of the draft of the mathematics program evaluation that Kathy has apparently asked John Nunnery to do. I have these urgent concerns\n1. The draft contains numerous errors of fact and interpretation-so many that if is going to take me a lot of time to document. 2. The District is paying Virginia Johnson full-time to do the math/science evaluation for NSF, and what Nunnery has written is not at all aligned with the reports that Virginia has done and submitted to NSF. We can get Into a lot of confusion with such different interpretations of the project! And we are terribly vulnerable to justified criticism if we say two different things. 3. The draft is not aligned with what Dennis and I wrote for the Compliance Report-so if Nunnery's report is submitted and it doesn't \"jive\" with the Compliance Report, we are going to look like fools a^ain. 4. The Nunnery report makes many of the same errors that PRE made originally. It is based on wrong assumptions\nit is devoid of context\nit is incomplete in its data analysis\nthe Interpretations are not informed by what we are doing this year, etc. My question is this: Why in the world did the District decide to spend yet more money on the NSF evaluation? especially when what is written is of such poor quality? PRE was never supposed to do a separate evaluation of math/science from what we are required to do for NSF. NSF is just as concerned about African American achievement as is die federal court here or Joshua. Aii the relevant information will be in the NSF reports. And again, I am the only person vi^o has all the of information in one place. Why in the world are we allowing to continue the practice of excluding from decision-making the one person who can help the District avoid these embarrassing problems? these very expensive problems? The two meetings of the Research Committee have been scheduled at times when I absolutely could not attend-which happened as well in the scheduled meetings with Steve Ross. I do not believe that all these incidents are coincidental. If this first paper is any indication of what we are going to get with the other reports-then we dont just have one problem. We have multiple problems. I am VERY weary of trying to clean up the mess when we didn't need to have one in the first place. It makes NO sense to me, given the last year's events, to allow Kathy Lease to continue overseeing the program evaluation requirements for this district. That is why I have removed Virginia Johnson from PRE and moved her into the office with Vanessa. And that is why I have assigned Eddie McCoy to do the ESL evaluation for this school year. At least this way I can be sure that the reports to NSF and OCR are of acceptable quality and do not contradict what we have written in other official reports. There are serious legal and financial implications in all this. Otherwise. I would just let it go. You have my concerns. You have my recommendation. Below is a list of errors that I identified in the report from just one quick read-through. 1. First sentence\nThe grant began in 1998-99, not 1997-98. 2. The \"drivers that he says \"ostensibly influence overall levels of student performance in mathematics and science\" are not something we dreamed upbut required in the NSF program evaluation. 3. The example given about CPMSA activities makes no sense. Everything the project has done involves ail those stakeholders, not just policy formulation.\" 855013744187 UALKEP LhU firm 050 P03 JUL 24 01 11:21 4. Lots of capitalization and punctuation errors. 5. Tkis draft uses imi as Ike basalins for 8AT9 scoras. Tka ccmplianca reporl used ^95?-58-Slnce it was Ike year before we began to implement changes. 6. Disaggregation is unclear. Is it \"white\" or is it \"non-black\" scores that are reported? 7. A big problem with cohort studies is also that students themselves changel 8. MAJOR PROBLEM: Scores are reported without any context that describes where we were in program implementation. No where does the paper establish when specific grade levels were implemented-and that is the only way to look at the data in any meaningful way. Grade 10 scores, for example, could not have been impacted before f^l 2000 because we didn't have any interventions before then that could have made a difference. 9. ANOTHER MAJOR PROBLEM: This report excludes the all-important Benchmark data. The grade 4 data are the BEST evidence that we have so far that the project is working. The grade 8 data are the best evidence that we have so far that change is imperative. 10. It is a terrible error to assume that SATO science scores tell us anything since that test is in no way aligned with the new curricula. We could use the scores, I suppose, but they surely need to be Interpreted with caution. Again, there is no context laid for making interpretations in this draft. 11. Inteipretations of the cohort data are the same problem. He looked at T-scorss for grades 5 and 7 without any explanation of when the reforms were implemented. 12. Achievement gap scores are not as easy to interpret on the SAT9 as they are on the Benchmark. Also, if we are truly trying to figure out if black kids are gaining, we need to look at their movement from Below Basic to Basic since when we started all this, the vast majority 13. There is a section called \"A\u0026lt;  were in the Below Basic level. access to High-Level Math and Science Courses.\" The ONLY course that is examined is Algebra l~hardly a high-level course, especially now that it is required of all students. We have pre- and post-data on course enrollments for both science and math that are outlined and analyzed in the Compliance Report. Those are the courses that should be examined. Near the end of the first paragraph is a gross error. He states that \"relatively large proportions of students who enrolled in Algebra I in Sth grace failed the course.\" Our very highest achieving students. the ones who take Algebra I in grade 8, and almost none of them fail! He drew that conclusion without any data are whatsoever! 14. The paper states that the \"district is providing increasingly equitable access to Algebra 1.\" Well, that's true, but it is grossly understated. We are requiring ALL students now to take not only Algebra I, but also Geometry and either Algebra II or Statistics. 15. This section fails to look at any of the data on Pre-AP, and there is a note that he didn't have the AP data to examine. Again, all of this is in the Compliance Report. 16. Fulfillment of Obligations Contained in the Revised Desegregation Plan-is the title of another section of the paper. The first topic is Obligation 2.6-the one having to do with access to and success in advanced, g/t, and AP courses. The programs that are outlined are for the most part remedial-implemented to ensure success in regular-level courses, not to ensure access to or success in advanced courses, necessarily. The interpretation is all wrong. Also, the section iarnores many other initiatives taken by the District to impact achievement in this area. All those programs, etc. are ouBineo in the Interim and final Compliance Reports. 17. There is a reference to policy IG as being the one allowing dual-credit courses. That is an error. Policy IG has to do with curriculum adoption. There is another policy and set of regs having to do with college enrollment (IHCDAand IHCDA- R). 18. Further, the writer apparently had no understanding of the University Studies courses as our best example of the opportunity to earn college credit while still in high school. All that information is in the Compliance Report. 19. The writer attempted to write about Section 2.6.1, which is the section on teacher/counselor training having to do with advanced courses. He had no data-and all of that is found in the Compliance Report. Are you seeing the pattern here? Why put into this paper the stuff that we have already described and analyzed in the Compliance Report? 20. The writer attempted to analyze increased enrollment in AP math and science-but again had no data and no information about the many actions taken to accomplish what we have. 21. The writer attempted to analyze Section 2.7, but he only mentioned SAIPs as what we have done for remediation. An examination of the Interim and final Compliance Reports would reveal MANY more examples of what we have done, including most of the programs that he erroneously listed under the advanced course section. 22. It seems to me that if he wants to evaluation Section 2.71 that a description of the new assessments would be appropriate, as well as a discussion of the Quality Index, the ACTAAP accountability requirements, etc. None of that is here. 23. Obligation 2.8. This section is pitiful-again because the writer did not understand the program or what we have done to engage parents, and we've done a million things, some of which have been wonderfully successful, and others of which have been a big failure. 24. This section also fails to Include in the analysis all of several other partnerships. 25. Now, here's the clincher\nUnder \"Findings and Conclusions,\" the writer states that \"For the most part, student outcomes in Mathematics (sic) and Science (sic) did not change substantially between 1997 and 2001 for LRSD students\" He based that profound finding on one measurement alone-the SAT9. No Benchmark data. No ALT data. No CRT data. No acknowledgement of the tremendous increases in course enrollments, participation, etc., etc.,, etc. We have paid big bucksto staff to write a first report, then to Ross to do whatever he has done, and now to Nunnery to declare that we have failed-and for that declaration to be absolutely wrong. And we are continuing to pay staff to work on the NSF report that looks at ALL the data that we have. 26. Then there Is a big long paragraph about the \"implementation dip,\" one of the phrases that I've heard Kathy use a lot of times. The fact of the matter is that we did NOT have an implementation dip. Fourth grade went up A LOT in the first year of implementatlon~if we look at the one test that is best aligned with what we are doing-the Benchmark. SAT9 declines are NOT due to implementation dips. They are due to the fact that the SAT9 does not correlate with the curriculum framework or the new curriculum and assessments we are using. Goodness! 27. The discussion about achievement gaps is based upon the same flaws in information and understanding. 865013744187 WALKER LAW FIRM 050 P04 JUL 24 01 11:22 2^ The paragraph on access to higher-level courses is very disappointing. Again, he only looked at Algebra I. There is innovative freshrnan Physics course. There Is no mention of the data we already have In the NSF data reports about course completions. This section is tembly Inadequate. And again, much of it is already rn the Com^iance Report. 29. The writer states that we have no documentation about our training program-and the fact is that we have tons of documentation throughout the Compliance Report-both on advanced courses and on the curriculum Implementation. We also have an assessment of the quality of teacher implementation of the new curriculum-again in the Compliance Report. I want to note here again the arrogance of PRE in even attempting to make judgments about these programs without meeting with the program staff and me to ensure that they know what they need to know to write a report. We are collecting data everywhere, and we are analyzing those data, and we are reporting those data to NSF-and Kathy never even asked what we had or for information on the phase-in of the reforms, for documentation on training, etc., etc., etc My insistence on being included was to prevent these kinds of errors and misinterpretations. 30. The Recommendations section is nothing but shallowbut then given what the writer knew of the program, what else could we expect? We have some critical issues that should be addressed (and we are in fact addressing many of them and even solved some of them already this school year based on our own analysis of what went wrong last year). One of the basics in program evaluation is to derive the recommendations for improvement both from data analysis and from deep conversations with the program staff who can shed light on interpretations and on identifying what went wrong or what could be done better. I personally think about this stuff all the time, and so does Dennis ano so does Vanessa. We have every right to be outraged that people without any direct information, with giant gaps of information, without observation of the program implementation, without knowledge of what we are doing and why. without information about NSF. without any attempt to find out what we know would deem it even possible to make judgments about the work, about what the outcomes mean, or what should happen next. For goodness sake! Or. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fex) GADBERRY, BRADY L. From: Sent: To: Subject: CARNINE, LESLIE V. Friday, March 02, 2001 12:31 PM GADBERRY, BRADY L\nSTEWART, DONALD M. FW: Central High School Parking and/or Baseball Field As both of you know there is always three side to the story but this Is going to go public and there will be a lot of finger pointing, would this not be a good time to visit with Baldwin Shell about the logistics of the Central renovation. That could then determine the number of portables and feasibility of the faculty parking and the other issues. Original Message From: Sent: To: Cc Subject: HOWARD, RUDOLPH Wednesday, Fetxuary 28, 2001 5:39 PM EATON, DOUGLAS LACEY, MARIAN 6.\nGADBERRY, BRADY L\nCARNtNE, LESUE V. Central Htgri School Parking and/or Baseball Reid We keep going \"around and around\" in an effort to avoid the issue. I asked for a meeting to determine whether or not the district was going to support the building of a baseball field. Specifically, how much was the district going to contribute in order to match what the baseball boosters(Mr.Yancey) would contribute. After waiting for a meeting for over 2 months. I receive this memo from Doug- 2/22/01- rehashing what has already been covered. Specifically, the issue about the parking lot and the portables. Now. I have indicated and the CLT has indicated that we would give up the teacher parking lot in order to accommodate the portables. WE ARE NOT AGREEABLE TO GIVING UP ANY ADDITIONAL SPACE ON THE PRACTICE FIELD. Doug, you continue to talk about the need for additional space for portables, but you ner tell us how many portables that are going to be needed. Therefore, we can never determine if the space on the parking lot and/or the space around Central is adequate or not. 875013744187 walker LAW FIRM 050 P01 JUL 24 01 11:20 JOHN IT. WALKER. P.A. Attorney at Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-5758 Fax (501) 574-4187 TRANSMISSION COVERSHEET Date: [, To: [. ] Fax: L 1 Re: L J Sender: J YOU SHOULD RECEIVE [ rmcluding cover sheet)] PAGE(S), INCLUDING THIS COVERSHEET. IF YOU DO NOT RECEIVE ALL THE PAGES, PLEASE CALL \"\u0026lt;(501) 574-3758\u0026gt;\" The information contained in this facsimile message is attorney privileged and confidential information intended only for the use of the individual or entity named above. If the reader of this message is not die intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, piease immediate notify us by telephone, and return the original message to us at the above address via the U.S. Postal Service. Thank you. I JOHN w. walker SHAWN CHILDS 5013744187 WALKER LAW FIRM John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 Via Facsimile 682-3479 March 26, 2001 388 P02Z05 MAR 26 01 13:17 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 HENDsnsoN Road LlTn. Rock, Askans.vs 72210 Phone: (5U1) 372-3425  Fax (SOl) 372-3428 Em-aiL: inchenryd@8wboU.nrc Representative Pat arker Bond House Of Represer\natives State Capitol, Rooi i 350 Little Rock, AR 7201 Dear Ms. Bond: 1 understanc annex or detach the that your bill which is now under consideration by the Legislature to deJacksonville area from the Pulaski County Special School District has not received comments from us and possibly from other interested panics in the long stating Pulaski County Desegregat on case. 1 am writing to inform you that while the bill may be popular with some of the Jacksoj ' desegregation plan\nville constituents, it may also have negative impact upon the court approved and that any legislation being considered will have to pass muster under the 14* Amendment as kvell as the law of the case concept. As you are\nrobably aware, no one has sought input from the Joshua Intervenors with respect to the legist ition or to the charter school which was approved for the Maumelle area. While our approval resort to the Coun is not required, our lack of knowledge and input will tend to cause us to o have matters ferreted out. Rather than get into a public dispute with you and the other propc nents of your legislation, 1 respectfully request that you and the other proponent legislate s meet with possibly the ODM, school officials and myself so that you have a better under landing of why opposition from Joshua, at least, is well placed. can Would you suggest that you sp :indly get in touch with me regarding this matter as soon as possible. I also with Ms. Ann Marshall of the Office of Desegregation Monitoring in order to obtain that office s perspective regarding pending legislation. !hn W. Walker f JWjS 5013744187 walker LAW FIRM 388 P03/05 MAR 26 01 13:17 cc\nMs. Ann Marshal Dr. Gary Smith Dr. Leslie Carni Mr. James Smitj Mr. Ray Simon le Ail Counsel of I ecord5013744187 WALKER LAW FIRd 388 P05/05 MAR 26 01 13:18 With due re peci lo the court, I remain, JWWjs cc: Mr. Chris Helle Ms. ,Ajin Brown Mr, Sam Jones Mr. Steve Jone: Mr. Richard Ro / Walker Sincerely yours, .chcll Mr. Timothy Gs iger '' I^EQSIVSO ^AR 3 0 200! GrBCECf ^^SESREGfiJJQSi^^- ^JIS C\u0026gt; CF John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS Via Facsimile March 26, 2001 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone\n(501) 372-3425  F.ax (501) 372-3428 Email\nrachenryd@swbell.net Honorable Judge Susan Webber Wright Chief Judge United States District Court 600 West Capitol Avenue Little Rock, AR 72201 Re: LRSD v PCSSD Dear Judge Wright: Due to the fact that I was in trial before the Honorable George Howard Jr. in Pine Bluff, Arkansas from March 19-22, 2001 and in intense preparation for the days preceding the 19* I am just getting in position to address the Little Rock filing. Notice of Filing Compliance Report and Request for Scheduling Order. I further note that Little Rock has indicated that it wishes to limit our time for filing challenges to twenty (20) days. This letter is being written to request that the Court set a time for a conference before addressing the issue of a scheduling order so that all parties, as well as the Office of Desegregation Monitoring, would have an opportunity to address the propriety of the scheduling order request. The compliance report is extensive. It appears to be more than two hundred (200) pages in length, is very detail oriented and it makes many claims which are unfamiliar to us and probably to the ODM as well. I am writing the Court this letter, rather than filin\nHeller, who I am advised is away until Wednesday, expressed an ig a motion, because Mr. interest in having some dialogue regarding this matter, and the State settlement as well, before this matter becomes, if it ever does. a public dispute which the Court must resolve. I understand that the Court intends to schedule a hearing in the near future regarding the middle school issues raised by the PCSSD. May I suggest that the matter of the hearing of the scheduling order be set for the same day inasmuch as all parties are expected to be in court for the PCSSD matter. Although I have been unable to speak with Mr. Heller and I have not attempted to reach his co-counsel, Mr. Clay Fendley who I intend to try and reach immediately, I have informed Ms. Ann Marshall regarding my concerns herein and will be having further conversations with the parties until such time I receive the Courts reply to this letter.With due respect to the court, I remain, JWW.js cc: Mr. Chris Heller Ms Ann Brown Mr. Sam Jones Mr. Steve Jones Mr. Richard Roachell Mr. Timothy Gauger Sincerely yours. n W. Walker ro mx JOHN W. WALKER SHAWN CHILDS John w. Walker, p.a. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 1 4 ZOQi. urfluE OF B^eSA'nGK5fiOtSITORIM\u0026amp; OF COUNSEL ROBERT McHENRY. P.A. DONNA J. McHENRY 8210 Hender.5O.\\ Road Little Rock. Ark.a.\\s.as 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Email: mchenrydSswbell.net Via Facsimile - 310-822-4824 April 9, 2001 Tr'mfl'i on g^ECESVc Dr. Terrence Roberts 932 South Oakland Pasenda, CA 91106 Re: LRSD Dear Terrence:' Joy gave me a report of your brief conversation with her on Friday. I am writing to inquire of your opinion as to whether the Little Rock School District has made it to the point where it can be established to be a unitary school system. I need a written response to this by the end of the week. The expectancy of the plan was that the Joshua consultant would be closely associated with Joshua as policies and procedures were being developed and established. In addition, the plan contemplated that we would be integrally involved in all aspects of policy devisation and promulgation. I thought we had established that during our several conversations with you. We had the same expectancy from Dr. Ross. To date, our involvement has been superficial and mostly nonexistent except for our initiative. Accordingly, when you provide your opinion regarding the readiness of the District for unitary status, would you kindly address our non involvement, i.e., in communication with you and District officials and in the reporting process in which you were involved. We believe that good faith was required of school officials in implementing the plan and that at minimal we were not to be circumvented by any persons in the process. I am sending Mr. Junious Babbs a copy of this letter because Junious has not kept us involved and, in our opinion, has actively sought to prevent our involvement, I believe, as provided for in the plan. His position seems to be that if you were invo.lved then we were involved, for you were our consultant rather than theirs. At a hearing, he, of course, will be a necessary witness regarding this point. Please let me hear from you as requested. Furthermore, if Mr. Babbs chooses to address these points with you, would you please let us know his position in your response to us. Office of Desegregation Monitoring FILE COPYWith warm personal regards, 1 remain, Sincerely, John W. Walker JWW:js cc: Mr. Junious Babbs Ms. Ann BrownAn. O' OOXQZ.H-^Z01 L K S D Rpr 1601 10:17a RITA ROBERTS SRD 626-793-7654 PAGE 02 P-2 Terrence J. Roberts, Ph.D. P.O. Box 96 Pasadena, CA 91102 (626) 644-4956 April 16, 2001 John W. Walker, P.A. Attorney at Law 1723 Broadway Little Rock, Arkansas 72206 RE: Your April 9,2001 letter to me Dear John: As always, it was good to hear from you, and I trust the report frna Joy was useful and informative. I will schedule lime lo meet with you when I am in Little Rock in the future. The work in the School District is going well and my feeling is that the employees have found the Coping With Difference program to be challenging and substantive. You ask, in your letter, about my opinion as to whether or not the School District has marie it to the point where it can be established as a unitary school system. Briefly, in my opinion, possibly. But, it is imperative to note that there arc many factors to be weighed and my opinion is but one of many to be considered. I add this because until all interested parties can come together and the available evidence, it is simply, and only, a matter of opinion. I feel ill equipped to comment on your level of non involvement in this process since I dont have enough information about communications between you and the District When I spoke to Mr. Babbs, he was surprised to find that you were of the opinion that he has actively sought to prevent your iiivolvement. As to Uk matter of whether or not T nm a Joshua consultant or a District consultant, I must say I find this rather confusing. In one sense it bespeaks an adversarial process which seems to pit you against the District with me somewhere in the middle. On the other band, it suggests a need for me to decide where my loyalties lie. In either case, the focus appears to be on things other than those that might benefit the children of the District. John, I am in this process because I want to see positive change that will result in greater educarional opportunities for children in this school system. My commitment is to do whatever it might take to realize that goal. If that end result is best achieved by unitary Office Of Desegregation Monitoring FILE COPYai/ ib / zooi 14: 04 501-324-2281 Apr IG 01 10:18a RITR ROBERTS LRSD SRO 62B-793-7G54 PAGE 03 P-3 status, so be it. However, if the opposite is true, I will support non-unitary status with a vengeance. You see, for me, this effort has never been about integration per sc. Integration in the absence of changed mind sets about the worth and value of children of color is an unworthy goal Obviously, there remains much to be done io this arena. Thats why I say, possibly, the District is ready for unitary status. In any case, we will talk further. Sincerely, A Terrence J. Rober^ PhJ), Cc: Mi. Junious Babbs, Ms. Ann Brown Received John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JUL 2 - 200J Off ICE OF DESEGREGATION MONITORING JOHN W. WALKER SHAWN CHILDS Via Facsimile - 376-2147 June 29, 2001 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mchenryd^wbeU.net Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center Little Rock, AR 72201 Dear Chris: Please provide all the information that has been provided to you by District officials at any time since June 10, 1999. Our tentative list of witnesses includes your senior administrators, beginning with Dr. Carnine and going to the level of Director. I am unable to give specific names because your letter of June 29, 2001 does not give specific names of the people responsible for [the] specific section of the Revised Desegregation and Education Plan. These are the names that I think are responsible: Dr. Les Carnine, Dr. Bonnie Lesley, Dr. Kathy Lease\nDr. Marion Lacey\nDr. Linda Watson\nDr. Richard Hurley\nDr. Ed Williams\nDr. Don Stewart\nDr. Gary Smith\nMs. Sadie Mitchell\nMr. Junious Babbs\nMs. Jo Evelyn Elston\nMr. Brady Gadberry\nMr. James Washington\nMr. Robert Robinson\nMs. Pat Price\nMr. Leon Adams\nMs. Vanessa Cleaver\nMr. Dennis Glasgow\nMs. Frances Jones: Ms. Kay Rainey\nMr. Michael Oliver\nMr. Everett Hawks\nMr. Larry Mitchell\nMs. Gayle Bradford\nMr. Lionel Ward\nMr. William Broadnax\nMr. Ray Gillespie\nMs. Levanna Wilson\nMr. Gene Parker\nMr. Michael Oliver\nMr. Larry Mitchell\nand Mr. Jim Mobsy. Other tentative witnesses include: Dr. Terrence Roberts\nDr. Steven Ross, Dr. John Fluker\nDr. Ray Simon, Dr. Charity Smith\nDr. Ken James\nand Mr. Willie Morris. I will supplement this list on Monday after receipt of all the requested information. With respect to exhibits, I intend to use some of the documents that you submit to me by the end of the day, the ODM reports, and the FOIA responses that you have received copies of as you requested those copies from the school staff. I also may find it necessary to use correspondence between us and yourself, Dr. Carnine and staff members of the Little Rock School District. I also expect that we may make reference to information provided to the District from Drs. Steven Ross and Terrence Roberts, as well as the ADE. We have asked Dr. John Fluker to look at some of your statistical data and are not certain what he has done with it at this time. I will share any reports from him as soon as I receive them. Finally, I expect to use the Monitor and Associate Monitors of the ODM as witnesses as well. Siiicerely, / ^hn W. Walker JWW:js cc: Ms. Ann Brown Counsel of Record Friday Eldredge \u0026amp; Clark HERSCHEL H FRIDAY (1922-1994) WILLIAM H SUTTON. P A BYRON M. EISEMAN. JR.. P.A. JOE D. BELL. P.A. JAMES A. BUTTRY, P.A FREDERICK S. URSERY. P.A. OSCAR E. DAVIS, JR., P.A. JAMES C. CLARK. JR , P.A. THOMAS P. LEGGETT. P.A. JOHN DEWEY WATSON, P.A. PAUL B. BENHAM UI. P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EDWARD HARRIS. P A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL UI. P.A. DONALD H- BACON, P.A. WILLIAM THOMAS BAXTER. P.A. BARRY E. COPLIN. P.A. RICHARD D. TAYLOR. P.A. JOSEPH B. HURST. JR . P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P A. ROBERT S. SHAFER. P.A WILLIAM M. GRIFFIN UI. P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL III. P.A. KEVIN A. CRASS. P.A. WILLIAM A. WADDELL. JR.. P.A. SCOTT J. LANCASTER. P.A. M. GAYLE CORLEY. P.A. ROBERT B. BEACH. JR., P.A. J. LEE BROWN. P.A. JAMES C. BAKER. JR.. P A HARRY A. LIGHT. P.A. SCOTT H. TUCKER. P.A. GUY ALTON WADE. P.A. PRICE C. GARDNER. P.A. TONIA P. JONES. P.A. DAVID D. WILSON. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayfirm.com 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 501-376-2011 FAX 501-376-2147 237 EAST MILLSAP. SUITE 7 FAYETTEVILLE, ARKANSAS 72703 TELEPHONE 501-695-2011 FAX 501-695-2147 JEFFREY H. MOORE. P.A. DAVID M. GRAF. P.A. CARLA GUNNELS SPAINHOUR. P.A. JOHN C FENDLEY. JR . P.A. JONANN ELIZABETH CONIGLIO. P.A. R- CHRISTOPHER LAWSON. P.A. GREGORY D TAYLOR, P A. TONY L. WILCOX. P.A. FRAN C. HICKMAN. P.A. BETTY J. DEMORY, P.A. LYNDA M. JOHNSON. P.A. JAMES W. SMITH. P.A. CLIFFORD W. PLUNKETT, P.A. DANIEL L. HERRINGTON, P.A. MARVIN L. CHILDERS K. COLEMAN WESTBROOK. JR. ALLISON J. CORNWELL ELLEN M. OWENS JASON B. HENDREN BRUCE B TIDWELL MICHAEL E. KARNEY KELLY MURPHY MCQUEEN JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN BRYAN W. DUKE JOSEPH G. NICHOLS ROBERT T. SMITH TAMARA G. MARTIN RYAN A. BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON OFCOUNSEL B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H.T. LARZELERE. P.A. JOHN C. ECHOLS. P.A. A.D. MCALLISTER 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2896 FAX 870-762-2918 June 29, 2001 JOHN C. FENDLEY. JR. LITTLE ROCK TEL 501-370-3323 FAX 501-244-5341 fendleyOfec.net Via Hand Delivery RECEIVED The Honorable Susan Webber Wright 522 U.S. Post Office and Courthouse JUN 2 9 2001 600 West Capitol Avenue Little Rock, Arkansas 72201-3325 OFRCEOF DESEGREGATION MONITIM RE: Little Rock School District v. PCSSD Dear Judge Wright: Enclosed please find two documents which the Little Rock School District may introduce as exhibits in the hearings beginning July 5, 2001, pertaining to Little Rock School Districts compliance with its revised desegregation and education plan. Little Rock School District will also rely on its interim Compliance Report filed March 15,2000, and its Compliance Report filed March 15,2001, which have already been filed with the Court. We thank you for your time and attention to this matter. Respectfully, JCF/jm Enclosures John C. Fendley, Jr. cc via hand delivery: Mr. John Walker Ms. Ann Marshall The Honorable Susan Webber Wright June 29, 2001 Page 2 cc via U.S. mail: Mr. Sam Jones Mr. Steve Jones Mr. Richard Roachell Mr. Sammye TaylorLittle Rock School District Pupil Services Department Scholarship Awards 2000-2001 School Year School # Scholar^ip Recipients BM BF WM WF OM OF Central 4 4% 11 10% 25 23% 64 4 1 HIS Male 0 HISF Female 1 58% 4% 1% 0 1% Total no BM J.A. Fair 6 22 4 8 0 0 1 1 42 14% 52% 10% 19% 0 0 1% Hall McClellan Parkview TOTALS 15 13 5 5 0 0 1 0 39 38% 8 21% 7 10% 40 13% 33% 26 68% 19 26% 91 30% 13% 0 0 7 10% 41 14% 13% 3 8% 31 42% 111 37% 0 0 0 2 3% 6 2% 0 0 0 4 5% 5 2% 1% 1 0 38 1% 0 3 73 0 3 1% 4% 5 302 2% SCHOLARSHIP AWARD TOTALS 5185,242 $32,600 $406,458 $91,496 $332,781 $1,048,577 BF WM WF HisM HisF OM $309396 $278,606 $284,752 $334,680 $425,881 $1,633,315 $454330 $116,640 $342,450 0 $97,610 $1,010330 $963,662 $40,072 $240,000 $46,316 $647,566 $1337,616 $74,000 0 0 0 $82,192 $156,192 $16,000 0 0 0 $195,662 $211,662 $10,000 $10,000 $60,000 0 0 $80,000 deceived JW 2 9 2001 OF 0 $4,000 0 0 $500 $4300 Total Award By School $2,012330.00 $481,918 $1333,660 $472,492 $1,782,192 $6,082,792.00 ScholarshipAwards.OlHighlights of Grades K-2 Results Developmental Reading Assessment 1999-2000 and 2000-2001 2 9 25\n,I OmCEOF All three grade levels improved in spring 2001. 1999-2000 Kindergarten Grade 1 Grade 2 72.2 53.6 67.5 2000-2001 80 7 63.8 75.4 First grade showed the greatest improvement in spring 2001. Kindergarten Grade 1 Grade 2 Change +8.5 +10.2 +7.9 More than 75 percent of the schools improved in spring 2001. Kindergarten Grade 1 Grade 2 # of Schools Improving 27 (77%) 29 (83%) 29 (83%) 1Both area and magnet schools did well. The five highest performing schools at each grade level for each year follow. 1999-2000 2000-2001 Kindergarten McDermott* Fulbright* Rightsell* Terry * Grade 1 Grade 2 Mitchell* Woodruff* Williams Wilson* Western Hills* McDermott* Rightsell* Williams Forest Park* Western Hills* Otter Creek* Denotes area schools. McDermott* Baseline* Fulbright* Gibbs Brady* Williams Carver McDermott* Booker Forest Park* Carver Williams Western Hills* Otter Creek* McDermott* 2Many schools improved dramatically in spring 2001. Schools improving 20 or more points are as follows. All are area schools, and most are high poverty schools. Kindergarten Grade 1 Grade 2 _______2000-01 Baseline (42.9)* Badgett (28.4)* Forest Park (27.1) Cloverdale (26.1)* Stephens (25.3)* Wakefield (44.6)* Watson (41.9)* Baseline (41.2)* Stephens/Garland (27.5)* Western Hills (25.8) Chicot (24.4)* Badgett (20.6)* Dodd (31.1) Badgett (31.1)* Stephens/Gariand (30.1)* Pulaski Heights (29.3) McDermott (22.5) Denotes schools with 75% or higher eligible for free/reduced lunch. 3The Incentive Schools are, in general, improving. With the exception of Mitchell and Rightsell at grade 1, a majority of the students are performing at or above the \"readiness\" level. Kindergarten Franklin Mitchell Rightsell Rockefeller Stephens 1999-2000 64.3 90.6 92.1 75.8 40.8 2000-2001 58.6 92.3 80.5 76.2 66.1 Change -5.7 1.7 -11.6 0.4 25.3 Grade 1 Franklin Mitchell Rightsell Rockefeller Stephens 1999-2000 57.6 25.0 35.7 76.3 23.5 2000-2001 58.9 25.0 41.7 65.2 51.0 Change 1.3 0.0 6.0 -11.1 27.5 Grade 2 Franklin Mitchell Rightsell Rockefeller Stephens 1999-2000 81.2 48.6 94.7 71.4 31.3 2000-2001 83.6 50.0 70.5 84.2 61.4 Change 2.4 1.4 -24.2 12.8 30.1 4The Newcomer Centers are improving, except for Terry at kindergarten and grade 2. Kindergarten Brady Chicot Romine Terry Washington 1999-2000 76.9 56.1 66.7 91.9 81.2 2000-2001 93.4 70.9 86.4 86.7 84.1 Change 16.5 14.8 19.7 -5.2 2.9 Grade 1 Brady Chicot Romine Terry Washington 1999-2000 34.9 26.8 59.6 47.1 35.5 2000-2001 53.5 51.2 76.5 59.8 41.1 Change 18.6 24.4 16.9 12.7 5.6 Grade 2 Brady Chicot Romine Terry Washington 1999-2000 70.8 38.6 68.8 81.2 63.3 2000-2001 79.6 52.1 81.6 67.1 81.4 Change 8.8 13.5 12.8 -14.1 18.1 5There are seventeen (49 percent) elementary schools in the District where 75 percent or more of the students are eligible for free/reduced lunch. Many of these schools improved dramatically in spring 2001 and/or some are performing in the highest range of scores (80 percent or higher). Kindergarten Badgett (94%)____ Franklin (90%) Stephens (90%) Chicot (87%) Baseline (86%) Woodruff (86%) Cloverdale (85%) Wilson (85%) Mabelvale (85%) Mitchell (84%) Watson (83%) Geyer Springs (83%)____________ Rightsell (82%) Meadowcliff (81%) Wakefield (80%) Fair Park (78%) 1999-2000 21.6 64.3 40.8 56.1 51.1 69.2 56.4 66.7 61.0 90.6 56.4 85.1 2000-2001 50.0 58.6 66.1 70.9 94.0 46.2 82.5 80.0 73.3 92.3 73.7 87.7 Change 28.4 -5.7 25.3 14.8 42.9 -23.0 26.1 13.3 12.3 1.7 17.3 2.6 92.1 77.4 46.8 68.3 80.5 77.1 61.1 75.6 -11.6 -0.3 14.3 7.3 6Badgett (94%) Franklin (90%) Stephens (90%) Chicot (87%) Baseline (86%) Woodruff (86%) Cloverdale (85%) Wilson (85%) Mabelvale (85%) Mitchell (84%) Watson (83%)_____ Geyer Springs (83%)____________ Rightsell (82%) Meadowcliff (81%) Wakefield (80%) Fair Park (78%) Grade 1 1999-2000 5.9 57.6 23.5 26.8 29.6 84.2 28.4 82.9 50.8 25.0 24.7 46.8 2000-2001 26.5 58.9 51.0 51.2 70.8 61.5 33.9 53.8 60.5 25.0 66.6 38.6 Change 20.6 1.3 27.5 24.4 41.2 -22.7 5.5 -29.1 9.7 0.0 41.9 -8.2 35.7 70.0 22.0 62.5 41.7 66.6 66.6 72.7 6.0 -3.4 44.6 10.2 7Badgett (94%)____ Franklin (90%) Stephens (90%) Chicot (87%)_____ Baseline (86%) Woodruff (86%) Cloverdale (85%) Wilson (85%) Mabelvale (85%) Mitchell (84%) Watson (83%)_____ Geyer Springs (83%)____________ Rightsell (82%) Meadowcliff (81%) Wakefield (80%) Fair Park (78%) Grade 2 1999-2000 11.8 81.2 31.3 38.6 47.1 78.3 57.9 60.4 43.4 48.6 54.4 72.5 2000-2001 42.9 83.6 61.4 52.1 60.5 86.5 45.1 61.4 63.0 50.0 51.2 66.0 Change 31.1 2.4 30.1 13.5 13.4 8.2 -12.8 1.0 19.6 1.4 -3.2 -6.5 94.7 57.9 40.0 62.9 70.5 75.0 54.4 67.7 -24.2 17.1 14.4 4.8 8Most of the Success for All (SFA) schools improved in spring 2001. Most are now enriching the SFA program with ELLA strategies. Kindergarten Brady Baseline Cloverdale Fair Park Meadowcliff Romine Woodruff 1999-2000 76.9 51.1 56.4 68.3 77.4 66.7 69.2 2000-2001 93.4 94.0 82.5 75.6 77.1 86.4 46.2 Change 16.5 42.9 26.1 7.3 -0.3 19.7 -23.0 Grade 1 Brady Baseline Cloverdale Fair Park Meadowcliff Romine Woodruff 1999-2000 34.9 29.6 28.4 62.5 70.0 59.6 84.2 2000-2001 53.5 70.8 33.9 72.7 66.6 76.5 61.5 Change 18.6 41.2 5.5 10.2 -3.4 16.9 -22.7 Grade 2 Brady______ Baseline Cloverdale Fair Park Meadowcliff Romine Woodruff 1999-2000 70.8 47.1 57.9 62.9 57.9 68.8 78.3 2p00E20Ql 79.6 60.5 45.1 67.7 75.0 81.6 86.5 Change 8.8 13.4 -12.8 4.8 17.1 12.8 8.2 Schools with the Reading Recovery program in grade 1 are performing well. Grade 1 Booker Chicot* 1999-2000 69.3 26.8 2000-2001 87.4 51.2 Change 18.1 24.4 9Dodd Franklin Fulbright** Geyer Springs Gibbs Jefferson Otter Creek Pulaski Heights** Williams Wilson* 58.3 57.6 61.0 46.8 65.9 69.1 67.7 50.0 84.1 82.9 *2000-2001 was a training year. Reading Recovery not continued in 2000-2001. Grade 2 1999-2000 73.5 58.9 66.6 38.6 71.4 73.9 69.6 61.7 97.1 53.8 2000-2001 15.2 1.3 5.6 -8.2 5.5 4.8 1.9 11.7 13.0 -29.1 Change Booker Chicot* Dodd Franklin Fulbright** Geyer Springs Gibbs Jefferson Otter Creek Pulaski Heights** Williams Wilson* 79.8 38.6 51.7 81.2 79.3 72.5 80.5 71.1 87.2 45.2 81.4 52.1 82.8 83.6 88.7 66.0 82.9 85.0 90.5 74.5 1.6 13.5 31.1 2.4 9.4 -6.5 2.4 13.9 3.3 29.3 89.7 60.4 92.6 61.4 2.9 1.0 The number of schools with a majority of students performing below the \"readiness\" level is declining. Kindergarten Grade 1 Grade 2 1999-2000 3 (9%) 13 (37%) 8 (23%) 2000-2001 1 (3%) 6 (17%) 2 (6%) 10The number of schools with at least 80 percent of the students performing at the \"readiness\" level is increasing. Kindergarten Grade 1_____ Grade 2 1999-2000 15 (43%) 5 (14%) 10 (29%) 2000-2001 21 (23%) 5 (14%) 18 (51%) The gap between the lowest and highest performing schools is decreasing. Kindergarte n Grade 1 Grade 2 1999-2000 73.2 2000-2001 48.1 Change 25.1 78.3 82.9 72.1 50.2 6.2 32.7 11Black students are improving at every grade level and at a higher rate than Non-Black students. 1999-2000 Kindergarte n Grade 1____ Grade 2 69.3 48.3 63.8 2000-2001 77.0 57.4 69.8 Change 7.7 9.1 6.0 Non-Black students are improving at every grade level. Kindergarte n Grade 1 Grade 2 1999-2000 84.7 71.2 81.6 2000-2001 88.8 77.3 86.8 Change 4.1 6.1 5.2 The achievement gap is much lower in grades K-3 now than in higher grade levels and is decreasing. It is lowest at kindergarten. Kindergarte n Grade 1 Grade 2 1999-2000 15.4 2000-2001 11.8 Change -3.6 22.9 17.8 19.9 17.0 -3.0 -0.8 12John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 RECEIVED JUN 2 9 2001 ^Of JOHN W. WALKER SHAWN CHILDS OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mchenryd^wbell.net Via Facsimile June 28, 2001 Honorable Judge Susan Webber Wright Chief Judge - United States District Court 600 West Capitol Little Rock, Arkansas 72201 Re: LRSD v. PCSSD, et al., Case No. 4:CV82-866 Dear Judge Wright: I am writing this letter to request that you schedule an informal conference between the Little Rock School District counsel and us regarding the forthcoming hearing. The timing of the hearing appears to be insufficient for us to prepare to make our case. The District officials simply have not cooperated with us in providing information on a voluntary basis. We are now met with the inability to communicate with any District official without going through counsel and we are experiencing other problems as well. This is due to instructions and advice of counsel. Let me cite an example of the problems that we are having. We met with Chris Heller, Clay Fendley and Ms. Marshall on Monday of this week. We were informed that there were large numbers of evaluation reports regarding the many programs that have been undertaken by the District in the past three years and before that are sitting, according to Clay, in Clays office. Those reports have been requested by us many times and we were essentially informed that no such reports existed. We still have not seen the reports. Now Clay and Chris do not make them and other District data available to us as has been the normal expectation and practice. That practice has abated since Joshua filed their objections. The timing problem also involves our inability to meet the courts directive that we provide our exhibits by tomorrow. With the Districts lack of cooperation, without there being formal discovery, and with the obstruction directed by Clay and Chris, we simply need much more time to meet our burden of proof. We request that we be allowed to use the time that you have set for trial in July and August to engage in discovery and that the matter be reset for a period of time thereafter. We also note that the District is in the process of preparing reports that it intends to submit in its portion of the hearing. If they attempt to do this, it will prejudice our presentation.This is so because they were obliged, at the time of their report in March, to have fiilly met their obligations and to have that established by documentation. A conference is sorely and urgently needed so that we can address these and other concerns of the parties. May we meet with you either by telephone, or in person, either later today or tomorrow? Sincerely, John W. Walker JWWjs cc: Mr. Chris Heller Ms. Ann Brown Mr. Richard Roachell Counsel of Record C  Cu/ RECEIVED JUL 2 - 7001 received JU12-2O(I1 OmCEOF desegregation MONITORING OmCEOF OESEgfGKnONIMHgm OFFICE OF THE ATTORNEY GENERAL STATE OF ARKANSAS Mark Pryor Attorney General Samrayc L. Taylor Chief Barrister Direct dial: (501)682-1320 E-mail: sammvet@aq.state.ar.us KL4 FACSIMILE Honorable Susan Webber Wright 302 U.S Post Office and Courthouse 600 West Capitol Avenue Little Rock, AR 72201 604-5169 Re: LRSD V. PCSSD\nUSDC\n4:82CV866SWW Dear Judge Wright: Mark and I would like to thank you for excusing us from the hearing currently being scheduled by the court for the morning of June 29, 2001. I was not scheduled to be in the office tomorrow and Mark has a deposition scheduled to begin at 10:00 a.m. If we were to attend the hearing, we would object to Mr. Walkers untimely request to continue the hearing dates in July and August, as these dates have been set by court order since April 4, 2001. Again, we appreciate your granting us leave to not attend the June 29 hearing. Respectfully yours, Chief Barrister SLT/alh cc: Counsel of Record via Regular Mail 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:\\Civil\\Sammye Taylor\\Deseg\\Judge 6-28-01 .doc 954 Peaces ju. 03 01 18:29 JOHN W. walker SHAWN CHILDS John W. Walker, P.a. AitorneyAt Law 1723 Broadway Lmts Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 Via Facsimile - 376-2147 July 3. 2001 OF COUNSEL ROBERT McHENKYEa. DONNA J. McHENRY 8210 Hbjdsrson Boao Email: nwhcnrydgawbelhaet Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center Little Rock, AR 72201 Dear Chris\nJoshua may use the following documents as exhibits during the hearings on July 5** and 6*: 1) Compliance Plan dated June 10, 1999 and any subsequent plans I D n________ J - 1 _______________ *  * -2) LRSD Interim Report dated March 15. 2000\n-3) LRSD Compliance Report dated March 15, 2001\nODM Report dated June 21, 1995\n^5) ODM Repon dated October 26, 1999\n*^5) ODM Repon dated March 29, 2000\n^7) ODM Repon dated April 11, 2001\nt-^) ODM Repon dated August 11, 1999\n9) Draft Ev^uations from PRE\n10) Responses to request for information dated 6-8-01 to Mr. Babbs\n11) Responses to request for information dated 6-13-01 to Dr, Lesley 12) Documents listed in Dr, Lesleys letters dated 6-14-01 and 6-27-01 to Ms, Springer\n13) Responses to request for information dated 6-20-01 to Ms, Mitchell\n14) Responses to request for information dated 6-27-01\n15) Responses to request for information dated 6-28-01 to Mr. Heller 16) Loan requests to State of Arkansas from LRSD\n17) Responses to requests for information dated 6-27-01 to Ms, Mitchell\n18) Responses to requests for information dated 7-2-01 to Dr, James\n19) LRSD 2000-01 Recruitment and Placement Service Annual Report 20) Dept, Of Exceptional Children Strategic Plans - 1998 and 2001 21) Budget and Enrollment data for LRSD elementary schools\n22) Manpower Reports for 1998-99 through 2000-01, 23) Standardized test results (SAT, ACT, Stanford) from 1982 to present 24) Leners dated April 14, 1999, April 20, 1999, May 12, 1999 to Dr. Carnine5013744187 WALKER LAW FIRM 954 803/03 JUL 03 01 18:29 ----- 25) Letters dated July 8, 1999 and October to John Walker\n18, 2000 from Christopher Heller - 26) Letter dated September 13, 1999 to Mr. Larry Berkeley\nLumpkin to Junious Babbs- ^'garding equitable allocation 1-29) Settlement Agreement dated 1989 pages 15-16\n26-27\nof resources\nAgreement between State and LRSD dated 3-19-2001 321 Walker d^ed 5-11-13-99- Correspondence between Mr. Babbs and Drs. Ross and Roberts- 341 from Mr. Babbs office on 7-2-01- and -34) Dr. Camine s Pnonty Repons.   There are several requests that are still outstanding and documents as exhibitc Tf  ana we may use some of those all documents that are given to tbs XVwkh \"structed District personnel to share you. Your cooperation is appreciated. Sincerely, John W. Walker JWWjs cc: Ms. Ann Marshall5013744187 UfiLKER LfiW FIRM 954 P01Z03 JUL 03 01 18:29 W. WALKER, P.A. Anorney at Law 5723 Broadway Tittle Rock, Arkansas 72206 Telephone (501) 374-3758 Fax (501) 374-4187 FAX transmission COVER SHEET Date: To: Fax: [. [, r 'Ll3-^0! J ] Re: L Sender: YOU SHOULD RECEIVE S J ] - ---------(including cover sheet)]PAGE(S), INCLUDING THIS COVERSHEET. TF YOU DO NOT RECEIVE ALL THEPAGES PLEASECALL \"\u0026lt;(501) 374-575S\u0026gt; . only for th use of the individiiBi or andconfideatial infonnationintentted ___ I entit-y- -n--a-m---e-d-- -a--b- ove. I*f t*he rea*der of' th-is mIessSage is HnOoTt tmhee iinmteenaodeedd J Wsibie to deUver it to the intended recipient, you are hereby notified that any dissenunation, distribution or copying of this communication is strirrlv i_____ received this communication in error, please immediate notify or copying of this communication is strictly prohibited. If you have to us at the above address via the U.S. Postal Service. Thank us by telephone, and return the original message :you. a 1015744187 WALKER LAW FIRM 932 P02/03 JUL 03 01 06:50 JOHN w. walker SHAWN CHILDS John w. Walker, p.a. Attorney At Law 1723 Broadway LmtE Rock, Arkansas 72206 TELEraoNE (501) 374-3758 FAX (501) 374-4187 Via Facsimile July 3, 2001 O' COUNSEL ROBERT McHENRY. Ra pONNALMcHENW 8210 Hknoceson Road Ti. . Liras Rock AaxANBAs 72210 Phons: (501) 87^3426  Faz (501) 372-3428 Email\nmcbeniydaswbellnat Honorable Judge Susan Webber Wright Chief Judge - United States District Court 600 West Capitol Little Rock, Arkansas 7220] Re: LRSD v. PCSSD, et al. - Case No, 4\nCV82-866 Dear Judge Wright\nnought to meet with Little Rock school officials since our  * Honor on Friday. After providing names of possible witnesses to Mr Heller nn R a u------- to them available on Monday. On yesterday 1 snnke m u n  Fnday, he agre the inteiviews and he indicated that he would ge?btk wth^me At Wn m that we will be unable to make thL Since our conference 5vith Her on Friday, agreed interviews this week, we will be unable to make them available for requesting a conference with the Court to assist us with an amicable resolution of this matter. ificerely, ictated but not read John W. Walker JWW:js cc\nMr Chris Heller Ms. Ann Brown Qffioeof OMsgregation MonRoring FILE COPYrxioAYdni.)^) H. lUTTOW. px. ,nm K. nioua. j., r.. ^AavmT.fA  uluny. C Aavtx. JAMtt C. CXaAX. JV F.A, tvomaa  Lcocxrr. zx. iotoi OCWT wanea. 7.A. FAUL X SXMXAM lU. r A. LAArrw auxxAF.A. A **cxurrpiSMr^jx..zA. MMXS C9WMP \"AAAiA. f-A. h FWUJF MaLCAM. F.A JAHJJ M. aWSAN. FJL ZAMttM. UXTAH. F.A. J siienBKo pj, H. MCON.  A. *nXlAMTTMH lAXrn. M AWY s. conm. f.a. UatAAA 0. TAVLOt. 7.A 5013744187 WALKER LAW FIRM iKLUAi liWKjbliGt\na CLARK 932 P03/03 JUL 03 '01 0002 06:50 Josmo. WMT. nu. i.a UZAtlTH kOMCN MUAXAt * a CttKTOnrBl Htuat F A. w/MWjunm iomTs.:RAPMu?.A vn.UAH M. oxtmw tn. f a. X noctt. ZA. iNAFCt. MACxrr r.A. OVtNA. fA. TA. A. WAPOBU. JtL. f.A. tCOTT I. a.A M.0AVVlC0V.tY..A. *O*\u0026lt;*T \u0026gt;. aCACM. flL. tjL. J. LZE BXOMr, r,A. jAMsac aAax.JK.. *y A. LWWI. F.A. rT K. rargy j fluy ALWN VAOe. FtlOSCOAMM\u0026amp;Lrx YONlA f. town. \u0026gt;.A. OAvw 0. YOMt. e.A. Friday Eldredge A Clark ATToaxeys t law * JMITSC tlAgiuTY rAfiTNBtSfllf \".friosyflrm.com 2000 AEQlONS CCNTgft 468 WZ6ST CAPITOt. ttls rock. ARKANflAa rzzovjAss TCLfPhone 501-378-4011 Fax 501-378-2,47 EAST utusAp. wire 'Avengviue. awcum \u0026gt;jj I^IEFMONE sei.AM.20lt Fax Ml.sMeMAT zM pipTM sneer eurrneviLtt. AMfA/tStit \u0026gt;ia TBLW\u0026lt;^\u0026lt; 70.m24M FAX x7eeTi.aia VIA FAZ No, 374-4187 July 2,2001 n MOOXX. ClAA F. A MO(Ar ALBteMVtA A trXAM Mtrna * CwJTOMttl tJhVSON. fJL ------------- OAlCAay a. TaVX^ Pji. WRXOX. zx. C meXMAN. r./i, tWOA K fOWiOt^ f,/c UMXX V. AMtTK r.A. msocrrr. oafju, t MtuuiiQmi XAKVatLORLOCM colbmam wunoLoox. m. AUUOKX OOwrVBU. aUXHHdWlK 'ASON 4. WN0A1N IUJC8 *. nowiu. WA.l.XAJlV OLLY ituKnrr Wttxro. woiQu nom TAMAAU MARYW ctaita. wmiAM C O'\" t T. WOBUZ ATOt s. 4AUrr \u0026lt;a\u0026lt;AAM. OITTQa XCAAXC *RiUM u. nouiT \u0026lt;r. LABxeLsix Kfk \u0026amp; COMU. F A. A\u0026gt; MGAtUlTEfc CMMstOPNCA malsx LiTTUenOCX rev Crt\u0026lt;47*tuA FAX CMeaMeMM Mr. John Walker JOHNW\nWALKER,?,A. 1723 Broadway Little Rock, AR 72206 Re: LRSD V. PCSSD Dear John\nme know the order in which they will testify so that I can mnlfB time. In accordance wrth your letter. Dr. Lesley wiU not be avaailrarbalneg uenmtieln tthse t oA hauveg thuemst pSreJseSnt? at the appropriate You have said fiiat you plan to call Ann Marshall, Gene Jones and Horace Smith fiom Desegregation Monitoring. I have called ODM to attempt as I hear something, I will let you know. to the Of\u0026amp;ce of arrange ameetingin advance of their testimony. As soon We also discussed tfaeavailability of Steve Ross and Terrence Roberts, Itold you that we have not made any arrangements to have them present on Thunday or Friday. Lk Camine is in the process of moving to FayetteviUe. Dick Hurley has not yet remmed firm not yet returned from a trip out the available for interviews\" this week to make them Yoj Christopher J. Heller CJH/dh I John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS July 3, 2001 OF COUNSEL ROBERT McHENRY, PA DONNA J. McHENRY 8210 Henderson Road LnTLE Rock, Arkansas 72210 Phone\n(501) 372-3425  Fax (501) 372-3428 Email: mchenryd^wbell.net Mr. Ray Simon Arkansas Department of Education #4 Capitol Mall Little Rock, AR 72201 RECEIVED JUL 5 - 2001 Dear Mr. Simon: OFFICE OF DESEGREGATION MONITORING Would you please let us have access today to your correspondence files and other files regarding the 20 million dollar loan forgiveness discussions that you have been having with Little Rock. You will recall that we asked to be included in those discussions and have not been. This is to also inform you that we expect to call you as a witness in the existing case. We may not get to you on Thursday or Friday of this week, but if we dont we, please expect to be called on either August I\" or August 2\". With best regards, I remain, Sincerely, John W. Walker JWW:js cc\nMs. Sammye Taylor Ms. Ann Brown Mr. Chris Heller / 5013744187 WALKER LAW FIRM 260 P02 AUG 15 01 11:22 LITTLE ROCK SCHOOL DISTRICT ADMINISTRATIVE DIRECTIVE: IMH Effective\nJuly 11,2001 CLASS INTERRUPTIONS Purpose The purpose of these regulations is to increase significantly the amount of time on task or engaged learning time without increasing the school day or school year. The organization of the school and the use of time in the allotted school day send a powerful message to teachers and students about the value of learning. Keeping instructional time sacred is respectful of both teaching and learning. Extending engaged learning time\" is a research-based strategy for improving student achievement. I Interruptions to Instruction The principal and the Campus Leadership Team of each school are directed to protect instructional time from interruptions for non-instructiona! matters to every extent possible. Schools should periodically audit the amount of potential engaged time that is being lost due to teacher absences, student absences, tardiness in beginning lessons, time lost due to discipline infractions, time lost due to assemblies or presentations unrelated to the course benchmarks, early releases, field trips not tightly correlated with the course benchmarks, and similar losses. These data collections will enable the school to find ways to increase the amount of instructional time without adding to the school day, week, or year. Some specific guidelines follow: 1. 2. 3. Principals and other office personnel should not use the intercom more than twice per day (once in the morning and once in the afternoon), except when an emergency justifies the interruption of instruction. Students should generally not be allowed to miss core instruction, especially English language arts and mathematics, for field trips, presentations on non-academic topics, health screenings, school pictures, non-academic assemblies, events to reward students, early dismissals for athletic participation, etc. Principals should generally forbid the showing of rented videos to classes, even when they are loosely connected to curriculum topics. Rather, teachers should use video that is tightly correlated to the course benchmarks or use only clips from longer videos to illustrate~a point. Entertainment videos should not be used during core instructional time. 4. Allowing students during the instructional day to play games of any kind that do not have an instructional purpose (i.e., related to the course standards and/or benchmarks) is inappropriate.I [ 5013744187 WALKER LAW FIRM 260 P03 AUG 15 01 11:23 LITTLE ROCK SCHOOL DISTRICT ADMINISTRATIVE DIRECTIVE: IMH Effective: July 11,2001 -continued- 5, Schools should not engage in the practice of giving students free time' at the beginning of school year, the day before holidays, days during semester examinations, the last week of school, for \"team\" days, and so forth. 6. Instruction should not be interrupted by pulling students out to take care of library business, to see the nurse, to see the counselor, to take unnecessary phone calls. Rather, the support staff should make arrangements with teachers ahead of time to send students at their convenience. These guidelines are not meant to suggest that classrooms should be devoid of joy. Rather, they are intended to communicate a climate of respect for teaching and learning, to communicate to students a consistent message that their learning is important, and to enable all of the Districts students to be successful learners. Each Campus Leadership Team shall include in its work a review of current practices that interrupt instruction and shall design strategies to eliminate or radically limit the times during any school day when teaching and learning are interrupted for unplanned, non-instructional issues.OlACutl/jy 5013744187 WALKER LAW FIRM 260 P01 AUG 15 01 11:22 fOHN W. WALKER, P.A. Attorn^ at Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 Fax (501) 374-4187 FAX TRANSMISSION COVER SHEET To: Date: Tax: Te: Sender: YOU SHOULD receive [ (including cover sheet)] PAGE(S), INCLUDING THIS CO VEE SHEET IF YOU DO NOT RECEIVE ALL THE PAGES, PLEASE CALL \"\u0026lt;(501) 374-3758\u0026gt;\" The information contained in this facsimile message is attorney privileged and confidential information intended only for die use of the individual or entity named above. If the reader of tliis message is not the intended recipient, or die employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication 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. Office of Desegregation Monitoring United States District Court  Eastern District of Arkansas Ann S. Marshall. Federal Monitor One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 (501) 376-6200 Fax (501) 371 -0100 July 23, 2001 Dr. Ken James Little Rock School District 810 West Markham Street Little Rock, AR 72201 Dear Ken: My associate, Gene Jones, has been closely monitoring the districts program evaluation efforts. Gene has been able to obtain some program evaluations, but he has been unsuccessful in procuring others, so Im asking for your help. While the districts March 2001 Compliance Report reads that PRE has evaluated a number of specific programs (page 148), most of those evaluations were not available when we made our latest request for them on June 26, 2001. Below is a list of the 12 evaluations we need in order to continue our monitoring. All are for 2000-01 unless otherwise indicated. 1. NSF (We received a copy on 6-26-01, but are unsure that its a final version.) 2. Middle schools 3. Extended year schools 4. Summer schools (for 1999-00) 5. HIPPY 6. Charter school 7. Campus Leadership Teams 8. English as a Second Language 9. Lyceum Scholars Program 10. Southwest Middle Schools SEDL program 11. Watson Elementarys Onward to Excellence 12. Collaborative Action Team Please forward these program evaluations to us as soon as possible. If any are still not available, please let us know the status of their preparation and when we may expect to receive them. Thank you very much for your assistance. Sincerely yours. Ann S. MarshallFriday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY {1M2-I994) WILLIAM H. SUTTON, P.A. BYRON M. EISEMAN, JR,, P.A. JOE D. BELL. P.A. JAMES A. BUTTRY, P.A. FREDERICK S. URSERY. P.A. OSCAR E. DAVIS. JR.. P.A JAMES C. CLARK. JR.. P.A. THOMAS P. LEGGETT. P.A. JOHN DEWEY WATSON. P.A. PAUL B. BENHAM 111. P.A. LARRY W BURKS. P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EDWARD HARRIS. P A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL 111. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A. BARRY E. COPLIN. P.A. RICHARD D. TAYLOR. P.A. JOSEPH B. HURST. JR.. P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A. ROBERT S. SHAFER. P.A. WILLIAM M. GRIFFIN HI. P.A. MICHAEL S. MOORE. P.A. DIANE S MACKEY, P.A WALTER M EBEL III. P.A. KEVIN A. CRASS. P.A. WILLIAM A. WADDELL. JR.. P.A. SCOTT J. LANCASTER. P.A. M. GAYLE CORLEY. P.A. ROBERT B BEACH. JR . P.A. J. LEE BROWN. P.A. JAMES C. BAKER. JR.. P.A. HARRY A. LIGHT. P.A. SCOTT H. TUCKER. P.A. GUY ALTON WADE. P.A. PRICE C. GARDNER. P.A. TONIA P, JONES, P.A. DAVID D. WILSON. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayfirm.com 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 601-376-2011 FAX 501-376-2147 237 EAST MILLSAP. SUITE 7 FAYETTEVILLE. ARKANSAS 72703 TELEPHONE 501-695-2011 FAX 501-695-2147 JEFFREY H. MOORE. P.A. DAVID M. GRAF, P.A. CARLA GUNNELS SPAINHOUR. P.A. JOHN C. FENDLEY. JR., P.A. JONANN ELIZABETH CONIGLIO. P.A. R CHRISTOPHER LAWSON. P.A GREGORY D. TAYLOR. P.A. TONY L. WILCOX, P.A. FRAN C. HICKMAN. P.A. BETTY J. DEMORY. P.A. LYNDA M. JOHNSON. P.A. JAMES W. SMITH. P.A. CLIFFORD W. PLUNKETT. P.A. DANIEL L. HERRINGTON. P.A. MARVIN L. CHILDERS K. COLEMAN WESTBROOK. JR. ALLISON J. CORNWELL ELLEN M. OWENS JASON B. HENDREN BRUCE B TIDWELL MICHAEL E. KARNEY KELLY MURPHY MCQUEEN JOSEPH P MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN BRYAN W. DUKE JOSEPH G. NICHOLS ROBERT T. SMITH RYAN A. BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON OFCOUNSEL B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H.T. LARZELERE. P.A. JOHN C. ECHOLS. P.A. A.D. MCALLISTER RECEIVED 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2898 FAX 870-762-2918 JUL 17 2001 CHRISTOPHER HELLER LITTLE ROCK TEL 501-370-1506 FAX 501-244-5344 hnrg?c.rot OmCEOF DESEGREGRniianDRm July 16, 2001 Ms. Ann Marshall Desegregation Monitor One Union National Plaza RECEIVED 124 West Capitol, Suite 1895 Little Rock, AR 72201 JUL 1 7 ZOOl Re\nLRSD Compliance Report - March 15, 2001 OFFlGfcOl DESEGREGATION MONITORING Dear Ann\nI will attempt to arrange a meeting among the representatives of the parties and the members of your staff in accordance with our conversation last week. In the meantime, I would like to request that you share with the parties any written information developed by your office concerning errors in LRSDs March 2001 Compliance Report. This would make it easier for the parties to prepare for possible meetings with the members of your staff as well as the hearing scheduled in August and November. Thank you for your consideration. very Christopher Heller CJH/bk cc\nMr. John W. Walker Mr. Richard Roachell Mr. Samuel Jones Ms. Sammye Taylor Mr. Steve Jones Dr. Ken JamesJohn W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKEK SHAWN CHILDS Via Facsimile - 604-5106 July 23, 2001 OF COUNSEL ROBERT McHENRY, PA. DONNA J. McHENRY 8210 Hendekson Road Little Rock, Aekansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mcheiuyd^wbell.net Honorable Judge Susan Webber Wright Chief United States District Judge 600 West Capitol Little Rock, AR 72201 RECESVED JUL 25 2001 Re: Case No. LR-C-82-866 OmCEOF OESEGi\u0026amp;GMlONHQWTOHifjS Dear Judge Wright: This IS to inform you that we have experienced some difSculty in obtaining documents from the Little Rock School District. We informed your office while you were away of one set of problems we were experiencing last week. We are mindful of the courts deadline to provide Mr. Heller and Mr. Pendley with a listing of our exhibits, which is tomorrow. Our FOIA requests were dated June 5, 2001, July 2, 2001 and July 11, 2001 respectively, well in advance of last Friday s deadline and we have not been given the data. As I am writing this letter, Mr. Hellers secretary is on the telephone requesting that we must come to his office, look at and copy whatever is in two boxes. That is entirely unacceptable and fhistrates our ability to be prepared I will ask the secretary to have the boxes delivered to our offices in order to see whether the matenal being provided is what we requested. We will safely keep the boxes and return them to Mr. Heller on tomorrow. The Court is being asked to schedule a conference for identification of documents and document delivery for Wednesday, assuming that we have been unable to get the information that we have requested. Thank you for your consideration. Sincerely, ictated but not read John W. Walker JWW:js cc: Mr. Chris Heller Ms. Ann MarshallOffice of Desegregation Monitoring United States District Court  Eastern District of Arkansas Ann S. Marshall, Federal Monitor One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 (501)376-6200 Fax (501) 371-0100 July 23, 2001 Mr. Christopher Heller Friday Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Avenue Little Rock, AR 72201-3493 Dear Chris: Your letter of July 16, 2001 arrived while I was out of state last week, so please understand my delay in responding to your request for information about errors we identified in the LRSDs March 2001 Compliance Report. Enclosed is a list of the math errors we found in the pages of the Compliance Report. These are solely errors in mathematical calculations, based on figures that the district used in its report. For example, page 13 charts the Masters Degree Plus Nine or More Years of Experience for elementary schools. In the 1999-2000 column, the numbers for Garland are 6/26 24% when 6 is actually 23% of 26. Most of the math errors we found were minor, but some are significant. For example, page 27, last paragraph, 6' line: The report claims that 66% of the districts African-American students participated in a co-curricular activity during the 1999-00 school year. The correct calculation is between 46% and 48%, depending on which enrollment numbers the district used to arrive at 62% as the corresponding proportion of African-Americans who participated in extracurricular activities, which is cited in the paragraph at the top of page 27. We have not catalogued any other errors we may have found in the report, such as a chart that erroneously lists a school as closed in a year when the building was actually open, inconsistencies among charts, or discrepancies between what a chart shows and what the accompanying narrative asserts. Sincerely yours,  Ann S. Marshall Enc. cc: All Counsel of Record Dr. Ken James . ^4 Math Errors Found by ODM in LRSDs March 15, 2001 Compliance Report 1. 2. 3. 4. 5. 6. 1. 8. 9. Page 7, bottom chart, 1997, Percent A-A Page 13, bottom chart. Garland, 1999-2000 Page 13, top of page. Rockefeller, 1\" column Page 13, bottom chart, ACC-Metro, 1998-99 Page 17, bottom chart, 1996-97 Page 17, bottom chart, 1998-99 Page 22, middle chart, 1998-99 Percents, White Females Page 22, middle chart, 1998-99 Percents, Other Females Page 22, middle chart, 1999-2000 Percents, Other Females 10. Page 22, middle chart, 2000-01 Percents, White Males 11. Page 24, 1* paragraph, 3\"* line 12. Page 27, last paragraph, 6* line 13. Page 27, last paragraph, b* line 14. Page 40, bottom row, 2000-2001, Other 15. Page 40, bottom row, 2000-2001, Total 16. Page 40, 1 bullet, second line 17. Page 40, 2\"** bullet, last line 18. Page 47, bottom row. Total 19. Page 47, bottom row. Total 20. Page 92, bottom row. Change 21. Page 93, bottom row. Change 22. Page 124, bottom row, 4\"' column 23. Page 127, 2\"* chart, 1999, Total 24. Page 129, 1 chart, 2000, Total 25. Page 129, 1* chart, Increases, Total 26. Page 129, 1* chart, % Change, Total 27. Page 132, 1 chart. All Students, % Change 28. Page 132, 1' chart. A-A Students, % Change 29. Page 145, ALC, 1999-2000, Total 30. Page 145, Totals, 1999-2000, Total 31. Page 146, ALC, 1997-98, D/0 32. Page 146, Total, 1997-98, D/0 33. Page 146, Total, 1999-2000, D/0 34. Page 146, Ft. Hgts., 1997-98 D/0 35. Page 146, Ft. Hgts., 1998-99, D/0 36. Page 146, Mann, 1998-99 D/0 37. Page 146, Pul. Hgt., 1997-98 D/0 38. Page 146, TOTAL, 1997-98 D/0 39. Page 146, TOTAL, 1999-00 Enr 40. Page 146, GRAND TOTAL, 1999-2000 Enr 41. Page 147, 1 paragraph, 4* line 42. Page 161, TOTALS, 1998-99 White 43. Page 161, 1\" paragraph, 4* line 1 /in/ 1*4 0 O-xn/ Z*4 /O 00X1/ Zo /O er\\n/  TZU 9 FL 7% -1% 1 on/ 1V / 0 1 /rn/ 1 0/0 ^on/ J V / o z-z-n/ 00 0 1 gn/ 1 3/0 . 1 gn/ 1 3/0 +5 +5 +22 ono/ oTTO 1 n ACi lo.4o F+tSO 669 1200 22 OTT 1 o 4 1 r\\ 1 n/  IvO 7% J fyv 690 oz~ *400 /in/ *4/0 6% F% 3% 339 67323 12733F YH} 3\n29e-\n46+ eight 15% 23% 26% 58% 8 9 0 0 9% 18% 42% 46% to 48% 19% 18% 18 19 135 81% 18.49 11.81 577 1282 2220 1061 92% -7% -7% 277 795 38% 600 466 5% 4% 0 0 326 5,343 12,351 173 3,290,452 nineArxwwAc -fo e.1- JOHN W. Walker, RA. Attorney Ar Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS OF COUNSEL ROBERT McHENRY, RA. DONNA J. McHENRY 8210 Hendebson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mchenrydi^wbell.net Via Facsimile: 324-2146 July 24, 2001 Dr. Kenneth James Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 received JUL 2 5 2001 Re: FOIA Office Of OSESKKfflONMONHOfflWe Dear Dr. James: This request is pursuant to the Arkansas Freedom of Information Act. Would you provide for review, inspection, and copying the responses received to the e-mail request dated July 12, 2001 from Dr. Lesley to members of the Cabinet for : the ways that ODM has been involved in our work- committees, reviews of materials, etc. By copy of this letter to Ms. Ann Marshall, we are asking that she allow us to inspect any documents that she has related to this request. We also intend to call Ms. Marshall as a witness on the good faith issue and her knowledge of the Districts implementation activities during the next hearing, if time permits. Please make all of these responses available to me by Friday, July 27, 2001 at 1:00 p. m. Sincerely, W. Walker cc: Ms. Ann Marshall JWW:fcJohn w. Walker, p.a. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKEE SHAWN CHILDS July 24, 2001 OF COUNSEL ROBERT McHenry pa. DONNA J. McHENEY 8210 Hendeeson Road Little RocxAskansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mcheiiryd@swbell.iiet Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, AR 72201 RECEIVED JUL 2 5 2001 Re: LRSD Compliance Hearings OFHCEOF DESEGREGATION MONITORING Dear Chris\nPlease find enclosed ave been told that they did not exist, we shall ask the court for sanctions that Jumous Babbs lied, i.e., perjured himself many times. It appears that r I hope that this pattern of deception and misrepresentation does not up m your exhibit list after we It is already evident continue. it was with your advice. JWW\njs Enclosure cc: Ms. Ann Marshall All Counsel of Record EXHIBIT LIST -Job description - Associate Superintendent for Desegregation -Job description - Associate Superintendent for Administrative Services -E-mails from J. Babbs desegregation folder provided by Clay Pendley on 7/18/2001 -E-mails to and from Junious Babbs provided by Clay Pendley on 7/18/01 -E-mails to and from Sadie Mitchell provided by Clay Pendley on 7/19/01 -Response from Dr. Bonnie Lesley dated July 20,2001 in response to POIA request dated 7/12/01 for test data and other data regarding Rightsell, Otter Creek, Pulaski Heights and Central -Response from Dr. Bonme Lesley dated 7/20/2001 in response to POLA request dated 7/12/01 for written instructions regarding the DRA and validation studies regarding DRA -Letter dated July 18, 2001 from Clay Pendley to Joy Springer regarding requests for information -Response to request dated June 13, 2001 requesting dis-aggregated summer school data for each of the last three years -Letter dated September 5, 2000 to Ray Simon from Brady Gadberry and Juniuos Babbs -Resource C: Standards from Programs Evaluation -Letter dated 6/26/01 from Dr. Bonme Lesley indicating that information regarding summer school should be obtained from School Services - Sadie Mitchells division -Letter dated 7/13/01 from Sadie Mitchell indicating that information regarding school should be obtained from Instruction - Dr. Bonnie Lesleys division summer -Letter dated November 16,2000 to Dr. Carnine from John Walker regarding Joshuas lack of participation in the development of program, policies and procedures -Memo dated 8/28/01 from Busbea and Preeman re: observation survey and DRA testing -Test results four (4) schools - Rightsell, Otter Creek, Pulaski Heights and Central -formats for reporting test results -Email dated 3/1/2001 from Dr. Lesley to Dr. Carnine-Letter dated 6/26/01 frora Dr. Lesley to Joy Springer -Letter dates 7/13/01 from Sadie Mitchell to Joy Springer -Email dated 8/23/99 from Bonnie Lesley to Associate Supts -Email dated 1/10/2000 re: Public Information Folder on compliance -Email dated 10/16/2000 from Babbs to Dr. Camine -Email dated 10/19/2000 from Dr. Lease to Babbs \u0026amp; Dr. Camine -Email dated 10/24/2000 from Dr. Ross to J. Babbs -Email dated 11/3/2000 from Babbs to Dr. Ross -Email dated 11/9/2000 from Babbs to Dr. Lesley -Email dated 11/19/200 and 11/18/2000 from Babbs to Dr. Lesley -Email dated 11/30/2000 from Dr. Camine to Babbs -Email dated 1/3/2001 from Lease to Camine -Email dated 1/11/2001 from Babbs to Lesley -Email dated 7/12/2001 from Lesley to Cabinet -Email dated 3/14/2001 from Babbs to Camine -Revised Desegregation Education Plan/Compliance Checklist -West Little Rock School -Letter dated 10/7/99 from Babbs to Compliance committee -Memo dated 4/20/99 from Babbs to Board -Parent Survey Results 1999-2000 -Letter dated 8/16/99 to Dr. Camine and othersE-mail dated 8/24/99 from Dr. Lesley to Compliance Committee members Arkansas Department of Education File regarding loan forgiveness Exhibits included by Little Rock School District on their exhibit listJOSHUA WITNESS LIST AUGUST 1-2, 2001 1. Dr. Leslie Camine 2. Sadie Mitchell 3. Dr. Bonnie Lesley 4. James Washington 5. Dr. Linda Watson Joshua also reserves the right to call the witnesses listed by Little Rock School District4 Friday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY (1932-1994) WILLIAM H. SUTTON. P.A. BYRON M. eiSEMAN. JR.. P.A. JOE D. BELL. P.A. JAMES A. BUTTRY. P.A. FREDERICK S. URSERY. P.A. OSCAR E. DAVIS. JR.. P.A. JAMES C. CLARK. JR.. P.A. THOMAS P. LEGGETT. P.A. JOHN DEWEY WATSON. P.A. PAUL B. BENHAM III, P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EDWARD HARRIS. P.A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL ID. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P A. BARRY E. COPLIN. F.A. RICHARD D TAYLOR. P A JOSEPH B. HURST. JR.. P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A. ROBERT 5. SHAFER. P.A. WILLIAM M. GRIFFIN HI. P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL III. P.A. KEVIN A. CRASS. P.A. WILLIAM A. WADDELL. JR.. P.A. SCOTT J. LANCASTER. P.A. M GAYLE CORLEY. P A. ROBERT B. BEACH. JR.. P.A. J. LEE BROWN. F.A. JAMES C BAKER. JR.. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayfirm.corn 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 501-376-2011 FAX 501-376-2147 HARRY LIGHT. P.A. SCOTT H. TUCKER. P.A. GUY ALTON WADE. P A. PRICE C GARDNER. P.A. TONIA P. JONES. P.A. DAVID D. WILSON. P A. 237 EAST MILLSAP. SUITE 7 FAYETTEVILLE. ARKANSAS 72703 TELEPHONE 501-695-2011 FAX 501-695-2147 JEFFREY H. MOORE. P.A. DAVID M. GRAF. P.A. CARLA GUNNELS SPAINHOUR. P.A. JOHN C. FENDLEY. JR.. P A. JONANN ELIZABETH CONIGLIO. P.A. R. CHRISTOPHER LAWSON. P.A. GREGORY D. TAYLOR. P.A. TONY L. WILCOX. P.A, FRAN C. HICKMAN. P.A. BETTY J. DEMORY. P.A. LYNDA M. JOHNSON. P.A. JAMES W SMITH. P.A. CLIFFORD W. PLUNKETT. P.A DANIEL L. HERRINGTON. P.A MARVIN L. CHILDERS K. COLEMAN WESTBROOK. JR. ALLISON J. CORNWELL ELLEN M. OWENS JASON B. HENDREN BRUCE B TIDWELL MICHAEL E. KARNEY KELLY MURPHY MCQUEEN JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN KASTEN BRYAN W. DUKE JOSEPH G. NICHOLS ROBERT T. SMITH RYAN A. BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON orCOUKSEL B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H.T. LARZELERE. P.A. JOHN C. ECHOLS. P.A. AD. MCALLISTER 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2698 FAX 870-762-2918 JOHN C. FENDLEY, JR. LITTLE ROCK TEL 501-370-3323 FAX 501-244-5341 fndl*yQfc.ntt Via Hand Delivery Mr. John W. Walker Attorney at Law 1723 South Broadway Little Rock, AR 72206 RE: LRSD V. PCSSD Dear Mr. Walker: July 24, 2001 RECEIVED JUL 2 5 2001 OmCEGF DESffiRESAnOHMGWnDfWS Enclosed please LRSDs Witness and Exhibit Lists for the August 1-2,2001, hearing. Please do not hesitate to call if you have any questions. Sincerely, John C. Pendley, Jr. JCF/jm Enclosurescc w/enc.\nMs. Ann Marshall Mr. Richard Roachell Mr. Samuel Jones Ms. Sammye Taylor Mr. Steve Jones Dr. Ken JamesLRSD WITNESS LIST FOR AUGUST 1-2, 2001 1. Dr. Bonnie Lesley 2. Sadie Mitchell 3. Dr. Leslie V. Camine 4. Dr. Linda Watson 5. James Washington 6. Jo Evelyn Elston LRSD would also reserve the right to call any witness listed by Joshua and to call witnesses solely for the purpose of rebuttal. H EB BQ LRSD EXHIBIT LIST FOR AUGUST 1-2,2001 1. 2. 3. 4. 5. 6. 7. 8. 9. Summary of Assessment/Evaluation Activities by LRSD Memorandum from Bonnie Lesley to elementary principals, Oct. 20, 1998, providing information on Smart Start training on standards, assessments, and accountability Copy of handout from ADEs training for educators on Smart Start: Higher Student Achievement through Standards and Performance Assessment, fall 1998 Plan and Process Alignment for Improved Student Achievement, Little Rock School District (Matrix showing relationship of various required plans to District processes), created fall 1998 Invitation to meeting on Systemic Planning Session for Assessment and Program Evaluation, May 18, 1999 Agenda for Assessment and Program Evaluation Work Session, May 18, 1999 Portfolio of Services of Division of Instruction, 1999-2000 Agenda for Division of Instruction, June 17, 1999 meeting\npresentation on the LRSD Assessment Plan Memorandum in July 28, 1999, Learning Links with attached article on Changing the Entitlement Culture -emphasis on results rather than process. 10. LRSD Assessment Plan\nUsing Assessment to Enhance Student Achievement (PowerPoint presentation slides)presented to Board of Education in August 1999 11. Reading List prepared to distribute at the summer 2000 Campus Leadership Institute\nsection on Building and Maintaining Accountability Systems is about assessment and program evaluation 12. Transparencies used in July 19, 2000, Curriculum Day for principals, assistant principals, and brokers. 13. Notebook/handouts for July 19, 2000, Curriculum Dayfocus on quality management, data-driven decisions, and LRSD assessment programs 14. Memorandum in August 23, 2000, Learning Links with attached Primer on Assessment Literacy for distribution to Campus Leadership Teams 15. District Assessments: The Assessment Program for 2000-01 116. Memorandum to the Board of Education for July 26, 2001, agenda on Proposed Amendments to the Assessment Program Memorandum to elementary and junior high principals, Nov. 16, 1998, on schedule for picking up SAT9 testing materials 17. Memorandum to elementary school principals, Dec. 14, 1998, on procedures for upcoming administration of the criterion-referenced tests in reading and mathematics 18. Memorandum to elementary and junior high principals, Jan. 5, 1999, on the testing procedures for grades 4 and 8 ACTAAP Benchmark examinations 19. Memorandum to elementary and junior high principals and counselors, Jan. 26, 1999, on inservice schedule for test coordinators for the ACTAP Benchmarks for grades 4 and 8 20. Memorandum to selected administrators on Data Quality with attached paper written by Dr. Glynn Ligon 21. Memorandum to elementary principals, Aug. 17, 1999, relating to use of released items from Smart Start assessments 22. E-mail to curriculum staff, Aug. 23, 1999, relating to use of released items from Smart Start assessments 23. E-mail to elementary and middle school principals, Sept. 17, 1999, inviting them to an overview session on the new pre- and post-test Achievement Level Tests developed by Northwest Evaluation Association. 24. Memorandum in Sept. 22, 1999, Learning Links to principals identifying training needs to administer the Observation Survey and Developmental Reading Assessment 25. Memorandum to principals and K-2 teachers in March 15, 2000, Learning Links setting up an assessment training review for the Developmental Reading Assessment and Observation Survey 26. E-mail to Bonnie Lesley on Mar. 17, 2000, suggesting a resource on how to assess technology knowledge 27. Memorandum in Apr. 5, 2000, Learning Links to elementary and middle school principals and test coordinators on new information relating to ACTAAP Benchmark examinations in grades 4 and 8 and the field testing in grade 6. 28. Document entitled Description of the Assessment System prepared in April 2000 in response to a request from the National Science Foundationrelating to the assessment of mathematics and science 229. Document entitled Procedures for Providing Data Analysis/Interpretation to Decision Makers prepared in April 2000 in response to a request from the National Science Foundationrelating to the assessment of mathematics and science 30. Document entitled Orientation to the Analysis and Interpretation of Test Results prepared in April 2000 in response to a request from the National Science Foundationrelating to the assessment of mathematics and science. 31. E-mail to Kathy Lease, May 23, 2000, providing feedback to proposed survey of middle school students and teachers. 32. E-mail to principals, Aug. 25, 2000, providing information on upcoming administration of the Achievement Level Tests in September. 33. E-mail to Bonnie Lesley, Aug. 31, 2000, providing information on new middle school report card 34. E-mail to Bonnie Lesley, Aug. 31, 2000, providing copy of new middle school report card report 35. Memorandum from Linda Austin to Marian Lacey providing Middle School Report Card Update 36. E-mail to middle school principals, Jan. 3, 2000, setting up training for teachers on how to administer the State Benchmark examinations 37. Memorandum to Division of Instruction, Feb. 1, 2000, setting agenda for Feb. 2 meeting, includes information on the District Assessment Plan 38. E-mail to elementary principals, Feb. 1, 2000, providing information on the use of calculators on Benchmark examinations 39. E-mail to principals, Feb. 3, 2000, providing copy of assessment schedule/matrix to distribute to teachers 40. Document prepared in fall 1999 by PRE on Achievement Level Tests: Assessments that Make a Difference 41. Memorandum to all principals and test coordinators, Mar. 17, 2000, establishing training sessions for the administration of the Benchmark and end-of-course examinations 42, Memorandum in Apr. 5, 2000, Learning Links to high school principals and test coordinators providing new information from ADE on the end-of-course literacy examination 343. E-mail to Kathy Lease and Les Carnine, Apr. 7, 2000, providing rationale for adding science assessments to the Achievement Level Tests 44. Memorandum in Aug. 30, 2000, Learning Links to elementary principals and K-2 teachers including pre-testing instructions for the Observation Survey and Developmental Reading Assessment 45. Memorandum in Aug. 30, 2000, Learning Links to all principals and test coordinators establishing inservice schedule for administration of the SAT9 and ALTs 46. Memorandum in Sept. 8, 2000, Learning Links to elementary principals relating to K- 2 assessment and the importance of the language arts instructional block 47. Memorandum in Sept. 27, 2000, Learning Links to elementary and middle school principals relating to the administration of the end-of-module tests in mathematics and the end-of-unit tests in science 48. Memorandum in Sept. 26, 2000, Learning Links to elementary principals relating to instructions to complete the Observation Survey and Developmental Reading Assessment 49. Memorandum to principals, Oct. 13, 2000, requesting feedback through a survey for consideration by the Assessment Focus Group\ncopy of survey attached 50. Memorandum to principals, Feb. 13, 2001, with information on the administration of the climate surveys for parents, teachers, students, and administrators 51. E-mail, Feb. 26, 2001, relating to administration of surveys for the Extended Year Education school evaluation 52. E-mail to curriculum directors, Feb. 27, 2001, relating to discussion of the potential purchase of an electronic curriculum/assessment management system 53. E-mail to principals and selected others on Mar. 1, 2001, relating to an information session on ALT online testing 54. E-mail to principals. Mar. 1, 2001, providing spring testing schedule for elementary, middle, and high schools 55. E-mail to Les Carnine, Mar. 8, 2001, providing outline of PRE responsibilities for Dr. James, incoming superintendent 56. Memorandum to elementary principals. Mar. 14, 2001, providing information on end- of-module mathematics criterion-referenced tests 457. E-mail between various staff. Mar. 14-15, 2001, relating to analysis of results of mathematics and science criterion-referenced tests 58. Document entitled Mathematics, Reading, and Language Achievement Tests\nAdministration Guide prepared by PRE for use in training sessions for the ALTs, 2000-01 59. Memorandum to elementary principals and teachers in Feb. 3, 1999, Learning Links. attaching the results for the second quarter reading and mathematics CRTs 60. Memorandum to Les Camine, June 1, 1999, providing status report on the development of the Quality Index and reporting on recommendations of Dr. Steve Ross relating to the assessment program 61. E-mail to Cabinet, Sept. 28, 1999, providing preview of grade 8 Benchmark examination results 62. E-mail to middle school principals, Oct. 8, 1999, relating to dissemination of Benchmark results 63. E-mail between Lucy Neal and Kathy Lease, Oct. 28-Nov. 2, 1999, relating to need for SAT9 scores to evaluate Title VI 64. Memorandum to Judy Milam, Nov. 4, 1999, requesting report on quarterly SFA assessments 65. Memorandum to Kathy Lease, Nov. 4, 1999, requesting report on DRA results for fall 66. E-mail to Kathy Lease, Dec. 3, 1999, advising her of Dr. Camines request for results of climate surveys 67. E-mail to Bonnie Lesley, Apr. 3, 2000, with report on Advanced Placement scores 68. Memorandum to principals in Apr. 5, 2000, Learning Links providing information on packets being sent to schools on ALT results 69. E-mail to John Ruflfins and Kathy Lease, Apr. 12, 2000, requesting course enrollment data for NSF report 70. Memorandum to principals and teachers in Apr. 26, 2000, Learning Links with comparisons of second quarter CRT results for 1998-99 and 1999-2000 71. E-mail to Diane Barksdale, Apr. 19, 2000, providing feedback on ALT scores 72. Memorandum to all principals in May 10, 2000, Learning Links providing information about a data interpretation workshop to be conducted by NWEA staff 573. Memorandum to counselors and ALT coordinators in May 10, 2000, Learning Links providing information about a data interpretation workshop to be conducted by NWEA staff 74. Memorandum to professional staff of Division of Instruction in May 10, 2000, Learning Links providing information about a data interpretation workshop to be conducted by NWEA staff 75. E-mail to Dennis Glasgow and Ed Williams, May 15, 2000, requesting a special report on the middle school ALT mathematics scores 76. E-mail to SFA principals. May 23, 2000, relating to training for SFA schools for improved academic achievement 77. E-mail to Virginia Johnson, May 19-23, 2000, relating to data collections for NSF evaluations and results of middle school student survey 78. E-mail to elementary principals, June 1, 2000, relating to results of 1999-2000 Developmental Reading Assessment 79. E-mail to Kathy Lease, June 7, 2000, requesting report on Science ALTs 80. E-mail to Virginia Johnson and Ed Williams, June 7, 2000, relating to data requests from Dr. Gamine 81. E-mail to Kathy Lease, June 7, 2000, requesting results of middle school student survey 82. E-mail to Bonnie Lesley, June 23, 2000, requesting interpretation of DRA results 83. E-mail to Les Gamine, July 7, 2000, providing information on interpretation of DRA results 84. E-mail to Kathy Lease, Ed Williams, and Linda Austin, July 13, 2000, requesting data for Southwest Education Development Lab relating to implementation of the Collaborative Action Team 85. E-mail to Sadie Mitchell and Frances Cawthon Jones, July 14, 2000, relating to DRA interpretations 86. E-mail to Pat Busbea, Patricia Price, and Ed Williams, July 14, 2000, relating to interpretation of DRA results\nattached document defines proficient 87. E-mail to Patricia Price and Pat Busbea, July 17, 2000, requesting correlation of teacher participation in ELLA training and student achievement 688. E-mail to elementary staff, July 21, 2000, attaching copy of presentation slides to the Campus Leadership Institute on DRA results 89. E-mail to Leon Adams, July 28, 2000, providing rationale from Mitchell Academy for the abandonment of Success for All, based on data analysis 90. E-mail to selected SFA principals, Aug. 8, 2000, with report on achievement of SFA schools as compared to others and with suggestions on possible abandonment of SFA based on data analysis 91. E-mail to Bonnie Lesley, Aug. 9, 2000, from Freddie Fields relating to possible modification of SFA and requesting ELLA training, based on data analysis 92. E-mail to Kathy Lease, Sept. 14, 2000, from Linda Austin requesting copy of LRSD Assessment Notebook 93. Memorandum to curriculum division, Oct. 25, 2000, announcing available reports on grades 4 and 8 Benchmark examinations 94. Memorandum to Board of Directors, Oct. 25, 2000, announcing available reports on grades 4 and 8 Benchmarks 95. Memorandum to Cabinet, Oct. 25, 2000, announcing available reports on grades 4 and 8 Benchmarks 96. Memoranda to selected principals, Nov. 3, 2000, congratulating them for achievement on grade 4 Benchmarks 97. E-mail to Kathy Lease, Nov. 6, 2000, requesting several sets of data to include in Compliance Report 98. E-mail to Patricia Price and Dennis Glasgow, Nov. 8, 2000, attaching spreadsheets on Benchmark data by SES status 99. E-mail to Kathy Lease from Tara Adams, Jan. 17, 2001, requesting information on interpretation of the ALT results 100. E-mail to principals and cabinet, Jan. 17, 2001, with attached reports on SAT9 scores, five-year comparison\nSAT9, three-year comparison\nand SAT9 quartile report. 101. E-mail to principals. May 30, 2000, with attached sample letter to parents that can accompany the ALT results 7102. Document entitled Identified Issues from Data/Attendance Focus Group prepared by PRE 103. Group Document entitled Assessment Window prepared with advice from Focus 104. Document entitled Assessment Advisory Committee, 2000-01 with names of advisory committee members 105. Copies of PowerPoint presentation to Board of Education, Nov. 16, 2000: A Quick Look at the 4* Grade Benchmark Exam and a Preview of the SAT-9 106. E-mail to Steve Ross, Nov. 20, 2000, including feedback to a draft plan he had written relating to Ioan forgiveness 107. E-mail to principals and Cabinet, Nov. 29, 2000, with information on how to access test data on the ADE web page 108. Memorandum to IRC Staff, Dec. 1, 2000, relating to available SAT9 and Benchmark reports 109. Memorandum to middle school principals, Dec. 11, 2000, attaching reports on assignments of eighth graders to high schools 110. E-mail to SFA principals and facilitators, Feb. 23, 2001, announcing training on the SFA Student Data Base 111. E-mail to Virginia Johnson, Mar. 14, 2001, relating to analysis of end-of-module test results 112. E-mail to Bonnie Lesley, Apr. 23, 2001, with attached information on the Duke Talent Search 113. E-mail to middle school principals, June 29, 2001, reminding them of information sent to them earlier about how to access test data on the ADE web site 114. E-mail to principals, June 29, 2001, attaching copies of DRA test results 115. Memorandum to Division of Instruction staff and others, Nov. 15, 1999, providing information on new requirements from the state on a personalized education plan, appointing a committee to develop a plan, and stating the committee charge 116. Memorandum to Board of Education, Aug. 24, 2000, requesting approval of the attached administrative regulations (IHBDA-R2) and review of other information 8117. E-mail to Dennis Glasgow, Patricia Price, and Suzi Davis, Sept. 15, 2000, requesting that they develop sample SAIPs for the teachers to use 118. Memorandum in Sept. 20, 2000, Learning Links to all principals from Bonnie Lesley stating a philosophy relating to the SAIPs 119. Memorandum in Sept. 20, 2000, Learning Links to elementary principals from Patricia Price clarifying the use of data in SAIPs and attaching sample SAIPs 120. Memorandum in Sept. 27, 2000, Learning Links to all middle school principals from Suzi Davis providing information on SAIPs and attaching sample SAIPs 121. Memorandum in Sept. 27, 2000, Learning Links to all middle school principals from Suzi Davis on how to use the SAtP form for parent conferencing 122. Memorandum in Sept. 27, 2000, Learning Links to middle school principals on how to use the SAIP form for middle school mathematics, how to use the ALT data to interpret need, and including a sample SAIP 123. E-mail to Bonnie Lesley, Sept. 21, 2000, from Lillie Carter expressing appreciation for the copy of the SALP philosophy and the sample SAIPs 124. E-mail to Bonnie Lesley, Sept. 27, 2000, from Eleanor Cox expressing appreciation for the SAIP philosophy and for the sample SAIPs 125. E-mail to middle school principals, Sept. 29, 2000, from Suzi Davis providing more assistance with SAIPs 126. Memorandum to Pat Price, Pat Busbea, and Ed Williams, Apr. 3, 2001, with attached document from Connecticut on interpretation of the DRA and use of that data with SAIPs 127. Memorandum to Division of Instruction, Dec. 3, 1998, with agenda for Dec. 9 meeting\nincludes reports on District-Level Curriculum Maps 128. Memorandum to Mona Briggs, July 16, 1999, with copy of a training notebook on curriculum mapping and with charge to put together a training program on curriculum mapping 129. Memorandum to Division of Instruction, Aug. 30, 1999, with agenda for Sept. 1 meeting\nincludes discussion led by Mona Briggs and Eddie McCoy on Curriculum Mapping Project 130. Memorandum in Nov. 9, 1999, Learning Links providing information on curriculum mapping with attached article 9131. Memorandum in Nov. 17, 1999, Learning Links to selected principals establishing training schedule for curriculum mapping training 132. Memorandum in Dec. 1, 1999, Learning Links to selected principals establishing training schedule for curriculum mapping 133. Memorandum in Jan. 12, 2000, Learning Links to selected principals establishing training schedule for curriculum mapping 134. E-mail to Mona Briggs, Eddie McCoy, and Kathy Lease, Jan. 18, 2000, requesting that they develop a plan for April inservice on curriculum mapping 135. Memorandum in Jan. 19, 2000, Learning Links to selected principals establishing training schedule for curriculum mapping 136. Memorandum in Feb. 16, 2000, Learning Links to selected principals establishing training schedule for curriculum mapping 137. E-mail, Feb. 15-17, 2000, relating to training for curriculum mapping trainers 138. Memorandum in Apr. 5, 2000, Learning Links to Brokers and IRC Specialists establishing training schedule on cuniculum mapping 139. E-mail to Mona Briggs and Marion Woods, Apr. 14, 2000, relating to additional curriculum mapping training 140. E-mail, Apr. 26~May 2, 2000, relating to plans for curriculum mapping 141. E-mail to Bonnie Lesley, June 6, 2000, with information on curriculum mapping 142. E-mail to Bonnie Lesley, June 6, 2000, relating to results of curriculum mapping training 143. Memorandum to designated principals from Mona Briggs, Aug. 23, 1999, providing information on standards for accreditation from ADE 144. Memorandum to elementary staff, Jan. 20, 1999, relating to an ADE evaluation of Early Literacy Learning in Arkansas (ELLA) 145. Memorandum to Kathy Lease and Ed Williams, June 29, 1999, on program evaluation with attached articles on qualitative research and an example of a research report from Austin ISD by Glynn Ligon 146. Memorandum to Division of Instruction, Feb. 1, 2000, with agenda relating to program implementation 10147. E-mail to Virginia Johnson and Debbie Milam, Feb. 4, 2000, suggesting a model for the evaluation of ViPS programs 148. Memorandum in March 15, 2000, Learning Link relating to progress made by schools implementing the ALT assessment program 149. Document from Kathy Leasecalendar of meetings with Dr. Steve Ross since March 15, 2000\nattached planning document on program evaluation 150. E-mail to Bonnie Lesley, Mar. 24, 2000, providing information about a meeting with Dr. Steve Ross to discuss the middle school evaluation 151. E-mail to Kathy Lease, May 23, 2000, providing feedback on proposed middle school student survey 152. E-mail to Bonnie Lesley, Marian Lacey, and Sadie Mitchell, June 12, 2000, from Les Camine requesting information about the middle school evaluation 153. E-mail from Steve Ross to Kathy Lease, June 27, 2000, with attached design notes for Title I/Elementary Literacy Program Evaluation 154. E-mail from Kathy Lease to her staff, Aug. 6, 2000, requesting them to place the memorandum and program evaluations on the Board agenda 155. E-mail from Kathy Lease to Les Camine, Aug. 10, 2000, providing copies of drafts of the ESL and middle school evaluations, then his questions and her answers. 156. Memorandum to Board of Education, Aug. 24, 2000, from Kathy Lease presenting the program evaluations: Title 1/Elementary Literacy, LRCPMSA (mathematics and science), English as a Second Language, and Middle School Transition and Program Implementation. Attached is her PowerPoint presentation\nProgram Evaluation. 157. E-mail from Steve Ross to Les Camine, Sept. 7, 2000, giving his feedback to the program evaluation reports. 158. E-mail from Debbie Milam to Cabinet members, Sept. 20, 2000, requesting permission to conduct interviews of parents on the subject of parental involvement. 159. E-mail from Kathy Lease to staff, Oct. 11, 2000, advising them of an upcoming meeting with Dr. Steve Ross related to program evaluation 160. E-mail from Virginia Johnson to Bonnie Lesley and Vanessa Cleaver, Oct. 20, 2000, relating to our required participation in an evaluation study conducted by the National Science Foundation 11161. Memorandum to Gene Jones, ODM, from Kathy Lease, Oct. 27, 2000, inviting him to an intensive work session with Dr. Steve Ross on program evaluation 162. Document prepared by PRE in November 2000 that lists Additional Programs and Strategies Requesting Evaluation 163. E-mail to Cabinet members from Kathy Lease, Nov. 28, 2000, attaching Dr. Steve Ross planned presentation to the Board of Education on Using Evaluation for Program Improvement: Lessons Learned 164. E-mail from Bonnie Lesley to Virginia Johnson, Jan. 2, 2001, setting up a meeting to finalize CPMSA program evaluation plan 165. E-mail from Virginia Johnson to Bonnie Lesley, Jan. 3, 2001, attaching her tentative plan 166. E-mail from Kathy Lease to Les Carnine and Junious Babbs, Jan. 5, 2001, providing information relating to outsourcing program evaluations to Dr. John Nunnery 167. E-mail from/to Virginia Johnson, Jan. 5-20, 2000, relating to submission of Core Data Elements to the National Science Foundation 168. E-mail from/to Virginia Johnson, Apr. 14-16, 2000, relating to CPMSA program evaluation issues 169. E-mail from Kathy Lease to Les Carnine, Jan. 22, 2001, attaching a draft of the work from Dr. John Nunnery 170. Memorandum (one of several) from Kathy Lease, Jan. 24, 2001, inviting participants to the first meeting of the Research Committee 171. Memorandum from Kathy Lease to John Walker, Jan. 24, 2001, inviting him to participate in first meeting of Research Committee 172. Agenda for Feb. 5, 2001, meeting of the Research Committee and sign-in sheet 173. E-mail from Bonnie Lesley to Eddie McCoy, Ed Williams, and Karen Broadnax, Feb. 16, 2001, to set up a meeting to discuss ESL program evaluation 174. Memorandum from Kathy Lease to Research Committee setting up Feb. 26, 2001, meeting 175. Agenda for Feb. 26, 2001, Research Committee meeting and sign-in sheet 12176. 2001 Invoice from Dr. John Nunnery to LRSD for services rendered, February-March 177. E-mail from Bonnie Lesley to CPMSA staff, Feb. 21, 2001, setting up a meeting to discuss the CPMSA program evaluation 178. E-mail from Virginia Johnson to Bonnie Lesley, March 14, 2001, providing updates 179. E-mail to middle school staff from Bonnie Lesley, Mar, 15, 2001, summarizing a meeting to plan for a Middle School Team Leaders Institute, including recognition of need to train team leaders on assessment and using data 180. E-mail from Bonnie Lesley to CPMSA staff. Mar. 19, 2001, setting up follow-up meeting to discuss CPMSA program evaluation 181. Memorandum to Carnegie Management Team, March 20, 2001, from Bonnie Lesley with information about counseling program and need for a program evaluation 182. Memorandum from Kathy Lease to Research Committee, Apr. 16, 2001, setting up next meeting on summer school evaluation and program evaluation for the National Science Foundation grant 183. Sign-in sheet for Apr. 23, 2001, meeting of the Research Committee 184. E-mail from Bonnie Lesley to Dennis Glasgow, Suzi Davis, and Laura Beth Arnold, April 17, 2001, to discuss program evaluation for Element 5 of the Safe Schools/ Healthy Students project 185. E-mail from Virginia Johnson to Bonnie Lesley, Apr. 18, 2001, relating to next steps in providing information about SAT9 item analyses for teachers 186. E-mail from Mona Briggs to Bonnie Lesley, Apr. 25,2001, relating to survey needs for national evaluation of Safe Schools/ Healthy Students project 187. E-mail from Dennis Glasgow to elementary and middle school staff, Apr. 26, 2001, summarizing a large scale study that links classroom practices to student achievement in mathematics 188. E-mail among team working on CPMSA program evaluation, Apr. 18-May 2, 2001, relating to model for program evaluation and data analysis 189. E-mail from Kathy Lease to Research Committee, May 2, 2001, with attached latest version of the Guidelines for Program Evaluations 190. Agenda for May 7, 2001, meeting of the Research Committee and sign-in sheet 13191. E-mail from Don Crary to Bonnie Lesley, May 24, 2001, announcing that a program evaluator had been hired by New Futures to conduct the program evaluation for Safe Schools/ Healthy Students 192. E-mail from Kathy Lease to Research Committee with attached memorandum relating to ne?d meeting on June 11, 2001 193. Agenda for June 11, 2001, meeting of the Research Committee and sign-in sheet 194. E-mail from Junious Babbs to Bonnie Lesley, June 12, 2001, relating to information on program evaluation 195. E-mail from Kathy Lease to Compliance Team, June 14, 2001, with an outline of a plan for the completion of the Middle School Evaluation 196. E-mail from Kathy Lease to Research Committee, June 14, 2001, attaching a copy of final draft of Dr. Nunnerys evaluation of the mathematics/science programs 197. E-mail from Dennis Glasgow to Ed Williams, July 3, 2001, requesting additional ALT reports 198. E-mail from Vanessa Cleaver to others working on CPMSA program evaluation, July 10, 2001, requesting help in publishing a three-year progress report on the CPMSA 199. PreK-3 Literacy Plan (with needs assessment, see pp. 12-26), June 1999 200. Memorandum to Board of Education from Bonnie Lesley, June 24, 1999, requesting their review of the proposed PreK-3 Literacy Program Plan 201. Report on Level of ELLA training for K-2 teachers, May 10, 2000 202. Definition of Proficient for the Developmental Reading Assessment, K-2, May 2000 203. Report on Spring 2000 Developmental Reading Assessment, Percent At or Above Readiness 204. Correlation StudyAmount of Training Hours and Student Achievement on the Developmental Reading Assessment, Spring 2000 205. Correlation StudyMultiple Comparisons of Effect of Four Approaches to Literacy Development, Spring 2000 206. Executive Summary, Title I/Elementary Literacy Program Evaluation, July 2000 14207. Title I/Elementary Literacy Program Evaluation, August 2000 208. 2000 Updated Draft of Title I/PreK-3 Literacy Plan Program Evaluation, December 209. 2001 Progress Report on Elementary Literacy Plan to Board of Education, January 210. Update on Implementation of the PreK-3 Literacy Program Plan, June 2001, presented to Board of Education 211. Copies of slide presentation to Board of Education on PreK-3 Literacy Program, June 2001 212. E-mail to principals and Division of Instruction from Bonnie Lesley, June 29, 2001, attaching copies of the formal Update on Implementation of the PreK-3 Literacy Program Plan to the Board of Education, plus the Highlights documents, and a copy of the presentation slides. 213. E-mail to elementary principals and other staff from Bonnie Lesley, June 29, 2001, attaching tables of DRA results by middle school feeder pattern. 214. Evaluation of Success for All Programs, Little Rock School District, Year 1: 1997-98 by Steve Ross, Mary McNelis, Tracey Lewis, and Steve Loomis, University ofMemphis 215. Evaluation of Success for All Program, Little Rock School District, Year 2: 1998-99 by Weipling Want and Steven Ross, University of Memphis, July 1999 216. Memorandum to elementary principals from Bonnie Lesley in Sept. 1, 1999, Learning Links, assigning supervision of the Success for All program in the Division of Instruction for greater effectiveness 217. Memorandum to Kathy Lease from Bonnie Lesley, Mar. 31, 1999, attaching a copy of a contract for the evaluation of the Success for All program 218. Memorandum from Bonnie Lesley to selected SFA staff, Oct. 8, 1999, setting up training on Success for All 219. Memorandum from Bonnie Lesley to SFA principals, Nov. 11, 1999, providing to them copies of their contracts with the University of Memphis for SFA services 220. Memorandum from Bonnie Lesley to SFA principals, Nov. 15, 1999, providing them a study on SFA effectiveness\nattached article, Success for All: A Summary of Evaluations, by Jeanne Weiler, ERIC. 15221. E-mail from Bonnie Lesley to selected SFA principals, Aug. 8, 2000, suggesting that data analysis indicates SFA not being effective in their schools\nattached tables. 222. Report on Success for All Inservice activities, 1999-2000 School Year 223. Reports from eight-week assessments in Success for All schools, 1999-2000. 224. Success for All Implementation Report for December 1, 1999 (site visit reports from the University of Memphis that are done twice annually) 225. Success for All Implementation Reports for Spring 2001 (site visit reports from the University of Memphis that are done twice annually) 226. Executive Summary, English as a Second Language Program Evaluation, July 2000 227. English as a Second Language Program Evaluation (submitted to Office of Civil Rights), October 2000Proposal to National Science Foundation, Aug. 1, 1998, to fund Collaborative Partnerships in Mathematics and Science Achievement (see pp. 2-4 for needs assessment). 228. Management Plan for Year One, 1998-99, CPMSA (based on proposal for funding to the National Science Foundation. 229. 1999-2000 Strategic Plan, CPMSA (based on data analysis and decisions about next steps) 230. September 2000February 2002 Strategic Plan, CPMSA (based on data analysis and decisions about next steps) 231. September 1, 2000August 31, 2003 Strategic Plan, CPMSA (based on data analysis and decisions about next steps) 232. Revised Three-Year Strategic Plan, April 11, 2001, CPMSA (based on data analysis and decisions about next steps) 233. Annual Progress Report, 1998-99, submitted to the National Science Foundation. 234. Letter from National Science Foundation to Dr. Les Carnine, May 20, 1999, with follow-up report to Site Visit of April 27-29, 1999. 235. Document prepared for December 3, 1999, Site Visit: Relationship of CPMSA Goals and LRSD Quality Indicators 236. Agenda for NSF Site Visit, December 3, 1999 16237. Letter from National Science Foundation to Dr. Les Camine, January 24, 2000, with follow-up report to Site Visit of December 1-3, 1999. 238. Annual Progress Report, 1999-2000, submitted to the National Science Foundation. 239. Copy of slide presentation to the National Science Foundation Site Visit team. December 1-3, 1999. 240. Letter from National Science Foundation to Dr. Les Camine, January 16, 2001, with follow-up report to Site Visit of December 6-8, 2000. 241. Copy of slide presentation to Board of Education relating to CPMSA progress. January 2001. 242. Copy of slide presentation to the National Science Foundation Midpoint Review (reverse site visit) in Washington, DC, February 5, 2001. 243. Letter from National Science Foundation to Dr. Les Camine, March 15, 2001, with follow-up report on Midpoint Review presentation in Washington, DC (reverse site visit) of February 5, 2001. 244. Systemic Initiatives Core Data Elements, 1998-99: Results for Little Rock, report submitted to the National Science Foundation relating to implementation of new mathematics/science programs 245. Systemic Initiatives Core Data Elements, 1999-2000: Results for Little Rock, report submitted to the National Science Foundation relating to implementation of new mathematics/science programs 246. Program EvaluationSigns of Success: Trends in Mathematics and Science Student Performance, 1997-98 and 1999-2000, report submitted by CPMSA Program Evaluator to project staff. 247. Program EvaluationBenchmark ExaminationOpen Response Mathematics Items: Student Outcomes of a Targeted Initiative with 4* Grade Students, 1998-99. 248. Program EvaluationACTAAP Benchmark Examination Mathematics Results, Grades 4 and 8, 1997-98 to 2000-01. 249. Program EvaluationDistrict Criterion Referenced Tests (CRTs), Higher-Level Mathematics and Science, 3^^ Quarter, 2000-01 250. Program EvaluationStanford Achievement Test, 9* Edition, Mathematics Results, 1997-98 to 2000-01. 17251. Program EvaluationStanford Achievement Test, 9* Edition, Science Reasoning Results, 1997-98 to 2000-01. 252. Program EvaluationAdvanced Placement Test: Mathematics Results, 1997-98 to 2000-01. 253. Program EvaluationAdvanced Placement Test\nScience Results, 1997-98 to 2000-01. 254. Program EvaluationAmerican College Test Results for 8* Grade EXPLORE, 1997-98 to 2000-01. 255. Program EvaluationAmerican College Test Results for 10* Grade PLAN, 1997-98 to 2000-01. 256. Program EvaluationAmerican College Test Results for 12* Grade ACT Test, 1997-98 to 2000-01. 257. Program EvaluationCompre\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resoources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_497","title":"\"Education Policy Analysis: A Catch-22 and More, Little Rock's Incentive School\"","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["Morgan, Bob","Arkansas Policy Foundation"],"dc_date":["1997"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Little Rock School District","Education--Arkansas","School improvement programs","School integration"],"dcterms_title":["\"Education Policy Analysis: A Catch-22 and More, Little Rock's Incentive School\""],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/497"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["documents (object genre)"],"dcterms_extent":["19 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nCo \\ --- IIP ARKANSAS POLICY FOUNDATION Greater Oftportunitv Throng Innovative Change RECEWSD 4. 0' '''\"O JUN 2 1997 OrriCEOF DEScGREGA'nQH E D U CATI 0 N POLICY ANALYSIS A Catch-22 and More Little Rock^s Incentive Schools (After Catch 22, A novel by Joseph Heller) by Bob Morgan Summer 1997 For those that never knew or have forgotten, a Catch-22 is: 1. a. A situation in which a desire outcome or solution is impossible to attain because of a set of inherently illogical rules or conditions\nb. The rules or conditions that create such a situation. 2. A situation or predicament characterized by absurdity or senselessness. 3. A contradictory or self-defeating course of action. 4. A tricky or disadvantageous condition. Ill Center Street, Suite 1610, Little Rock, Arkansas 72201 501-376-9967 Fax: 501-376-6556 email: Aggiemw2@AOL.comin ARKANSAS POLICY FOUNDATION Greater Opportunity Through Innovative Change I I I I - I  I  I ' I 4 'JUN 2 W97 EDUCATION POLICY ANALYSIS A Catch-22 and More Little Rocks Incentive Schools (After Catch 22, A novel by Joseph Heller) by Bob Morgan Summer 1997 For those that never knew or have forgotten, a Catch-22 is: 1. 2. 3. 4. a. A situation in which a desire outcome or solution is impossible to attain because of a set of inherently illogical rules or conditions\nb. The rules or conditions that create such a situation. A situation or predicament characterized by absurdity or senselessness. A contradictory or self-defeating course of action. A tricky or disadvantageous condition. 111 Center Street, Suite 1610, Little Rock, Arkansas 72201 501-376-9967 Fax: 501-376-6556 email: Aggiemw2@AOL.comIMP ARKANSAS POLICY FOUNDATION Greater Oplmrhmity Tfirou^ Innovative Change Foreword With special acknowledgment and appreciation to the University of Arkansas Little Rock (UALR) and an unequivocal endorsement for its timely and candid study...  Plain Talk: The Future of Little Rock's Public Schools II In introducing, last February, their milestone analysis of Little Rock's deeply disturbing school crisis and the serious challenges represented by our city's long-running desegregation case, UALR authors quoted Thomas Jefferson. II II n II fl H II II II II II II I know of no safe depository of the ultimate powers of the society but the people themselves\nand if we think them not enlightened enough to exercise their control with a wholesome discretion, the remedy is not to take it from them, but to inform their discretion. Thomas Jefferson Jefferson was right to trust in the power of citizenship and the innate will of people to do what is right and best. And UALR was right to sound a call for the broadest possible citizen involvement in solving our education woes. The key to ending the school crisis in Little Rock hinges on bringing the full community back into the process of changefully armed with facts, knowledge and information, and empowered to get the job done. Responsibility for repairing and restoring high quality education in Little Rock cannotmust not be solely left to those with narrowly defined agendas. They are destined to fail\nand as evidence of their failure, nothing has happened after all these years that resolves our crisis in spite of their continuing actions. Those who would, at all costs, preserve and protect their own interests in this tragedy perpetrate a great wrong on our community and its children. Resolution can never come from the war of competing interests. Nor will courts and government get the job done. They can, however, play a pivotal role in facilitating a return of local control and autonomy. Give responsibility back to the people who own the system and who pay for it. When this happens we will fix our schools and rescue future generations from the continued failure that has characterized public education in Little Rock. The UALR study, in a stunning rebirth of community frankness and intellectual honesty, offered up more \"plain talk\" on our schools than we have heard in years. It is refreshing beyond measure. The Arkansas Policy Foundation pledges to continue the trend by offering more \"plain talk\" from time to time. We begin with an insightful analysis of the \"Catch 22\" aspects of our incentive schools. The commentary that follows was developed by Bob Morgan, a former Associate Monitor with the Office of Desegregation Monitoring. We commend it to your review and believe it to be a timely and eye-opening analysis. Michael Watson President, APF Jack T. \"Steve  Stephens, Jr. Chairman, APFSchools are established those seats attributable to LRSD will be available for those students who otherwise would or could have been assigned to an incentive school\nany recruitment and/or any II assignment shall be in accordance with each districts student assignment plan. (Point 2) ll As to Point I - This provision is a Catch-22 because as the white enrollment decreased in size there were no applicants for these seats yet the Office of Desegregation Monitoring (ODM) has insisted that the seats be held long after black parents who could have used the seats had made other choices) Point 2 - For at least six years the LRSD must keep incentive schools but could not phase them out as intended, yet another Catch-22 situation. As inter-district schools were built only a small number of seats were taken out of service at Ish and Stephens compared to the seats added at M. L. King, Washington, Crystal Hill and Clinton The double funding obligation is also ordered by the plan: \"Funding for the incentive schools shall be set at two times the level for the elementary area schools to ensure that the children who are in racially-isolated settings are provided meaningful opportunities for desegregated \u0026gt;1 n I I I I experiences/activities. (Point 1) The purpose of the incentive school program is to promote and ensure academic excellence in schools that have been difficult to desegregate. (Point 2) It is believed that the incentive school program will not only compensate the victims of segregation, but the program will also serve as a tool for promoting meaningful and long-lasting desegregation in these schools and in the entire school district.\"(Point 3) As to Point 1 - Certainly with the high percentage of black students in area schools and the low percentage of white students there is not much meaningful opportunity for desegregated experiences/activities\". Catch-22 once again! Point 2 - The purpose of the incentive school program should not be confused with the purpose of the schools which was to put enough black students into them to create a situation where a 60 40 black white ratio would have been possible. Point 3 - The incentive school program is too broad and nebulous to accomplish this goal. How would meaningful and long-lasting desegregation promoted by this tool be measured? At the time the desegregation plan was sanctioned by the Eighth Circuit Court of Appeals in December of 1990 there were 9,344 children in the LRSD area schools. There were 5,980 black children and 3,364 of other races. To attain the 60/40 ratio 934 black children would have to be assigned to incentive schools. To the credit of the LRSD the enrollment numbers confirm that about 400 black students were transferred to incentive schools and there was an increase in other race enrollment, improving the area school ratio in the 91-92 school year. In the 92-93 school year incentive school enrollment decreased by 298. Analysis of enrollment numbers is difficult because of the variables to consider: demographic changes out of the inner city, the closing of Ish and Stephens, the construction of inter-district schools, etc. The almost explosive growth of four- year-old classes also distorts the analysis. However, the strict adherence to incentive schools limited the ability of the district to adapt, and to devise and execute policies that would have retained and attracted more white and other race children. The Little Rock incentive schools fit the description of a Catch - 22! 2I A CATCH 22 AND MORE - LITTLE ROCK INCENTIVE SCHOOLS [AFTER CATCH-22, A NOVEL BY JOSEPH HELLER] For those that never knew or have forgotten a Catch-22 is 1. a. A situation in which a desired outcome or solution is impossible to attain because of a set of inherently illogical rules or conditions: b. The rules or conditions that create such a situation. 2. A situation or predicament characterized by absurdity or senselessness. 3. A contradictory or self-defeating course of action. 4. A tricky or disadvantageous condition.' p I For those new to the Little Rock school desegregation case, you might not be aware of what an incentive school is or why we happen to have them in the Little Rock School District. Some of the explanation will become evident as we continue, but the incentive school remedy to the wrongs of discrimination is traceable back to a law case involving the Detroit School District commonly referred to, as \"Milliken 11\". In this case the United States Supreme Court ordered additional funds to improve Detroit's segregated minority schools. The decision stated that the education components were a means to \"restore the victims of discriminatory conduct to the position they would have enjoyed in the absence of such conduct\". p p The parties in the Little Rock school desegregation case in January 1989 incorporated the Milliken case approach into their agreement thereby creating the \"incentive schools\" as the vehicle to desegregate the district. They were to motivate black children to higher achievement despite a segregated setting and the program quality was to be an \"incentive\" for white parents to choose them. Why are the Incentive Schools a Catch-22? p The desired Incentive Schools solution is plainly spelled out in the Inter-district Plan page 4: 11' There shall be a limited number of incentive schools, for a period of at least six years, sufficient  to accommodate that number of black students who, by attending these schools, make it possible to achieve a student population in the remaining Little Rock schools (elementary area schools) of 55 percent black and 45 percent white with a variance of 5 percent. The recruitment of white students to these elementary area schools may increase the percentage of white students in these schools to a maximum percentage of 60 percent. The incentive schools shall be: Franklin, Garland, Ish^, Mitchell, Rightsell, Rockefeller, and Stephens. The incentive schools will be desegregated in phases through a combination of white recruitment into the incentive schools, and by reserving a designated number of seats in each incoming kindergarten class for the enrollment of white students. (Point 1) As new Interdistrict 1 The American Heritage Dictionary of the English Language, Third Edition copyright  1992 by Houghton Mifflin Company. Electronic version licensed from InfoSoft International, Inc. All rights reserved. Ish closed at the end of the school year 1992-93. ^Stephens closed at the end of the school year 1993-94How did Little Rock get into this Catch- 22? I Federal Judge Henry Woods rejected the Little Rock School District plan that had been submitted to him for approval and prophetically said \"The plan adequately explains why the Incentive Schools, but fails to explain how...The availability of \"double funding\" is meaningless if the programs on which the money is spent are not designed and implemented to achieve educational excellence. M He knew the plan would fail by saying \"Approval of the LRSD long range plan would have resulted in progressive segregation of elementary schools over a six year period.\" In fact that has happened. I I The Little Rock School District appealed Judge Woods' rejection of the plan to the Eighth Circuit Court. Judge Woods recused himself from the case and it was assigned to Judge Susan Weber Wright, who still has the responsibility for it. In its argument for the acceptance of its desegregation plan the district promised everything, with an attitude that getting out of court was the primary objective. The district naively thought that the court would release them on their own recognizance to do whatever they wanted once the desegregation plan was approved. The district must have been surprised when the Eighth Circuit Court Order of December 1990 continued court supervision and created the Office of Desegregation Monitoring with primary responsibility for monitoring the incentive school implementation. I Do the Incentive Schools provide a workable, equitable solution? I I The Eighth Circuit order* states A court has a strong interest in not involving itself, along with the prestige of the law in an ongoing equitable decree which is manifestly unworkable or plainly unconstitutional on its face. In addition, this is a class action, and courts are not obliged, indeed they are not permitted to approve settlements that are unfair to class members, or negotiated by inadequate class representatives. II I I Reference also the years of Incentive School Monitoring Reports from the Office of Desegregation Monitoring. Basically these reports are quality control reports on the efforts of the LRSD to follow the plan. They find that the district either by design, ineptitude or poor execution is unable to make the schools work. The District Court has expressed reservations about the Incentive Schools and the plan in general but the Eighth Circuit Court of Appeals imposed the terms and conditions of this desegregation plan and in effect gave the District Court its \"marching orders\". The District Court judge has made suggestions to the parties as to remedies that they might seek, even asking that the law be researched to determine if another case involving a consent decree could be used to seek relief on the basis of \"changed circumstances\", but no motions were ever filed using \"changed circumstances\". Circumstances have changed in the LRSD. In regard to the Incentive Schools the parties have failed to acknowledge the shift in population out of the so called inner city to southern Little Rock. That shift was recognized by the Joshua Intervenors when they brought suit to reapportion the school board zones, but they have failed in their representation of those children that moved from Incentive Schools to the 09 zip code or to address the westward growth of the city. The District Court also took the unusual step of holding hearings on its own to determine if the Incentive Schools were a viable tool in this desegregation case. Nationally recognized 4 Page 35 Eighth Circuit Court of Appeals order of December 1990 3professionals were invited to appear in open court to help provide the District Court and community with some indication if the incentive schools were effective, and if ineffective what new strategies might hold promise for Little Rock. Dr. Herbert Wahlberg, an educational psychologist, testified that the extra funding and enhancements of incentive schools had failed to raise the achievement scores of black children. He stated that he did not believe that incentive schools were effective in raising achievement levels anywhere: he stated that he did not know whether the failure was caused by poor implementation or whether the theory simply does not work. Wahlberg testified that the schools failed in three aspects: They failed to attract white children, achievement scores of black children were not raised, and the \"exotic\" curriculum was inefficiently implemented so that it harmed learning. Wahlberg was asked what he would do to help disadvantaged students in the Little Rock School District. He stated that there is a crisis of achievement in the United States, not just in Little Rock. He said that he would concentrate on learning, would assign more homework, extend the school year and would also change methods of teaching to incorporate mastery learning and cooperative learning. Dr. David Armor stated that most efforts to desegregate schools are counterproductive and do not improve achievement. He said \"my opinion here is that one of the reasons why racial balance by itself doesn't have an impact is that, in fact, it has to overcome really major kinds of family background differences in economics and education. And there's not really a single desegregation plan to my knowledge that has ever overcome those economic conditions, because they are not aimed at the family. They are aimed at school buildings and students and faculty.\" In his expert opinion then, the LRSD desegregation plan was not a workable solution toward reducing the disparity or improving the achievement of black children. Dr. Gary Orfield, of the Harvard Project on School Desegregation, led the writing of a report Giving Separate But Equal Another Chance\", which goes into some detail as to how unworkable the LRSD incentive schools are, also testified. One telling comment on how unworkable the plan was is \"The implementation of Little Rock's Milliken II plan illustrates how unchecked planning and design procedures common in such remedies can produce fundamentally incoherent, ill- conceived and unaffordable programs which so far have demonstrated little promise for reducing educational inequity.\" In his testimony here, he stated that the incentive school plan had lots of conceptual problems magnified with poor implementation. The incentive school plan, he said, was burdensome and complex, required big energy for a low payoff, and contributed to administrative overload. In response to a direct question Orfield said the benefits expected couldn't be obtained. The District Court, having heard this testimony, has not issued an order or opinion, perhaps waiting for a \"white knight\" or \"silver bullet\" solution to this \"Catch-22\" that would free it from issuing a controversial opinion. To the LRSD this testimony could be a \"silver bullet\", but so armed the LRSD has not asked for relief from the District Court. p p p p p p p p p p p Are the Incentive Schools unfair to class members? k This desegregation case is a class action suit and all black children in the LRSD are members of the class\nthose black children for whom relief was sought from the courts. The double funding (LRSD has expended far above the actual double funding obligation) has proven ineffective in improving achievement in the incentive schools and promoting k 4desegregation. Those 64% of class members attending area schools are consequently deprived of scarce resources. In year after year of budget cuts, when computer aides, instructional aides, music teachers, new computers etc. were stricken from the budget, area schools bore the brunt of cuts while incentive school budgets were sacrosanct. The attached chart shows clearly the extent of the inequity to class members in other than incentive schools (area schools, magnet schools and inter-district schools). The LRSD unfortunately has a large percentage (58.52%) of its elementary students that are considered \"disadvantaged\". Of 7,824 disadvantaged children most of whom are black, only 1,167(15%) are enrolled in incentive schools while 6,658 (85%) are in other schools. Of the ten schools (41% of the total) with the highest numbers of disadvantaged children, only Franklin is an incentive school. The 6,658 children needing help require our attention. If one black child was being physically abused in these schools the public outcry would be loud and clear to correct that inequity. Yet this is a different form of abuse inflicted on thousands of children that is ignored. These abused children need early and concentrated help to ever achieve at an acceptable level. I The editorial page of the Arkansas Democrat Gazette on April 15, 1997 (tax day) addressed the same question, albeit in a different context: \"The greatest social injustice of American society is no, not the back-breaking tax burden foisted on poor working families (including a tax on their groceries in Arkansas) but a system of public education that deprives the children of the poor and ghettoized of anything like an equal chance at acquiring knowledge, self-discipline, and the self- respect that comes with real accomplishment. These kids are being set up for one heckuva fall.\" I I I I I I I I 5School WASHINGTON WAKEFIELD CHICOT FRAhKUN MABELVALE WATSON CLOYffIDALE WEADOWCUFF BOOKS? WLSON Totd StiKlerts 602 426 430 377 429 423 402 402 601 366 Hack 391 365 333 352 306 350 348 304 319 297 Other 211 61 97 25 123 73 54 98 282 69 Black% 64.95% 85.68% 77.44% 93.37% 71.33% 82.74% 86.57% 75.62% 53.08% 81.15% Frcc/Rcduccd Meals Percent 6298% 81.07% 77.31% 86.52% 73.88% 74.83% 77.97% 73.33% 46.94% 73.70% Totd Disadvantaged 379 345 332 326 317 317 313 295 282 270 ML KING DODD MITCFELL BASELINE BALE GARLAhD GEYB? SPRINGS CARXiER \"ROCKEFELLB? MCOB?MOTT 488 284 243 284 307 237 278 627 314 484 252 188 237 223 224 223 223 323 211 262 236 96 6 61 83 14 55 304 103 222 51.64% 66.20% 97.53% 78.52% 7296% 94.09% 80.22% 51.52% 67.20% 54.13% 51.71% 86.90% 98.45% 81.73% 74.93% 94.55% 76.56% 33.02% 65.92% 41.32% 252 247 239 232 230 224 213 207 207 200 p B P WESTERN HILLS JEFFB^SON BRADY FULBRIGHT PULASKI HTS FAIR PARK ** RIGHTSELL FOREST PARK TERRY ROMINE 320 506 374 509 422 242 205 434 537 277 209 220 238 247 201 198 197 204 241 192 111 286 136 262 221 44 8 230 296 85 65.31% 43.48% 63.64% 48.53% 47.63% 81.82% 96.10% 47.00% 44.88% 69.31% 61.32% 38.34% 49.61% 36.15% 43.55% 75.46% 8296% 36.95% 28.65% 54.59% 196 194 186 184 184 183 170 160 154 151 P   P BADGETT WOODRUFF GIBBS OTTER CREEK WLLIAMS 185 202 309 332 513 13371 151 136 164 135 264 8728 65% 34 66 145 197 249 4643 35% 81.62% 67.33% 53.07% 40.66% 51.46% 77.73% 68.46% 39.35% 34.83% 2242% Total Disadvantaged in Incentive Schools Total Disadvantaged in Other Schools 144 138 122 116 115 7824 58.52% 1167 6658 15% 85% Mt Incenthe Schools The enrollment figures are based on the 1995-96 school year. The chart is based on information obtained from the LRSD. II P I 6Is money being wasted? On page 40 of the Eighth Circuit Court of Appeals order of December 1990, the Court wrote \"If the District Court becomes convinced in the future that money is being wasted, and that desegregation obligations are being flouted, it will be fully authorized to take appropriate remedial action. tl Some people have argued that none of the money spent on children is wasted money. But a prudent person would suggest that there is waste if spending on \"exotic\" programs is done carelessly or if there is a vacant seat in a classroom or on a school bus, if facilities are neglected, if necessary supplies are not purchased, or expensive items are purchased then are not used or are misused. The extra staff at the incentive schools including underutilized teachers, and class size limitations is waste. The old buildings that are in constant need of repair and are energy inefficient constitute a waste of resources. A particularly embanassing waste was the Program for Accelerated Learning (PAL) on which almost twenty million dollars was expended with poor results. I I I The excess number of seats with the resultant overstaffing in the school district and the failure of the school board to reduce the excess by closing schools is waste of the highest magnitude. In other school districts (Cleveland Ohio, Hartford Connecticut and the District of Columbia) the Court recognized the waste of excess capacity and ordered schools closed. Cleveland closed 14 at one time\nD.C. is under order to close 16. Most of the old incentive schools already have replacement schools in the area (M. L. King, Carver, and Washington) or seats available in the new PCSSD Interdistrict Schools (Clinton and Crystal Hill). For year after year the Office of Desegregation Monitoring (ODM) has calculated the double funding obligation of the LRSD for the incentive schools and in almost every year expenses in the incentive schools have exceeded that obligation. In the December 18, 1996 ODM report on incentive school double funding Recommendation 1 stated \"In each annual budget, allot an amount of money adequate to meet the double funding obligation in the incentive schools, and then control expenditures to prevent overspending that budget category.\" This is a classic \"Catch- 22\" for the only way to control expenditures is to cut the wasteful programs and extra staff, but cuts have not been looked on favorably by the District Court. Would a prudent person say there is waste in the LRSD Incentive Schools? I Why are the Incentive Schools so important? The Incentive Schools are the crux of the LRSD desegregation plan. The Interdistrict Plan still would exist and the Financial Settlement still would exist, but if the Incentive School provisions in the LRSD Desegregation Plan were removed there would not be much left. Most of that remainder is obsolete timelines or has lost its significance i.e. the pages devoted to curriculum at Parkview High School. In its December 1990 order, the Eighth Circuit Court of Appeals said on page 38 \"In order for some schools to be well integrated it may be necessary to tolerate a small number of all-black 7schools.\" (Emphasis added) and on page 39 \"The commitment to provide double funding for the incentive schools is crucial to our holding that the settlement plans are not unconstitutional per se.\" This would imply that the Eighth Circuit Court of Appeals felt too, that the Incentive Schools were the crux of the desegregation plan for the LRSD. Our schools have not become well integrated and we have created a class within a class. The continued existence of the incentive schools serves the purpose of various special interest groups. These groups could be called the \"desegregation establishment\". Their interests might be power, influence or continued existence. It has little to do with children, black or white. n What Next? v The importance of doing something now to help our disadvantaged black children to be successful is obviously important to the black community but it is important to the white community as well. As a society we cannot tolerate a perpetuation, under a new guise, of the two tiered education system of segregation. We cannot allow a black child to fail to learn to read in the first grade and then whine when lack of accomplishment by that child leads to discipline problems in the fourth and tragically later on, a prison sentence. II II The Incentive Schools are not the answer to this problem! II Time has run out on the Little Rock School District. The Incentive Schools have been around since 1990 and certainly have not achieved their objective. The district is about to start the tenth stanza of the same old song. To put it another way we have a 1966 Buick and if we paint it, put new tires on it and get the best radio money can buy we still have a 1966 Buick not a 1997 Cadillac. We need a new transportation system not a fixed up old car! II I A noted management book \"High Velocity Culture Change\" warns \"Culture change moves at a slow crawl if the existing culture gets to call the shots on methodology. Or to put it another way, you'll have trouble creating a new culture if you insist on ways that are consistent with the old one.\" They also point out that we are in an era where organizations must adopt a \"do what works\" mentality instead of trying to live out a \"do what feels good\" philosophy. V R The LRSD is too tied to the old culture and lacks the board leadership and management capability to even ask for change. The chilling effect of being involved in court for so many years has created a paranoid mentality that stifles innovation. The current efforts of the district using various \"work groups\" while commendable are simply those new tires on an old car. We need the money that is being spent on this tired old, out of gas car to provide equity to our children and the seed capital for innovative change. R R By any basic category for evaluation  such as educational, managerial, financial, and discipline  the school system has failed our children placing itself in a state of educational and operational crisis. Fundamental justice for the school children, their parents, and all the taxpayers and citizens who support and depend upon the LRSD, requires a complete overhaul in governance structure and management systems. 8I Because action by the parties is lacking the District Court appears to be the only authority with the capability to force the necessary systemic change that is needed. It should act unilaterally to change the status quo and provide the guidance towards new solutions and reform. There should be a new approach to the issue of governance. The present system is not working but we pretend that it is as evidenced by the \"business as usual\" search effort for a new superintendent and the failure of the board of directors to address the financial situation. Other districts have faced the same types of problems and different authorities have imposed new governance for failed school systems as precedent. In the District of Columbia, Chicago, Hartford and Newark, the existing leadership systems were replaced by structures more accountable for education performance, less bureaucratic, and less sensitive to politics. I Most recently, the Connecticut legislature on April 16, 1997 took control from the Hartford School Board and created a trusteeship. In New Jersey three school districts, Jersey City, Patterson and Newark have had new governance imposed on them. On a larger scale the Kentucky Supreme Court in 1990 ordered complete school reform from finance to curriculum for the entire State of Kentucky and the latest reports are very favorable. Is it a transferable system? H There are some who feel the Kentucky story is too unique to be transferable, because it was n5 launched by a court case and swept out the old system. \"But that may be its very strength: I Improving America's schools may demand radical surgery rather than piece-meal experimentation. By dumping an inadequate system and starting from scratch, by investing more and tying funding to performance, Kentucky has boosted its children's academic prospects. Arguably, that has lifted I .,6 its economic prospects as well. Those are important lessons from an unlikely place. The goal of sweeping change is to not only improve the efficiency of management, but also, and more importantly, educational effectiveness. The mission of any school system is to educate students and its failure in this mission provides a compelling basis for intervention. For Little Rock a governance structure would have to be established to insure accountability to the District Court and community. Accountability not based on numbers of tasks performed, bodies counted, maps on the wall, color of the paint etc. but on the financial stability of the district and the achievement of our children. Plain Talk, the UALR report identifies several \"backlog\" items as priorities and there are others but the issues and problems are overwhelming for this district to address. A court appointed Chief Operating Officer with court and community support, working with a new superintendent might provide a radical format for success. We know where the current path leads - to failure. The problem of achievement in the early grades is another issue requiring immediate court intervention. The District Court should order that attention be directed to improving achievement. Currently there is no Assistant Superintendent of Curriculum, no direction and the usual dysfunctional result. There needs to be professional leadership by staff with proven track records of curriculum development, staff development and innovation. Plain Talk, the UALR report called for bold experimentation to identify \"things that work\". We have some people in the district that 5 Susan Traiman, Director of the Education Initiative for the Business Roundtable from Business Week April 7,1997  Peter Galuszka in Harlan County Ky. -Business Week April 7, 1997 9are successful in implementing programs and the new leadership should use them as examples that the LRSD can do things successfully. Instead of a new desegregation plan the court should order that an education plan with the goal of increased achievement for all LRSD students be implemented. Again from \"High Velocity Culture Change\": II It's time for tough love. Caring Harder. Caring enough to take the company (district) through the tough, unpopular struggle of culture change so that it can survive. Trying not to disturb people, seeking to appease everybody by taking it slow and easy, can be the crudest move of all.\" p Parting Words p As the Little Rock School District searches for a new superintendent and the work groups continue their tasks. Plain Talk, the UALR report on the LRSD, has appropriate comments in Chapter 7 that bolster the previous section and are worth repeating. II p It is hard to avoid the conclusion that the problem is systemic. Changing the p players, specifically the superintendents, has not changed the outcome of the game. Figure 7-1 indicates that they are simply burning out sooner. It is also hard to avoid the conclusion that some important changes a modem urban school district should undertake simply will not occur, given the current complexity of the decision-making environment. For example, a strong case can be made for offering a calendar and schedule deliberately constructed to fit the needs and schedules of parents and families today. But it is obvious that LRSD officials do not have the time and energy to develop and put into place a revised or p p p expanded calendar and schedule. II Continued: p What Does It Add Up To? Several observations seem unavoidable after this review of the sources and consequences of complexity as faced by LRSD officials. p The environment within which LRSD officials operate is so complex that it is crippling. The superintendent and the central administration frequently suffer \"system overload\"like an electrical power system sometimes does in extremely hot weather, or like a tractor does when too many heavy wagons have been hitched at one time. p k The LRSD cannot unilaterally simplify the decision-making environment within which it operates. The keys to a manageable future lie outside the LRSD itselfin the hands of the community and the court. k k The LRSD needs stable leadership to give it direction and consistency and to assure soundness in all its operations. Since 1982, however, the LRSD has had six \"permanent\" and four interim superintendents\na total of 10 leadership changes in k 10 k riI I 15 years. Frequent changes in leadership have meant that instability and uncertainty have become almost permanent features, with negative effects on the morale and performance of school personnel. Frequent changes in leadership also undermine public confidence in an organization. In a fundamental sense, it does not appear to matter who the superintendent is. We conclude with an assessment of the status quo as reflected in comments by former superintendents:  Little Rock would be one of the top five most troublesome desegregation cases in the country. The district has the reputation of just not being workable at all.  The Little Rock desegregation plan is so complex and so difficult to administer, it is preordained that people cannot carry out the plan in the schools.  The desegregation plan in Little Rock is unworkable. It is so prescriptive that it ties the hands of the superintendent and the board. The system is like a dysfunctional family. You have a system that is set up to fail.  The way things are now, a superintendent cannot succeed. I Observations and Options The status quo is an option that could be chosen deliberately or by default. But the plans that were intended to be a pathway out of an undesirable situation in 1989 have become an impediment to progress.\" I Post Script I Only fundamental change will reverse the situation as described in \"Plain Talk\" and this paper. The community of Little Rock must have the civic will to institute a structure for the public schools that puts students first, links performance and accountability for education results, and provides a disciplined environment in which learning can occur. Achieving this objective requires that the District's parents and children, its teachers, and other school system employees recognize that the status quo is harmful to the goals of a quality public education and therefore is unacceptable. At this time the civic will is lacking and the responsible officials don't have the collective strength to make necessary changes. Action by the court would be loudly decried as \"more federal intervention\" but it could force change and prepare the district for a return to complete local control. Since 1957 the federal court has been involved with this district\nlet 1997 be the year that the court defines the terms of disengagement. 11I Afterthoughts on Bob Morgan's Suggestions I Where there is a will, there is a way. The people have the will. Even the Judge may have it. The school board doesn't. I I I Bob Morgan's timely suggestions are born out of a sincere desire to avert the serious consequences of an almost certain economic collapse of the Little Rock School District. He is among a handful of area business and political leaders who have astutely discerned that the district simply cannot operate, or move forward, with any real success under the status quo of the current desegregation plan. Something must changeand quickly. The Catch-22 of the incentive schools in Little Rock is, indeed, a convoluted and complex barrier to freeing our schools from federal oversight and the clutches of a \"consent decree\" that, in many respects, seems unbreakable. I Dire situations often call for unprecedented solutions and Little Rock is surely a case where bold actionas opposed to no actionis warranted. The judge has reason to intervene even in a consent decree if there is a defect in the plan (this plan is demonstrably unworkable) or if there is a change of circumstances (as LRSD has had) or to further the original purpose of the plan. What better purpose could be served than restoring a measure of equity to disadvantaged black children. I I Still, while there may be some precedent for a judge's unilaterally intervening in a desegregation case ( Hillsborough County in Florida), several APF legal experts on desegregation issues feel it is unlikely that Judge Susan Weber Wright would take such action. The responsibilities she would take upon herself would be enormous-with no real guarantees of success. It would be risky for one person to assume such a burden-especially a judge. Moreover, in a time when \"judicial activism\" is an issue dominating the national policy debate, judges are taking care to stick to their role of upholding law rather than making it. Never-the-less, Bob Morgan has made the all-important first part of a critical argument that provides compelling reasons to dissolve the plan. The Catch-22 of incentive schools and the structure of the plan itself make it \"impossible\" to break or to administer. I What would further compel a judge to \"break a contract\" between parties? APF believes it hinges on a demonstration of political and civic will by the people. The current obstacle is, of course, the local school boardthe seven member elected body representing the people. Some school board members are captive to special interests who clearly have a stake in the case. Others fear the personal or business consequences of being too bold or aggressive. The people of Little Rock have been content to tolerate a board unwilling to unify on this issue and seek its resolution. So have many local politicians and business leaders. The political and civic will is simply not there yet, or a school board reflective of that will would be in place. And until the Judge sees an expression of such will, it is likely she will not act regardless of who may file a motion or seek to intervene. I I In the meantime, a growing number of business leaders are suggesting that it may, in fact, take the district's financial collapse to disrupt the status quo and set the stage for a whole new paradigm of education...one open to ideas such as charter schools and parental choice. They may be right. The war of competing interests will rage on in Little Rock's desegregation case\nthe peoplefrustrated by the dominance of those interestswill continue exhibiting a sense of futility in affecting change, and the Judge will sit and wait...and wait...and wait. I And in her waiting there is a disturbing irony. Why? Because Judge Wright likely wants relief for Little Rock's schools as much the people in this city want it. But she needs visible evidence in her courtof a community and its leaders united in their common will to take responsibility for such a dramatic change. Little Rock is more than ready\nweary of the disabling and divisive effects of the nation's longest running desegregation case (forty years). But the school board itself, representing the people, cannot seem to muster the wisdom or courage to lead a desperately needed initiative for the sake of our schools and our children. They cannot find their own collective political will to band together, putting children above all else, and move for our release. Until they do. Little Rock will remain a community torn by competing education interests and hostage to its past. Will we ever move on? The answer, at least for now, appears to be no. Michael Watson, President, APF\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resoources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n\u003cdcterms_creator\u003eMorgan, Bob\u003c/dcterms_creator\u003e\n\u003cdcterms_creator\u003eArkansas Policy Foundation\u003c/dcterms_creator\u003e\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_381","title":"Construction","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["1990/2007"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Little Rock School District","Education--Arkansas","Little Rock (Ark.)--History--21st Century","School facilities"],"dcterms_title":["Construction"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/381"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["documents (object genre)"],"dcterms_extent":["159 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nTO\nFROM: THROUGH: SUBJECT: LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, ARKANSAS April 2, 1990 Office of the Metropolitan Supervisor James Jennings, Associate Superintendent for Desegregation Monitoring and Program Development ' Dr. Ruth Steele, Superintendent of Schools Dr. Herb Cleek, Deputy Superintendent of Schools Building Plan for Incentive Schools Please find attached the proposed plan for expanding the capacities of the e incentive schools.LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREETS LITTLE ROCK, ARKANSAS April 2, 1990 TO\nFROM: SUBJECT: Dr. Ruth Steele, Superintendent of Schools Dr. Herb Cleek, Deputy Superintendent of Schools Dames Dennings, Associate Superintendent for Desegregation Monitoring TTiS and Program Development Building Plan for Incentive Schools According to the Tri-District Desegregation Plan, the Little Rock School District must submit a detailed plan for closing incentive schools with small capacities and enrollments and building larger schools in the approximate vicinity for the purpose of integregation. The plan must be submitted to the Office of the Metropolitan Supervisor by April 1, 1990. The District has discussed this matter with the Metropolitan Supervisor's office on several occasions. It is the District's understanding that certain parameters must be followed in developing plans to close and rebuild incentive schools. First, the purpose of this plan is to increase the elementary building capacity in central and east Little Rock. Any school closings must be accompanied by a building expansion at some other school(s) and/or the construction of a new school building. The increase in building capacity will eventually help reduce the burden o\" busing on black elementary students. Second, in a case of a building expansion, the new capacity must yield enough seats to enable the school to meet desegregation requirements. The incentive schools must have enough space to obtain a racial balance of approximately 60-70% black. The same requirement applies to the construction of a new scheol building. Closing a school also involves reassigning students to either a new building, an expanded facility, or an existing school outside of the target area. Whatever the case, the reassignment process must comply with desegregation requirements. Another parameter involves the number of classes at each grade in a particular school. Each grade must have enough seats to accommodate the total capacity at the preceding grade. This factor is often overlooked in preparing for future capacity needs. For instance, some schools have three classes feeding into two classes at the next grade level. The only way to correct this problem without reassigning students is to move a teacher to the problem grade level. This factor must be considered in developing plans to expand school buildings. p (1)The last factor for consideration relates to physical limitations at the school site and/or in the target community. In considering building expansions, attention must be given to the space limitations at the school site. Some of the incentive schools do not have enough space for extensive expansions. The District has observed these factors as an extensive search for a new school site in the target area has been underway since 1988. Real estate agencies and others who are familiar with availability of properties that might be suitable for a new school site have been engaged to assist in the identification of potential sites. The old King School is the only site east of / University Avenue that the District has been able to identify for new con- struct!on.  In addition to the mandate to close and rebuild/expand incentive schools, the I ri-Di strict Desegregation Plan also directs the Little Rock School District to place four-year old programs in all incentive schools. The following is a plan which addresses the need to provide an early childhood education program in each incentive school as well as the closing and rebuilding/expansion of existing incentive schools. The plan is based on the following assumptions: a  All sixth graders enrolled at the incentive schools in the 1989-90 and 1990-91 school year will be promoted. b. c. d. e. All K-5 students currently enrolled at the incentive schools will remain at these schools for the 1990-91 school year, in 1990-91 will remain at these schools in 1991-92. included for magnet transfers The K-5 students No projections are All K-5 incentive school students will be promoted in 1990-91 and 1991-92 to the next grade level at the end of the respective school year. Kindergarten seats in the incentive schools will be filled using a 60% black and 40% white ratio. If necessary, seats will be reserved to ensure a 60/40 racial balance. All assignments (including sibling preference transfers) to the incen- tive schools are subject to desegregation requirements. Seats will be reserved for white students to ensure compliance with desegregation requirements. ^f. __ pl eted before the beginning of the 1991-92 school year if thq All building expansions, if necessary, and construction will be com- Little Rock School District is able to obtain long-term financing for construction costs. g. Meetings will be scheduled with parents and other community representatives to discuss plans for closing and/or expanding schools in their neighborhoods. (2)I I fl I Ish Ish school will be closed at the end of the 1990-91 school year. Approximately 146 black students in grades 1-6 will be enrolled at Ish at the time of the school closing. The students at Ish will be reassigned to Rightsell and Mitchell for the 1991-92 school year. A site selection committee will be appointed to identify a site for a new school in the general proximity of Ish, Mitchell, and Rightsell. Within the allowable time frame, the District will use every legal means to acquire adequate property for a new school in this proximity (including the right of eminent domain) and will engage the assistance of professional real estate agents in its search. The committee will submit its findings to the Metropolitan Supervisor's office by May 15, 1990. If the District is unable to acquire a site for a new building, the District will proceed with the following plan to expand Mitchell and Rightsell. Mitchel 1 Seven classrooms will be added to Mitchell: - one first grade - one second grade - one third grade - one fourth grade - one fi fth grade one ixth grade - one four-year old class The first through sixth grade additions will change Mitchell's capacity from 280 to 400 students. The addition of 75 students from Ish will still enable Mitchell to obtain a 68/32 black/white racial balance if all of the remaining seats are filled by white students. Rightsell The classroom presently in use for Rightsell's mass media specialty will become a fourth grade classroom. Also, six classrooms will be added to Rightsell: - one first grade - one second grade - one third grade - one fifth grade - one sixth grade - one four-year old class The first through sixth grade additions will change Rightsell's capacity from 260^to 380 students. The addition of 71 students from Ish will still enable Rigtitsell to obtain a 70/30 black/white ratio if all of the remaining seats are filled by white students. These plans are contingent upon adequate space at Rightsell to complete the proposed classroom additions. Rockefeller The CARE activity room will be used for an additional kindergarten class. will give Rockefeller a total of three kindergarten classes and will allow the This 60 four-year old students currently at Rockefeller to be able to remain for kindergarten. The G/T class will be moved to another area of the building. A new second grade class will be assigned to the room formerly used by G/T. At least four classrooms will be added to Rockefeller: - one third grade - one fourth grade - one fifth grade - one sixth grade UIThe classroom changes and additions will change Rockefeller's capacity from 300 to 420 students. The new capacity will allow Rockefeller to obtain a 53/47 black/white ratio if all of the remaining seats are filled by white students. (NOTE: Consideration will be given to adding a total of six new classrooms to Rockefeller to accommodate the relocation of the G/T class.) Old King Site A new school will be constructed on the old King site. the incentive school program and will have a capacity of approximately 700 students. The District will initiate discussions with city officials relative to improvement of street access to the old King site. All students enrolled at Garland and Stephens will be reassigned to the new school. The school will offer open in the 1991-92 school year. The new school will Careful attention will be given to alternative educational/service uses for Ish, Garland, and Stephens. Contact has already been made with an agency that is interested using Ish. These closings will also require that the District give prompt attention to a new site for the IRC. In addition, the District will give special attention to maintaining the names o'' King, Ish, and Stephens. The individuals for whom these schools were named have made important contributions to the black community, and the District should continue to honor them with school names. Fundi ng The District will use proceeds from the 8 mill tax increase to fund the incen- tive school building plan if approved by the voters. If the tax increase is not approved, the District will ask the Metropolitan Supervisor's Finance Committee to make the incentive school building plan a high priority from desegregation funds. - ............... -- If the Finance Committee disallows funds for the incentive school building plan, then the District will ask the Court for funding. (4)LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, ARKANSAS November 29, 1990 TO: Board of Directors FROM: THROUGH: SUB3ECT: r.'- \\  Dames Dennings, Associate Superintendent for Desegregation Monitoring and Program Development Dr. Ruth Steele, Superintendent of Schools First Quarter Enrollment - 1990-91 School Year Please find attached the enrollment report for the first quarter of the 1990-91 school year. cc: Senior Management TeamLITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, ARKANSAS COMPARISON OF ACTUAL ENROLLMENT FOR FIRST QUARTER OF 1990-91 AND 1989-90 1990-91 Actual enrollment as of October 31, 1990, First Quarter of the 1990-91 School Year. WHITE BLACK OTHER TOTAL %BLACK Special Schools Elementary (w/o Kindergarten) Junior High Schools 48 4041 1861 High Schools (w/o Kindergarten) 2159 26 8209 4004 3077 0 144 87 87 74 12,394 5,952 5,323 35% 66% 67% 58% SUB TOTAL 8109 15,316 318 23,743 65% Ki ndergarten 681 1,206 21 1,908 63% GRAND TOTAL .8790 16,522 339 25,651 64% 1989-90 Actual enrollment as of November 1, 1989, First Quarter of 1989-90 School Ysdr  WHITE BLACK OTHER TOTAL %BLACK Special Schools Elementary (w/o Kindergarten Junior High Schools 47 3905 1917 High Schools (w/o Kindergarten) 2408 28 8212 3883 3186 1 76 119 12,236 97 83 5,897 5,677 37% 67% 66% 56% SUB TOTAL 8277 15,309 300 23,886 64% Ki ndergarten 628 1,269 20 1,917 66% GRAND TOTAL 8905 16,578 320 25,803 64%GRADE K 1 2 3 4 5 6 UNGR TOTAL ELEM. 7 8 9 UNGR TOT. 3R HIGH 10 11 12 UNGR TOT. SR HIGH TOTAL: SPEC SCHOOLS DIST TOTALS SUMMARY OF FIRST QUARTER ENROLLMENT October 31, 1990 WHITE BLACK OTHER* TOTAL %BLACK 681 727 659 670 684 666 595 40 4722 589 638 601 33 1861 703 718 709 29 2159 8742 48 8790 1206 1450 1271 1279 1408 1380 1309 112 9415 1366 1391 1182 65 4004 1082 980 967 48 3077 16,496 26 16,522 SUWARY OF STUDENTS LISTED IN \"OTHER\" SPANISH ASIAN/PACIFIC ISLANDER ESKIMO/AMERICAN INDIAN OTHER 21 30 21 24 29 14 26 0 165 21 26 40 0 87 32 30 24 1 87 339 0 339 CATEGORY: - 93 - 218 - 24 - 4 1908 2207 1951 1973 2121 2060 1930 152 14,302 1976 2055 1823 98 5952 1817 1728 1700 78 5323 25,577 74 25,651 63% 66% 65% 65% 66% 67% 68% 74% 66% 69% 68% 65% 66% 67% 60% 57% 57% 62% 58% 65% 35% 64%LITTLE ROCK SCHOOL DISTRICT FIRST QUARTER ENROLLMENT OCT. 31, 1990 SCHOOL/GRADE WHITE BLACK OTHER TOTAL %BLACK l^CENTRAL UNGRADED 10 11 12 SUBTOTAL KIND. TOTAL 0 203 174 227 604 0 604 5 308 278 307 898 49 947 0 12 9 13 34 0 34 5 523 46r' 547 1536 49 1585 100.00% 58.89% 60.30% 56.12% 58.46% 100.00% 59.75% IMPAIR UNGRADED 10 11 12 SUBTOTAL KIND. TOTAL 14 107 126 107 354 3 357 12 184 160 132 488 10 498 0 3 4 1 8 0 8 26 294 290 240 850 13 863 46.15% 62.59% 55.17% 55.00% 57.41% 76.92% 57.71% b-^ALL UNGRADED 10 11 12 SUBTOTAL KIND. TOTAL 12 147 180 156 495 10 505 12 223 202 236 673 8 681 0 7 5 3 15 0 15 24 377 387 395 1183 18 1201 50.00% 59.15% 52.20% 59.75% 56.89% 44.44% 56.70% ^'MCCLELLAN UNGRADED 10 11 12 SUBTOTAL KIND. TOTAL 3 127 121 113 364 2 366 19 209 200 158 586 17 603 1 6 2 2 11 0 11 23 342 323 273 961 19 980 82.61% 61,11 5, 61.92% 57.88% 60.98% 89.47% 61.53% V-^ARKVIEW UNGRADED 10 11 12 SUBTOTAL KIND. TOTAL 0 119 117 106 342 0 342 0 158 140 134 432 11 443 0 4 10 5 19 0 19 0 281 267 245 793 11 804 0.00% 56.23% 52.43% 54.69% 54.48% 100.00% 55.10%SCHOOL/GRADE '-\"'CLOVERDALE UNGRADED WHITE BLACK OTHER TOTAL %BLACK TOTAL DUNBAR UNGRADED TOTAL 7 8 9 7 8 9 FOREST HEIGHTS UNGRADED 7 8 9 TOTAL HENDERSON UNGRADED 7 8 9 TOTAL MABELVALE UNGRADED 7 8 9 TOTAL MANN UNGRADED 7 8 9 TOTAL PULASKI HEIGHTS UNGRADED TOTAL 7 8 9 2 61 75 80 218 1 190 180 155 526 0 1 2 2 5 3 252 257 237 749 33.33 o. 75.40% 70.04% 65.40% 70.23% 120 55 56 231 7 62 70 83 222 5 44 74 88 211 9 64 76 67 216 104 134 113 351 4 76 100 78 258 158 143 111 412 9 156 186 174 525 16 214 250 209 689 16 142 147 92 397 196 166 152 514 8 153 138 148 447 3 0 3 6 0 7 3 8 18 0 5 8 9 22 0 0 1 1 2 4 5 6 15 0 1 2 4 7 281 198 170 649 16 225 259 265 765 21 263 332 306 922 25 206 224 160 615 304 305 271 880 12 230 240 230 712 56.23% 72.22% 65.29% 63.48% 56.25% 69.33% 71.81% 65.66% 68.63% 0.00% 81.37% 75.30% 68.30% 74.73% 64.00% 68.93% 65.63% 57.50% 64.55% 64.47% 54,43% 56.09% 58.41% 0.00% 66.52% 57.50 \"O 64.35% 62.78% ASCHOOL/GRADE SOUTHWEST UNGRADED WHITE BLACK OTHER TOTAL %BLACK TOTAL BADGETT UNGRADED SUBTOTAL KIND. TOTAL BALE UNGRADED SUBTOTAL KIND. TOTAL BASELINE UNGRADED SUBTOTAL KIND. TOTAL 7 8 9 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 6 58 54 36 154 15 157 181 141 494 0 5 7 12 21 215 240 184 660 0.00 5, 73.02% 75.42% 76.63% 74.85 *0 2 6 4 8 10 11 5 46 11 57 3 10 10 8 11 14 4 60 7 67 13 14 11 6 14 13 71 19 90 3 16 25 35 39 17 21 156 9 165 4 50 38 47 46 41 44 270 32 302 49 42 38 37 30 30 226 37 263 0 0 0 0 0 0 0 0 0 0 0 0 0 1 4 0 1 6 1 7 1 1 2 0 0 0 4 1 5 5 22 29 43 49 28 26 202 20 222 7 60 48 56 61 55 49 336 40 376 63 57 51 43 44 43 301 57 358 60.00% 72.73% 86.21% 81.40% 79.59% 60.71% 80.77% 77.23% 45.00% 74.32% 57.14% 83.33% 79.17% 83.93% 75.41% 74.55% 89.80% 80.36% 80.00% 80.32% 77.78% 73.68% 74.51% 86.05 Q, '5 68.18% 69.77% 75.08% 64.91% 73.46%SCHOOL/GRADE BOOKER UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL BRADY UNGRADED SUBTOTAL KIND. TOTAL CARVER UNGRADED SUBTOTAL KIND. TOTAL CHICOT UNGRADED SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 43 36 34 40 46 34 233 30 263 44 50 51 52 53 56 306 44 350 1 4 0 3 0 0 8 1 9 88 90 85 95 99 90 547 75 622 50.00 5, 55.56% 60.00% 54.74% 53.54% 62.22% 55.94% 58.67% 56.27% 2 20 17 17 16 19 5 96 21 117 31 40 43 45 38 44 241 23 264 10 31 25 20 21 22 20 149 27 176 3 52 41 47 56 51 45 295 37 332 38 44 49 54 54 53 292 34 326 8 66 46 43 46 42 48 299 50 349 0 1 1 1 1 0 1 5 0 5 1 2 0 1 1 2 7 1 8 0 1 0 0 0 1 0 2 0 2 5 73 59 65 73 70 51 396 58 454 70 86 92 100 93 99 540 58 598 18 98 71 63 67 65 68 450 77 527 60.00% 71.23 69.49% 72.31% 76.71% 72.86% 88.24% 74.49% 63.79% 73.13% 54.29% 51.16% 53.26 54.00% 58.06% 53.54% 54.07% 58.62% 54.52% 44.44% 67.35% 64.79% 68.25% 68.66 o, o 64.62% 70.59 66.44% 64.94% 66.22%SCHOOL/GRADE LOVERDALE UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL DODD UNGRADED SUBTOTAL KIND. FAIR PARK UNGRADED SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 FOREST PARK UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 13 13 26 19 12 14 97 10 107 3 22 17 16 11 28 18 115 19 134 14 9 8 8 6 6 51 10 61 29 23 31 20 19 22 144 33 177 35 45 34 46 52 41 253 29 282 4 20 28 28 28 25 40 173 19 192 56 41 40 37 42 32 248 29 277 19 26 39 35 33 30 182 26 208 0 0 0 0 1 0 1 1 2 0 1 0 0 0 1 1 3 0 3 1 0 0 0 0 0 1 0 1 1 0 1 0 0 2 4 1 5 48 58 60 65 65 55 351 40 391 7 43 45 44 39 54 59 291 38 329 71 50 48 45 48 38 300 39 339 49 49 71 55 52 54 330 60 390 72.92% 77.59 56.67% 70.77% 80.00% 74.55% 72.08% 72.50% 72.12% 57.14% 46.51% 62.22% 63.64% 71.79% 46.30% 67.80% 59.45% 50.00% 58.36% 78.87 Q. *0 82.00% 83.33% 82.22% 87.50% 84.21% 82.67% 74.36% 81.71% 38.78% 53.06% 54.93% 63.64% 63.46% 55.56% 55.15 43.33% 53.33%SCHOOL/GRADE FRANKLIN UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL FULBRIGHT UNGRADED SUBTOTAL KIND. TOTAL GARLAND UNGRADED SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 t^EYER SPRINGS UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 1 5 5 7 11 6 11 46 11 57 7 65 54 33 46 53 42 300 49 349 0 1 0 3 3 1 1 9 0 9 8 71 59 43 60 60 54 355 60 415 87.50% 91.55% 91.53% 76.74% 76.67% 88.33% 77.78% 84.51% 81.67% 84.10% 5 33 43 34 38 41 35 229 32 261 4 47 30 54 41 42 47 265 27 292 0 3 0 0 3 1 0 7 0 7 9 83 73 88 82 84 82 501 59 560 44.44% 56.63% 41.10% 61.36% 50.00% 50.00 Q, *6 57.32% 52.89% 45.76 52.14% 0 5 2 2 1 0 3 13 3 16 14 18 23 26 37 39 35 192 16 208 0 1 2 2 1 1 2 9 0 9 14 24 27 30 39 40 40 214 19 233 100.00% 75.00% 85.19 Q. *0 86.67% 94.87% 97.50% 87.50 89.72 84.21% 89.27% 7 7 8 14 4 7 47 13 60 16 16 14 22 36 16 120 27 147 0 0 0 0 0 0 0 0 0 23 23 22 36 40 23 167 40 207 69.57% 69.57% 63.64% 61.11% 90.00 o. 69.57% 71.86 67.50 a. o, 'o 71.01%SCHOOL/GRADE GIBBS UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL ISH UNGRADED SUBTOTAL KIND. TOTAL JEFFERSON UNGRADED SUBTOTAL KIND. TOTAL MABELVALE UNGRADED SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 20 17 16 29 24 20 126 15 141 26 26 25 34 27 23 161 25 186 1 1 3 1 0 0 6 0 6 47 44 44 64 51 43 293 40 333 55.32% 59.09% 56.82% 53.13% 52.94% 53.49% 54.95% 62.50% 55.86% 0 2 0 0 1 0 0 3 0 3 6 33 17 16 26 11 15 124 16 140 0 0 0 0 0 0 0 0 0 0 6 35 17 16 27 11 15 127 16 143 100.00% 94.29% 100.00% 100.00 96.30% 100.00% 100.00% 97.64 100.00% 97.90% 3 30 33 34 38 31 26 195 32 227 6 36 32 32 35 36 33 210 27 237 0 3 0 1 1 0 1 6 1 7 9 69 65 67 74 67 60 411 60 471 66.67% 52.17% 49.23% 47.76% 47.30% 53.73 5. 55.00% 51.09% 45.00% 50.32% 2 38 34 45 33 25 32 209 28 237 4 60 39 29 44 57 51 284 31 315 0 0 1 0 0 1 0 2 1 3 6 98 74 74 77 83 83 495 60 555 66.67% 61.22% 52.70% 39.19% 57.14% 68.67 61.45 Q, 'O 57.37% 51.67% 56.76%SCHOOL/GRADE MCDERMOTT UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 0 23 33 22 35 22 27 162 29 191 2 46 38 59 47 54 47 293 26 319 0 2 1 1 0 0 0 4 4 8 2 71 72 82 82 76 74 459 59 518 100.00% 64.79% 52.78% 71.95% 57.32% 71.05% 63.51% 63.83% 44.07 Q, 61.58% MEADOWCLIFF UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 23 17 24 25 17 18 124 28 152 49 47 39 49 39 34 257 31 288 0 0 1 1 0 1 3 0 3 72 64 64 75 56 53 384 59 443 68.06% 73.44% 60.94% 65.33% 69.64% 64.15 66.93 3. o 52.54% 65.01% MITCHELL UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 0 10 2 3 2 2 2 21 5 26 7 30 26 24 19 29 18 153 31 184 0 0 0 0 0 0 0 0 0 0 7 40 28 27 21 31 20 174 36 210 100.00% 75.00% 92.86% 88.89% 90.48 % 93.55% 90.00% 87.93% 86.11 87.62% OTTER CREEK UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 26 26 26 20 26 28 152 24 176 22 23 24 31 26 24 150 32 182 0 0 0 0 0 0 0 0 0 48 49 50 51 52 52 302 56 358 45.83% 46.94% 48.00 60.78% 50.00% 46.15% 49.67% 57.14 50.84 5. ASCHOOL/GRADE PULASKI HEIGHTS UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL RIGHTSELL UNGRADED SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 1 2 3 4 5 6 ROCKEFELLER UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL ROMINE UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 22 17 16 7 12 7 81 23 104 26 30 29 33 31 33 182 31 213 1 0 1 1 0 1 4 2 6 49 47 46 41 43 41 267 56 323 53.06% 63.83% 63.04% 80.49% 72.09% 80.49% 68.16% 55.36% 65.94% 0 0 0 0 0 0 0 1 1 23 6 4 7 8 2 50 26 76 3 9 8 11 8 7 6 52 8 60 33 33 27 27 21 17 158 32 190 34 24 27 25 26 23 159 33 192 10 58 41 40 39 37 52 277 43 320 0 1 0 0 0 0 1 0 1 3 1 0 1 0 0 5 0 5 0 0 0 0 0 2 1 3 0 3 33 34 27 27 21 17 159 33 192 60 31 31 33 34 25 214 59 273 13 67 49 51 47 46 59 332 51 383 100.00% 97.06 100.00% 100.00% 100.00% 100.00% 99.37% 96.97% 98.96% 56.67% 77.42% 87.10% 75.76% 76.47% 92.00% 74.30% 55.93% 70.33% 76.92% 86.57% 83.67% 78.43% 82.98% 80.43 Q, 88.14% 83.43% 84.31% 83.55%SCHOOL/GRADE STEPHENS UNGRADED WHITE BLACK OTHER TOTAL %BLACK 2 4 5 6 SUBTOTAL KIND. TOTAL 0 0 0 1 0 1 0 2 3 5 7 35 23 19 32 30 17 163 28 191 0 0 1 1 1 1 2 6 1 7 7 35 24 21 33 32 19 171 32 203 100.00% 100.00% 95.83% 90.48% 96.97% 93.75% 89.47 o. *5 95.32% 87.50% 94.09% TERRY UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 33 32 30 39 37 28 199 32 231 40 37 41 44 46 52 260 26 286 2 1 1 1 0 0 5 2 7 75 70 72 84 83 80 464 60 524 53.33% 52.86% 56.94% 52.38% 55.42% 65.00% 56.03% 43.33% 54.58% WAKEFIELD UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 0 29 27 22 24 23 21 146 21 167 0 45 40 41 54 54 57 291 39 330 0 1 1 2 1 2 0 7 0 7 0 75 68 65 79 79 78 444 60 504 0.00% 60.00% 58.82% 63.08% 68.35% 68.35% 73.08% 65.54% 65.00% 65.48% WASHINGTON UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 2 47 45 58 38 44 43 277 39 316 7 115 65 57 52 51 34 381 51 432 0 2 2 0 1 0 3 8 3 11 9 164 112 115 91 95 80 666 93 759 77.78 70.12% 58.04% 49.57 57.14% 53.68% 42.50% 57.21% 54.84% 56.92%SCHOOL/GRADE WATSON UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOAL KIND. TOTAL \\x15estern : UNGRADED 1 2 3 4 5 6 20 30 22 28 25 27 152 19 171 55 43 51 55 58 55 317 41 358 0 1 0 1 1 0 3 0 3 75 74 73 84 84 82 472 60 532 73.33% 58.11% 69.86% 65.48% 69.05% 67.07% 67.16% 68.33% 67.29 HILLS 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 19 17 14 19 22 14 105 17 122 29 32 31 31 31 38 192 19 211 0 0 1 0 0 1 2 1 3 48 49 46 50 53 53 299 37 336 60.42% 65.31% 67.39% 62.00% 58.49% 71.70% 64.21% 51.35% 62.80% WILLIAMS UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 30 32 31 41 30 26 190 26 216 38 37 38 49 45 39 246 33 279 2 0 1 2 0 2 7 0 7 70 69 70 92 75 67 443 59 502 54.29% 53.62% 54.29% 53.26 60.00 *6 58.21% 55.53% 55.93% 55.58% WILSON UNGRADED 1 2 3 4 5 6 SUBTOTAL KIND. TOTAL 4 32 13 13 12 14 18 106 12 118 16 39 52 37 42 41 36 263 43 306 0 0 0 0 0 0 2 2 0 2 20 71 65 50 54 55 56 371 55 426 80.00% 54.93% 80.00% 74.00% 77.78% 74.55% 64.29 o. 70.89% 78.18% 71.83% ASCHOOL/GRADE Lx^bODRUFF UNGRADED WHITE BLACK OTHER TOTAL %BLACK SUBTOTAL KIND. TOTAL 1 2 3 4 5 6 9 5 5 7 16 9 51 9 60 10 17 15 18 20 31 111 8 119 0 0 1 1 0 2 4 0 4 19 22 21 26 36 42 166 17 183 52.63 77.27 71.43 a. *0 Q. 6 69.23% 55.56 73.81% 66.87% 47.06 Q. O 65.03% EASTER SEALS UNGRADED TOTAL 15 15 5 5 0 0 20 20 25.00% 25.00% ELIZ. MITCHELL UNGRADED TOTAL 26 26 13 13 0 0 39 39 33.33 33.33% E. MITCHELL(DAY) UNGRADED TOTAL 7 7 8 8 0 0 15 15 53.33% 53.33%School Orig Lang Capacity May Doc 3-15-91 I jj memo B Enrollment 1st Quarter NB T Orig Lang % Black May 1st Doc Quarter Blk May Doc Enr Cap Psb % Blk Badgett Bale Baseline Brady Chicot Clov Elem Dodd Fair Park Forest Pk Fulbright Gyr Sprgs Jefferson Mabelvale McDermott Meadowcliff Otter Creek Pul Heights Terry Wakefield Watson Westn Hills Wilson Woodruff 275 394 417 420 563 420 424 351 436 607 235 490 541 531 465 383 328 537 472 472 328 409 257 401 390 467 257 415 390 491 558 i 558 492 j 464 i 328\n386 351 376 1 165 302 57 74 383 403 540 i 587 328 5 492 515 517 442 351 351 492 492 492 328 394 324 I 255 513 562 562 481 378 378 537 517 537 355 428 209 222 376 263 95 I 358 332 11221 454 1 349 I 178\n527 I 282(109\n391 192 277 53% 60% 62% 52% 57% 73% 69% 55% 52%  31% 60% 72% 74.32% 80.32% 73.46% 73.13% 66.22% 72.12% 137 329 I 62\n339 165-7-257 = 64.20% 302-r 401 = 75.31% 263^390 = 67.44% 332-^467 = 71.09% 3494 558 = 62.54% 282-^492 = 57.32% 55% ' 52% 54%\n51% 58.36% 81.71% 1924 328 = 58.54% 277-^-351 = 208 i182i 292 147 237 390 53% ! 48% 53.33% 208-376 = 55.32% I I 268 I 315 319 288 560 60 : 207 53% i 51% 55% i 67% 52.14% 71.01% 292 4 540 = 54.07% 1474 328 = 44.82% I I 1 234i 471 I 240: 555 i 199( 518 155 I 443 I 52% 47% 50.32% 2374 492 = 48.17% 53% 55% 56.76% 3154515-61.17% 182 176 213 110 I 286 238 330 358 211 306 119 174 174 125 120 64 358 323 524 504 532 336 426 183 55% 57% 53% I 57% I 53% I 50% 57% 54% 54% 59% 54% 57% I 42% 46% 68% 66% 54% 54% 59% 61.58% 65.01% 50.84% 65.94% 54.58% 65.48% 67.29% 62.80% 71.83% 65.03% 319-^517 = 61.70% 2884 442 = 65.16% 1824 351 = 51.85% 2134 351 = 60.68% 286 4 492 = 58.13% 330492 = 67.07% 358- 492 = 72.76% 2114 328 = 64.33% 306-^394 = 77.66% 119^324 = 36.73%02.13.-91 13:39 501 3762147 FRIDAY LAW FIRM @002.-004 KCR5CHCI, hj, FRiOAT, P.A O. 5 CLAftk POBEWT V. LICHT, P A WILLIAM H. CUJTTOM, P.A. aCQPQi E. PiKS. . JAMES SV. MQOflE evnoN M CISCMA jOe O. SELL. P A. M itHACL a. TMQMPSON. P.A. JOHN C. CCmOlS. P.A. JAMES A. OVTTRt. Pa HREQCR CK S. l'ASER''. P.A H T LARZELERE, P.A. FRIDAY, EXDHEOGE \u0026amp; CLARK A PARTNERSHIP Of IN0I710UALS AND PROFESSIONAL ASSOCIATJONS ATTORNCYS AT LAW 2000 FIRST COMMERCIAL eUlUDING 400 WliST CAPITQC t-ITTLE ROCK, ARKANSAS 72201-34,93 OAfiBV E COPL.N, B.J. RiCHAfta 3. TAV.OR, P. A JO9CP\u0026gt;1 O. HUBBT, TclcpmonC CtiZAaETh J. ROOBCN, P a. CHfciaroPrtEfl HE-uEft, P.A LAURA HClvSuer SMITH. P.A HOaeST . ShAFLK. b*. a WILLIAM M, GR|Rri4 111, P.A. THPMAS N. *6ae, P.A oacAft E c-AviS. . -AMgg C. CUAHK. R, \u0026gt;R . B. 301-376.OH MiCKACL s. OtANt\na. MACKCV AA,.TttM M. eSCL 1.1 HE VI * A. C BASS TmOmAS P. LtCOETT. P.A JOHN OtWEY WATSON, PA, LwiS MAT-)|S, P.A. Paul B BENHAM I.I, P.A. LAARTW aURKS.PA. A W*CKLlFr NtSeT. JK,, P.A .AMES COWARQ HaRR'S, *A - MIU-IP malCOm, P.A, JAMES M. SIM PSQN, P, A February 15, 1991 MCMCO Tirt  CAri,E f-.A BY FAX WluLIAM A. WADOfcLL, JR., P.A. clyoc \"tab Tunner C ALVI N , 5CQ-T W CBSV u I. lanCabtcr MALONC JAMES M CAXTQn.P. A J. SMSPUCRC RUSSELLI'i OOVAlO h BaCON. P.A. WILLIAM MOMAB BA.KTCR, P.A. WAUTCft A It, P A. Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 M. Oaylc CORLCV AO\u0026amp;CNT B. BCAJH, 3. RA^OOLPPI LOQNCT J LEE BROWN jAMcs C. BArtee,LR. H. Oaci-iw5p.0, JH. HARRV A LICHT SCOTT TLCKCR JOHN CLAYTON RANOOlPM MARV l.WiSCmAN ojy Alton waoe HR ICC. C. OAPDnlH THSHAS F mElKS J. M ichal hi crcna Mr. John Walker JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 Re: Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 3400 Capitol Towers Capitol \u0026amp; Broadway Little Rock, AR 72201 Mr. Richard Roachell MITCHELL \u0026amp; ROACHELL, P.A. 1014 West Third Little Rock, AR 72201 LRSD Renovation and Construction Projects Dear Counsel: The renova planned and commitments f seeking a st for the cons the continua- WILL Wil 1. COJASC. AM J. SMITH \u0026gt;AM A. CUCaCCipE, WILLIAM L. CPBV WlLLIAr L. PAT-QllJ, JR TC-SCOniin csQ.i c.ECOh cn lasii u u Hcr-r no 370^1506 i.on and construction projects described below pursuant to either th^ were ^^'ri-District Plan, the during the millage cam|5|b , or both. 1 will be ition concerning these s'cH^ls and court approval The construction projects at these schools, of the Central High School International Studies Program and the implementation of desegregation transfers at the elementary level within the Little Rock School District should be the only issues LRSD must seek to have resolved in advance of the submission of the modified settlement plan. \"ion. The following is a summary of the proposed renovation and construction projects: Woodruff Eleinentary: The Tri-District Plan (p. 8) states: Approximately two hundred students will be added to Woodruff's enrollment, which will require additional classroom space. which will require Some of these classrooms will be used for an early childhood education program. The school program.02 13 91 16:00 501 3762147 FRIDAY LAW FIRM @003 004 will also offer and Extended Day Program to attract children whose parents work in State government offices. A percentage of Woodruff's seats will be reserved to meet desegregation requirements. LRSD proposes to continue the renovation and expansion of Woodruff. The work at Woodruff will consist of adding five classrooms and expanding capacity from 209 to 344 (not counting the space for the four year old program). This expansion will require a slight enlargement of the Woodruff attendance zone, which will allow more Woodruff area students, most of whom are black, to attend a closer school. The expansion will also create the space necessary to recruit students whose parents work in nearby state government offices, and to balance the grade structure at Woodruff at two classes per grade (Woodruff presently has one class each at K-4, and two c sses each at grades 5 and 6). Western Hills Elementary: The Tri-District Plan (p. 8) states\nThe capacity of Western Hills will be expanded by 1991-92 to two hundred students, and its portables, which currently serve one hundred children, eliminated. LRSD does not propose to enlarge Western Hills Elementary (present capacity is 355, proposed is 358) but only to replace portable buildings with permanent classroom space. require any adjustment to attendance zones. The racial composition of Western Hills Elementary is expected to remain approximately 63% bitch.. There is no satellite attendance zone for Western Hills. This project will not black. Cloverdale Elementary and Junior High Schools: Plan (p. 8) states\nThe Tri-District The capacity of each school wiT approximately one hundred students. e increased by The project at the Cloverdale campus involves building a new cafeteria between the schools and renovating former cafeteria space into classrooms. In addition, a new classroom wing will be built at the junior high school so that portable classrooms can be eliminated. The capacity of Cloverdale Junior Hiah School win High will remain at 750. The capacity of Cloverdale Elementary will be increased from 464 to 492. This will allow LRSD to replace the present uneven grade structure (2 classes each at grades K, 1 and 6\n3 classes each at grades 2,3,4 and 5) with three classes per grade. The assignment zones for Cloverdale Junior High and Elementary will not change as a result of this project. ' There is no satellite zone for Cloverdale Elementary . The racial composition of the two schools (70% black at the junior high\n72% black at the elementary) is not expected to change a result of this project. as 02.-15 91 16:01 501 3762147 FRIDAY LAW FIRM @004'004 Geyer Springs Elementary\n____________ Except for Cloverdale Junior High and Western Hills, Geyer Springs has the highest concentration of portable buildings in the district. The renovation and expansion plan for Geyer springs calls for the replacement of portable classrooms with permanent construction, expansion of the kitchen, and the addition of sufficient classrooms so that the school can accommodate two classes each at grades K-6 and a new library. The capacity of Geyer Springs Elementary will be increased from 255 to 328. The racial composition of the school (71% black) is not expected to change as a result of this project, no satellite zones for Geyer Springs Elementary. There are The present imbalanced grade structure (2 classes each at grades K, 4 and 5\none each at grades 1,2,3 and 6) will be balanced at two classes per grade. Forest Heights Junior High: ________ The plan for Forest Heights Junior High School is to demolish most of the existing classrooms and to replace them with a new structure. by two architectural firms. This approach was recommend* Both fixrms reported that renovation the existing buildings would not be economical and would not sol the existing site problems such as drainage and supervision. new structure will house classrooms, The administrative area. The cafeteria, new library and a new gymnasium and vocational buildings (six classrooms) will remain intact but will undergo minor renovations. This project will replace thirty of the thirty-six existing classrooms and three portable classrooms with thirty-nine classrooms, for a net gain of six classrooms. These additional new classrooms are necessary to provide permanent classroom space to teachers who are now required to \"float\" a-nng classrooms which are empty during certain periods of the day day. ^nges in the number of students who attend Forest Heights Junior I School, the racial composition of those students (68% black/ and the attendance zone for Forest Heights Junior High School are not expected as a result of this construction. a These projects should have no detrimental effect on the implementation of our desegregation plan. The funds for these projects were budgeted following the successful millage campaign. Please let me know your position with respect to these proposals as soon as possible. I will be happy to provide any additional information you may need to assess these proposals. Yours very truly'. Christoph^'' feller CJH/k cc: 1 Dr. Ruth Steele Office of Desegregation Monitoring JOFFICE OF DESEGREGATION MONITORING 201 EAST MARKHAM, SUITE 510 HERITAGE WEST BUILDING LITTLE ROCK, AR 72201 Date: February 26, 1991 To: Chris Heller From: Ann Brown Subject: Questions Regarding Proposals for LRSD Construction I've gone over the proposals for building in the LRSD very carefully. Attached are the questions that have occured to me as I've thought it through and researched some data. If you'd like to talk it all over, just give me a call.Questions about Proposed LRSD Construction Woodruff Elementary\n1. First paragraph quotes approximately 200 students\nthe Tri-District Plan provision which would add 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. to 344, a difference of 135 seats. second paragraph says capacity will expand from 209 Which is the proposal, 200 or 135? If the proposal is for 135 new seats rather than 200, why this deviation from the Tri-District Plan provision (which was taken directly from LRSD's December 1, 1989 revised Preliminary Plan submission to the Metropolitan Supervisor?) Do we correctly understand that the proposed five new classrooms will house one each of K - 4th grade? If five classrooms are added, one each for K through 4, a maximum of only 123 students can be placed in these classes according to state standards, the other 12 seats for, early childhood? What are Are we to understand that the proposed early childhood education (ECE) program is for four-year-olds? How many ECE classes will there be? How many students in each? If capacity is expanded from 209 to 344 \"not counting the space for the four year old program\", what are the plans for ECE space? Do you propose to offer an Extended Day Program as provided in the Tri-District section quoted? If so, what will the proposed Extended Day Program entail (what and when for which students?) Are you also proposing to implement the quoted Tri-District provision which calls for a percentage of Woodruff's seats to be reserved to meet desegregation requirements? If so, what percentage, representing exactly how many seats, will be reserved? What will be the black/white percentage of these reserved seats? What is the plan and timeline for recruiting children whose parents work in state government offices? The recent FOCUS says that new students register February 26 - March 8, 1991. How will children of state government workers be assigned to Woodruff: M-to-M, Act 609, intradistrict desegregation transfer? LRSD represented to the Special Master that Woodruff could not be expanded because of state elementary building and playground standards. How is it now possible to expand the school without violating state regulations? Exactly how will the Woodruff attendance zone be enlarged and by how many students? How many students will have to change schools as a result of the zone change? attend!ng? How many of these students are black? What grade level are these students? -1- Which schools are they nowWestern Hills: 1. 2. How many portables are currently at the school and what classes/grades to they house? How long have portables been in use at the school, by year and by number of portable buildings? 3. How many Western Hills students reside in an attendance zone that is other than that of Western Hills? How many of these students are not in their zoned school because of controlled choice and subsequent grandfathering? How many of these students are at Western Hills because their zoned school is full (e.g., incentive school, etc.) an 4. How many students are eligible to leave Western Hills to return to an incentive school or area school? How many of these students are black? How and when wi11 you determine how many children will actually leave Western Hills to return to their zoned school? 5. If all the students who could leave Western Hills to return to their home zone school did so, what would the enrollment of Western Hills be? 6. What does demographic data indicate the enrollment of Western Hills will be when populated solely by children who live in the current attendance zonewithout redrawing linesa few years down the road when all grandfathered students are out of the school? Cloverdale Elementary and Junior High Schools: 1. The quoted Tri-District provision states that both schools will be expanded by about one hundred students each, a provision included in the Tri-District Plan from the December 1, 1989, LRSD revised Preliminary Plan\nyet expansion of only the elementary school is proposed, proposed? Why is expansion of the junior high not 2. How many students who live in the Cloverdale Junior High attendance zone presently must attend another junior high because of grandfathering or inadequate seating at Cloverdale? 3. How many portables are currently at the school? What classes do they house? 4. Will increasing the capacity of Cloverdale Elementary by 28 seats, rather than the 100 in the Tri-Di strict Plan (and the LRSD Dec. 1, 1991, revised Preliminary Plan,) provide adequate seating for the proposed three new classes (one each at K, 1 and 6?) At maximum state class size at these grade levels, as many as 73 students could be enrolled in these three classes. 5. Figures recently provided this office by LRSD Student Assignment indicate that the capacity of Cloverdale Elementary was 422 in 1989-90 (with an enrollment of 419)\n1990-91 capacity is 464 and enrollment 389. How was the capacity of the school enlarged by 42 seats between 89-90 snd 90-91? Why was the capacity enlarged when enrollment actually decreased by 30 students? -2-6. Where will the students for the new K and first grade classes come from? 7. How many Cloverdale Elementary students are grandfathered? assigned to the school because their home zone school is full? How many have been Geyer Springs Elementary: 1. How many portable buildings are presently at the school and what classes/grades do they house? 2. The Geyer Springs attendance zone does not appear to exhibit a growth pattern. As a matter of fact, capacity and enrollment figures indicate that the school has been underenrolled for some time. So why is the school slated for expansion? 3. The district proposes to expand capacity by 73 more seats and to add four more classes (which could contain as many as 103 students.) Are attendance zone changes proposed? classes come from? If not, where will the children who will populate these 4. Neither the Settlement nor Tri-District Plans (nor the preliminary desegregation plans submitted to CMS by LRSD) propose altering the capacity of Geyer Springs. Why is the district now proposing to expand Geyer Springs before addressing building which is provided for in the Settlement and Tri-District Plans? Fore^t^leights Junior High: 1. How will the total capacity of Forest Heights be changed by the proposed new additions? 2. Figures supplied this office by LRSD Student Assignment Office in January 1991, along with those taken from the Aerospace Magnet grant proposal, indicate that Forest Heights currently has a capacity of 780, with 754 students (69% black) enrol led. This means the school is at 97% capacity. (Figures more recently povided this office by James Jennings put enrollment at 772, 99% of capacity.) The aerospace grant proposal states, on page 121, that \"space is available in the designated junior high schools to house the number of students being projected.\" Your current proposal states that \"changes in the number of students who attend Forest Heights Junior High School, the racial composition of those students (68% black) and the attendance zone for Forest Heights Junior High School are not expected as a result of this construction.\" But the aerospace grant proposes to attract White students from North Little Rock and Pulaski County schools. (page 25.) How many M-to-M students are anticipated to participate in the magnet program? How many intradistrict transfers will be accepted into the program? What will the total capacity of the school need to be in order to accommodate these new students? What is the total projected enrollment, the magnet program projected enrollment, and the projected black/white ratio (both school and magnet program) as a result of the magnet program? -3-General: 1. What is the projected total cost of the building proposals? What portion of these building costs does LRSD propose to underwrite with desegregation monies? 2. How will these building plans affect the burden of busing on black children? 3. What does the district intend to do with the portable buildings that are removed from Western Hills, Geyer Springs, etc.? 4. In an Attendance Zone Report submitted to OMS on April 2, 1990, James Jennings states a problem which is recognized in both the Settlement and Tri-District Plans: \"The Little Rock School District currently uses 90% of its total non-magnet elementary capacity. The District has stated on several occasions that the elementary building capacity, particularly in central and east Little Rock, needs to be increased. The District's capacity problem is compounded by the fact that the interdistrict magnet program reduced the number of elementary seats available to Little Rock students. Gifted/Talented have caused a reduction in school capacity.\" Also, programs such as PAL and Both the Settlement and Tri-District Plans agree that building capacity in central and east Little Rock must be increased {as did the LRSD revised Preliminary Plans of December 1, 1989) and there is a timeline for doing so. There are provisions in the Settlement plan (page 30, LRSD Vol II) for 1990-91 to \"relocate Stephens Elementary near the 1-630 corridor between 1-30 and University Avenue.\" Also, \"to build a new King Elementary School in downtown Little Rock...in the general area along 1-630 between 1-30 and University Avenue.\" Over the past several months, this office has received reports and proposals from the LRSD which deal with expanding seating in central and east Little Rock. However, the proposal currently before the parties does not address the pressing need to expand capacity in the downtown area. When will there be firm plans to address it? How can the district expect the Court to approve building in the western part of the city when the district has made no move to fulfill its obligation to build in central/east Little Rock area? 5. The building proposal provides for some adjustment of attendance zones. The LRSD April 2, 1990, Attendance Zone Report states \"The elementary capacity must be addressed before attendance zones are adjusted. will Otherwise, any adjustments simply shift the current capacity problem from one school to another school.\" This same report states repeatedly that \"the plans to close and rebuild incentive schools should be finalized before attendance zones are adjusted.\" We agree that this a sensible approach. Why has the LRSD abandoned it? 6. The recent FOCUS (on page 7) states that \"Tuition-free programs for children who will be four years old on or before October 1, 1991, will be offered at Badgett, Franklin, Garland, Ish, Mitchell, Rightsell, Rockefeller, Stephens, Washington and Woodruff.\" When will plans for expanding Rightsell in order to accommodate the four-year-old program be submitted? How will Mitchell physically accommodate the four-year-old program it was to have implemented two years ago? -4-7. There are numerous indications (including capacity and enrollment figures, statements by LRSD Board members at public meetings, and newspaper articles) that LRSD is short on junior high capacity. The LRSD Settlement Plan (Vol I), on page 174, states that: \"The capacities of junior high schools will be reviewed in light of needed programs. Such capacities will then be revised as necessary. If upon review, it is determined that inadequate junior high capacity exists in the Di strict to meet programmatic need of the Di strict and/or intradistrict and M-to-M needs as they develop, then an adequate site will be located and planning will begin for the construction of a new junior high school.\" When will the district review the capacities of junior high schools? When wi11 there be a plan to assure that junior high students will not have to wait for a seat? 8. The district seems to be predicating much of its proposed construction on the Tri-District Plan provision that all portable buildings will be eliminated. Can we therefore expect the district to move to modify the LRSD Settlement Plan (Vol II, page 5) provision that \"every effort will be made to install portable buildings in order to accommodate overflow situations at a particular grade level?\" The provision of one plan to do away with portables contradicts the provision of another plan which justifies their use. -5-FRIDAY, ELDREDGE \u0026amp; CLARK HERSCHEL H. FRIDAY. P.A. B. S. CLARK A PARTNERSHIP OF INDIVIDUALS ANO PROFESSIONAL ASSOCIATIONS ROBERT U. LIGHT. P.A. WILLIAM H SUTTON. P. GEORGE E. PIKE. JR.. I JAMES W. MOORE attorneys at law p. 2000 FIRST COMMERCIAL BUILDING 6YHON M. EISEMAN, JR.. P.A JOE D. BELL. P.A. MICHAEL O. THOMPSON, P A. JOHN C. ECHOLS, P.A. JAMES A. BUTTRY. P.A, FREDERICK S. URSERY, P.A. AOO WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 Telephone SOi-376-2Oii LAURA HENSLEY SMITH. P.A. ROBERT S. SHAFER. P.A WILLIAM M. GRIFFIN III, P. A. THOMAS N. ROSE. P.A. MICHAELS, MOORE DIANE S. MACKEY WALTER M, EBEL III, P.A. KEVI N A. CRASS WILLIAM A. WADDELL. JR.. P. P CLYDE \"tab\" ThRNER H. T. LARZELERE. P.A. OSCAR E, DAVIS. JR. JAMES C. CLARK, JR.. THOMAS P. LEOOE''T. Fax No. 5OI-376-2IA7 p. JOHN DEWEY WATSON. P.A. LEWIS MATHIS. P.A. PAUL 8. BENHAM III, P.A. LARRY W. BURKS, P.A. A, WYCKLiFF NISBET, JR., P.A, JAMES EDWARD HARRIS. P.A, J. PHILLIP MALCOM, P.A. JAMES M. Simpson, p.a, MEREDITH P. CATLETT, P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL III DONALD H. BACON, P.A WILLIAM THOMAS BAXTER, P.A. February 25, 1991 WAI ER A. PAULSON II, P A. SCOTT J. LANCASTER JERRY L. MALONE M. GAYLE CORLEY ROBERT B. BEACH, JR. S. RANDOLPH LOONEY J. LEE BROWN JAMES C. BAKER, JR. H. CHARLES GSCHWENO, JR HARRY A. LIGHT SCOTT H. TUCKER JOHN CLAYTON RANDOLPH GUY ALTON WADE PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TON lA P. JOKES DAVID O. WILSON JEFFREY H. MOORE BARRY E. COPLIN, P.A. RICHARD O. TAYLOR, P.A. JOSEPH a. HURST. JR., ELIZABETH J. ROBBEN. P. \u0026gt; CHRISTOPHER HELLER. P. COUNSCL WILLIAM J. SMITH WILLIAM A. ELDREDGE. JR.. P a WILLIAM L. TCPRY WILLIAM L. PATTON, JR.. P.A. WRITCP'S OlPCCT NO. Mr. Sam Jones o'. Mr. Steve Jones 370-1506 WRIGHT, LINDSEY ii JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 JACK, LYON \u0026amp; JONES, P.A. 3400 Capitol Towers Capitol \u0026amp; Broadway Little Rock, AR 72201 Mr. John Walker Mr. Richard Roachell JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 MITCHELL \u0026amp; ROACHELL, P.A. 1014 West Third Little Rock, AR 72201 Re: Construction Issues Dear Counsel: Since I wrote you last there has been a slight modification of our plans for Forest Heights Junior High School. We intend to leave standing and to renovate an additional five classrooms which will be used to educate no more than forty handicapped students. Please let me know if you have any questions or concerns about this change or about our other construction proposals. As you know, the Philander Smith College Board rejected an LRSD proposal to locate a new interdistrict school on the campus. Since then, with John Walker's help, we have reached the point that Dr. Titus is willing to consider a modified proposal for an interdistrict school at Philander Smith. LRSD is also considering Westside as a possible interdistrict school site, but is not yetready to propose that to the parties. I would welcome any suggestions you may have concerning the possible location of the new Stephens and King schools within the area described in our desegregation plan. Yours very truly Christopher eller CJE/k cc: Dr. Ruth Steele Office of Desegregation MonitoringOFFICE OF DESEGREGATION MONITORING 201 EAST MARKHAM, SUITE 510 HERITAGE WEST BUILDING LITTLE ROCK, ARKANSAS 72201 PROGRESS REPORT ON NEW CONSTRUCTION March 4, 1991 Little Rock School District Woodruff Construction ongoingbeen there about a week- -ground work being done for foundations currently facility. no work being done inside the Western Hills Construction ongoingcurrently digging for foundationnothing currently inside facility Cloverdale Elem Construction ongoingground work being done for foundation of cafeteriacurrently no work being done inside the facility Cloverdale Jr. Construction ongoingground work being done for foundation of cafeteriacurrently no work being done inside the facility Geyer Springs - Construction ongoingground work being done for foundationsparking lot torn up- playground torn upsome work being done inside buildingin six of seven classroom no heat, no ceiling and lighting reduced. Forest Heights Junior High - Currently no construction startedsurveying and meeting with principal0 3 Z 0 6 z 1 9 9 1 1 1 ! 3 ? FROM JOHN W.WALKER P.fi. TO 3710100 P .02 MEMORANDUM to\nMR. JOHN W. WALKER FROM\nMR. KIRK HERMAN MRS. JOY CHARLES-SPRINGER re\nLRSD V. PCSSD - New Construction within the LRSD date\nMARCH 5, 1991 On site visits to four elementary schools (Geyer Springs, Cloverdale, Woodruff, and Western Hills) within the Little Rock District revealed substantial construction underway. Over 5.5 million dollars has been budgeted to effectuate changes in the present structures that were visited. Changes range from construction of additional classrooms, new playgrounds, parking lots. and cafeterias. Construction at all sites has been tentatively set for completion by the beginning of the new school year, August, 1991. Mr. Herman visited Woodruff and Western Hills. I visited Cloverdale and Geyer Springs, as follows: Our findings at the locations were CLOVERDALE ELEMENTARY Principal: Sadie Mitchell (black female) Current Student capacity: 400 students 75% black 25% white Current number of classrooms: 15 After construction the school will have \"21\" classrooms (3 sections each of K-6) The construction will consist of ng II additional classrooms, a new playground, office, nurses station and a cafeteria to be shared with Cloverdale Jr. High School. Final students student capacity (after construction): 492 I 1 I03/06Z1991 11!3S FROM JOHN U.UflLKER P.fl. TO 3710100 P. 03 I i I i I 1 PAGE TWO March 5, 1991 The only portable building at Cloverdale Elementary is the music room. Cloverdale Jr. High has several portablej, The budget between Cloverdale Elementary and Jr. High is approximately 2 1/2 million dollars. GEYER SPRINGS ELEMSMTARY Principal: Eleanor Cox (black female) Current student capacity: 200 students 76% black 24% white Current number of classrooms: 9 After construction, the school will have \"2 3 classrooms. The construction will consist of 14\" new classrooms, a new playground and a new parking lot. Final student capacity: 400 Anticipated capacity next school year\n326 There are currently 8 portable buildings that house the intermediate classes. There is also classroom sharing at Geyer Springs. The budget for Geyer Springs construction has been set at 1 1/2 million dollars. WESTERN HILLS ELEMENTARY Principal\nMargie Puckett (white female) Current student capacity: 336 students 63.7% black 35.3% white .5% other The construction will consist of \"10\" additional classrooms. II 03x06/1991 11:39 FROM JOHN U.WALKER P.fl. PAGE THREE March 5, 1991 TO 3710100 P . 04 There are currently 6 portable buildings that house classes at Western Hills. The budget for Western Hills has been set at 1 million dollars. WOOPRPPg ELEMENTARY Principal\nPat Higginbotham (white female) Current student capacity: unknown 80% black 20% white The construction will consist of expansion of the cafeteria. 10' new classrooms and There are no portable buildings that house classes at Woodruff. The budget for Woodruff has been set between $800,000 and 1 million dollars. Please let us know if additional information is needed. I 1 I I I 1 J I i iI  - . 03/05/1991 10:12 FROM JOHN U.WALKER P.A JOHN W. WALKER RALPH WASHEsGTON MARK Bt 'RNETTE WOLEy A. BRANTON, JR. 'Afcw a^niUffd to Prartwc in Gcongi. A tfin bbuk-t yC Cohmb-n. DELIVERED VIA FAX Ms. Anna Brown Ms. Arma Hart TO 3710100 P. 02 John W. W/kLKER. P.A. ArroRNEl AT Law 1723 Broadway Litti.e Rock. Arkansas vzaje Telephone (501) -iTi-aT.ss FAX (501) 3744187 March 5, 1991 \u0026lt; Office of Desegregation Monitoring _201 East Markham Little Rock, AR 72201 Dear Ms. Brown and Ms. Hart: Would ionformation you kindly advise me whether , _ regarding construction which xt.^xu capacities in certain Little Rock School buildings? Mr. Chris Heller advises only normal maintenance - ---------is occurring. checking into this at once. LAZAR M. iALNTCK LAW  FINANCE BLDG. SLTTE 1\u0026lt;X'2 429 FOURTH AVENUE PITTSBLIRGH, PA 15219 (412) 2S8-9220 you have additional includes enlarging me that this is not happening and I would appreciate your into this matter and By copy of this letter to Mr, Heller, I am he look call me today if after he has received reply to this inquiry. I also asking that at all possible, With best regards, Z-----\\ 1 I cc: Mr. Chris Heller Ukii At J^n W. Walker Walker M TOTAL P.02I I 03/05/1991 10:12 FROM JOHN Id. WALKER P.A. TO 3710100 P. 02 JOHN W. WALKER RALPH WASHINGTON- MARK BURNETTE WILEY A. BRANTON, JR. * AWi\u0026gt; s'4a7niUed tc Practice in GcorgiA Oi*} Liislrit. 'jI Coh DELIVERED VIA FAX John w. Walker, P.a. Attornet At Law 1723 Broadway Lrrn.E RocK. Arkansa,s 7221)6 Tei,ephone (501) 374-3758 FAX (501) 3744187 March 5, 1991 Ms. Anna Brown Ms. Arma Hart Office of Desegregation Monitoring 201 East Markham Little Rock, AR 72201 Dear Ms. Brown and Ms. Hart\nWould ionformation regaraing construction which includes capacities in certain Little Rock School buildings? you kindly advise regarding me construction whether which LAZAR M. PALNICK LAW \u0026amp; FINANCE BLDG SUITE 1\u0026lt;X\u0026gt;2 429 FOURTH AVENUE Pm^BURGH. PA 15219 (412) 2SS-9220 you have additional enlarging Mr. Chris Heller advis only normal maintenance is checking into this at once. es me that this is occurring. not happening and I would appreciate your By copy of this letter to Mr. -----\"* into this matter and after he has received he look Heller, I am call me today if reply to this inquiry. also asking that at all possible, cc: Mr. Chris Heller With best regards, W. Walker M03/06/1991 11:37 FROM JOHN U.WALKER P.P. TO 3710100 P .02 MEMORANDUM I I I I ! I to\nFROM: re: date\nOn site MR. JOHN W. WALKER MR. KIRK HERMAN MRS. JOY CHARLES-SPRINGER LRSD V. PCSSD - New Construction within the LRSD MARCS 5/ 1991 visits to four elementary schools (Geyer Springs, Cloverdale, Woodruff, and Western Hills) within the Little Rock District revealed substantial construction underway. Over 5.5 million dollars has been budgeted to effectuate changes in the present structures that were visited. Changes range from construction of additional classrooms, new playgrounds, parking lots, and cafeterias. Construction at all sites has been tentatively set for completion by the beginning of the new school year. August, 1991. Mr. Herman visited Woodruff and Western Hills. Cloverdale and Geyer Springs, as follows: Principal: I visited Our findings at the locations were CLOVERDALE ELEMENTARY Sadie Mitchell (black female) Current Student capacity: 400 students 75% black 25% white Current number of classrooms: 15 After construction the school will have \"21 classrooms (3 sections each of K-6) The construction will consist of i5ir additional classrooms, a new playground, office, nurses station and a cafeteria to be shared with Cloverdale Jr. High School. Final students student capacity (after construction): 49203/'06zl991 11:33 FROM JOHN U.UflLKER P.O. TO 3710100 P . 03 PAGE TWO March 5, 1991 The only portable building at Cloverdale Elementary is the music room. cloverdale Jr. High has several Cloverdale Jr, portable^, The budget between Cloverdale Elementary and Jr. High is approximately 2 1/2 million dollars. GEYER SPRINGS ELEHSMTARY Principal: Eleanor Cox (black female) Current student capacity: 200 students 76% black 24% white Current number of classrooms: 9 After construction, the school will have 23\" classrooms. The construction will consist of \"14\" new classrooms, new playground and a new parking lot. a Final student capacity: 400 Anticipated capacity next school year: 326 There are currently 8 portable buildings that house the intermediate classes. Geyer Springs. There is also classroom sharing at The budget for Geyer Springs' construction has been set at 1 1/2 million dollars. WESTERN HILLS ELEMENTARY Principal: IF Margie Puckett (white female) Current student capacity: 336 students 63.7% black 35.8% white ,5% other The construction will consist of \"10\" classrooms. additional03/0BZ1991 11:39 FROM JOHN UI.UflLKER P.R. TO 3710100 P. 04 PAGE THREE March 5, 1991 There are currently 6 portable buildings that house classes at Western Hills. The budget for Western Hills has been set at 1 million dollars. ffOOPRPPP ELEMEMTARY principal: Pat Higginbotham (white female) Current student capacity: unknown 80% black 20% white The construction will consist of 10 new classrooms and expansion of the cafeteria. There are no portable buildings that house classes at Woodruff. The budget for Woodruff has been set between $800,000 and 1 million dollars. Please let us know if additional information is needed.John w. Walker, p.a. Attorney At Law 1723 Broadway Little Rcxk, Arkansas 72206 Telephone (501) 374-37.58 FAX (501) 374-4187 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE 'WILEY A. BRANTON, JR. AIm admitted to Practice in Georgia \u0026amp; the District of Columbia. March 5, 1991 LAZAR M. PALNICK LAW \u0026amp; FINANCE BLDG. SUITE 1002 429 FOURTH AVENUE PITTSBURGH, PA 15219 (412) 288-9220 DELIVERED VIA FAX Ms. Anna Brown Ms. Arma Hart Office of Desegregation Monitoring 201 East Markham Little Rock, AR 72201 Dear Ms. Brown and Ms. Hart: Would ionformation you kindly advise me whether regarding construction which you have includes capacities in certain Little Rock School buildings? additional enlarging Mr. Chris Heller advises only normal maintenance me that this is not happening and checking into this at once. is occurring. I would appreciate your he look By copy of this letter to Mr. Heller, I am into this matter and call me today if after he has received reply to this inquiry. also asking that at all possible. With best regards, J Ignn W. Walker cc: Mr. Chris HellerLRSD CONSTRUCTION PROPOSALS As a backdrop to the current LRSD construction proposals, it will be helpful to keep in mind that the LRSD (and to a somewhat lesser extent, NLRSD and PCSSD) has repeatedly found itself in difficulties with desegregation efforts from the \"domino effect\" resulting from failure to thoroughly think through, evaluate, and learn from the following: 1. Cause and effect: All of the districts persist in tunnel vision and short sightedness, but LRSD is the worst of the lot. These \"eye problems\" frequently prevent the districts from recognizing that there may be several diverse factorsnot just one or twowhich work together to create a certain situation. They also have difficulty identifying the potential multiple effects that may ensue as a result of one course of action or another. They repeatedly fail to anticipate all sorts of things: the short and long tern consequences of decisions, changing scenarios, altered needs, etc. Neither do they seem to learn much from the history of their mistakes or their successes. 2. Broad scale and long term context and impact: The desegregation plans and programs are not something \"over there\", somehow separate from the normal, day to day business of delivering educational services to kids. Rather, desegregation is a part of the definition and means of how those services are delivered to all of the children. Anything done in a school district, either programmatically or operationally, invariably has an impact on desegregation because desegregation means the integration not just of bodies, but of ideas, programs, operations, and opportunities. This is the substance of true equity. 3. For every action there is a reaction: The desegregation plan must not be viewed as a disjointed, non-related series of stand-alone sections. What happens as one part of the plan is implemented {one program, one operation, one construction project) invariably impacts what's happening elsewhere in the district (and often in the other districts as well.) Each plan, program, and action must be seen in the context of the whole and as part of an action and time continuum, piece in place, changes. The puzzle (desegregation plan) is not complete without each Remove or distort just one puzzle part, and the whole picture 4. Responsibility: Each school district is ultimately responsible for the effective implementation of its desegregation plan. Placing blame or even giving credit to some external force obscures the fact that what happens in each district is the full responsibility of that district, make them do it! The devi1 did not 5. The LRSD does not seem to recognize the importance of good faith. The district has not been able to build trust with either the Court nor the community because of lies. mi stakes, broken promises. inconsistent and arbitrary actions, and frequent changes without any indication of the \"why\" of the changes. The old saw \"It's easier to get forgiveness than permission\" is not going to work, even in the cases where it might be appropriate, if there is no foundation of trust and a clear record of good faith action. What i s the LRSD doing to build a relationship with the Court and community which clearly demonstrates the district's good faith?Summary: A. Each decision must be considered in the context of the entire desegregation plan, keeping in mind the interrelatedness of the sections, the immediate and future impact of any action, and how one district's actions affects another. Think big picture and long term. B. Desegregation wholi Stic, involving and impacting all students. Desegregation plans are integral to how each district educates ALL its students. Education is describednot dichotomizedby a desegregation plan. C. Each district is responsible for the successful implementation of its desegregation plan. i s D. A record of consistently acting in good faith as well as in accordance with the provisions of desegregation plans is basic to eventually achieving unitary status.AS \"^^Ut/J)\" Questions about Proposed LRSD Construction Woodruff Elementary: 1. First paragraph, quotes the Tri-District Plan provision which would add approximately 200 students\nsecond paragraph says capacity will expand from 209 to 344, a difference of 135 seats. Which is the proposal, 200 or 135? 2. If the proposal is for 135 new seats rather than 200, why this deviation from the Tri-District Plan provision (which was taken directly from LRSD's December 1, Supervisor?) 1989 revised Preliminary Plan submission to the Metropolitan 3.Do we correctly understand that the proposed five new classrooms will house one each of K 4th grade? 4.If five classrooms are added, one each for K through 4, 123 students can be placed in these classes according to What are the other 12 seats for, early childhood? a maximum of only state standards. 5. Are we to understand that the proposed early childhood education (ECE) program is for four-year-olds? 6. How many ECE classes will there be? How many students in each? 7.If capacity is expanded from 209 to 344 \"not counting the space for the four year old program\", what are the plans for ECE space? 8. Do you propose to offer an Extended Day Program as provided in the Tri- District section quoted? If so, what will the proposed Extended Day Program entail (what and when for which students?) 9.Are you also proposing to implement the quoted Tri-District provision which calls for percentage of Woodruf f's seats to be desegregation requirements? reserved to meet many seats. will be reserved? If so, what percentage, representing exactly how these reserved seats? What will be the black/white percentage of 10.What is the plan and timeline for recruiting children whose parents work in state government offices? February 26 March 8, 1991. The recent FOCUS says that new students register 11.How will children of state government workers be assigned to Woodruff: M- to-M, Act 609, intradistrict desegregation transfer? 12.LRSD represented to the Special Master that Woodruff could not be expanded because of state elementary building and playground standards. possible to expand the school without violating state regulations? How is it now 13.Exactly how will the Woodruff attendance zone be enlarged and by how many students? zone change? now attending? How many students will have to change schools as a result of the How many of these students are black? What grade level are these students? Which schools are they aWestern Hills: l.How many portables are currently at the school and what classes/grades to they house? 2. How long have portables been in use at the school, by year and by number of portable buildings? 3.How many Western Hills students reside in an attendance zone that is other than that of Western Hills? How many of these students are not in their zoned school because of controlled choice and subsequent grandfathering? How many of these students are at Western Hills because their zoned school is full (e.g., incentive school, etc.) an 4.How many students are eligible to leave Western Hills to return to an incentive school or area school? How many of these students are black? How and when will you determine how many children will actually leave Western Hills to return to their zoned school? 5. If all the students who could leave Western Hills to return to their home zone school did so, what would the enrollment of Western Hills be? 6.What does demographic data indicate the enrollment of Western Hills will be when populated solely by children who live in the current attendance zone-- without redrawing lines--a few years down the road when all grandfathered students are out of the school? Cloverdale Elementary and Junior High Schools: l.The quoted Tri-District provision states that both schools will be expanded by about one hundred students each, a provision included in the Tri-District Plan from the December 1, 1989, LRSD revised Preliminary Plan\nyet expansion of only the elementary school is proposed, proposed? Why is expansion of the junior high not 2.How many students who live in the Cloverdale Junior High attendance zone presently must attend another junior high because of grandfathering or inadequate seating at Cloverdale? 3.How many portables are currently at the school? What classes do they house? 4.Will increasing the capacity of Cloverdale Elementary by 28 seats, rather than the 100 in the Tri-District Plan (and the LRSD Dec. 1, 1991, revised Preliminary Plan,) provide adequate seating for the proposed three new classes (one each at K, 1 and 6?) At maximum state class size at these grade levels. students could be enrolled in these three classes. as many as 73 5.Figures recently provided this office by LRSD Student Assignment indicate that the capacity of Cloverdale Elementary was 422 in 1989-90 (with an enrollment of 419)\n1990-91 capacity is 464 and enrollment 389. school enlarged by 42 seats between 89-90 and 90-91? How was the capacity of the enlarged when enrollment actually decreased by 30 students? Why was the capacity 6.Where will the students for the new K and first grade classes come from? 7.How many Cloverdale Elementary students are grandfathered? assigned to the school because their home zone school is full? How many have been Gever Springs Elementary: l.How many portable buildings are presently at the school and what classes/grades do they house? 2.The Geyer Springs attendance zone does not appear to exhibit a growth pattern. As a matter of fact, capacity and enrollment figures indicate that the school has been underenrolled for some time. So why is the school slated for expansion? 3.The district proposes to expand capacity by 73 more seats and to add four more classes (which could contain as many as 103 students.) changes proposed? classes come from? Are attendance zone If not, where will the children who will populate these4.Neither the Settlement nor Tri-District Plans (nor the preliminary desegregation plans submitted to OMS by LRSD) propose altering the capacity of Geyer Springs. Why is the district now proposing to expand Geyer Springs before addressing building which is provided for in the Settlement and Tri-District Plans? Forest Heights Junior High: l.How will the total capacity of Forest Heights be changed by the proposed new additions? 2.Figures supplied this office by LRSD Student Assignment Office in January 1991, along with those taken from the Aerospace Magnet grant proposal, indicate that Forest Heights currently has a capacity of 780, with 754 students (69% black) enrolled. This means the school is at 97% capacity. (Figures more recently provided this office by James Jennings put enrollment at 772, 99% of capacity.) The aerospace grant proposal states, on page 121, that \"space is available in the designated junior high schools to house the number of students being projected.\" Your current proposal states that \"changes in the number of students who attend Forest Heights Junior High School, the racial composition of those students (68% black) and the attendance zone for Forest Heights Junior High School are not expected as a result of this construction.\" But the aerospace grant proposes to \"attract White students from North Little Rock and Pulaski County schools.\" (page 25.) magnet program? How many M-to-M students are anticipated to participate in the program? How many intradistrict transfers will be accepted into the What will the total capacity of the school need to be in order to accommodate these new students? What is the total projected enrollment, the magnet program projected enrollment, and the projected black/white ratio (both school and magnet program) as a result of the magnet program?General\n1. What is the projected total cost of the building proposals? What portion of these building costs does LRSD propose to underwrite with desegregation monies? 2. How will these building plans affect the burden of busing on black children? 3.What does the district intend to do with the portable buildings that are removed from Western Hills, Geyer Springs, etc.? 4.In an Attendance Zone Report submitted to OMS on April 2, 1990, James Jennings states a problem which is recognized in both the Settlement and Tri-District Plans: \"The Little Rock School District currently uses 90% of its total non-magnet elementary capacity. The District has stated on several occasions that the elementary building capacity, particularly in central and east Little Rock, needs to be increased. The District's capacity problem is compounded by the fact that the interdistrict magnet program reduced the number of elementary seats available to Little Rock students. Also, Gifted/Talented have caused a reduction in school capacity.\" programs such as PAL and Both the Settlement and Tri-District Plans agree that building capacity in central and east Little Rock must be increased (as did the LRSD revised Preliminary Plans of December 1, 1989) and there is a timeline for doing so. There are provisions in the Settlement plan (page 30, LRSD Vol II) for 1990-91 to \"relocate Stephens Elementary near the 1-630 corridor between 1-30 and University Avenue.\" Also, \"to build a new King Elementary School in downtown Little Rock...in the general area along 1-630 between 1-30 and University Avenue.\" Over the past several months, this office has received reports and proposals from the LRSD which deal with expanding seating in central and east Little Rock. However, the proposal currently before the parties does not address the pressing need to expand capacity in the downtown area. When will there be firm plans to address it? How can the district expect the Court to approve building in the western part of the city when the district has made no move to fulfill its obligation to build in central/east Little Rock area? 5.The building proposal provides for some adjustment of attendance zones. The LRSD April 2, 1990, Attendance Zone Report states \"The elementary capacity must be addressed before attendance zones are adjusted. Otherwise, any adjustments will simply shift the current capacity problem from one school to another school.\" This same report states repeatedly that \"the plans to close and rebuild incentive schools should be finalized before attendance zones are adjusted.\" agree that this a sensible approach. Why has the LRSD abandoned it? We 6.The recent FOCUS (on page 7) states that \"Tuition-free programs for children who will be four years old on or before October 1, 1991, will be offered at Badgett, Franklin, Garland, Washington and Woodruff.\" Ish, Mitchell, Rightsell, Rockefeller, Stephens, accommodate the four-year-old program be submitted? When will plans for expanding Rightsell in order to How will Mitchell physically accommodate the four-year-old program it was to have implemented two years ago? 7.There are numerous indications (including capacity and enrollment figures, statements by LRSD Board members at public meetings, and newspaper articles) that LRSD is short on junior high capacity. The LRSD Settlement Plan (Vol I), on page 174, states that: \"The capacities of junior high schools will be reviewed in light of needed programs. Such capacities will then be revised as necessary. If upon review. it is determined that inadequate junior high capacity exists in the District to meet programmatic need of the District and/or intradistrict and M-to-M needs as they develop, then an adequate site will be located and planning will begin for the construction of a new junior high school.\" When will the district review the capacities of junior high schools? When will there be a plan to assure that junior high students will not have to wait for a seat? 8.The district seems to be predicating much of its proposed construction on the Tri-District Plan provision that all portable buildings will be eliminated. Can we therefore expect the district to move to modify the LRSD Settlement Plan (Vol II, page 5) provision that \"every effort will be made to install portable buildings in order to accommodate overflow situations at a particular gradelevel?\" The provision of one plan to do away with portables contradicts the provision of another plan which justifies their use.03/06/91 16:02 301 374 7609 L R School Dlst ODM 0002/002 LITTLE ROCK SCHOOL DISTRICT 810 WEST MARKHAM STREET LITTLE ROCK, AR 72201 March 6, 1991 TO: Chris Heller, Attorney FROM: (^jZChip Jones, Manager of Support Services SUBJECT: Incentive School Facility Improvements The following summarizes renovations at the incentive schools during the last three years: Mitchell $115,000 Renovations including air conditioning, carpeting, and playground equipment Franklin 1,330,000 Classroom addition, cafeteria remodeling, and furniture Rockefeller 176,000 Re-roofing, minor renovation Ricfhtsell 178,000 Air conditioning, re-roofing, classroom conversion, painting Stephens 63,000 Air conditioning, painting, carpeting Ish 135,000 Renovation, re-roofing, playground equipment addition. for additional renovations at the inventive schools in the amount of $180,000. funds are currently budgeted cc: James JenningsTO: FROM: RE: Little Rock School District 810 West Markham Little Rock, AR 72207 March 6, 1991 Ruth Steele, Superintendent Herb Cleek, Deputy Superintendent ip Jones, Manager of Support Services Status of Construction Projects Cloverdale Elementary/junior High: Architect: Contract signed: Bid Advertisement: Bid Opening: General Contractor: Contract signed: Status: Sims, Grisham, Blair May 8, 1990 December 5, 1990 December 28, 1990 Carson \u0026amp; Associates January 3, 1991 100 mobilized, fencing, poured piers. Contract Price: some demolition and excavation, underslab plumbing, some foundation forms set. $2,677,000 Western Hills: Architect: Contract signed: Bid Advertisement Bid Opening General Contractor Contract signed: Status: Roark, Perkins, \u0026amp; Perry July 23, 1990 December 5, 1990 December 19, 1990 NLR Plumbing and General Contractors January 2, 1991 Site utilities in portable building, 50 place. relocated 30% excavation. site demolition. foundations formed and Contract price: pouring foundations in progress. $1,005,400 Woodruff: Architect: Contract signed: Bid Advertisement: Bid Opening: General Contractor: Contract signed: Status: Contract price: Witsell, Evans, \u0026amp; Rasco July 10, 1990 January 6, 1991 January 24, 1991 Wilkins Construction Co. January 28, 1991 100% mobilized, demolition and excavation 50% complete, mechanical 2% complete. $749,711Building Status Report Page 2 Gever Springs: Architect: Contract signed: Bid Advertisement: Bid Opening: General Contractor: Status: Dan Stowers July 25, 1990 January 13, 1991 January 30, 1991 Kulander Construction Mobilized, demolition has begun inside and outside, utilities Contract price: istration relocated. $1,760,000 relocated, admin- Professional Development Center and Southwest Junior High: Architect: Contract signed: Status: Wittenberg, Deloney, and Davidson August 13, 1990 Finalizing programs and developing working drawings. Forest Heights Junior High: Architect: Contract signed: Status: Polk, Stanley, \u0026amp; Associates November 27, 1990 Finalizing programs and developing working drawings. New Incentive/Interdistrict School: Architect: Contract signed: Status: Blass, Chilcote, Carter Informal Agreement Preparing drawings for prospective sites. buiIplan.wpdDate\nMarch 5, 1991 To: Susan Webber Wright From: Ann Brown Subject: LRSD Proposals for School Construction Attached is a copy of a list of questions which I've sent to Chris Heller. Chris had asked me to review the LRSD proposals for new construction and let him know what questions or concerns I had. Here's a summary of my overall observations and concerns about the LRSD proposal. 1. Separate provisions from the Tri-District and Settlement Plans are being crossedor interwoven with entirely new provisionsinto what is essentially a hybrid, third plan. These building proposals seem to be something other than an attempt to find an \"appropriate fit\" between the two plans: some provisions represent an entirely new proposal\n,Others constitute a retreat from the more stringent provisions of the Tri-District Plan without completely returning to the essentially more modest provisions of the Settlement Plan. This cut-and-paste approach is resulting in some strange mosaics. For example, in some instances, part of a sentence from one plan is being spliced to an entirely new concept that exists neither in the Tri-District nor Settlement Plans. do one half of the sentence but not the other. Another time, they want to proposals are in neither one of the plans and are, completely new. Some of the therefore, I'm not suggesting that every bit of the intermixing is yielding an undesirable or unreasonable proposal or concept, but it does leave us to wonder why the plans are being crossed when there's not an apparent reason for it\nthat is, there's nothing in the quoted Tri-District provisions that have actually been started because of court orders and therefore now need to be melded into the Settlement Plans so they can continue \"in order to make a smooth transition\" as the Circuit Court has provided. Did the Court intend for the districts to wind between the Settlement and Tri-District Plans, clipping and twisting and occasionally introducing an entirely new thread, thereby weaving the fiber of a new plan? I think not. My interpretation of their opinion is that the Court acknowledges the need to find a sensible, workable bridge between the two plans in those instances where differences between them require a mechanism to assure a \"smooth transition\" from one to the other. So, the Court has wisely provided for \"the details of the settlement plans to be adjusted.\" Surely the word \"details\" is significant, especially in conjunction with the word \"adjusted, \" putting one in mind of attuning minor items or parts rather than rewriting for the purpose of altering a previous condition or requirement. If the parties are going to continue to pick and choose parts of the provisions of the two plans, occasionally tossing entirely strands onto the loom, the result may be a tangled Gordian knot rather than a smoothly interwoven transitional fabric.(By the way, in publications which are currently being distributed to parents, I also see this unraveling and reweaving happening in other areas of the two plans besides these construction proposals. The Rockefeller Early Childhood Education Magnet Program is a prime example.) Illustrations of the hybridization in the building proposals: (a) At Woodruff Elementary, the Settlement Plan calls for Woodruff to be closed. The Tri-District Plan calls for Woodruff to not only remain open but to add approximately two hundred students to the school's enrollment. however. The LRSD doesn't want to go quite that far, Their building proposal calls for adding 135 seats. Although current enrollment and capacity figures indicate that Woodruff is presently 23 students short of capacity, the 135 new seats added to the 23 that are presently vacant equals only 158 seats , District. still 42 seats short of the 200 proposed in the Tri( b) The Settlement Plan makes no special provisions for Western Hills Elementary but the Tri-District Plan calls for it to be expanded by 200 seats and for the portables which house 100 kids to be eliminated. sentence, but not the first part. The LRSD proposal is to do the last part of the (c) Cloverdale Elementary and Junior High Schools are not slated for expansion in the Settlement Plan but are to be expanded by about 100 students each in the Tri-District Plan. The LRSD proposal will do part of the sentence: Junior High at all (amazing since the district is it won't expand Cloverdale so short on junior high space) but it will expand Cloverdale Elementary, but only by 28 seats. (d) Geyer Springs Elementary is not slated for expansion in either the Settlement Plan or Tri-District Plans but the LRSD wants to make it bigger by 73 seats. However, both plans do impact the school in that they call for the elimination of portable buildings and Geyer Springs has a bunch of those. (e) Neither of the plans call for building at Forest Heights. The school facility is very much in need of improvement and the district has the right as well as the responsibility to provide an environment conducive Heights, located at to learning. Evergreen and However, ] University redoing Forest in white neighborhood, certainly should not be a priority implemented before building the schools in the downtown (black) area that are mandated by both plans. 2. There is no excuse for Heller waiting until now. after construction contracts have been signedand construction begun on every one of these schools except Forest Heightsto seek approval of school construction. 6) states: \"VII. The Interdistrict Settlement Plan (page Further School Construction: All school construction shall be subject to the court's prior approval and shall promote desegregation.\" Maybe the context of this provision would indicate that it's really about the construction of new schools\nbut it does say \"all\" and not \"new\". In any event, even Chris Heller told me he thought these building proposals needed to come before the Court. Chris said he didn't know that the LRSD had a entered into building contracts, but I sure wonder why: attachedis a memo from Chip Jones to James Jennings which we received as part of Jennings' October 1990 report to his board. states construction is on the way. It clearly The newspapers also knew about it and covered it in at least two stories (attached.) John Walker had told him of the articles only recently. Chris said 3. LRSD is trying to slip expanding western school capacity past the Court in various guises, replacing portable buildings being the favorite. The LRSD knows better than to try the capacity ploys\nthey've been severely reprimanded by both the Court and Gene Reville for it. As a matter of fact, all of the districts know that portables are a real touchy subject\nthat's why PCSSD just sent a memo to us begging to be allowed one portable at an elementary school to house some staff. PCSSD doesn't want to risk the displeasure of the Court over the old portable issuesits hands have been smacked before. a new Court not knowing the old tricks. But it seems LRSD is counting on The LRSD capacity figures on any one school change faster than a chameleonand always to suit the need of the moment. LRSD has shamelessly expanded schools in white parts of town while doing little or nothing to add seating in the central and eastern part of the city, even though both the Settlement and Tri-District Plans specifically address the need to increase downtown capacity. This is why the burden of busing remains on black kids. What the words \"build\" and \"replace\" often really mean is increasing the size of schools, especially in white neighborhoods. 4. The next thing that may happen is LRSD may want to increase the capacity of the incentive schools by moving the portables to them (as Dr. Steele has said in a t.v. interview but not in writing.) This could result in many black children being transferred out of the white neighborhood schools and back to the central/east side. A lot of black kids in central and east Little Rock had to be reassigned out of their attendance zone to schools in the west. (These reassignments are because of the old controlled choice assignment plan, or because magnets displaced them, or the children didn't apply or didn't get accepted to a magnet. or because incentive schools were full.) But the grandfathering that is in the Settlement Plan (and, at LRSD's insistence, also in the Tri- District Plan) guarantees that those youngsters who have been reassigned out of their attendance zone have the right to remain in the school they were reassigned to. Moving kids back and forth between schools is, of course, traumatic for the children and so isn't usually in their best interest. 5. The Interdistrict Settlement Plan states on page 7: Quality\n\"Building An aim of the plan shall be to ensure for all students equal educational facilities. Schools which are located in lower socio-economic areas shall receive attention and resources at least equal to those in more affluent areas in respective districts. n If portable buildings aren't good enough for schools in the western part of town, they aren't good enough for kids in the downtown area either. 6. It is important to note what the two plans have to say about portable buildings. itself. The Settlement Plan essentially contradicts One of its provisions (LRSD Plan, Vol II, Page 5) says that \"every effort will be made to install portable buildings in order to accommodate overflow situations at a particular gradelevel\" but it also says (on page 174 of the same document) \"Any school which has portable buildings will have these portables replaced with new units or repaired such that they will be in a condition suitable to housing a class and provide a positive environment for learning.\" However, knowing how portables can be used to play the capacity game, the Tri-District plan has little patience with trailers and banishes them all within five years: (on page 8 of the Area Schools section) \"All portable buildings will be eliminated over a five-year period beginning in 1990-91. n 7. other points about capacity: A. There are twice as many students as capacity in the schools in central and east Little Rock. of busing falls more heavily on black children. This is the main reason the burden B. Main causes of lower capacity in central/east Little Rock: older buildings are smaller so hold fewer kids\n(1) (2) downtown magnets can displace as much as 80% of the neighborhood kids who would normally attend them\n(3) a few schools in the downtown area have been closed, some of them for many years (Kramer, East Side, West Side, Lee, Gillam, King to name the ones that come to mind.) Not all of these schools were replaced with downtown buildings. 3. Grandfathering (found in the Settlement Plan and, much to Mr. Reville's chagrin, also the Tri-District Plan) has had a lot to do with the capacity issue. Under the old controlled choice assignment plan, downtown kids who couldn't get into a magnet because their number didn't come up or couldn't get into an incentive school because there wasn't room had to be bused to a westerly school. schools like Western Hills. This is when so many portables got added to Grandfathered students have the right to remain at their reassigned school but they're moving up a grade each year. So, within another few years, all the grandfathered elementary kids will have moved out of the primary grades. Now the schools expanded with portables to accommodate controlled choice reassignmentsand also more white kidsare asking to make those temporary portables permanent.FRIDAY, ELDREDGE \u0026amp; CLARK HERSCHEL H. FRIDAY, P.A. B. S. CLARK ROBERT V. LIGHT, P. A. WILLIAM H. SUTTON, P.A. GEORGE E. PIKE. JR., P.A. JAMES W. MOORE BYRON M. EISEMAN, JR., P.A. JOE O. BELL, P.A. MICHAEL G. THOMPSON, P.A. JOHN C. ECHOLS, P.A. JAMES A. BUTTRY, P.A. FREDERICK S. URSERY, P.A. H. T. LARZELERE, P.A. OSCAR E. DAVIS, JR. JAMES C. CLARK, JR., P.A. THOMAS P. LEGGETT, P.A. JOHN DEWEY WATSON, P.A. LEWIS MATHIS, P.A. PAUL S. BENHAM HI, P.A. LARRY W. BURKS, P.A. A. WYCKLIFF NISBET, JR., P.A. JAMES EDWARD HARRIS, P.A. PARTNERSHIP OF INDIVIDUALS AND PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 FIRST COMMERCIAL BUILDING 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 Telephone 501-376-2011 Fax No. SOi-376-2147 March 11, 199 RECeWED J. PHI JP MALCOM, P.A. JAMES M. SIMPSON, P.A. MEREDITH P. CATLETT, P.A. JAMES M. SAXTON, P.A. J. SHEPHERD RUSSELL HI DONALD H. BACON, P.A. WILLIAM THOMAS BAXTER, P.A. WALTER A. PAULSON II, P.A. BARRY E. COPLIN, P.A. RICHARD O. TAYLOR. P.A. JOSEPH B. HURST, JR., P.A. ELIZABETH J. ROBBEN, P.A. CHRISTOPHER HELLER, P.A. HAND DELIVERED,,.  Ms. Ann Brown Ms. Arma Hart Office of Desegregation Monitoring 201 East Markham, Suite 510 Heritage West Building Little Rock, AR 72201 Re: Construction at LRSD Schools Dear Ann and Arma: LAURA HENSLEY SMITH, P.A. ROBERT S. SHAFER, P.A. WI JAM M. GRIFFIN HI, P.A. of 1 1 1991 THOMAS N. ROSE, P.A. MICHAEL S. MOORE DIANE S. MACKEY WALTER M. EBEL HI, P.A. KEVIN A. CRASS WILLIAM A. WADDELL, JR., P.A. CLYDE \"tab turner CALVI N J. HALL SCOTT J. LANCASTER JERRY L. MALONE M. GAYLE CORLEY ROBERT B. BEACH, JR. S. RANDOLPH LOONEY J. LEE BROWN JAMES C. BAKER. JR. H. CHARLES GSCHWENO, JR. HARRY A. LIGHT SCOTT H. TUCKER JOHN CLAYTON RANDOLPH GUY ALTON WADE PRICE C. GARDNER THOMAS F. MEEKS J. MICHAEL PICKENS TO N lA P. JONES fJEFFREY H. MOORE COUNSEL WILLIAM J. SMITH WILLIAM A. ELDREDGE, JR., P.A. WILLIAM L. TERRY WILLIAM L. PATTON, JR., P.A. WRtTERS DtRCCT NO. 370-1506 I am writing to provide you additional information about the construction projects at Woodruff, Geyer Springs, Western Hills, Cloverdale and Forest Heights. After sending to you and to counsel on February 15, 1991 a basic description of the proposed construction projects, I learned last week that construction is underway at Woodruff, Geyer Springs, Western Hills and Cloverdale. We intend to seek court approval of these projects as quickly as possible and have explored the impact of stopping the projects pending court approval. I have enclosed for each project the assessment of the project architect concerning the impact of suspension of construction work. The LRSD Desegregation Team has also reviewed the impact of the construction on our desegregation plan, and I have a good deal of information to share with you regarding that issue. I would like to meet with you as soon construction projects. as possible to discuss the I also intend to meet with the parties and to prepare a comprehensive motion for the court concerning these projects.I will be available to meet at your convenience, for your consideration. Thank you Yours very truly^''^ Christopher TIeller CJH/k cc: All Counsel - w/enc. Dr. Ruth SteeleWitsell. Evans iScRasco Architect I Planners March 8, 1991 Mr. Doug Kendall Little Rock Public Schools 3601 South Bryant Street Little Rock, Arkansas 72204 Re: Proposed Suspension of Work Woodruff Elementary School Dear Doug: In response to the District's request, we submit the following issues to be dealt with concerning suspension of construction work on the Woodruff Elementary School alterations and addition. The primary issue is scheduling. This project is under an extremely tight time frame with anticipated completion to be August 9, 1991. This would allow approximately two weeks for the District to occupy the new addition and the remodeled areas of the existing facility prior to the beginning of the 1991-92 school year. It has been our position that this schedule was obtainable under reasonable circumstances, but for an additional emphasis, we included $500 per day liquidated damages for time spent beyond August 9th to pronounce the District's intent to the Contractor. Any delay caused by the Owner (LRSD) would effectively waive all rights to liquidated damages and allow the Contractor to create his own timetable. Secondly, we have estimated additional expenses that the District would incur should a suspension of work be required. These expenses are those of the Contractor, Subcontractors and their suppliers which would directly transfer to the Owner. Items would include, but are not limited to: 1) Extended field overhead for the period of shutdown and the possibility of start-up delays due to weather, coordination, etc. The Contractor has estimated a cost of $770 per day for an expected three week downtime. Total Cost: $16,170 2) Due to the location of this project, aU on site materials and equipment would need to be removed and stored in a secured area. An estimated cost to move these materials, store in a secured area, and then transfer these items back to the job site would be a lump sum. Total Cost: $1,800 3) The phase of construction that this project is in has left the site extremely vulnerable to the impacts of weather. Currently the final construction grading has been done leaving exposed undisturbed soil. Footings are being poured, and should be 90% Witscll, Evans Rasco, P.A. 101 Ea^t Capitol Avenue. Suite 410 Little Rock. Arkansas 72201 (501) 374'5300Page 2 Mr. Doug Kendall March 8, 1991 complete by the 12th of this month. If we shut down at this point, without floor slabs in place, serious consequences would arise from any measurable rainfall. The dug footings would act as moats around the building line, trapping water and destroying the integrity of the undisturbed soil in our concrete slab areas. To rectify this probable situation, the soil within our building perimeter would need to be undercut and hauled off at a cost of $7 per yard and replaced with new compacted fill at a cost of $9 per yard. $9,770 Total Cost: 4) The work is at a stage where the temporary fence surrounding the project has been removed to allow perimeter grading and sidewalk demolition. A fence would be required around the site on the occurrence of a shut down. The Contractor would need to remove it once again when work resumes, therefore doubling his efforts. $2,106 Total Cost: Estimated Grand Total: $29,846 To avoid additional project delays and costs of Item 3, we suggest that a minimal compromise might be to allow the Contractor to complete his work on foundations and floor slabs. After this stage, the site could remain dormant for an indefinite period of time. Ironically, the time frame for completing this work will be approximately eleven days, nearly the full amount of time that you have requested to shut down. This issue is full of unusual circumstances. The items we have mentioned have some conjecture intertwined with some very real probabilities. Our architectural position concurs with your desire to keep this construction project on schedule. If I can be of any further assistance, please do not hesitate to let me know. Cordially, Witsell, Evans and Rasco, P.A. Eldon W. Bock, AIA Project Architect EWB:lhWILKINS SIMS ARCHITECTS 1001 WEST MARKHAM STREET LITTLE ROCK, ARKANSAS 72201 501 375-3356 March 8, 1991 Mr. Doug Kendall Director of Plant Services Little Rock School District 3601 South Bryant Little Rock, AR 72204 RE: Addition and Modifications to Cloverdale Jr. High and Elementary Schools Little Rock, Arkansas Dear Mr. Kendall: As you reguested, I will attempt to address the affects of stopping the work on the above referenced project. It is difficult to be very accurate in our assessment of this action, since in our twenty-one years of experience, we have never stopped work on any project. The completion of the work on this project is so critical that we have scheduled certain portions of the work to occur within a certain time period. Some of this work is scheduled for the spring break If we and other portions for the summer months. stop the contractor, even for a short period, he will have a very good reason to miss these scheduled items. Possibly the most critical item is the remo- val of asbestos from the existing cafeteria, this is not done as scheduled, it impacts the If It is almost certain the school remaining work. will not be completed and available in time for the spring semester as anticipated. The contractor has advised us that there will be additional costs if the work is stopped. He has estimated his overhead costs, such as office expenses, salaries for key people, utilities, insurance, costs for rental equipment, etc. will be apprioxima- He estimates the costs for the tely $l,985/day. sub-contractors will add another $2,p00/day, for a total of almost $4,000/day. ARCHITECTUR\u0026amp;PLANNING/INTERIORS/GRAPHICSMr. Doug Kendall March 8, 1991 Page 2 Most of the building materials have already been ordered, so someone will have to be on-site to receive them. Some materials can not be left on the site, so there could be costs for storage of these items. Liquidated damages are included in this contract in the amount of $300.00 per day. If the time of completion exceeds the contract time, I am sure the contractor will use this as an excuse for not completing the work. The loss of momentum could affect his schedule much longer than the actual period he is stopped. If you have any questions, please call. Sincerely yours. WILKINS/SIMS/ARCHITECTS/P.A. Kenneth F. Sims KFS/ptg15 16 west third street little  P  rock, o . box 2 2 3 6 arkansas 72203 pho f a n e X 3 7 6 - 3 2 7 7 3 7 4 - 813 3 d a n f s + o w e r s a r c h I e c p. a. dan f. Stowers, a.i.a. March 8, 1991 Mr. Doug Kendall Director of Plant Services Little Rock School District 3601 South Bryant Street Little Rock, AR 72204 RE: Little Rock School District Little Rock, Arkansas Additions and Renovations to Geyer Springs Elementary School Project No. 90-1005 Dear Mr. Kendall: As per our conversation regarding suspension of work on the above captioned project, will attempt to answer the following questions. If a stop order is issued: 1. Determine Contractor. the amount of immediate hardship placed on the 2. Monetary value created by the stop order. 3. The detrimental impact that it would have on the construction process. first phase of the question, the Immediate impact on the General Contractor, is rather difficult to determine in as much as Kullander Construction has begun demolition work in most of the classrooms and corridors and all of the ceilings have been removed. Some of the roof and structural components have been removed where possible and all of the gravel from the existing roof has been removed. The asbestos contractor is scheduled to move into the building on April 1, 1991, to remove all sensitive materials. T-h-i-s will allow Kullander Construction to continue the demolition of the kitchen and April 1 office areas. If a stop order is issued, the asbestos contractor cannot be rescheduled until June 15, 1991. I Mr. Doug Kendall March 8, 1991 Page 2 The Principals Office is now located in a metal classroom building with telephone, intercom and fire alarm having been connected to this newly established office. Partitions have been constructed and a restroom provided for use as a Teachers' Workroom. Soil has been delivered to the site and is being compacted in anticipation of pouring foundations on March 13, 1991. The playground equipment has been removed and is not usable by the students at this time. Therefore, if a stop order is Issued, I think it would be necessary for the School District to plead with the Court to allow Kullander Construction a minimum of a week to secure the building. In addition, materials such as conduit and plumbing pipe have been delivered to the job site in anticipation of placing these items in the existing building and the new sections. We are scheduled to receive on Monday, March 11, 1991, concrete reinforcing bars and footing foundations will be poured beginning Wednesday, March 13, 1991. Electrical panels and other electrical switch gear should be on the job site before April 1, 1991. Other materials which have purchase orders include overhead structural steel members, heating and air conditioning units, brick and Haydite block and kitchen equipment. All of these materials require approximately ninety to one hundred and twenty days lead time in order for the manufacturers to schedule and deliver the materials. Therefore, Kullander Construction has secured delivery dates of June 1, 1991, for these materials and equipment. Should a stop order be issued to Kullander Construction, the result would be devastating to the contract completion date. The reason being that all of these materials and equipment would have to be reordered and new delivery dates scheduled. The esprit de corps on the project is running very high. Contractors, as well as subcontractors, have great expectations of being able to complete their work in a minimum amount of time and the cooperation of each and every man on the job is focused on the needs of the students. I am almost certain that a stop order would interrupt the continuity that we presently have and would never be able to regain.Mr. Doug Kendall March 8, 1991 Page 3 is Therefore Secondly, if the project is stopped, particularly by the Courts, there is no guarantee when or if the project will resume. Theiexute, I anticipate some of these contractors will seek other projects and we will lose the qualified people that we presently have on this construction project. To address the question regarding anticipation costs resulting from the stop order is probably the most difficult of the three propositions to actually determine at this time. AIA Document A201, General Conditions of the Contract for Construction, paragraph 14.3, IS on Suspension By The Owner For Convenience, states: The Owner may, without cause. order the Contractor in writing to suspend, delay or interrupt the Work in whole or in part for such period of time as the Owner may determine. This Section of the AIA document continues that an adjustment shall be made for increases in the cost of performance of the contract. According to my understanding, the Contractor could be required to cancel orders for materials and each and every manufacturer would be entitled to a \"restocking fee\"\nand the General Contractor, as well as the subcontractors, could be entitled to expenses and anticipated profit fees. Tn reviewing this proposition with Mr. Karl Kullander, if a stop order were issued, we have estimated that it could cost the Little Rock School District in excess of $175,000.00. Mr. Kendall, I hope that this information will be helpful and I pray that the Courts will be lenient in this matter. If we can be of further assistance, please feel free to call. Sincerely, Q Tn Dan F. Stowers DFS:met ROARK  PERKINS PERRY ARCHITECTS ENGINEER  713 W. SECOND LITTLE ROCK AR 72201-2287  501 372-0272 March 8, 1991 Mr. Doug Kendall Little Rock School District 3601 S. Bryant Little Rock, AR 72204 Re: Western Hills Elementary Renovation Dear Doug: As per your request, we have asked the contractor for a letter identifying additional costs related to a two-week shut-down of this project. His letter (copy attached) identifies a minimum of $18,140. additional cost. They also would expect to have the liquidated damages clause of the contract eliminated. In addition, we would expect to have a minimum of 10 hours architectural time at $60.00/hour for our additional involvement with the shut-down and subsequent restarting of this project. We would strongly advise against the two-week shut-down, as the momentum of the project would be lost, and it will ije virtually impossible to have this project available for the start of school the last of August, 1991. Yours very truly, ROARK, PERKINS \u0026amp; PERRY H. Price Roark HPR/bp Enclosure H. PRICE ROARK AIA PE  DAVID W. KENNEDY AIA CSI FRED M. PERKINS. JR. AIA  DAVID W. PERRY AIA SALLY BOWEN CSI MARC H. HATFIELD AIA / North Little Rock Plumbing \u0026amp; General Contracting March 8,1991 Roark, Perking \u0026amp; Perry RE: Western Kills Elementary Project Shutdown Listed below are a few of the cost that we would acure upon a project shutdown of approximatly two weeks. We would like to make clear that this shutdown is not at all feasible 4 these are only a fev\nof the foreseeable cost listed below has been scheduled for this project 4 will not have ar to go to. The equipment her project 1) One Padfoot Roller: $1,175.00 per week i? 2week3 q2,250,00 2) One Dozer: $650,00 per week  2 weeks= $1,300.00 plus $200.00 delivery= $1,500.00 3) One Backhoe: $800.00 per week  2weeks =$1,600.00 plus $200.00 delivery* $1,800.00 Total Rental Equipment: $5,550.00 1) Additional Overtime cost not figured in project which will be required to get project batk on schedule. 5 men s $65.00 including labor burden for 100 Hr3= $6,500.00 2) Plumber, Apprentice i Backhoe to rough-in slab that would have been ready within the next week \u0026amp; 4 half. Plumber i Appren, Backhoe \u0026amp; Operator Total Plumbing Cost AOHrs. X 30.00 = 40Hr5 X 43.00 = $1 ,200.00 $1,800.00 $3,000.00 3) Overhead cost on insurance, managment 4 Labor Burden that will not cease: $3,140.00 We would also have to have all liquidated damaged completely waived off this project. If this project is closed down indefinitly than we would expect ccmpldte payment on all Profit'\u0026amp;Overhead. Thank You, Vic Smith,Project Manager 18 North Dcpch Street  P.O. Dox 127  North Little Rock, Arkansas 72115  Office 501-374-2313  PAX 501-374-3215 I POLK  STANLEY \u0026amp; ASSOCIATES March 8, 1991 ARCH I T  C T S, LTD. Mr. Doug Kendall Director of Plant Services Little Rock School District 3601 S. Bryant Little Rock, AR 72204 Re: Additions and Renovations to FOREST HEIGHTS JUNIOR HIGH Project No. 264 Dear Doug: In response to the question raised about the impact of halting all work on this project while the court reviews the improvements at Forest Heights for compliance with the comprehensive plan, I have enclosed a copy of the proposed Construction Schedule. If our work is halted for as much as one week, the construction schedule cannot be met for the completion of Phase I renovation work by the 1991-92 school year as requested by the Little Rock School District. This would leave us with two options: 1. Phase I work would be delayed to the summer of 1992 causing the final completion date to be extended to August of 1993. 2, Phase I work would run over into the 1991-92 school year with Band, Choral and either Business Education or Art being displaced temporarily until the construction in their area is complete. Phase II schedule could remain as is, with the understanding that we could end up with an overlapping of construction (two contractors on the same site at the same time) leading to added confusion. The impact of added cost to the District under Option One would include the possible duplication of work under a make-do situation until the actual renovation work could be done and maintenance costs that would have been unnecessary had the renovation been completed a year earlier. The impact of added cost to the District under Option Two would include the rental and installation of portable buildings to house the displaced classrooms. 700 S. Schiller ' Little Rock, Arkansas 501'378 0878 72201Mr. Doug Kendall March 8, 1991 Page Two The only additional fees required by us to begin our work after a period of holding would be if the scope of the work changed so greatly that we were required to redesign the project. We have completed work through twenty-two percent of our contract which translates to a fee earned of approximately $38,000 -of which approximately $26,000 has been paid to date. This leaves a balance earned at this point of approximately $12,000. Sincerely, Carolyn Lindsey cc: Vernon Smith, LRSD Chip Jones, LRSD FOREST HEIGHTS JUNIOR HIGH SCHOOL Additions and Renovations March 1, 1991 CONSTRUCTION SCHEDULE PHASE I - Renovations, New Music Classroom March 4 Mar. 25,1991 3 weeks March 25 - April 1, April May June 1 - May 21, 21 - June 10, 4 - June 11, 1991 1991 1991 1991 1 week 7 weeks 2 weeks 1 week June 7, 1991 June 8 June 22, 1991 2 weeks June 12, 1991 June 23, 1991 Aug. 6, 1991 6 weeks Aug. 7 - Aug. 18, 1991 12 days Aug. 14, 1991 9 weeks Aug. 14 - Aug. 18, 1991 5 days Aug. 19, 1991 Design Development Phase I \u0026amp; Phase II Review Construction Documents Bidding ' Bid Opening, Negotiations, Sign Contract Teachers' last day in school Asbestos Abatement of first building Begin Construction of new Music Classroom Begin Renovations of first building Complete Renovations, Asbestos Abatement Move in Renovated Buildings Complete new Music Classroom Move in new Music Classroom First day of classes PHASE II - New Classroom and Administration/Library Building, Sitework, Demolition of Existing Buildings May 15 July 30 Aug. 2 0 - July 29, 1991 - Aug. 19, 1991 - Sept. 2 1991 11 weeks 3 weeks 2 weeks Sept. 3 Aug. 10 '91 Aug. 9'92 Aug. 24, 1992 - Aug 23, 1992 11 months 2 weeks Construction Documents Bidding Bid Opening, Negotiations, Sign Contract Construction Move in First day of classesMAR 19 '91 17:17 P.2 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS MOTION FOR APPROVAL OF SCHOOL CONSTRUCTION For its motion, plaintiff Little Rock School District (LRSD) states: 1. schools: LRSD seeks approval of construction projects at eight Forest Heights Junior High School\nCloverdale Junior High School\nCloverdale Elementary School\nRightsell Incentive School, Mitchell Incentive School, Geyer Springs Elementary School\nWoodruff Elementary School\nand Western Hills Elementary School. Each construction project and its impact upon LRSD's desegregation plan will be described below. 2. With the exception of Woodruff Elementary School, the proposed elementary capacity figures presented in this motion are based upon twenty students per four year old class and the average number of students per class required by Arkansas Department of Education regulations for the elementary grades. Those averages are: Twenty students per kindergarten class\ntwenty-three students per class at grades 1 through 3\ntwenty-five students per Aflpfowi Seb \"-nwMAR 19 '91 17:17 P.3 class at grades 4 through 6. Woodruff Elementary School's capacity is calculated at twenty-two students per class for grades 1 through 6 because most of the classrooms for the upper elementary grades are too small to accommodate more than twenty-two students per class. The junior high school capacities are calculated in accordance with a formula which takes into account the size and use of each classroom as well as class scheduling requirements. The proposed projects which are the subject of this motion follow construction and renovation projects at schools in east and central Little Rock which were then known as \"major enhancement\" schools. The largest of the \"major enhancement\" projects was at Washington school, with a 1987-88 capacity of three hundred five (305), which was completely demolished. A new Washington school was constructed on the same site at a cost of $4,932,377.00. The capacity at Washington was increased by five hundred sixty-one (561) students to eight hundred sixty-six (866) . 4. A new wing of ten classrooms was added to Franklin 3. Incentive School and Franklin's cafeteria was remodeled in 1989. The cost of the Franklin project was $1,330,000.00. 5. Rockefeller, Rightsell and Ish Incentive Schools were renovated. including reroofing. beginning in 1988. Mitchell Incentive School was also renovated at the same time. Stephens Incentive School received air conditioning, painting and carpeting. but was not renovated to the extent of the other buildings because of the plan to build a new Stephens school. The combined cost of the Rockefeller, Rightsell, Ish, Mitchell and Stephens projects was knhy\\Mx\u0026gt; Ajipwrei SdiCc* 2MAR 19 '91 17:13 approximately Six Hundred Sixty-Seven Thousand Dollars. P.4 Capital improvements have also been made recently at Garland Incentive School at a cost, since 1988, in excess of $400,000.00. 6. The LRSD Board of Directors voted on March 15, 1990 to seek to increase the LRSD millage rate by eight mils, five and one- half mils for maintenance and operation and two and one-half mils for debt service. The debt service mils were designated for capital improvement projects. LRSD committed to its patrons that capital improvement projects would be undertaken at Woodruff, Western Hills, Cloverdale, Geyer Springs and Forest Heights if the millage passed. The millage was approved by the voters on April 19, 1990. 7. During the 1988-89 school year, LRSD prepared desegregation plan which proposed that a new King school and a new Stephens school be constructed in the area of Interstate 63 0 between University Avenue and Interstate 30. That desegregation plan was agreed upon by all the parties but rejected by the district court. The parties were ordered to implement a different desegregation plan, the Tri-District Desegregation Plan. 8. The Tri-District Plan called for the expansion of Woodruff Elementary School, the expansion of Western Hills Elementary School and the elimination of portable classrooms there, and the expansion of Cloverdale Elementary and Junior High Schools. The parties appealed but did not seek to stay implementation of the Tri- District Plan. LRSD notified the associate metropolitan a supervisors on July 26, 1990 that the \"building expansion projects lalhy\\Mo Seta CoaK 3MfiR 19 '91 17:19 P.5 for Woodruff, Western Hills, and Cloverdale will continue\". 9. Architects were hired during the summer of 1990 for the Cloverdale, Geyer Springs, Woodruff and Western Hills projects. The architect for the Forest Heights project was hired in November, 1990. During December 1990 and January 1991, LRSD advertised for bids, opened bids and hired general contractors for the Cloverdale, Western Hills, Woodruff, and Geyer Springs projects. Work has begun on those projects. No contractor has been hired and no work has begun on the Forest Heights project. Architects have not yet been hired for the Rightsell and Mitchell projects. 10. The \"Interdistrict Desegregation Plan\", which was approved by the Court of Appeals on December 12, 1990, says that \"[a] 11 school construction shall be subject to the court's prior approval and shall promote desegregation\". Interdistrict Plan, 8 J.D.R. 1723. The recruitment of students to non-magnet, non-incentive schools is a part of LRSD's desegregation plan. Interdistrict Plan, 8 J.D.R. 1721-22\nLRSD Desegregation Plan, 10 J.D.R. 2198. The proposed projects at Woodruff, Cloverdale, Geyer Springs, Western Hills and Forest Heights will contribute to LRSD's ability to accomplish that goal. 11. The project at Woodruff would add six new classrooms to the school. Woodruff's capacity would be increased from two hundred nine (209) to three hundred twenty-four (324) . With the increased capacity. Woodruff could accommodate forty-four (44) students per grade for grades 1 through 6, forty (40) kindergarten students and twenty students in the four year old program. 4 kubyvMo SA.MAR 19 '91 17:56 P.l 12. There is no satellite attendance zone for Woodruff School. LRSD does not propose to change the Woodruff attendance zone. There are presently 174 students in grades K-6 who reside in the Woodruff attendance zone. Fifty-nine percent of those students are black. Assuming full participation in Woodruff's four year old program, the present Woodruff attendance zone would yield 194 students, or sixty percent of Woodruff's proposed capacity. Ths remainder of Woodruff's capacity will be filled by recruitment. Woodruff's Care Program (at which students can remain until 5:30 p.m.! and Woodruff's location (adjacent to Interstate 30 near downtown Little Rock) will be used by LRSD recruiters to market the school to parents who work in state government offices, Arkansas Children's Hospital and downtown Little Rock. 13. Woodruff presently has one class each at grades K-4 and two classes each at grades 5 and 6. The expansion of Woodruff will create the space necessary to balance the grade structure with two classes per grade. 14. The construction project at Western Hills consists of replacing nine classrooms in portable buildings with nine permanent classrooms. LRSD does not propose to enlarge Western Hills Elementary School. This project will not require any adjustment to attendance zones. 15. There is no satellite attendance zone for Western Hills. Two hundred ninety-one students in grades K-6 reside in the Western Hills attendance zone. That group, which is fifty-four percent (54%) black, would fill Western Hills to eighty-nine percent (89%) Ans will lACoat 503'20/91 09:37 301 376214\" FRIDAY LAW FIR3I @002 of capacity. As a result of previous desegregation plans and the grandfathering provision in the current plan, one hundred eighty (180) students who reside within the Western Hills zone attend Western Hills, one hundred fifty-four (154) students who reside outside the Western Hills zone attend Western Hills and one hundred eleven (111) students who reside within the Western Hills attendance zone attend schools other than Western Hills. Grandfathering will be phased out according to LRSD's Desegregation Plan (10 J.D.R. 2198 \u0026amp; 2199) which allows students \"presently assigned\" to elementary schools ho remain in those schools but requires that kindergarten and new students will be assigned by attendance zones. 16. All but one of the portable buildings presently in use at Western Hills are approximately twenty years old. One portable building is only two years old. 17. The project at Geyer Springs Elementary School consists of building twelve classrooms by a combination of new construction and the conversion of some existing space to classroom use. Portable buildings which house eight classes will be removed, for a net increase at Geyer Springs of four classrooms. The additional classrooms will allow the school to provide two classes each at grades K-6. The construction project will also increase the size of the kitchen and create a new library at Geyer Springs. 18. The capacity of Geyer Springs Elementary School would increase from two hundred fifty-five (255) to three hundred twenty- eight (328) . The present enrollment at Geyer Springs is two 6 inhyVWo Afptw*! Sch CowSSraEBBBflSa  03/20 91 09:37 301 3762147 FRIDAY LAW FIRM 003 hundred seven (207), although two hundred sixteen (216) students reside in the Geyer Springs attendance zone. Eighty*-four students who reside in the Geyer Springs attendance zone attend Geyer springs Eleinentary School. The remaining one hundred thirty-two (132) LRSD students who reside in the Geyer Springs attendance zone attend various other LRSD schools. One hundred thirteen (113) students who reside outside the Geyer Springs attendance zone presently attend Geyer Springs Eleinentary School. 19. The present racial composition of Geyer Springs Elementary School is seventy-one percent (71%) black. The racial composition of the students who reside in the Geyer Springs attendance zone is sixty-seven percent (67%) black. After grandfathering is phased out, the school will reflect the racial composition of the attendance zone. No change in the assignment of students to Geyer Springs, however, will result from the construction project. 20. The LRSD students who reside in the Geyer Springs attendance zone would fill Geyer Springs to sixty-six percent (66%) of capacity, The remaining capacity will be filled by recruitment to the public schools of students who reside within the Geyer Springs zone and by the assignment of students who cannot be accommodated at neighboring Wakefield Elementary School which is presently operating at ninety-nine percent (99%) of capacity. See 10 J.D.R. 2198-99. 21. The project at Cloverdale Elementary school consists of the construction of new cafeteria, the addition of five a lathyVMo AppMnal Sds Cent 7MAR 19 '91 17=26 P.4\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resoources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_301","title":"Compliance correspondence","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["2002/2006"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","Education--Arkansas","Educational law and legislation","Educational planning","Education--Evaluation","School administrators"],"dcterms_title":["Compliance correspondence"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/301"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["correspondence"],"dcterms_extent":["167 pages"],"dlg_subject_personal":["Walker, John W."],"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nFriday Eldredge \u0026amp; Clark HERSCHEL H FRIDAY (1922-1994) WILLIAM H. SUTTON. P.A. BYRON M. EISEMAN, JR.. P.A. JOE D. BELL. P.A. JAMES A. BUTTRY, P.A. FREDERICK S. URSERY. P.A. OSCAR E. DAVIS. JR.. P.A. JAMES C. CLARK. JR., P A. THOMAS P. LEGGETT, P.A. JOHN DEWEY WATSON. P.A PAUL B. BENHAM 111. P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET. JR.. P.A. JAMES EDWARD HARRIS. P A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON, P.A JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL III, P A. DONALD H BACON, P.A. WILLIAM THOMAS BAXTER, P A BARRY E. COPLIN, P.A. RICHARD D. TAYLOR, P.A. JOSEPH B. HURST. JR., P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P A. ROBERT S. SHAFER. P.A. WILLIAM M. GRIFFIN Hl. P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY. P.A. WALTER M. EBEL HI. P A KEVIN A. CRASS. P.A. WILLIAM A. WADDELL. JR.. P.A. SCOTT J. LANCASTER. P.A. M. GAYLE CORLEY. P.A. ROBERT B- BEACH. JR.. P A. J. LEE BROWN, P.A. JAMES C. BAKER. JR . P A. HARRY A. LICHT. P A. SCOTT H. TUCKER. P A. GUY ALTON WADE. P.A. PRICE C. GARDNER. P A. TONIA P. JONES. P.A. DAVID D. WILSON. P A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayfirm.com 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 501-376-2011 FAX 501-376-2147 3425 NORTH FUTRALL DRIVE. SUITE 103 FAYETTEVILLE. ARKANSAS 72703-4811 TELEPHONE 501-695-2011 FAX 501-695-2147 JEFFREY H. MOORE. P.A. DAVID M. GRAF. P.A. CARLA GUNNELS SPAINHOUR, P.A. JOHN C. FENDLEY. JR., P.A. JONANN ELIZABETH CONIGLIO. P A. R. CHRISTOPHER LAWSON. P A. GREGORY D. TAYLOR. P.A. TONY L. WILCOX. P.A. FRAN C. HICKMAN. P A. BETTY J. DEMORY. P.A. LYNDA M. JOHNSON. P.A. JAMES W. SMITH. P.A. CLIFFORD W. PLUNKETT. P.A. DANIEL L. HERRINGTON. P.A. MARVIN L. CHILDERS K. COLEMAN WESTBROOK. JR. ALLISON J. CORNWELL ELLEN M OWENS JASON B. HENDREN BRUCE B. TIDWELL MICHAEL E. KARNEY KELLY MURPHY MCQUEEN JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN BRYAN W. DUKE JOSEPH G. NICHOLS ROBERT T. SMITH RYAN A. BOWMAN TIMOTHY C. EZELL T MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON PHILIP B. MONTGOMERY KRISTEN S. RIGGINS ALAN G. BRYAN OF COUNSEL B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H-T. LARZELERE, P.A. JOHN C. ECHOLS, P.A. A.D. MCALLISTER 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2898 FAX 870-762-2918 JOHN C. FENDLEY, JR. LITTLE ROCK TEL 501-370-3323 FAX 501-244-5341 ftnclleyQftc.net January 2, 2002 received The Honorable Susan Webber Wright 522 U.S. Post Office and Courthouse 600 West Capitol Avenue Little Rock, Arkansas 72201-3325 JW3 M OffittOF VIA FAX: 604-5169 RE: Little Rock School District v. PCSSD Dear Judge Wright: We are writing in response to Mr. Walker's fax of December 28, 2001, concerning a continuance of the January 28 hearing. While we do not question the basis on which Mr. Walker requests a continuance, we respectfully submit that Mr. Walker's associate, Robert Pressman, could ably represent the Joshua Interveners at the hearing. Mr. Pressman has been present and participated in previous hearings. In particular, Mr. Pressman examined Dr. Bormie Lesley, who will be the District's primary witness on the issues of achievement and advanced placement courses. The Joshua Interveners will not be prejudiced because Mr. Pressman does not have time to prepare for the hearing. The parties first exchanged exhibits on December 28, 2001, the same date as Mr. Walker's fax. Thus, Mr. Walker has not spent a great deal of time reviewing the District's exhibits which will now have to be duplicated by Mr. Pressman. For several reasons the Little Rock School District wants a decision in this case as soon as possible. One reason is the District's agreement with the State which is a part of the record as Court'sThe Honorable Susan Webber Wright January 2,2002 Page 2 Exhibit 548. Based on that agreement, any delay could eventually result in the District owing the State $5,000,000.00. Accordingly, the Little Rock School District respectfully requests that the January 28 hearing go forward as scheduled. Sincerely, wn C. Fendley, Jr. cc: Ms. Ann Marshall Mr. John Walker Dr. Ken James0: JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 RECEIVED FEB 1 - 2002 OmCEOF DESEGREGATION MONITORING Via Facsimile - 376-2147 January 30, 2002 Mr. Clay Fendley Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, AR 72201 Re: LRSD v PCSSD Dear Clay: I am in receipt of your letter dated January 28, 2002. Due to my limited resources and staffing, and since District officials to whom I have directed my correspondence have support personnel, may I suggest that you advise District officials when they receive a request for information or referral from me that they have their support personnel forward copies to your attention. I am not conducting discovery. I am continuing my role as a monitor for the Joshua Intervenors. Furthermore, I am not aware of any order from the Court which states that Joshua monitors are prohibited from monitoring the Districts compliance with its plan(s) as ordered by the 8' Circuit Court of Appeals. Nor am I aware of any order which states that I cannot conduct my monitoring activities as I have done so previously. Finally, I do not believe my monitoring activities are contrary to any court order. Please give me a call if you have a problem with my suggestion that District officials forward any correspondence from me to your attention. Sincerely  Joy C. Springer Joshua Monitor JCS/ cc: Dr. Ken James Mr. Junious Babbs Friday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY (1922-1994) WILLIAM H. SUTTON. P.A. BYRON M. EISEMAN. JR.. P.A JOE D. BELL. P.A. JAMES A. BUTTRY, P.A. FREDERICK S. URSERY. P.A OSCAR E. DAVIS. JR.. P.A. JAMES C. CLARK. JR.. P.A. THOMAS P. LEGGETT. P.A JOHN DEWEY WATSON. P.A PAUL B. BENHAM III. P.A LARRY W. BURKS. P.A A WYCKLIFP NISBET. JR.. P.A. JAMES EDWARD HARRIS. P.A. J. PHILLIP MALCOM. P.A JAMES M. SIMPSON. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL HI. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A BARRY E. COPLIN. P.A. RICHARD D. TAYLOR. P.A. JOSEPH B. HURST. JR.. P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER. P.A. LAURA HENSLEY SMITH. P.A ROBERT S. SHAFER. P.A. WILLIAM M. GRIFFIN UI. P.A MICHAEL S. MOORE. P.A DIANE S. MACKEY. P.A. WALTER M. EBEL III. P.A. KEVIN A. CRASS. P.A WILLIAM A. WADDELL. JR,. P.A. SCOTT J. LANCASTER. P.A M. GAYLE CORLEY. P.A ROBERT B. BEACH. JR.. P.A. J. LEE BROWN. P.A. JAMES C. BAKER, JR.. P.A. HARRY A. LIGHT. P.A SCOTT H. TUCKER, P.A. GUY ALTON WADE. P.A. PRICE C. GARDNER. P.A. TONIA P. JONES. P.A. DAVID D. WILSON. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayflrm.com 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 501-376-2011 FAX 501-376-2147 3*25 NORTH FLITRALL DRIVE. SUITE 103 FAYETTEVILLE, ARKANSAS 72703-4811 TELEPHONE 501-805-2011 FAX 501-895-2147 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-782-2898 FAX 870-762-2918 January 28, 2002 JEFFREY H. MOORE. P.A. DAVID M. GRAF, P.A. CARLA GUNNELS SPAINHOUR. P.A. JOHN C. FENDLEY. JR., P.A JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN JONANN ELIZABETH CONIGLIO. P.A. BRYAN W. DUKE R. CHRISTOPHER LAWSON, P.A. GREGORY D. TAYLOR. P.A. TONY L. WILCOX, P.A FRAN C. HICKMAN, P.A. BETTY J. DEMORY, P.A. LYNDA M. JOHNSON, P.A. JAMES W. SMITH, P.A CLIFFORD W. PLUNKETT, P.A. DANIEL L. HERRINGTON. P.A. MARVIN L. CHILDERS K. COLEMAN WESTBROOK. JR. ALLISON J. CORNWELL ELLEN M. OWENS JASON B. HENDREN BRUCE B. TIDWELL MICHAEL E. KARNEY KELLY MURPHY MCQUEEN JOSEPH G. NICHOLS ROBERT T. SMITH RYAN A. BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON PHILIP B. MONTGOMERY KRISTEN S. RIGGINS ALAN G. BRYAN LINDSEY MITCHAM SLOAN OP COUNSEL B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H.T. LARZELERE. P.A. JOHN C. ECHOLS. P.A. AD. MCALLISTER JOHN C. FENDLEY. JR. LITTLE ROCK TEL 501-370-3323 FAX 501-2*4-9341 fendley@fec.net VilS C Ms. Joy Springer John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 RE: LRSD V. PCSSD ,'5 e n Z7 Dear Ms. Springer: This letter is in response to your follow-up letter to Mr. Babbs of January 22, 2002, concerning contact with Joshua. District officials were advised of the Court's order quoted in your letter. Without waiving our attorney client privilege, we can tell you that we did not instruct Mr. Washington or Mr. Babbs to stop providing you information. You state in your letter that it has been your practice to put any referrals to the Ombudsman in writing. We would respectfiilly request that you continue to do so. Also, as a courtesy, we ask that you send me a copy of your written requests for information. We have asked District officials to commumcate with you in writing as well. Hopefully, this will avoid disputes about the subject or content of the communications. To respond to your final inquiry, the District will respond within a reasonable time and in a reasonable manner to reasonable requests for information made by you. We continue to object to Joshua conducting discovery via the FOIA or informal requests. To the extent Joshua seeks discovery for upcoming hearings, we respectfully request that Joshua comply with the Federal Rules of Civil Procedure.Ms. Joy Springer January 28, 2002 Page 2 Finally, we expect that Joshua will comply with the Court's order concerning contacting District persoimel. As we read your letter, you interpret the Court's order as only applying to oral or in-person communications, but not to written communications. Please let us know if we have misinterpreted your position. We would like to develop a common understanding of the Court's order. We appreciate your cooperation. Please do not hesitate to call if you have any questions. Sincerely, John C. Fendley, Jr. cc: Dr. Ken James Mr. Jnnious Babbs John W. Walker, P.A. Attorney Ar Law 1723 Broadway Ltitle Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 RECEIVED FEB 1 - 2002 OFHCEOF DESEGREGATION MONITORING JOHN w. WAT,try,B. SHAWN CHILDS Via Facsimile -324-2281 January 22, 2002 OF COUNSEL ROBERT McHenry, P_A. DONNA J. McHenry 8210 Hendeeson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mcheiiryd@swbell.net Mr. Junious Babbs Associate Superintendent for Administrative Services Little Rock School District 501 Sherman Street Little Rock, AR 72201 Dear Mr. Babbs\nI am in receipt this date of your letter dated January 14, 2002 in response to mine of January 7, 2002. My request for information from Mr. Washington is a part my continuing role to monitor the activities of the District. I am somewhat puzzled by your letter because you, Mr. Washington, other District staff members and I have communicated on similar issues since the hearings and I have not been advised by you or anyone else that I must first notify counsel for the District in order to receive written requests for information. Moreover, I am not aware of any court order where: Judge Wright instructed Joshua not to communicate with District employees without notifying counsel for the District while litigation was ongoing\" Her order states: the Court directs counsel for Joshua Intervenors to go through counsel for the Little Rock School District when seeking information from district or district officials and personnel that is pertinent to the case, and to inform cowtselfor the Little Rock School District prior to contacting officials and personnel about matters not currently before the Court.  Your letter raises some questions. First of all, if it was the Districts position not-to provide information to me because of Judge Wrights order, it occurs to me that I should have been notified of this position months ago when the requests were made. There is no court order precluding the District from providing the requested information. In addition, my requests were written, not verbal\nand you and/or Mr. Washington could have easily shared them with your counsel before now. Finally, are you saying that District counsel instructed you not to provide the information? It has been my practice to put any referrals to the Ombudsman and requests for information to you and other District personnel in writing. I will continue to do so. It is unclear to me how you, Mr. Washington and other District staff (if you are also speaking for them at this point) intend to respond to my requests for information in the future. I would appreciate clarification from you or Dr. James regarding this question. Joy C. Springei On Behalf of Joshua JCS/ cc: Dr. Kenneth JamesLITTLE ROCK SCHOOL DISTRICT 501 SHERMAN STREET LITTLE ROCK, AR 72202 OFFICE OF ADMINISTRATIVE SERVICES Junious C. Babbs, Associate Superintendent Phone: (501)324-2272 icbabbsstuasn.lrsd.kl2.ar.us -i* January 14, 2002 Ms. Joy Springer John W. Walker, P. A. 1723 Broadway St. Little Rock AR 72206 Dear Ms. Springer\nDr. James asked that I respond to your letter of January 7, 2002, concerning the Ombudsman providing you copies of his investigation reports. As you know. Judge Wright instructed Joshua not to communicate with District employees without notifying counsel for the District while litigation was ongoing. Mr. Washington, along with all other District administrators, was advised of Judge Wrights decisiich in this regard. However, Mr. Washington has been authorized to provide you copies of hiss lleetttteerrss ttoo ppaarreennttss rreeppoorrttiinngg tthhee ffimnddiinngess off hhiiss iinnvveessttiicgraattiionnnss rm mni referred to Mr. Washington by you. on matters If I can be of any further assistance, please let me know. Sincerely, Junious Babbs Associate Superintendent Cc\nDr. Ken James James Washington John w. Walker, p.a. ArronNEy At Law 1723 Broadway Lettle Rock, Arkansas 72206 Tels\u0026gt;hone (SOI) 374-3756 FAX (501) 374-41S7 JOHNW. walkek SHAWN CHILDS OP COUNSEL KOBEKT MuLENK?, PA- DONNA J. McSEM\u0026amp;T SaiOHnffiSSUONBw LdTLS SOCS, 72J10 Phons\n(501) 372-S42S  P.y:(60U ElulL isci\u0026gt;eiu7di0\u0026gt;wtMli.aet Via Facsimile\n604-5149 Honorable Wilham R. Wilson United States District Judge 600 W. Capitol Suite 149 Little Rock, Arkansas 72201 Dear Judge Wilson\nDuring e hearing we had on July 12,2002,1 indicated that the Court had previously disallowed d^sitions from ODM staff. I was reminded that the one exception to that was the occasion when LRSD filed a motion to have Judge Wright recused. As I understood Her Order, the reason for that occasion was because of the nature of the motion being filed which raised the issue of the Courts possible prejudice against the District. In previous hearings, the Court, Herself, offered elicited testimony for the record from ODM staff. On those occasions, there was neither objection from the parties nor a request for deposition or pre-court interview. I am writing this letter only to clear up a comment that I made which was not totally accurate but in context. My statement did reflect the Courts past procedure. We have no objectiQn to LRSD iaterviewing Ms. MaKhall our presence. any other ODM staff person either in or out of S/nserely, I W. Walker cc\nAU Counsel of Record (via fax)RECEIVED John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JUL 3 2002 OFFICE OF DESEGREGATION MONITORING JOHN W. WALKER SHAWN CHILDS Via Facsimile - 604-5149 July 1, 2002 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone: (601) 372-3425  Fax (501) 372-3428 Email: mchenryd@swbell.net Honorable Judge William R. Wilson United States District Judge 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: Case No. 4:82CV0866WRW/JTR LRSD V. PCSSD Dear Judge Wilson: I received your order dated July 1, 2002 after 5:30 p.m. when I returned to the office from a trial before the Honorable George Howard, Jr., USA v. Dennis Williams 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 somewhat vexed with counsel. I believe the Court would not be vexed were I to have had a reasonable time in which to respond and to make the following explanation. Joshua has been monitoring the Districts record of compliance since the entry of the original Decree. In that role, we constantly receive concerns from class members about race related matters in each of the three Districts. We first seek to get the Districts information by letter. When that fails, we make a request under FOIA. The District usually responds to our letter requests unless a hearing like the one set for July 22 is approaching. Our monitoring was contemplated by the 8\"* Circuit and the Settlement 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 Courts conclusion that the requested information appears quite certain to be not timely. The Court seems persuaded that we did not meet the deadline for exchanging exhibits and names of witnesses. We each did so. Mr. Hellers office delivered his exhibits to us at the close of business on June 24, 2002 and we returned our witness list and exhibits to Mr. Heller by his own courier. We agree with the Courts comments that the requests are not pertinent to the three remaining issues in this case as the case relates to the Districts compliance as ofMarch 15, 2001. That does not mean, however, that Joshuas monitoring ended upon the filing of the report by the District on March 15, 2001. For the foregoing reasons, I request the Court to simply rescind its Order, afford us a reasonable reply time and then allow either party an opportunity to request a hearing thereon. In that way, the burden of proof would be upon the moving party on the issue rather than having Joshua in the position of being the moving party. For the information of the Court and the other parties, a criminal jury trial in which I am counsel before Judge Howard is expected to last at least through July 8, 2002. Thank you for your attention to this matter. Sincerely hn W. Walker JWW:js cc: All Counsel of Record Clerk of the Court SILL WILSON JUDGE UNITED STATES DISTRICT COURT eastern district of ARKANSAS 6OOW. CAPITOL, ROOM 423 UTTUE ROCK, ARKANSAS 72201-3S2S (501) 504-5140 Eaccimila (501) 504-5140 July 10, 2002 BY FAX Mr. Chris Heller Mr. Clay Fendley Mr. Sam Jones Mr. Richard Roacheii Mr. John Walker Mr. Dennis Hanson Re\nLittle Rock School District v. Pulaski County Special School, et al. 4\n82CV00866 Dear Counsel: A telephone conference was held on short notice yesterday at about 4:45 p.m. It was among counsel for LRSD and Joshua. I anticipate entering an order based upon information developed at that hearing. It should be filed no later than 2:00 p.m. today, and you may obtain a copy from the clerks office if you wish. Cordially, Wm, R. Wilson, Jr. cc\nThe Honorable J. Thomas Ray Mr. James W. McCormack 20/Z0 39Wd 6t\u0026gt;TSt\u0026gt;09T0S St\u0026gt;:60 2002/0T/Z0 JIX. 10.2002 10:48Hf1 jom W t^KLR P A NO.600 P.2Z2 JOHN W. WALKER SHAWN CHILDS John W. Walker, P.A. attorney At Law 1722 Bro-WWAy Lirru Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 Via Facsimile: 604-5149 OK COUNSEL ROBERT McHSNBY, PA. DONNA J. MeHENRY 8210 Henduson Roas ttnu Bock. AKKANaah 722M PSONE: (501) 37J-S425  Rja (Ml) 372.3*28 Emmu niciiiry(i8wbeU.a0t July 10,2002 Honorable William R-Wilson United States District Judge 600 W. Capitol Suite 149 Little Rock, Arkansas 72201 Dear Judge Wilson\nI have just been called back to Court on a case before Judge Howard which was expected to end by Friday of last week. The case went to the jury yesterday evening at approximately 4:00 p,m, I was unable to participate in your conference call yesterday because I was in that case. I understand tiiat you extended the deadline for the exhibits until 2:00 p.m. We have worked to provide the exhibits by 2:00 p.m. I am having to go to Judge Howards Court now. I would appreciate it if you would extend the deadline by one hour. If this presents a hardship on any person or a prejudice to the school district, I would be greatly surprised. 1 appreciate your acconunodation for one hour. icereJ W. Walker JWW:Ip cc: AU Counsel of Record JOHN W. WALKER SHAWN CHILDS John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 Via Facsimile: 604-5149 OF COUNSEL ROBERT McHENRY. P.A. DONNAJ.McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mchemydl^wbell.net July 11,2002 Honorable William R. Wilson United States District Judge 600 W. Capitol Suite 149 Little Rock, Arkansas 72201 received JUL 15 MO OFFtCE OF DESEQREQATIQN MQMITOWHQ Dear Judge Wilson: Thank you for allowing the additional two hours yesterday in which to submit our exhibits. We are now in the process of preparing for the hearing in the morning on the plaintiffs motion in limine and believe that it is appropriate to make preliminary remarks to the Court before the hearing begins. First, we have attempted to meet the Courts time, date of appearance and substance of testimony requirements in our submission filed yesterday. We have listed 23 witnesses who will testify. We intend to subpoena them pursuant to the Courts Order so that they will be present at 8:30 a.m. on July 22, 2002. Dr. Terrence Roberts and Dr. Steven Ross are outside the range of normal subpoena reach and we may need the Courts help in securing their presence. I intend to speak with them about their availability at the times that I have scheduled their testimony. Because they are out of state, I ask that the Court relieve them of the requirement to be present at 8:30 a.m. on the morning of the 22\"''. Second, the exhibits to which reference is made in Para. 2 of Plaintiff s memorandum have been provided to the plaintiff and the court. Third, plaintiff seeks to exclude its own exhibits as evidence that Joshua may utilize in its presentation. The established procedure in this case is that exhibits identified by either party may be relied upon and used by either party provided that they are otherwise admissible. There has not been stated any reason for deviation from past practice in this case. Moreover, there is no prejudice to the plaintiff if we use the exhibits which it has identified and intended to use itself.Page Two July 11,2002 Fourth, the District objects to our inquiring into good faith except as related to the issues involved in this hearing. We agree. 1) The District, however, in this hearing intends to address good faith itself at myraid points. Quality management was discussed extensively by Dr. Bonnie Lesley at the earlier hearing. The District seeks to readdress the issue through Ms. Sadie Mitchell. 2) The testimony of Mr. Baker Kurrus relates to good faith outside the three areas. The covenant referred to by Mr. Kurrus has not been challenged by Joshua because it was not pail of the negotiated agreement. Moreover, there is no issue raised by Joshua regarding compliance by the District with respect to the fee agreement. Mr. Kurrus testimony about Joshua appearances before the Board cannot be an issue. Although we do not object to Mr. Kurrus being a witness, his anticipated testimony must address the three issues before the Court. 3) The District requests that Joshuas effort to present Mr. Junious Babbs testimony on the tliree subjects be disallowed. We have set forth the areas and anticipated testimony of Mr. Babbs. Judge Wright limited us at the first hearing in such a way that the issues now before the Court were not fully explored. Moreover, Mr. Babbs is the Districts official who has chief responsibility for monitoring and oversight from a desegregative perspective over the counseling areas and as the monitor over each of the areas being presented to the Court. 4) The District wishes to exclude a number of Joshuas exhibits on the basis that they are not related to the issue now before the Court. Most of them are e-mails between District officials. Judge Wright previously allowed these to come in as admissions against interest or as evidence which either put matters into context or as rebuttal to contentions made by the District. We otherwise make reference to the response filed by Joshua, Par. 4 on July 8,2002. 5) Plaintiff wishes to exclude all testimony and evidence which was not brought before the school board in a public meeting. Plaintiff seems intent upon imposing an exhaustion of remedies requirement upon Joshua. The plan does not require exhaustion and with good reason. This was an agreement between parties who stood equally before the Court. The agreement defines the relationship between the parties. Good faith is key to the agreement because the actions flow from the District for the purpose of benefitting the class and for complying with the 8* Circuit commands. We otherwise make reference to our submission of July 8, 2002. 6) Plaintiff suggests that it is not informed of the scope of our rebuttal. The present position of the District is that the ODM assisted the District with its evaluations and assessment and that Ms. Marshall, in particular, consulted with Dr. Leslie regarding certain evaluation reports. Mr. Gene Jones was said to have been a participant in the evaluation process utilized by the District. The rebuttal evidence that they will offer will explain the ODM role. It will also address the issue of evaluation verses assessment which will include the ODM perspective that evaluation differ fromPage Three July 11,2002 look-see type assessment. We note here that Judge Wright had difficulty with the implementation of the evaluation/assessment that appeared on Page 148 of the March IS* report. 7) Plaintiff lists several employee witnesses who will discuss subjects and events that were not included, and which were subsequent to, the March 15, 2001 report. See the references to the anticipated testimony of Dr. Bonnie Leslie which include events that are clearly post March 15, 2001\nthe anticipated testimony of Dr. James regarding any subject because he was not employed by the District as of March 15, 2001\nand the anticipated testimony of Ms. Sadie Mitchell and Ms. JoEvelyn Elston regarding post March 15, 2001 events. The groimd rules for this hearing can only relate to inquiries for information from Joshua or from other parties who are seeking to be informed by District officials of activities and events which occurred and were measured by March 15,2001. Joshua information which is post March 15, 2001 must likewise relate to the status report of the plaintiff for that date. On the other hand, Joshua will seek to exclude documents created subsequently by the District which were prepared for the purpose of buttressing its March 15, 2001 report. The Court has imposed measures to facilitate the trial which are in sync with those followed by Judge Wright. We believe that the observations made herein ai'e absolutely consistent with Judge Wrights earlier ruling and we ask the Court to follow the same process that has been in place during the earlier evidentiary presentation regarding the Joshua opposition to the plaintiffs motion for declaration of unitary status. Thank you for taking the time to read this lengthy letter. fihcferely, 1^. Walker J0hn^. JWW\ncc: Mr. Chi'is Heller Ms. Ann Brown Marshall All Other Counsel of RecordRightFax 7/11/2002 4:23 PAGE 2/2 RightFax EDWARD L. WRIGHT ROBERT S. UNO\u0026amp;r (ISU'IUD ISAAC A. SCOTT, JR. JOHN G. LILE GORDON s Rather JR TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS SUPORD. JR. PATRICK J. GOSS ALSTON JENNINGS. JR. JOHR R. TtSOALE KATHLYN GRAVES M SAMUEL IONES \"I JOHN WILLIAM SPIVEY lit LEE J. MULDROW N.M. NORTON CHARLES C. PRICE CHARLES T. COLEMAN JAMES J. GLOVER COWIN L. LOWTKCR, JR. CHARLES L. SCHLUMBERGER WALTER E MAY GREGORY T. JONES H. KEitH MORRISON SETTINA e. BROWNSTEIN WALTER U^PADDEN KUGgR D. ROWe JOHN 0. DAVIS Juor StUUONS IICNRY WRIGHT. LINDSEY \u0026amp; JENNINGS LLP ATTORNEYS AT LAW 20C VJEST CAPnOL AVENUE SUITE 2200 LITTLE ROCK, ARKANSAS ?2201-3699 (so\u0026lt;)371-oeoe FAX (Sot) 370'0442 WWW.wt).com or COUNSEL ALSTON JENNINGS RONAIO A MAY JAMES R. VAN DOVER Writer'! Direct Diil No. 501-212-1273 mjonesQwti.com KIMBERLY WOOD TUCKER RAY F. COX, JR. TROY A. PRICE PATRICIA SIEVERS HARRIS JAMES U. MOODY. JR KATHRYN A. PRYOR J. MARK OAV'.S CLAIRE SHOWS HANCOCK KEVIN W KEMNfOV jeRRY J. SALUNOS WILLIAM STUART JACKSON MICHAEL 0. SARNES STEPHEN R. LANCASTER JUDY ROBIKSON WiLBER KYLE R WILSON C. TAO MICHELE SIMMONS ALLGOOD KRISTI U MOODY J. CKARLeS DOUSHERTY* M. SEAN HATCH J. ANDREW VINES JUSTIN T ALLEN CHRIeTiHE J. DAUGHERTY. PnO. MICHELLE M KAEMMERLING ERIKA ROSS MONTGOMERY SCOTT ANDREW IRBY HOLLY A AOEE MICHELLE HARGIS OILLARD PATRICK 0 WILSON * Ucsmatf to finetu betor* M UnM 5Ws P9Kn andTrasBour* Office July 11,2002 RECEIVED VIA FACSIMILE JUL 1 1 2002 The Honorable Wm. R. Wilson. Jr. U.S. District Courthouse 600 West Capitol Avenue. Suite 360 Little Rock. Arkansas 72201 OfTlCEOF DESEGREGATION MONITORING Re: Little Rock School District v. Pulaski County Special School District\net al. USDC Docket No.: 4:82CV00866WRW Dear Judge Wilson: A few moments ago I faxed to the Court and the parties a letter concerning Ray Simmon. Mr. Clay Fendley informs me that Mr. Simmon is not listed as a witness on Joshua's revised witness fist\". Unfortunately, I do not have a copy yet of the revised witness list\nprobably will get it In the mail tomorrow. Assuming this is correct, this seems to remove the sole issue from the proceedings that wrould directly concern the PCSSD. Given that, I would request that the Court excuse me both from the hearing tomorrow and the unitary hearings. By the way, I have another case that is hopping in Your Honor's Court that can be keep me plenty busy. Cordially yours, WRIGHT, LINDSEY \u0026amp; JENNINGS LLP MSJ:wmh M. imuel Jones, ID ( cc: Honorable J. Thomas Ray All Counsel of Record 350455-V1mkjt:. nignirax EDWARD L. WRIGHT nD3.1r7J ROBERT S. LINOSEV .'SAAC A SCO7T. JH. JOHN G. LILE GORDON S. RATHER. JR. TERRY L, MATMEWS DAVID U. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD. JR. PATRICK J. GOSS ALSTON JENNINGS. JR. JOHN fi. TfCnALS KATHUYN GRAVES N. SAMUEL JONES UI JOHN WILLIAM SPIVEY III LES J. MULDROW N.M NORTON CHARLES C. PRICE CHARLES T. COLEMAN JAMES J. GLOVER B9WW . LQTMSf. JU Charles l. scHUUMaERGER WALTER 6. MAY GREGORY T. JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER MCSPADOEN ROGER 0. naVfE ' JOHN D. DAVIS JUDY SIMMONS MEN.RY WRIGHT, LINDSEY \u0026amp; JENNINGS LLP ATTORNEYS AT LAW SOI WEST CAP5TOL AVENUE SUrTE 220C Li'TTLc ROCK. ARKANSAS 7220t-56d5 \u0026lt;SC1|371-0808 FAX (SOI) 376-9442 wwfw.wlj.com OF COL'NSEL ALSTON JENNINGS RONALp A UAY JAMES R. VAN DOVER KIMBERLY WOOD TUCKER RAY F. COX. JR.' TROY A. PRICE PATRICIA SIEVERS HARRIS JAMBS M. MOODY. JR KATHRYN A, PRYOR J. nKKf. OAVtS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY 4. SAktlNOS WILLIAM STUART JACKSON MICHAEL D. SARNES STEPMEN R. LANCASTER jVGV ROBINSON WILBER KYLE R WILSON C TAS BOHANNON MICHELE SIMMONS ALLGOOD KRISTI u MOODr J. CHARLES DOUeHERTY* M. SEAN HATCH J. ANDREW VINES JUSTIN T. ALLEN CKRtSTIME J. DAUGHERTY. PKO. MICHEUE M KA6MMERUNC \u0026gt;O9 MOHTQOMeP.Y VIA: FACSIMILE Wrlttr's Dfct Dial No. 501-212-1273 mjonestgwlj.com SCOTT ANOREW tftSY MOLLY A. AOEE MtCHELLE HARflJS DILLARD PATRICK O WILSON ' tcnMOsjnaceMkveinetMee Safei raflw/t M July 11.2002 The Honorable Wm. R. Wilson, Jr. U.S, District Courthouse 600 West Capitol Avenue, Suite 360 Little Rock, Arkansas 72201 Re: Little Rock School District v. Pulaski County Special School District' et al USDC Docket No.: 4\n82CV00866WRW Dear Judge Wilson: I have the Courts Letter-Order of July 11, 2002 and I write in my capacity as counsel for the Pulaski County Special School District I have tried to follow the recent proceedings and I have a general sense that the issues lA/ITnOC^ftr' ____i _i . . \u0026gt; ' Witnesses and exhibits have been pared down considerably. y sole interest in the heanngs next week revolves around Joshua's designation of Ray Simmon, Director of The State Department of Education, as a witness whom they intend to call. If memory serves, he is listed as witness number 29 on Joshua's witness list and will be called to give testimony concerning \"the agreement\" between the State and LRSD. That agreement respects terms and conditions of the loan forgiveness to Little Rock and also mciudes a bilateral agreement between Little Rock and the State concerning a sunset provision  -------------\u0026lt; aw WWI I III 1^ a by which payments such as those for magnet schools and M to M transfers wiii cease. Let me first say I cannot fit this particular testimony and this agreement into the 1 7 uaihiui lit Ulis paiucuiar lesiimony and this agreement into the parameters of what I understand to be the issues that will in fact be addressed next week. Al the same time I do not I ccall an order which specifically addressed Mr. Simmon and this agreement. It is my underetanding that this agreement has never been submitted directly to the Court for approval ar disapproval. However, 'when it first surfaced, I did have occasion to -write Judge 350409-vlnxgii cr ux WRIGHT. LINDSEY \u0026amp; JENNINGS LLP July 11. 2002 Page 2 Wnght advis^ that the PCSSD had not been a party to either the negotiation of or the execution of this agreement and that we opposed it. If this evidentiary item is not going to be addressed during the unitary hearing, 1 would ^peatfuily request to be excused from those hearings. Evenrf it is gohg^o be addre^ed I would ask me indulgence of the Court to simply require the parties to notify me as to approxirnateiy wnen dunng the proceedings this issue might be addressed so that participation could be limited to that wimess and this issue. my 01 position io assess and address this matter today with the presence at the hearing in the morning would not be required, that would be splendid to know. Thank you very much. Cordially yours, WRIGHT, LINDSEY \u0026amp; JENNINGS LLP MSJ:wmh cc\nHonorable J. Thomas Ray / All Cou.nsel of Record ( '^amuelyilli Iones, ill 350409^rivr aA Z/XX/Z.UV\u0026lt;^ H : LJ KAUE. Z/Z ftigntrax .k EDWARD L. WRIGHT (ISOS-ieTT) ROBERT 5. UNOSEv ISAAC A. SCOTT, JR. JOHN G. LILE GORDON a RATHPR JR TERRY I. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD. JR. FATRiCX J. GOSS ALSTON JENNINGS, JR. JQHfi R. TtSOALS KATHLYN GRAVES M NAMUeL JONES \"I JOHN WILLIAM SPIVEY lit LEE J. MULDROW N M. NORTON CHARLES C. PRICE CHAftuES T. COteWAN JAMES J. 6LOVER EDWIN L. LOWTKCR. JR. CHARLES L. SCHLUMBERGER WALYFR E MA* GREGORY T. JONES M. KEITH MORRISON BETTINA 5, BROWNSTEIN WALTER McSPAOOEN NOGisR O. ROWS JOHN 0. OAVIS JUCY SIMMONS KCKRY WRIGHT, LINDSEY \u0026amp; JENNINGS LLP ATTORNEYS AT LAW 20C VVcST CAPnOL AVENUE SUITE 2200 LITTLE ROCK. ARKANSAS ?220l-3699 (SOI) 37i-080e (SOI) 376.9442 ww.w(|.co(n OF COUNSEL ALSTON JENNINGS RONALD A. MAV JAM6S R. VAN DOVER Writer'! Direct Oral No. 501-212-1273 rnjones@wti.com KIMBERLY WOOD TUCKER RAY F. COX. JR. TROY A. PRICE PATRICIA SIEVERS HARRIS uAMES U. MOODY. jR. KATHRYN A. PRYOR J. MARK OAVIS CLAIRE SHOWS HANCOCK KEVIN W KENNEDY JERRY J. SALLINOS WILLIAM STUART JACKSON MICHAEL O. SARNES STEPHEN R. LANCASTER JUOY ROBiHSON WILBER KYLE R WILSON C. TAO BOHAHNCn MICHELE SIMMONS ALLGOOD KRISTI U. MOODY J. CHARLES OOUSmERTY* M. SEAN HATCH J. ANDREW VINES JUSTIN T. ALLEN CKRlSTiME J. OAUGHfiRTY. PnO.' MICHELLE M. KAEMUERUNG SniKA ROSS MONTGOMERY SCOTT ANDREW IRBY HOLLY A. AQEE MICHELLE HARGIS OILLARD PATRICK 0. WILSON * UOBRSM \u0026lt;D tncHec Mlore M UWetf States Pw ano' Tiaatman I ! I I I VIA FACSIMILE The Honorable Wm. R. Wilson, Jr, U.S. District Courthouse 600 West Capitol Avenue, Suite 360 Little Rock, Arkansas 72201 Re: July 11,2002 Little Rock School District v. Pulaski County Special School District\net al USDC Docket No.\n4:82CV00866WRW Dear Judge Wilson\nA few moments ago I faxed to the Court and the parties a letter concerning Ray Simmon. Mr. Clay Fendley informs me that Mr. Simmon is not listed as a witness on Joshuas revised witness list. Unfortunately. I do not have a copy yet of the revised witness list\nprobably will get it in the mail tomorrow. Assuming this is correct, this seems to remove the sole issue from the proceedings that would directly concern the PCSSD. Given thaL I would request that the Court excuse me both from the hearing tomorrow and the unitary hearings. By the way. I have another case that is hopping in Your Honor's Court that can be keep me plenty busy. Cordially yours. WRIGHT, LINDSEY \u0026amp; JENNINGS LLP MSJ:wmh cc\nHonorable J. ( M. ^mu^i J^es. Ill ! Thomss Rsy /* All Counsel of Record 350455-V1'jrm \u0026gt; jvmi w WHLKxC-f*? NO.671 P.2/3 I JOHN W. WALKER, P.A. Attobnby At Law 1723 BsoaDWav Lrmz Bock, Aklucas Telephone (5O1) 374475\u0026amp; FAX (501) 374-4187 JOHNW. Walker SHaWN CHILDS July 15, 2002 OP COUNSEL BOBEET McHENBY. P X DQNNA4.McHENRy \u0026amp;210 HrKDiasON Sgad Linu Rook, Arkansas 72210 PSOtffi: (601) 3T2-5425  PaX (331) STZ-SiSa Email: Mr. Christopher Keller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W, Cqiitol, Suite 2200 Little Rock, Arkansas 72201 Dear Chris\nIn preparing for the heanng, I note that Dr. Bonnie Lesley will testify at approximarely 1:00 p.m. on July 24,2002. lam writing to inform you that I will not object to her testimony with respect to the following statements in your detailed statement of her expected testimony\n1) 2) 3) the Districts compliance with Revised Plan Sections 2.6,2.6.1 and 2.6 J2\nthe section on Advanced Placement Courses on Pg. 36 of the Compliance Report of March, 2001\nand we object to any and all of the remaining proposed testimony foi her which includes, but is not limited to\na) b) c) d) e) f) g) h) i) j) the latest results from the K-2 readily assessments\na description of a recent study conducted by a team in her division on the academic effects of participation by African American students io the Districts Pre-K program for students now in grade K-8 verses the scores of African american Students 'who did not participate\nnew grants to elementary schools for school iinprovenient\nthe post-March State Bench Examinatinns for grades 4,6 and 8\nthe Districts new writing curriculum for Pre-K-12\nefforts by the District at the secondary level and the results achieved by the District so for, two studies related to the Districts Advanced Courses at the .oaenndary level\nthe partnership wifri the Southern Regional Education Board\nthe trend^TBsearch for high schools to admit more and more non traditional students to advanced courses\nthe review of the NaaCPs call for action in education\nw WMursC-f^ NO.671 P.3Z3 1 Page Two July 15,2002 k) D a description of a study that Dr. Lesley conducted on class size at the middle and high school levels and the class sizes of AP courses since March 15 2001\nan update of her testimony from November 2001\nand the Districts plan for implementing new federal legislation and an end the to Districts post Court supervision activities 'a- As you can see, there is little for Dr. Lesley to testify airout from your proposed statement of her expected testimony. Accordingly, she should be limited to the areas that you propose which precede March 15,2001 insofer as the Districts activities are concerned. If you disagree with friis posmon, t^ch e Court has embraced in its Order, and you intend to revisit it at trial, please inform me by return fax. JWW\nIp cc\nAll Counsel of Record received JUL 1 9 2002 OFHCEOF DESEGREGATION MONITORING BILL WILSON JUDGE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 600 W. CAPITOL, ROOM 423 LITTLE ROCK, ARKANSAS 72201-3325 (501)604-5140 Facsimile (501)604-5149 filed U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS July 16, 2002 JUL 1 6 2002 JAMES W Mr. John Walker 1 723 South Broadway Little Rock, AR 72206 BY FAX Re: Little Rock School District v. Pulaski County Special School, et al. 4:82CV00866 Dear Mr. Walker: The clerk reports that you filed no exhibits by 4:00 p.m. yesterday  the deadline for presenting exhibits that would be offered next Monday morning during Joshuas rebuttal. I assume, therefore, that you will offer no rebuttal exhibits. Cordially, Wm. R. Wilson, Jr. cc: The Honorable J. Thomas Ray Counsel of Record Original to the Clerk 1 6-fo -fAf BILL WILSON JUDGE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 600 W. CAPITOL. ROOM 423 LITTLE ROCK, ARKANSAS 72201-3325 (501)604-5140 Facsimile (501) 604-5149 3^IS\u0026lt;fcWF U.S, DISTRICTCOURT EASTERN DISTRICT ARKANSAS JUL 1 6 2002 JAMES W By\n^CLERK \u0026gt; July 16, 2002 BY FAX RECEIVED Mr. Chris Heller Mr. Clay Fendley Mr. Sam Jones Mr. Richard Roachell Mr. John Walker Mr. Dennis Hanson JUL 1 9 2002 OFFICE OF DESEGREGATION MONITORING RE: Little Rock School District v. Pulaski County Special School, et al. 4:82CV00866 Dear Counsel: Mr. Walker called my staff a while ago to say that he thought rebuttal exhibits had to be filed by 5:00 p.m. today. I treat this call as a motion to extend the deadline to 5:00 p.m. today, and it is granted. Mr. Hellers request in his letter is granted, and the deadline of 4:00 p.m. today referenced in that letter is extended until 10:00 a.m. tomorrow. Cordially, Wm. R. Wilson, Jr. cc: The Honorable J. Thomas Ray Original to the Clerk I 1d:u tAA 3U1 J/0 2147 FRIDAY ELDREDGE \u0026amp; CLARK 0002/002 Friday Eldredge \u0026amp;c. Clark HBHOfili. u. FUDaY WILLIAM H SVTTOM, \u0026gt;.A. BYRON M. BIS\u0026amp;UaN. JR.. PA. JOe 0. BELL. r-A. JaMU BUTTKY, yjL nRBosweae s. ubsery. p.a OSCAR E. OA*i$. JL. P R. JAMES C CLARK. JR.. P-A. THOMAS P. LBCCBTT. P.a. JOHN OevBY WATSON. P.A PAUL B DRWHxM in. P A Larrv w. noux P.A A WVetUFT NISBET. JA. P .A James eovajko uarjuS. p.a J. PMXLLJPMALCO.M. p.a. JAMBS M. SIMPSON. P.A JAMBS M. SAXTON. P.A J. SUBPHBRD BUSSELL OL F.A. DONALD K. OACaN. P.A. WlUTAM THQMAS BAXTER. P.A UCHARO D TAYLOA P.A JOSEPH!. HORST. JR. P.A QLIZAUTH tcOOBEN MCOUaY. P.A CKMBTOMTB* rkllbil f.a LaUBA rem^ley smith. P A. BOBERT X SHAPU. WnXlAM M. OBIPPIN UI. r.A. MICHAEL 3. M00R2. P A BiANE S. MAQUY. F-*- 'fALTisx H. BBfil in. P.A KBVtW A CRABS. F.A. attorneys at law A LIMJTCO LlAeiLlTYPARTNlUSKIP www.Frida^firm.eom 2Qt)0 REGIONS CENTER ACO WEST CAPITOt wruuM WAOOELL. JA. TA SCOTT 7 LAWCXrrBB. F A. ROBERT . SCACM. JK. F.A. I.LESSBOWH.F.A JAMBS C. BAIUUL JB.. P-A HARRY A. LtCtrf. T-A. SCOTT M, TUCEER. P.A OUT ALTON wade. P.A HUCX c. CaRBNEB. P.A TONTa P. jokes. P.A David d. wasow. p JEFTEfY R. MOORS. P.A David m. qrap. p.a Lirrkfi ROCK. ARKANSAS 72201*3^93 telephone 501.3702011 ^AA4Wl-37e-2lA7 M25 MOATH FuTAaU. DRIVE. SUITE 103 FAVETTCVILLE. ARKAMSAS 72703^811 TELERhORE ar\u0026gt;.M5-20n FaX476.MS.2147 CAELa OIAINELS SPAINHOUR. P.A 3OW C. 7INCLSY. JB.. JON AMI* BLtZABVTH COVTQUO. F.i A CMiaSTOPURK bARrsOK. P.A PmUt C inQCMAN. P.A BCTTY J. BBMOAY. P.a LYKOa M. lONKBON. Pj\\. James w. smitb. pa. CUPFOXO V. PLUNUTT. DANIEL 1. HBRIUMGTON. P.A. MARVIN L. dULAEBS R. COLBMAN WS*r*OOK. JX. ALUSOM J. CORlfWELL UU4NM. 0EM /jkMV 1. BENDEBH BROCS S. TIDWELL MICBaRLS. KASMEY KELLY MUEWY mCQUBEN jasxnt p. mckay ALSXAhORA A IPfAH JAY T. 7AYLOK martin a. Ka$TEN BAYA14 W. DUKE rasiPSG. HICHOU tOBERT T SMITH RYAN A TtMOTHY C BZnU. T. MlCaSLU ATOB KAUN 3. HaIMULT SABjsSU. COTTOTi MRUP B. wnncoMsKY KRMWi S.RXCCiMS ALAM C. BAT AN UNDSBT M\u0026gt;TOUM aLOaN ROAYTAM M. EDDQUU MKN F. FEUEJUCM OSCOVHSIL B.S.QJ\\*R VUAZAML. TgRBY V1U4AN L. rATTON. IB. H.T. LaMBSUBZ, f.A. lOKM C. eCBOLS, P_A. a.d. mcaluster u / / ZM NORTH Firm STRUT BLVTHEVrLUe. ARKANSAS 7331$ TELERHOH\u0026amp; a70.7fta.2SM FAxro.fft2-3etft CHfUSrOFNER HELLCR UTTUg RCK TEk FAX Srt234 July 16, 2002 Via Fax No. 604-5149 Honorable William R. Wilson, Jr. United States District Court 423 U-S. Post Office and Courthouse 600 West Capitol Avenue Little Rock, AR 72201 Re: LRSD V. PCSSD USDC 4:82CV366\"AT1W Dear Judge Wilson\nI have arranged a time to interview Ann Marshall and Gene Jones. It will not be necessary to schedule any depositions. Yours very truly, Christopher Heller CJH/bk cc via fax: All Counsel of RecordFriday Eldredge \u0026amp; Clark KBXSCBELB- FUPAY (1923-(994) wiluam X. Simon, BYRON M. E1S2HAN. JK. F.A JOEO. BELL. FA. James a. buttry. f.a. FBEPEUCK k. UKEEKY. F.A. OSCAR S. OaVIS. n.. F.A. JAMES C- CLaBK. L. Fa. THOUaS F. LESfiSTT. FA. JOHN DEWEY *ATSON. F.A PAUL 9. BlMllAM (U. \u0026gt;.A. LABRYW. BURKS. F.A A WYOUJfP mSftST.F.A JAMBS BPWaRP KABBJS. F.A I. wnxip MALCOM. T.A Jambs M. SIMPSON. P.A IaMSS M- EAXTOU, .A J. SfBFHBRD RCUEU. OL P.A. DONALD R. Bacon. p.a WTUIAM THOMAS BAXTER. KA KJCHA1U3 P. TAYLOX F.A- JOEEFH E llUkST. JR . F. A EUZaBBTH IOBOEB MUEftAY. 7 A. CnST0\u0026gt;ai( 'HELLEB. rJk. LAUBA HCKSLCA smith, fa. BOBKB.T a. SUAFSA. F.A. vniXAK M. OWrFIN UI. F.A. MICBAEL . ttonu^ P A PUNO S. MACJUJY. F.A. WaLTBB M. EBEL lU. F.A. \u0026lt;4ViN WTLLtAM A. WaDPELU JR.. FJL SCOTT J. LANCA9TXIL r.A. BPSBBT 9. BEACH. JIL. KA i. Ua SBOWM. F4K- JAMP9 C. ttAKKX. JR., P A liAKBY UCW^.K*. SCOTT B. TUCKWL F-a. OUT AVtOV * . A- MtlCB C- 0 ARbNBA. TJt. TOWa ^. ioms. F-A. lUVlS O. W1L90N. FA. JITnSYK MOOU. f.A. OAVID M GRAf. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayftrm.com 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK. ARxaNEAS 7220l\u0026gt;34e3 TELEPHONE 501-S76-2011 FAX S0*..378.21Ar 9424 KORTH FUTRALL ORIVS, SUHE 1M PAYCTTEVILLe. ARKANSAS 72709^151 telephone 479.4-:0t t FAX A7O.\u0026amp;S\u0026gt;2147 CAltLAOWieU B7AINM0UB. T.K JOHN t- TBNftlST. J3L. F.A. lONAXN KLOABBrn COMICUO. F A 8L CiBSran{C\u0026amp;t.AWtdN. r.A. flAN C. HICKMAN. .A. 0rTV J. OKtiOAi. \"t.A- LYNOA m. jowuqk. fa. JaMRS W. SUtTB, F.A. CLinou) V. nmtKTx. f.a Daniel l. Koajuoiw. MARVOtU CUILPERS C. COLEMAN WSST^MOOK. JR- ALLISOH I. CCMtfVBLL CLUtN M. OVENS JaSON ft. MMOftm ORUCS ft. rmvcu. MTOun. 1. KAWMnr KELLY MURFITV MCQUEEN SOSKFM F. MCKAY aLCXANSIU iruui JAT T. TAYLOTL MARTIN A. tUOrBN SKY AN W. DUIU josfinic fmcwols KOuerrt SMTTB ftVAN A. BOWMAN 'nWQTWY c exell T. MICHELLE ATOR KAMN S. UALUET SAKAO M. nUUf B. MONTGOMUY laOSTEN 3- VOOTKS ALAN 0. BJtYAN UN1M\u0026amp;V kOlCUAM LOAN KHAYYAM K COOmOS JOHN F. PEUBUCti OrCMWCEL b.s.Claix WiUiAM U TERRY WIUIaM U FaTTOK. JR. H.T. IaBFJIFBF fa. JOHN C. EOHUJS. FA. AD. MCALUSTER 2 mOATN fifth STREET BkVrHSVtLLE. aAiCAMSAS 7291 TELEPHOHE a7d*7\u0026lt;2-34M FAX B7.T2..2et e CMai8TOFH MetUfiR urrru aock T6L PM MV2-394 nNr\u0026lt;f.t July 16,2002 Via Fax No. 604-5149 Honorable William R. Wilson, Jr. United States District Court 423 U.S. Post Office and Couithouse 600 West Capitol Avenue Little Rock, AR 72201 Re: LRSD V. PCSSD USDC 4\n82CV866WRW Dear Judge Wilson: I told the Court last week that I would prefer to interview rebuttal witnesses Ann Marshal) and Gene Jones than to depose them. I am confident that interviews can be arranged but, in view of the fact that Ms. Marshalls husband ranains hospitalized follovTug surgery, I would prefer to wait to talk to her until such tune as she contacts her office rather than attempt to track her down al the hospital. I have hesitated to contact Ms. Marshall for two reasons. First, I wanted to be sure that Mr. Walker was aware of her situation and still intended to call her as a witness. I spoke with Mr. Walker yesterday and he was unwilling to say that he would not call her. Second, I wanted to see whether Mr. Walker would submit anyrebuttal exhibits bythe Courts deadline yesterday afternoon.lUvvj' wui\u0026gt; Hon. Wzlham R. Wilson July 16,2002 Page 2 I have left word with Ms. Marshalls office to have her contact me at her earliest convenience and I expect to hear from her today. I therefore request an extension of the time within which I may notify the Court of my intent to schedule a deposition rather than an interview until 4:00 p.m, today. Thank you for your consideration. Yours very truly Christopher Heller CJHyQ)k cc via fax: All Counsel of RecordO^/IO/ZOOZ ix: exboasiaa PAGE 02/02 BILL WILSON JUDGE UNITED STATES DISTRICT COURT EASTEBN DISTRICT OF ARKANSAS 800 W. CAPITOL, ROOM 423 LiTTLE ROCK, ARKANSAS 72201-332S (501)804-5140 Facsimile (SOI) 604-5149 July 16, 2002 Mr. John Walker 1723 South Broadway Little Rock, AR 72206 BY FAX Re\nLittle Rock School Distria v. Pulaski County Special School, et al. 4:82CV00866 Dear Mr. Walker: The clerk reports that you filed no exhibits by 4:00 p.m. yesterday  the deadline for presenting exhibits that would be offered next Monday morning during Joshua's rebuttal. I assume, therefore, that you will offer no rebuttal exhibits. Cordially, Wm. R. Wilson, Jr. cc: The Honorable J. Thomas Ray Counsel of Record Original to the Clerk FRIDAY Eldredge \u0026amp; Clark 'MBBACREL H. PBXDat tlP22t*\u0026gt; VaUAM . fiVTTON. P JU SYBOM M BIUMAM. JA. PJU 9OS\u0026amp;BB1X.PJU MMSS BvrTAY. r.A FRSmiCK g. VUtY. OZCAA B. DAVIS. J*.. P.A. JAMBS C CLARK. JIm?. A TNOMaJ F. UCCETT. Fji. lOHNOEVEY VATSON. F.A PAUL B. BEKXaM nt P.A LAMY W. RUBES. P.A. A WYCXUPTHUBET. JI.. 9JL. KAJUnt.  A. J. FSILUF MALCOM. P.A JAMBF M. TmP5e\u0026gt;K. P-A- JAMBf K 9AXTON. P.A. J. 5M8PMUD KUISBLL m. P.a. DONALD H. BACON. P.A. VZUJAU THOMAS BAXTER, .'j RTCHARO D. TAYLOA P.A. jo37u\u0026gt;. mnEr. jk. pja tLOANETN IhOMCM MUiAV. *. causTonnt Biun. pju LAUtA MBNSIBY pcnK. lOSXlT L SKAfEI. r JU VtUlAM M. OUmM U. MiCHAfiL C. MOO9A. .A. OlANE 9. MACKEY. P.A. * alter M.BML nr. rrnw oau. p.a. VOUaM VAOOCIX. nu. P.A. scorr X lancastba pju ftOaSBT a. RRAOt A.. P.X J. UCE BBOVN. P.A. James C-N\u0026lt;era ia.p.x Harry A. LIO ST. P.X 9COTT H. Tvexn, P.X GUY AXTON VAOA PJU TTUCS C. G.MtDNCB. P.A. TOMA P. JONBS. 9AV D. \"TUOA r JU APPUY K MOORE. FX. DAV7D U. 3RAF. aTTOANCYS at UAW A LIMITEO UlABKITV PARTNSRSMIP ww.\nnaaynn.com 2000 ACGIOHS eSMTCR 400 WBST CAFITOL utrruc ROCK Arkansas 72201*3493 fAX 501-378-2447 9425 NORTH FUntAU. ORJVE. SUITE 103 FAYeTTeVit.LS. ARKANSAS 72700-4111 rtAfiPH0N6 47B.4B6.24n FAX 47B.44S-2147 CaBAA GUVKIL2 ttAlMMOUA P.A fOtOI C FOfOLEY. fJL wyak V, evst J0SETH0.WC80U AMAin* aiizA*T ooMOLMi unsxT T. mmi A ClUttfTOPHER LAW50W. PJU PlAN C. KKXMaM. g.A. Bem). MMOBY. rju LYMDa M. JOHNSON. PjU JAMES V. SMTrn. PJU CUFPDXD V. PIUNUTT. PJU DAMEL U iflEfUlINCTON. 7ju MaB YIN U CmLOEU K. COLEMAN VtSTBBOOIC. lA ALU6OMJ. COBNVBIX nxswALomm JASON A HBHDBEN MUCBAnpwHL UICBaEL A KaBNEV KEU.Y MDKRtY WCODEEN JOCEPtt P. MCKAY ALSCUtORAX :ritAtt JAY T. TAYLOB NA\u0026amp;TDf sAsnof AYAN MVMAM nMOTW C EZSU. T.MICKSUZArOA KAUN S. KAUUI iAAANM. COTTON NHUr 9. MONTGOMTAY aurnNKUMtNS KLAKa.BXYAN LINKBY MITCUAM 4U\u0026gt;AN KUATTAM K. SOMfCS JOHN r. WUUCK OrCWFCBA *4. CLARK VtLUAMUmRY VaUAM U PATTON. JA AT. LARZBLBRA r./L j\u0026lt;no^C.BCaOi4, r.x xB.HCALUmA TSLSPHOME f0l.97t4e^t 204 mOBTM fifth STHeET BLYTMeYKLe. ANKAHSAB ItM iT9-792-i9M PAX 97A.742-2A14 jQMtt C. FCNOACY. JM. Um,* ROCK tel 59t3TWa39 fn 591-344-SM1 July 17,2002 The Honorable William R. Wilson, Jr. United States District Court 600 W. Capitol, Room 423 Little Rock, AR 72201 VIA FAX: 604-5149 RE: LRSD V. PCSSD, No. 4:82CV00866 Dear Judge Wilson: This letter is in response to the Joshua Intervenors letter to the Court dated July 16,2002. At e July 12,2002 hearing, the Court noted that Joshua failed to identify exhibits which would be introduced through the rebuttal testimony of Ann Marshall or Gene Jones and ordered diat Joshua identify those exhibits by 4:00 p.m. Monday, July 15,2002. In their letter of July 16,2002, Joshua identified seven exhibits for this purpose. However, only one (CX 599) had been previously identified by Joshua as an exhibit. The remaining six are being identified as exhibits for the first time - almost a month after the Courts original June 21 deadline. For this reason, the LRSD asks that these exhibits be excluded. Joshua represented to the Court that Marshall and Jones testimony was to respond to testimony offered by Dr. Lesley concerning their involvement in the program evaluation process. The LRSD has reviewed Dr. Lesleys testimony and can find nothing to support JoshuasThe Honorable William R Wilson, Jr. July 17,2002 Page 2 representation to the Court. So that the LRSD and Court may be properly advised of the testimony to which they are the LRSD asks dial Joshua be directed to identify by page and line number the testimony of Dr. Lesley which readers this rebuttal testimony necessary. In its Motion in Limine, the LRSD objected to Joshuas reading into evidence all of the depositions of Board members because the entire depositions were not related to three issues for the July 22-26 hearing. The Court ordered Joshua to provide page and line designations to facilitate resolution of this issue. In their letter of July 16, Joshua for the first time asserts that the Board member depositions will be read into evidence for the purpose of rebuttal. With one exception (Dr. Katherine Mitchell, page 27, lines 13-23), the testimony designated by Joshua relates exclusively to the issues of achievement and program evaluation. The LRSD asks that Joshua be prohibitsd from using the depositions for rebuttal purposes. If the C ourt allows Joshua to read the depositions into evidence, this time, including the time reading the LRSDs counter-designations (see below), should be counted against Joshuas 30 minutes to present rebuttal evidence. Fed. R. Evid. 106 provides: When a writing or recorded statement or part thereof is introduced by a party, an adverse party may require the introduction at that time of any other part or any other writing or recorded statement which ought in taimess to be considered contemporaneously wi it. As the LRSD understands Rule 106, it requires Joshua to read into evidence the LRSDs counterdesignations. Accordingly, all of the time required to read into evidence the depositions should be counted against Joshua. Should Joshua be permitted to introduce the Board member depositions as indicated in their letter of July 16, the LRSD hereby identifies the following pages and lines which ought in fairness to be considered contemporaneously therewith: Ms. Suc Stri(land  Page 1 i, lines 10-25  Page 12, lines 1-13  Page 13, lines 18-25  Page 14, lines 1-17  Page 16, lines 20-25  1*7,1*9  Page 20, lines 9-16  Page 24, 'lines 19-23  Page 26, lines 1-7The Honorable William R. Wilson, Jr. July 17, 2002 Page 3 Dr, Katherine Mitchell  Page 6, lines 22-25  Page 7, lines 1 -3  Page 8, lines 17-25  Page 10, lines 7-25  Page 11, iines i-6  Page 13, lines 7-17  Page 14, lines 10-23  Page 15, Unes 6-9  Page 16, lines 10-23 * Page 18, line 25  Page IS, line 1-5  Page 20, lines 7-11  Page 24, lines 1-3  Page 25, lines 22-25 (related to advanced placement)  Page 27, lines 2-12 (related to advanced placement) Tony Rose  Page 5, lines 18-25  Page 6, iines 1-4,11-19  Page 7, lines 3-9  Page 8, lines 18-25  Page 12. lines 9-14  Page 13, lines 3-7  Page 19, lines 1-23  Page 20, lines 20-25  Page 21, lines 1-23 Judy Magness  Page 19, lines 1-16  Page 21, lines 20-25 * page 26, lines 1-17  Page 27, lines 14-25  Page 28, lines 1-3,19-25  Page 29, line 1  Page 40, lines 19-23  Page 41, lines 11-22The Honorable WilKam R. WSson, Jr. July 17,2002 Page 4 Larry Berkley Page 7, lines 2-20 Pate 12, lines 23-25 Page 13 Page 14, lines 1-15 Page 27, lines 1-13 Page 30, lines 21-25 Page 31 Page 33, line 25 pages 34-35 Page 36, lines 1-15 Thank you fot youT time and attention to this matter. Sincerely, John C. Fendi \u0026gt;, Jr. cc\nOriginal by Mail to Clerk The Honorable J. Thomas Ray via fax All Counsel via fex07/18/2002 11:16 5016045149 PAGE 02 RECEIVED JUL 2 2 2002 OFFICE OF DESEGREGATION MONITORING U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS JUL 1 8 2002 ARKANSAS JAMES W McCORMACK CLERK OFFICE OF THE ATTORNEY GENERAL Mark Pryor Attorney General Attorney General Civil Department Direct dial: (501)682-2586 July 17, 2002 r / The Honorable William R. Wilson 1^/1^' United States District Court 600 West Capitol, Suite 423 Little Rock, AR 72201 ^JUL 11 2002 - 5- Wilson, Jr P, District Judge E.D. of Arkansas School District v. Pulaski County Special School District, et oL Case No. 4:82CV0866WRW/JTR Dear Judge Wilson\nOn behalf of e Office of e Attorney Education in the above-referenced matter,GjJ^tfunylEqucst'thaT AvinAntiOtnr *U T Ar. .r. ___ ___ ____ counsel for the Arkansas pepartment of Ute aouvc-reierenceo matter,(4xesgecfl^y requestthat we be 5iS^from the final iSTCraiJfySuiSset (0 begin on presentation of evidence by Joshua and the Little Rock School em^ning issues ndoote sin nteont da ppear to require our attendance at the hearing and we do not mtend to examine witnesses or oerwisten pAavratmicmipAat etr.it^xar.^n ^a.1_______:_________iivu4XX^ OiAU WC UU Thank you for your consideration of the foregoing. Very truly yours, DENNIS R. HANSEN Deputy Attorney General DRH/km cc: The Honorable J. Thomas Ray Mr. Christopher Heller Mr. Samuel Jones, 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:\\Civil\\DennisH\\de5eg\\2002\\Correspondence\\jijdge)trt)7-17.iloc RECEIVED JUL 1 9 2002 . CmCEOF ^SIGfiEGAflON MONITORING STATE OF ARKANSAS OFFICE OF THE ATTORNEY GENERAL Mark Pryor Attorney General Dennis R. Hansen Deputy Attorney General Civil Department Direct dial: (501) 682-2586 E-mail: dennish@ag.state.ar.us The Hoi ^le William R. Wilson July 17, 2002 Unij^States District Court West Capitol, Suite 423 tittle Rock, AR 72201 RE: Little Rock School District v. Pulaski County Special School District, et al. Case No. 4:82CV0866WRW/JTR Dear Judge Wilson: On behalf of the Office of the Attorney General, counsel for the Arkansas Department of Education in the above-referenced matter, I respectfully request that we be excused from the final evidentiary hearing on the Little Rock School Districts Motion for Unitary Status 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. Very truly yours, , DENNIS R. HANSEN Deputy Attorney General DRH/km cc: The Honorable J. Thomas Ray Mr. Christopher Heller Mr. Samuel Jones, 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:\\Civil\\DennisH\\deseg\\2002\\Correspondence\\judgeltr07-17.doc received JUL 1 8 2002 SNmoiiNow Noiivsauoasaa United States District Court EASTERN DISTRJC OmCEOF ITLE 61^MWSKSS?, iCT T TTTT i: onrv U.i ARKANSAS EION IRT eastern district ARKANSAS JUL 1 1 2002 LASKI COUNTY SRECIAL SCHOOL DISTRICT, ec JAMES W McCORMACK, CLERK 1U . THO\u0026gt;LAS RAY '9, 2002 nu\u0026lt;r Christopher : I 'Ca^Tyn Eant .Isr, et '^P.CLERKj 2002 8 T Ifir caAlgQiH Case NUNIBbR\n4:82CV00S. iMva*k*rian^(r Sam Jones, r^ttfnoaa OtMTT ec al. I I Kat'nv Swanson ourt xhib s ^4^ 1 .'-'daTctC .OF7ZRSO \"bbk. -SCO-.-' re L^I - \"CoiiilZ. pyi- 0 0. -OI DESCKIFTTOK.OF EXHIBITS - y- 3 I o.. Tb oVn ~ \"Q-rYidGG, G/- I dA^- GV- i^\\ J I CI 94^ I I I ex qsT ex 9^1 ex -752 I ex iz\u0026gt; 1 \\ \\ _\\ i I (^-fKtZlZ- chzijL:^ U - lie -Oi? '1 - co - CC ,^rn, l!^ ZL5 Ji k h \u0026lt;i'3-o7-c?i \u0026gt; fb \" y - .1 . ,i i .-^ d , IJ z,- . - ~ /I C'l/TyoAiL C'^-\\i^-ol GJb\\^ Cpj-f^ 6 '/i (C'hijXijl , I J _ I, -- ___--.^ - 0-^ A^: 17b /I ex .'Y^ydj-L-^-, eA. Uy I'jGi /4 39 D U ) - /\" IUnited States District Court EASTERN 1 tt't\nDISTRICT OF n Bnrv ARKANSAS DIVISION lTtle rock school district EXHIBIT LIST ULASKI COTOTY special SCHOOL DISTRICT, ec al. Case NUMBER\n4:82cvooi M K.'SCK J. THOMAS RAY JULV 9, 2002 Court's . Exhibit .,-DA~:,- - - OFFERED - OOI 2 aCreaKT Christopher\nTTarolvn Fant red. eller, et al. 90V**n alfteMT Sam Jones, et al. raurrtMa ovwrr Karhv Swanson fa DHSCPJPTTOKOF'SXHISITS - /Li,' .Oc-co -o\\ _____________________AgT Cl/el Sb ) cLiiAlil G\u0026lt;e-Ac\u0026gt;~ol ~ - fv-CGc,'/-,^ /1A' \u0026lt;3-\u0026lt;J- Sz-Y^/^ C:li\u0026lt; 'c Ogi-1:5 'c (3-LI. I /t/ru..AXx iri fc:YfcO I j CX U (l\n3 I Ci TfcM j I CX 1. CX f LvI.7 i i i CX I \\ i / CX ( L'-nu.vL -12 -0 I CiXLTxMi.. S \u0026lt;3^L i\\-n-0G ^~YyL''L/i- l~bLLj^ ^Ajl- G^'':q-cc ctai-. 'f  Cl J Tc A' ttasAL- ry\\2,^2^L2JlSLl 2, TKEfcA^iiZ to- LC\u0026gt;\u0026lt;^United States District Court EASTERN ____DISTRICT OF T TTTT ARKANSAS _ DIVISION ETTLc. ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, ec al. CASE NUMBER\n4:82CV00{ J. THOMAS RAY JUlv 9, 2002 I Christopher icpwT _ Carolyn Fat eller, et . Sam Jones, et al. raaiBMMOuvn Kat'nv Sw\nor. Court's . Exhibit o\n.-DAx RED - :-~'DESCRJPTTGIN:OTS\u0026lt;HI3ITS :\u0026gt;s-oo -fv lex i lex 1 pE 'Q'-tQ ! I ex I ex ex ex \u0026lt;3,0 \u0026lt;^0 I ex '15i :x L i i ( Jiati, /o - lo -cc 7\u0026gt; CJZXZZ, c\u0026lt;i-^l3-oc { Sec'}.. CPaj\u0026gt;^. O5~-p,^-o( o-Q -01-oc \u0026lt;(Z-Yy^'^C Z 1 . dJ / 1 \" I /C ~h) 'ii-~z^ :7 (OXCtlX-zc.! A 7United States District Court EASTERN DISTRICT Or T TTTT r -pnrv ARKANSAS DIVISION ITTLE ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, ec al. CASE NUMBER: 4:82cvooi HOMAS RAY Cn scooner eller, et al 3m ^rbd JUV 9, 2002 1 Carolyn Fane awmun^  rmjT Sam Jones, et al. rwn094 /VfT Kathv Swanson_____ Coure's . Exhibit ..-DATE-'-' -OFFERED ' obi. satx - 'r-lDESCRIPTtOKOF'SXAlHlib.  0 1 I -^ci -^cc (y-^jbrd- IhzM C ex I I OKI 1 1 I I ! -hl '-Dtrz^ te I -.m\" / A  I /2\u0026lt;, C 0 KKOA-Cjiy^ 1 (kzklt. \"^Ua-I \\ ' i jcx-'7i3g.| I kx I I p-i lAXZ, '1 I X i\u0026lt;zvLt^ /Uy' c'YYf \u0026lt;''j Kt I IT Taite,rtUnited States District Court EASTERN DISTRICT Or 1 tttt Tsnr ARKANSAS _ DIVISION .ITTLE ROCK SCHOOL DISTRICT EXHIBIT LIST /. ULASKI COUNTY SPECIAL SCHOOL DISTRICT, et al. CASE NUMBER: 4:82cvoo J. THOMAS RAY I jurv 9, 2002 Court's . Exhibit 0931 C9^3h Christopher Helle Carolvn Fant e acro*xT\u0026gt;  n^MT San Jones, et rournoBiouw ^^^^^^anscn al ..-DAx:\n-'.- '  OFEERZD  -7, \u0026lt;7,03, OOI. sno-.. DESCRIPTKM.OF =:\u0026lt;Hi3rTS i ! 1 I I cxU'?! icK n :xT9% CX ,^0.1 Q' 'T^y^ Ki- Llty ~7^ (-yr z P/P- (i-rT\u0026gt; 3jOgc .^o( /^i rY\\i2.' T c -0( f I -h(~2:,^~aQ )________ Cp-pp- S10-? 1 ._6^.sLZdMUr^Un2W^United States District Court EASTERN DISTRICT OF T TTTT g ARKANSAS DIVISION LITTLE ROCK SCHOOL DISTRICT EXHIBIT LIST V. PULASKI COUNTT SPECIAL SCHOOL DISTRICT, eC al CASE NUMBER: 4:82cvoc \u0026gt;4\u0026gt;CXU J. THOMAS RAY a** teTllO JUIV 9, 2002 ACreuavr Christopher Heller, et al 1 ocallyn Fant Sam Jones, et al. ('Qtanaa. ew\u0026gt;^ Katb.v Swa mhI Court ' s Exhibit ..- DAin-'.-' --OFrH^\u0026lt;D OOI. san-. DESCRIPTION'.CF^CtIBITS  -J- \u0026amp; C/i ?ol a. ------------------------------------------------- ------------------ X. lex I 1 :j2Av\\ii^ -v^ hlCTf^^ Ho 4 1 I \\inLAjp (jy Tii k t Z' -ri) I ex ?0'? (2j! ex ^0^ I ex i 0 J r 1 \u0026gt; y-33-- C'Cc^TTL^^ I'-rn- tt. oH. ?L\u0026lt;_zH i(^- ! i I 'T\u0026gt; /- oi-i -Clr^^ tv ^?-0iyyiP. U '4United States District Court EASTERN T 7TTJ DISTRICT OF RO'^v ARKANSAS DIVISION lTTLE rock school district CLASKI COUNTY SPECIAL SCHOOL DISTRICT, eC al. M AAA J. THOMAS RAY Christophe Heller, aM*4*n\u0026lt; JUiV 9, 2002 Courts . Exhibit ..-DATE:-' - - OFFERED - 00'. 'saui l.rarpTyn Fant EXHIBIT LIST CASE NUMBER\nSam Jones, et al. rTea wvrr Katb.v Suanson DESCRIPnOKOF HXHBrrS 4:82CV00? a. -'--a.^j'Sx 0(0 o cx'2)M ~h\u0026gt; S\" 1 rt Q\u0026gt;)^ ^iic/yor^- P-12.^ I i ex 1 ?\u0026gt;ll^ 'TO'^\u0026lt;7\u0026gt;ve '~ic\u0026gt; PpA jTfyjticCz, !- ^-) f gl'? I ! Cl-Q pI - X-  U ^('S I I I 1 '7j u I : (PP r ex. ^0 '3-1 ex cr. sx D4 _- __-Z  ,.-Z U-.S . u.TJ nt' '  ' ' i I Q, /HoiX Tt '^ ') Lrilrtnsmsi J -6)1 f^: u.Pq^ U-PUP_ \u0026lt;9^ Cl | 4^ _______ - I EH BOiUnited States District Court EASTERN DISTRICT OF 1 TTTT u Qnrv ARK.ANSAS DIVISION ITTLE ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNTY SPECIAL SCHOOL DISTRICT, ec al. CASE NUMBER: 4\n82cvoo J . THOMAS RAY JUJ.V 9, 2002 Christopher I IrauirwmTu _ ..Carolyn Fant Heller, et al Sam Jones, et al. rvanoB. owwrr Ka^hv Swa son Court's . Exhibit ,75 ATE:'-' - .- Crr:z:\u0026lt;^ '' obf,'- 'SQOi. *  red. '^'DeSCRIPTTONIOFHXHIBTrS- ' ex i ''i I |CX 7 '-fl I 1 tx 1 1 CH I Z'^ ex I CFr-i\u0026gt;/Di (( -'^'?~^73xGo5'3 -j-i aJL^ 1 6-^S'-c2cd8:) ss Ulf / 0 3C-O1 c -ic ct: *63^ 1 Cl ex 137 I X 331 i C ) _______ _________ ________,, Z\u0026gt;PC /--:\u0026gt;? J' ri \u0026lt;^ /\\ n . -7  zz. ! /'^ . ' OKUnited States District Court eastern DISTRICT OF ^cry ARKANSAS DIVISION ^TTLE ROCK SCHOOL DISTRICT EXHIBIT LIST rt-ASKI COUNTY SRECIAL SCHOOL DISTRICT, et al. CASE NUMBER: 4:82cvoo8 . THOMAS RAY JUIV 9, 2002 Christopher Heller, et al. i ^rolvn Eant Sam Jones, et al. I I Kathv Swanson Court's . Exhibit ,.-DA.TH:.-' -  Qrr\u0026lt;SD' oo. sua  * ''red.' V-TD5SCRJFn0K0F3G3SITS-' CX S39 a CiL - 0^0)/! CX ^40 -O! CX I ^41 /\u0026gt;ro\nio3Z/'7 CX p. S\u0026gt;4S I 1 \\ 1^ ^.y-T CX I -^CP i}~J- ' 'D'0^^2-r^v\u0026lt;\n~/S) \u0026lt;? ^D^i i. f 2i^oo-WI CtjL:, -3\u0026gt;l /2^ CX 'iUY ^^-\u0026gt;3-0! ryy^cCc'Xsi^ C\u0026gt; J CX ^4^ L'l.Liy i ?e7) \u0026lt;:\u0026lt; ( CX L / O-3-^--o -tT\u0026gt; SaiiZc? iP \u0026lt;zJL dLz^ ll-Oy-C)( , . SPjP I -O'^L/s 3\\ C  fHJ.United States District Court EASTERN DISTRICT OF T TTTT T pnrv ARKANSAS DIVISION ITTLE ROCK SCHOOL DISTRICT EXHIBIT LIST ULASKI COUNIT SPECL.A.L SCHOOL DISTRICT, et al. Case number: 4 s 2CVOO$ 0. THOMAS RAT ArTMwrT '9, 2002 Christopher Heller, et al - llCa^Tyn Fant Sam Jones, et al. Kathv Court' s Exhibit ex ex r t ..-DA.TH'\u0026lt;.' - .OFFFRE3 ~ 001, PESCRiroON'.bF'Sg-IBTIS ' ' ^'O\u0026amp;O - -h J (  o\u0026gt; (2\u0026gt; I 2*-^ p i I / 7 7- iV- c DI 1 i CI I -TTi Z-O?'.- I ^Cbf - J ex ^5-^ 1 ex 8^ 1^0 I ex oAiO- 1 t :x C')- Tt u-x\u0026gt;-5vrJ A-^^-f^TU^/ H-\u0026gt;' oC.'^^dL -=a ? 3^-0 1 412:=UX^L=_^Tl22_A2Zt^^_______________ g-? t U f I f V  I  I . bO, (jy- /7/C \u0026lt; i ^CCC ('1'-^-is 7--6Wj fi 10United States District Coun EASTERN DISTRICT OF ARK.\\NSAS DIVISION lttle rock school district tXHIBI i LIS i ULASKI COUNTY SPECL4L SCHOOL DISTRICT, et al. CA.seNUMBER: 4:82cvoos M.\u0026lt;CC ll ABk* J. THOMAS RAY JuXv\" 9, 2002 Christopher Keller, et al. l/Ca^lyn Fant Sam Jones, et 'BkSTMnagwvn Kachv Sva lA son al Court's . Exhibit ..-DA\" .-OrEE:  OOI. snu-. '' ^-^DHSCRIPTTONIOF SCTSrrS  ' ex I ex iex ex I ex I p 1 icx I i ex L ex cc I ex ex '^C^o  oi CJ7 ____________a.______________________________1________________ U. PAJL-}^r\u0026lt;:6h ' IBILL WILSON JUDGE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 600 W. CAPITOL, ROOM 423 LITTLE ROCK, ARKANSAS 72201-3325 (501)604-5140 Facsimile (501) 604-5146 July 19, 2002 BY FAX Mr. Dennis Hansen Deputy Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201 RE\nLittle Rock School District v. Pulaski County Special School, et al. 4:82CV00866WRW/JTR Dear Mr. Hansen: You may be excused from next weeks evidentiary hearing in this case at your discretion. Wm. R. Wilson, Jr. cc\nThe Honorable J. Thomas Ray All Counsel of Record Original to the Clerk 20/SG 39Wd 6tTSt09T0S 2t\u0026gt;:ST 2002/6T/Z0 RECEIVED John W. Walker, P.A. JUL 3 0 2002 OmCEOF DESEGREGATION MONITORING Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Ro.w Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mchenryd^wbell.net Via Facsimile: 604-5149 July 19, 2002 Honorable William R. Wilson United States District Judge 600 W. Capitol Suite 149 Little Rock, AR 72201 Dear Judge Wilson: One of the witnesses that we listed Ms. Ethel Dunbar, Principal of Franklin Elementary School has been subpoenaed for the 8:30, July 22, 2002 hearing as directed by the Court. She 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 as a witness on Wednesday. I see no problem in having her appear on Wednesday other than your Order. The District, I am sure, will also want her excused if it is also possible. I am therefore writing to request that she be allowed to report on Wednesday morning, July 24, 2002, rather than July 22, 2002. Thank you for whatever consideration you may give regarding this request. /Jo W. Walker mcarelw^ JWW:lp cc: Honorable J. Thomas Ray Mr. Chris Heller Ms. Ethel Dunbar JUL.19.2002 1:06PM JOHN W UtfILKER P A NO.738 P.2 .JOHN W. WALKER SHAWN CBODS John W. Walker, P.A. Aitohney At Law 1723 Broadway LmiB Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (601) 374-4187 Via Facsimile: 604-5149 OP COUNSEL ROBERT McKENRY. PA DCNNa J. McHENRY 8210 Hbowsw Road Lnru Hock, Aixaksas 72210 PEOM\n(501) 372-3425  Pax (SOI) 372-3428 EaUIL\nmdhBnrydatwbtll.ntt July 19.2002 Honorable William R. Wilson United States District Judge 600 W. Capitol Suite 149 Little Rock, AR 72201 Dear Judge Wilson: One of the witnesses that we listed Ms. Ethel Dunbar, Principal of Frankl in Elementary School has been subpoenaed for the 8:30, July 22,2002 hearing as directed by the Court, She 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 as a witness on Wednesday. I see no problem in having her appear on Wednesday other than your Order. The District, I am sure, will also want her excused if it is also possible. I am therefore writing to request that she be allowed to report on Wednesday morning. July 24,2002, rather than July 22,2002. Thank you for udiatever consideration you may give regarding this request. loJ W. Walker JWW\nlp cc: Honorable J, Thomas Ray Mr. Chris Heller Ms. Ethel Dunbar 07/19/2002 13: 54 5016045149 PAGE 02/0: cf JUU.19,2002 jOHT-i w wfaj\u0026lt;S p s NO.732 P.2 ^w.wm,P.A. ASKOiOa kill's 172S BeoADWAV (MW 3743 (6e J!aX (901) 3/4-4187 or sy riSSS: WST eioSBonBral^ tziwt AmtOM iSni)  . Fa(S01\u0026gt;S7S4428 Joauwjfw^ VU FKSiB\u0026gt;UT 604-5149 July 19,2002 b L. / Honorable WlHam R. Wflson LIniled Statea District 600 W, Capitol SuilB 149 Little Rock, AR 72201  Ji I .... iv/vvcvit- t/' Cf If Dear Judge Wilsooi Piujcaipneallo ofFt hTrSannkKlmnaE clrjahmueolary\n. , nup^, n ijjB'[)vputBaeato{'S^}3esl\u0026amp;osi. J_ Wedaesd^. iaeetFo*l District, I am sore, wfi also Oneofthe^dtnesa^^l^Hsted^-g^^^^ _ School has bean siibpocBaed has caUedmeto ask excuse ^cdSHsee - woiU Ttei you '-hew W. Walker JWW-.^ OC: HoootaWo J. Thomas Ray Mr. Chris Heilw Ms. Ethd Dunbar 10/10 39Vd \u0026amp;frXS\u0026gt;09T0S 8T\neT 2002/6T/Z0 07/30/2002 16:38 5016045149 PAGE 02 eiUL WILSON juase UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 600 W. CAPITOL. ROOM 423 LITTLE HOCK. ARKANSAS 72201-3325 (SOI) 604-5140 Facsimile (501) 804-5149 July 30, 2002 BY FAX Mr. Chris Heller Mr. Clay Fendley Mr. Sam Jones Mr. Steve Jones Mr. John Walker Mr. Richard Roacheii Mr. Dennis Hanson RE\nLittle Rock School District v. Pulaski County Special School, et al. 4\n82CV00866 Dear Counsel: We recently received a letter regarding the above-referenced case from Ms. Cathy Cagle, a teacher at J.A. Fair High School. Judge Wilson has not read the letter, and he does not intend to read it unless it is brought to his attention in due course by one of the parties. I am forwarding a copy of the letter to all counsel. Sincerely, Christina Rose Conrad Law Clerk to Judge Wm. R. Wilson, Jr. cc\nThe Honorable J. Thomas Ray Anne Marshall Original to the Clerk* 07/30/2802 16:38 5016045149 PAGE 03 Cathy Cagle 7 Brookridge Cove Little Rock, AR 72205 501 228-9971 U. S. Federal Court 600 W. Capitol Suite 402 Dear Judge Wilson, I am writing you concerning the Little Rock School District case now in court. I was disturbed by comments of two star witnesses from J. A. Fair High School. I am a chemistry teacher at J. A. Fair High school and am very familiar with both students. From my perspective Chris Payne received no unfair treatment due to his race. He was the president of the Rotary Interact Chib that I sponsored last year at J. A Fair. I personally helped him get accepted into camp RYL A sponsored by Rotary, with a foil scholarship during the 00/01 school year. I iso wrote several letters of recommendation to assist him in gaining scholarships to college. To the best of my knowledge he received around fifty two thousand dollars in scholarship money. That was more than our valedictorian or salutatorian or any other student received to the best of my knowledge. He did receive a one thousand-dollar scholarship from the Rotary Club. Martha Rains, her husband, Tom Rains, Dr. Vic Anderson, former vice-superintendent, Greg Downs, West Little Rock Rotary Club President, and Dr. Jim Westbrook, a West Little Rock Rotary Club member were all involved at some point trying to help Chris Payne in some form or another in his leadership, scholarship and career goals of becoming an electrical engineer. Al! the above mentioned people are Caucasian, including myself. Ctwis appeared at my classroom door before graduation last year to thank me personally fi\u0026gt;r all that we had done to help open doors for him. As to any mention of the Quiz Bowl, it was my understanding when it was first kicked off Chris was not available to practice because of other school activities he was committed to at the time. Other students who were available were selected. I was one of the teachers who volunteered to give up a portion of my lunch to help the Quiz Bowl team practice. Melony Harder, Tom Ross, Mr. Wilder, all white, and Mf. Burton, black also gave up lunchtime. Judith Pickering, the club sponsor, gave up many hours preparing the students for competition. I hope that you will consider the contents of this letter when making your final decision. Sincerely, Cathy Cagle Chemistry TeacherOffice of Desegregation Monitoring United States District Court  Eastern District of Arkansas Ann S. Marshall, Federal Monitor One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 (501)376-6200 Fax (501) 371-0100 September 17, 2002 Dr. Ken James, Superintendent Little Rock School District 810 West Markham Street Little Rock, AR 72201 Dear Ken: All of us at ODM join in congratulating you and your colleagues in the Little Rock School District on attaining partial unitary status. The beaming faces in the newspaper said it all, and share in your sense of satisfaction. we Weve been pleased to work closely with the district over the years as weve shared our skills and perspectives, lent our support to work teams and committees, and celebrated the schools accomplishments. Under your leadership, the district has made significant progress that makes the community proud. We look forward to resuming our work with you through the coming months as the district continues to move ahead. Sincerely yours, Ann S. Marshall cc: Board of DirectorsLittle Rock School District '5?\nOFFICE OF THE SUPERINTENDENT RECEIVED SEP 2 5 2002 OFFICE OF DESEGREGATION MONITORING September 23, 2002 Mrs. Ann S. Marshall Office of Desegregation Monitoring One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Dear Ann: Thank you for your recent letter. We are very pleased with the recent court decision granting the Little Rock School District partial unitary status. We are also working very hard to outline a plan of action to address the one remaining area. We look forward to working with you and your staff in the coming months. In the very near future, we will forward a copy of our proposed plan for your review and subsequent input. Sincerely, I T. Kenneth James, Ed.D. Superintendent of Schools TKJ/bjg cc: Board of Directors Cabinet 810 West Markham Street  Little Rock, Arkansas 72201  (501) 447-1002RECEIVED John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 OCT -2 2002 OmCEOF DESEGREGATION MONITORING JOHN W. WALKER SHAWN CHILDS October 1, 2002 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock. Ark.ansas 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Email: mcheiiryd@swbell.net Honorable Judge William R. Wilson United States District Court 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: Little Rock School v. Pulaski County School Case No. 4:82CV00866 Dear Judge Wilson: On page 172 of your Order of September 13, 2002, you determine a compliance remedy with respect to the Joshua Intervenors, Section D. You also require the ODM to monitor LRSDs compliance with Section 2.7.1. May I bring to your attention that the remedy being imposed is not preceded by any court order determining and defining the parameter of Joshuas monitoring. Those issues were not before the Court. The Court now determines that Joshua must monitor and must immediately bring to the LRSDs attention all problems that are detected as the court has determined those problems to be. In doing so, the Court seems to impose a greater burden upon Joshua than it has imposed upon the Office of Desegregation Monitoring. I, therefore, would like to request that the Court define the nature of the monitoring that it expects of Joshua, i.e. access to information by Little Rock, cost of production of such information, access to staff responsible for fulfilling the obligations (must this be done in writing with communication directed to LRSD counsel), and so forth. I believe that it would be appropriate for the Court to spell out the obligations which it now imposes upon Joshua and the legal basis therefor in view of the fact that the remedy defined was not sought by LRSD or any party. I also note that LRSD is not required to inform Joshua of anything set forth on pages 170 through 172 except to provide a compliance report on or before March 15, 2004. I must also object to Courts imposing monitoring requirements upon Joshua that were contemplated to be the responsibility of the ODM. The Courts comments indicate that it does not forsee or require a continued responsibility for monitoring of the intensity which the Court of Appeals for the S* Circuit required. In this respect, we note that the Court created the ODM and expected the ODM to carefully monitor on a daily basis, full-time, the activities of the Little RockPage 2- Letter to Judge Wilson October 1, 2002 and other school districts. By placing the responsibility that you appear to place on Joshua, unless clarification otherwise provides, the Court is shifting the required monitoring from the ODM to Joshua. We do not believe that to be fair or reasonable. Before your final order is entered, and becomes appealable, I respectfully request a hearing on this matter so that an appropriate record on the issues of the role of ODM monitoring and Joshua monitoring may be fully developed. Sincerely, ?7L !iin W. Walker JWW:js cc: All Counsel of Record Ms. Ann MarshallJohn w. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS Via Facsimile: 604-5149 October 9, 2002 OF COUNSEL ROBERT McHENRY. P.A. DONNA J. McHENRY 8210 Hendeeson Road Little Rock, Aekansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 EilAlL\nmchenryd@swbell.net Honorable William R. Wilson United States District Judge 600 W. Capitol Suite 423 Little Rock, Arkansas 72201 received OCI - 9 ^00^ DESEGREGffi\u0026amp;OHnOWHG Re: LRSD V. PCSSD Dear Judge Wilson: I have just received by mail a note that the LRSD filed a response to Joshuas Motion for Reconsideration and for a New Trial and that service reflects the date of October 7, 2002 therefor. The Response is clearly out of time and therefore, I ask that the Court sua sponte so hold. I have also received in the same mail a Response to the Joshua October 1, 2002 letter. .(John W. Walker Sincerely, / JWW:Ip cc: All Counsel of Record Ms. Ann Marshall Brown  I J JOHN W. WALKER SHAWN CHILDS Honorable William R. Wilson United States District Judge 600 W. Capitol Suite 149 Little Rock, Arkansas 72201 Re\nLRSD V. PCSSD John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 Via Facsimile: 604-5149 October 9, 2002 received OCT - 9 2002 OF COUNSEL ROBERT McHENRY. P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email\nrachenryd^swbeU.net OFFICE OF DESEGREGATION MONITORING Deal- Judge Wilson\nThis is a supplement to my letter motion of October 1,2002. I appreciate the Court treating it as a motion, although I did not so couch it, and I believe that the appropriate action taken by the Court in inviting the parties to react will be most useful. I believe that it is important for me to specify, however, what Joshua believes it would be appropriate for the Court to do with respect to clarifying the monitoring role of tire Office of Desegregation Monitoring. I am therefore asking that the Court conduct a hearing\n(a) to identify tlie instructions received by the Office of Desegregation Monitoring (later referred as the ODM) regaiding monitoring and reporting in reference to the LRSDs Motion for Unitary Status\n(b) to consider whether the instructions received by the ODM were consistent with the earlier identification of ODMs role as set forth by the Court of Appeals for the Eighth Circuit\nand (c) to identify with greater particularity ODMs monitoring and reporting role regarding the three school districts. If the Court is inclined to have me formalize my October 1,2002 letter and todays letter in motion form, I will be happy to do so. I am also writing to obsei-ve that the Joshua Intervenors filed a Motion for Reconsideration within the time allowed by law and that there has no response filed by either party within the rule time to our motion. Local Rule 7.2(b) requires that any party opposing our motion shall file such motion within eleven days. By my count, any opposing party should have filed its opposition not later than October 4,2002. Today is obviously October 9,2002. I am not aware that the Court has a received a Motion to Extend the Time and I have not had a request from any counsel regarding an extension of such time.Page Two October 9,2002 Accordingly, we request that the Court rule on tire motion. /John W. Walker JWWdp cc: All Counsel of Record Ms. Ann Marshall Brown HERSCHEL H. FRIDAY (1922.IW4) WILUAM H. SUTTON. P.A. ^RON M. EISEMAN. JR. P.A. BELL, P.A. A BUTTRY. P.A. J'' ) ^^ICICKR .S... .U...R...S..E...R...Y.... .P...A. O^^^DAVIS. JR. P.A. XARK. JR.. P.A. . LEGGETT. P.A. JOHN DEWEY WATSON. P.A. PAUL B. BENHAM UI. P.A. LARRY W. BURKS. P.A. A. WYCKLIFF NISBET, JR., P.A. JAMES EDWARD HARJUS. P.A. J. PHILLIP MALCOM. P.A. JAMES M. SIMPSON. P.A. JAMES M. SAXTON. P.A. J. SHEPHERD RUSSELL lU. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A. RICHARD D. TAYLOR. P.A. JOSEPH B. HURST. JR. P.A. ELIZABETH ROBBEN MURRAY. P.A. CHRISTOPHER HELLER P.A. LAURA HENSLEY SMITH. P.A. ROBERT S. SHAPER P.A. WILLIAM M. GRIFFIN Ill. P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY, P.A. WALTER M. EBEL lU. P.A. KEVIN A. CRASS. P.A. WILLIAM A. WADDELL. JR.. P.A. SCOTT J. LANCASTER, P.A. ROBERT B. BEACH. JR.. P.A. J. LEE BROWN. P.A. JAMES C. BAKER JR. P.A. HARRY LIGHT. P.A. SCOTT H. TUCKER. P.A. GUY ALTON WADE, P.A. PRICE C. GARDNER. P.A. TONIA P. JONES. P.A. DAVID D. WILSON. P.A. JEFFREY H. MOORE. P.A. DAVID M. GRAF. P.A. RECEIVED OCT 1 1 2002 OmCEOF DESEGREGATION MONITORING ( By Hand Delivery) Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, #146 P.O. Box 17388 Little Rock, Arkansas 72222 RE: Friday Eldredge \u0026amp; Clark ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP CARLA GUNNELS SPAINHOUR P.A. JOHN C, FENDLEY. JR.. P.A. BRYAN W. DUKE JOSEPH G. NICHOLS JONANN ELIZABETH CONIGLIO. P.A. ROBERT T. SMITH www.fndayfirm.com 2000 REGIONS CENTER 400 VUEST CAPITOL LITTLE ROCK. ARKANSAS 72201-3493 TELEPHONE 501-376-2011 FAX 501-376-2147 3425 NORTH FUTRALL DRIVE. SUITE 103 FAYETTEVILLE. ARKANSAS 72703-4811 TELEPHONE 470-605-2011 FAX 470-605-2147 R. CHRISTOPHER LAWSON. P.A FRAN C. HICKMAN. P.A BETTY J. DEMORY. P.A. LYNDA M. JOHNSON, P.A. JAMES W. SMITH. P.A. CLIFFORD W. PLUNKETT. P.A. DANIEL L. HERRINGTON. P.A. MARVIN L. CHILDERS K. COLEMAN WESTBROOK. JR. ALLISON J. CORNWELL ELLEN M. OWENS JASON B. HENDREN BRUCE B. TIDWELL MICHAEL E. KARNEY KELLY MURPHY MCQUEEN JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN KASTEN RYAN BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON PHILIP B. MONTGOMERY KRISTEN S. RIGGINS ALAN C. BRYAN LINDSEY MITCHAM SLOAN KHAYYAM M. EDDINGS JOHN F. PEISERJCH AMANDA CAPPS ROSE BRANDON I. HARRISON 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2608 FAX 870-782-2018 October 11,2002 Mr. Sam Jones Mr. Steve Jones OF COUNIEL B.S. CLARK WILLIAM L. TERRY WILUAM L. PATTON. JR H.T. LARZELERE. P.A. JOHN C. ECHOLS. P.A. A.D. MCALLISTER JOHN C. FENDLEY, JR. LITTLE ROCK TEL 501-370-3323 PAX 501-244-5341 tandlcyQfec.nat Wright, Lindsey \u0026amp; Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, Arkansas 72201 Jack, Lyon \u0026amp; Jones, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201 ( By Hand Delivery) Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, Arkansas 72201 Compliance Remedy Mr. Dennis Hanson Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Arkansas 72201 Dear Counsel and Ms. Marshall: At a special meeting last night, the LRSD Board voted to approve the Proposed Comphance Plan provided to you by letter dated October 4,2002, with the exception of proposed regulation IL-R2. It was decided by the administration that IL-R2 was unnecessary and it was withdrawn. The admimstrations reasoning will be discussed below as a part of the Districts response to questions submitted by Ms. Marshall. Ms. Marshalls memorandum to Dr. James dated October 10, 2002, set forth 12 observations/questions related to the Proposed Compliance Plan. The Districts response to each observation/question is set forth below: i ( F:\\HOMEkFENDLEY\\LRSD 2001\\uni(ary-all-counseM0-l l-02.wpd I All Counsel and Ms. Marshall October 11, 2002 Page 2 1. 2. 3. 4. 5. Of the eight program evaluations the district proposes to have re-written by outside experts (page 12), will new data for continuing programs be added to those evaluations, or will the re-wntes be limited to the data that were used at the time the eight evaluations had been written? RESPONSE: The re-wntes will be limited to the data that were used at the time the eight evaluations were written. Page 7 of the Proposed Compliance Plan identifies Primary Reading/Language Arts as a program to be evaluated as part of the evaluation agenda, while the IcTraElementary Literacy is used on page 15. The first term connotes PK-3, while the second cormotes K-5. Do the different titles actually identify different programs? Which grades are to be included in the evaluation? RESPONSE: There is one program to be evaluated for PK-5, and the title of that evaluation will be Elementary Literacy, rather than Primary Reading/Language Arts. 99 Another evaluation agenda item is K-12 Mathematics and Science. The list of assessments on page 5 includes nothing for math and science in grades K-3. What data will be used in evaluating the primary grades, considering the lack of assessments in math and science at that level. RESPONSE: The data to be used for the K-12 Mathematics and Science evaluation will be the same as that previously used for the NSF Mathematics and Science evaluations with the exception of the ALTs which will no longer be administered. In the evaluation of primary literacy, what measures will the district institute to off-set potential bias or conflict-of-interest inherent in the process of teachers administering assessments to their own students? RESPONSE: The District attempts to off-set potential bias resulting from teachers admimstering student assessments through its training of teachers in administering the assessments and monitoring the results of assessments. hl the evaluation of primary literacy, IL-Rl, requires a clear description of each program that is to be evaluated. To what extent will those descriptions include not only the subject content that students are expected to learn, but also teaching methods, materials, time allotment, and so on? F:\\HOME\\FENDLEY\\LRSD 200I\\unitvy-ali-couQsel-]0-] l*02.wpd II All Counsel and Ms. Marshall October 11,2002 Page 3 RESPONSE: The program description will be prepared by the evaluation committee pursuant to IL-Rl. Teaching methods, materials and time allotment may be included in the program description to the extent the evaluation committee deems it relevant. It is important to note the evaluation will be of the overall program and not individual program components. 6. 7. 8. 9. The proposed regulation requires that all relevant student performance data will be used in the evaluations. Will other data, such as interviews with teachers and students, case studies, and classroom observations, supplement the performance data for the evaluation? RESPONSE: The data necessary to answer the research questions will be determined by the evaluation committee. The degree and quality of program implementation have received little attention in previous evaluations. What procedures will the LRSD develop to measure program implementation (such as its quality, uniformity, and completeness throughout the district) in order to assure that the student performance data reported in the evaluations are actually the result of the programs described. RESPONSE: The evaluation committee will determine the necessity of such data and the manner in which it will be gathered. The compliance plan section headed, Continue to administer student assessment through the first semester of 2003-04\" (page 4) details how the LRSD has recently altered its assessment plan. The 2002-03 assessment plan, board-approved on September 26, 2002, provides only for spring testing, as it eliminates all fall testing that is reported to and maintained by the LRSD and, of course, incorporates ADEs move of SAT-9 testing to the spring. Page 5 of this section reads that the final student assessment before March 15,2004 will be administered in the spring of2003. We note that the spring 2003 tests will not only be the final assessment, but also the only assessment reported to or maintained by the LRSD between now and March 15, 2004. Will the data from this one testing cycle be complemented by that of previous years. RESPONSE\nYes, for the three new, comprehensive evaluations. As stated above, no new data will be gathered for the evaluations to be completed pursuant to Paragraph C of the Compliance Remedy. We note that the new assessment plan includes administration of student assessments only in English language arts and mathematics. Also, the 3\"* grade has no assessments. F:\\HOMEkFENDLEY\\LRSD 2001\\unitary-all-counsel-10-11-02. wpd 1 i\u0026lt; All Counsel and Ms. Marshall October 11,2002 Page 4 RESPONSE: The assessment plan outlined was only that for English language arts and mathematics. Even so, it is noted that the SAT9 will be administered and the total battery of that test includes a science and social studies component. It is correct that there will be no assessment of 3\"* graders this year or next. The State will be developing and administering a test after that to comply with the No Child Left Behind Act. 10. 11. 12. Given the assignments in the Action Plan Timeline, what is the role of the districts Plannings Research and Evaluation department under the new compliance plan? Under the envisioned Program Evaluation Agenda? RESPONSE: PRE staff may serve on the evaluation committees. Proposed regulation, IL-R2, Informal Program Evaluation, requires that a written record be prepared and maintained to support any decision to modify an academic program. The purpose of this regulation is unclear. Are the program evaluation standards relevant to information evaluations? Does the regulation mean that LRSD will informally evaluate all programs? Or, will suspect programs be targeted for informal evaluation? Or, is the regulation intended to protect programs from unfair criticism? RESPONSE: The administration withdrew IL-R2 before approval of the Proposed Compliance Plan by the Board. The administration decided that the regulation would be redimdant of information to be included in the new, comprehensive evaluations required by Paragraph A of the Compliance Remedy. Rather than a separate written record, the program description in the new, comprehensive evaluations will include a description of program modifications made during each year of implementation satisfying the requirements of Paragraph B of the CompUance Remedy. How is the LRSD planning to alter its budget to purchase the services of outside evaluation experts? Which budget items will be reduced to accommodate the purchase of evaluation services? RESPONSE: This decision has not yet been made. The District will make this decision when it has a better idea of the total cost of these services. The Board has instructed the administration and counsel to work with the parties in an effort to achieve a consensus that the LRSDs Compliance Plan meets the requirements of the District Courts Compliance Remedy. The Board contemplates some give and take before a final consensus may be reached. So at this may be done in a timely manner, the LRSD asks all parties to F:\\HOME\\FENDLEy\\LRSD 2001\\unary-aU-counsel-10l l-02.wpd1 All Counsel and Ms. Marshall October 11,2002 Page 5 specifically identify in writing any perceived deficiency in the Board-approved Compliance Plan on or before Monday, October 21,2002. Please let us know if this deadline presents areal problem for you or your client. We will be happy to answer any questions the parties may have before that date. We ask that the questions be submitted in writing, and the LRSD will respond in writing so that all parties will have the benefit of the question and response. Thank you in advance for your cooperation. Sincerely, cc: Dr. Ken James John endley, Jr. F:\\HOMEVFENDLEY\\I-RSD 2001\\uniBry-aII\u0026lt;ouDsel*10-l l-02.wpdFriday Eldredge \u0026amp; Clark HSRSCHSL K, FRIDAY 0*42-1794) william H SUTTON. F A. BYRON M EiSMAN. JR, Fa JOB D. SELL. F a JAMBS A. BVTTRY. F A. FREDERICK 9. URSERr. p a. OSCARS DAVIS JR. P a JAMES C CLARK. JR . F.A Thomas f. teoGeTT. p a. JOHN 0BW6Y WaTSOn. F.a. FaUl . 86NHAM (((. P.A. larry W. BURKS. F.A. A. WYCKLIFF NISBET. JR.. F.A. JAMES bdward Harris, f.a J FHJLLIF MALCOM. F.A. James m. simfson. f a. JAMBS M. Saxton, f.a. i. SHBPHERO RUSSELL HI. F A OOnaLO K. bacon, p a. WILLIAM THOMAS BAXTER. F.A RICHARD 0 Taylor. F A JOSEPH B. HURST. JR. F a. ELIZaBSTK RO88BN MURRAY. F.A. christotmer heller. F.A. LAVRA MCNSLEY SMITH. F A ROfiERT s. Shaper, f.a. WILLIAM M. CRlFPlN IK. F A. MICHAELS. MOORE. F A DIANE S, MkCKty. F.A Walter M ebel hi. f a KEVIN A CRAW. F A WILLIAM A WaOOELL. JR . f.A. SCOTT J. LANCaSTSR, f,K, ROBERT B. beach. JR.. F A J- LEE BROWN. F.A. JaMBT C. BAKER, JR.. F.a. HARRY A LIGHT. F,A. SCOTT M. TUCKER. F a. GUY ALTON WaDC. F.a. FRIC6 C OaRONCR. F.A. TONIA F. JONES, F.A. OAVID 0, WILSON. F.A. JEFFREY H. MOORE. F A OAVlO M. fSRAF. F A. ATTORNEYS at LAW A LIMITED liability PARTNERSHIP www.fridaynrni.coin 2000 REGIONS CENTER 400 WEST CAPITOL LITTLI ROCK. ARKANSAS 72201-3493 telephone 501-378-2011 PAX 401-378-2147 3429 NORTH FUTRaU ORIV6. SUlTfi 103 FAY6TT6VIH.S. ARKANSAS 72703.4911 TELEPHONE *79.fiBS.20l1 FAX *78.8e5.2u7 CARLa OUNNBLS SPAINMOUR. F.A JOmHC FENOlBY, JR . F.A. JONANN BLiaABETHCONIOLIO. F.A. R. CKRISTOFHBR LawSOh. F A. FRAN C HICKMAN, F.A. BETTY J. OBMORY. F.A. LYNOA W. JOHNSON. F.A. JAMES W. SMITH. F.A. Clifford w flunkstt. f.a, Daniel l. herrinqton. f.a. Marvin l. chjloers K. COLBMAN WESTBROOK. JR ALLISON J. CORNWELL ELLEN M OWENS iaSOn b kkndrcn SRVCS B. TIDWELL MICNaBL b. karney KELLY MURFKY MCOUEEN JOSBFH J. MCKAY ALEXANDRA A. IFRAH JAY T. Taylor MARTIN A Kasten Bryan w ouke JOSBFKO, N1CHOU BOeeUT T. SMITH BYaN a bowman TIMOTHY C S2BU T. MICHEU8 ATOA KaRtn 5. MaLOEKT SARaN M. cotton PHILIF a MONTGOMBSY KRISTEH $. RJGGINS ALAN O. anyAN IfNOSZY MITCHAM SLOAN KHAYYAM M. BOOtNCfi JOHN f PEISESUCR aMaNOa caffs KOBE 8BANOON I HA.HH1SOU 209 NORTH FIFTH STREET BLYTHEVILLC. ARKANSAS 72319 telephone 870.792.ZBse FAX 9?0.r2.28lt or COUNJEV B.S. CLARK WILLIAM L. TERRY WILLIAM U FATTON. JR H.T. LARZSL8RB. F A. JOHN C ECHOV9. F A A 0 MCALLISTBR October 14, 2002 JOHN C. FENOL0T. JR. LITTLE ROCK TEL J1-3T9.33J5 FAX a0l\u0026gt;24fiS4i iFABlay^raa.nct J Honorable William R. Wilson, Jr. United States District Court 423 U.S. Post Office \u0026amp; Courthouse 600 West Capitol Avenue Little Rock, Arkansas 72201-3325 / RE: Little Rock School District vs. Pulaski County Special School District et al. United States District Court, Eastern District, No. 4:82CV00866 WRW/JTR Dear Judge Wilson: We note that Ms. Marshall provided you a copy of her October 10,2002, memorandum to Dr. James setting forth observations/questions related to the Little Rock School Districts Compliance Plan for complying with the Compliance Remedy set forth in the Courts Memorandum Opinion of September 13,2002. We submitted a response to Ms. Marshall on October 11,2002, but were uncertain whether we should provide a copy of that to the Court. While we would be happy to provide copies to the Court, it would be presumptuous on our part to presume that the Court wants to review all correspondence between counsel in this case. We respectfully request the Court advise the parties what it would like them to do in this regard. Thank you for your time and attention to this matter. Sincerely, John C. Fendley, Jr. vHonorable William R. Wilson, Jr. October 14, 2002 Page 2 cc: Mr. John W. Walker Mr. Sam Jones Mr. Steve Jones Mr. Richard Roachell Ms. Ann Marshall Ms. Sanunye Taylor Mr. Ken James F:TOMBB8n.n\\rBBdlqUlS0MtMg'ijuJS wibwi h wpdO' latoHn JUHIN w WALKER P A W.*'9e3 Fl //n. ''P.2 JOHN W. WaLKEK SHAWN CHILDS John w. Walker, p.a. Attorney At Law 1725 Broadway Little Bock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 October 23, 2002 or COUNSEL ROBEETMcHENKVP^ DONNA J, McHENEY 8210 Heotekson Eqad LITOZ EOCE, ARKANSAS 72210 Phone: (501) 372-3425  Fax (501) 372-^8 tNuiL: nicheni7dwi)alln.et Mr. Christopher Heller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Re\nLRSD V. PCSSD Dear Chris\n/ This letter sets forth additional Compliance Plan. We comments of the Joshua Intervenors concerning the LRSD  offered the data' OTdent assignment results, attention should be given to the quality of \"** on the RA and the Observation Survey in ways not their own students, the past use made of the data scores for was in conflict with the districts recognition in the newly enacted Regulation IL-Rl that Conflict of XoSeT 1. We are concerned about the fcr fhr J\nned about the manner in which the regulation describes the team process for prepari^ evaluations, again in the context of conflict of interest - ' to write aTc\no7a^  miX Ptogian, Evaluation Loedums In order to insure that guarantee that the external expert will have these roles, manner which we describe, there would be no .c LT with a differing interpretation of the evaluation resits do not Of course, if reports were prepared in the bar to LRSD staff preparing comments to the Board nI,nynA?' ^0 conceiDed about the global, general manner in which the content of nas adopted a policy and two regulations dealing with remediation for ______ IS be ow par. Studying the actual implementation of these dealing wth remediation for students whose performanc :e -- otuuymg me actufi). impiemenTation of these standards (in all or a renresentative sample of schools) is of vital mponanee to the Intervenor class because class members^ so much Tnorei\nt'P'ivTHe.T,/'TK...-e, J , cittss mcmoers are SO much Perfonnmce on the Benctaerlt end Stanford Acme ement Tests. A satisfactory descnpuon by the School Board of the evaluations which it : exhibit  10/24/2002 THU 09:03 [TX/R2 NO 8580] i2|002.:4.2002 8:07fiM JOHN W WALKER P fi NO.963 P.3 Page Two October 23, 2002 require sxaff to undertake should make clear that the actual implementation of remediation factor (see .Ajccuiacy Standards, para. 2). (h . * Of Affic:., American smdenxs for J uSiui. rue or to dL i^ SlSe necessary to satisfy the coun. We would like to receive tihned Befoinairtde sf uastusurer,a nncoet school board. Wewouldappreciale your providing thisletter to the Superintendent and the members ofthe . Walker SincereN, JWW:Ip cc: All Conngp.) Ms. Ann Marshall Judge Thomas Ray 10/24/2002 THU 09:03 [TX/RX NO 8580] [2)003 IIV. r John w. Walker, P.A. Attoeney Aff Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN w. waleee SHAWN CHILDS OP COUNSEL KOBEST McHENRY. PA DONNA J. McHENRY 82X0 Henderson Road LmLESOCE, AJUUNSaE 72210 Phone. (601) 372-3425  Ru(501) 372-3428 HmaCc mchaD^yd9b4Q.se[ Via Facsimile - 376-2147 October 24, 2002 Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, AR 72201 RECEIVED OCT 2 5 2002 Re: Little Rock School District v. PCSSD, et at Case No. 4:82CV00866 OWCEOF desegregation monitoring Dear Chris: We are in receipt of your letter dated October 25, 2002 regarding LRSDs compliance remedy. Instead of these exchanges of paper, it would be advantageous to all concerned for us to have some meetings in order to respond to these issues so that we can better understand each others position. Not everything is black letter and there should be room for discussion in mutual agreement. Sincerely, ^ohnW. Walker JWW\njs cc\nMs. Ann Marshall AU Counsel of Recordft JOHN W. WALKER SHAWN CHILDS John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 October 23, 2002 Mr. Christopher Heller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 RECEIVED OF COUNSEL ROBERT McHENRY. P.A DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone\n(501) 372-3425  Fax (501) 372-3428 Email: mchenryd^wbell.net Re: LRSD V. PCSSD OCT 2 9 2002 OFHCEOF DESEGREGATION MONITORING Dear Chris: This letter sets forth additional comments of the Joshua Intervenors concerning the LRSD Compliance Plan. We are offering these comments, although we are unable to discern that the comments we offered earlier were given consideration. 1. In using historical student assignment results, attention should be given to the quality of the data. In the past, LRSD has used results on the RA and the Observation Survey in ways not consistent with the purposes of those instruments. In addition, because teachers provided scores for their own students, the past use made of the data was in conflict with the districts recognition in the newly enacted Regulation IL-Rl that Conflict of Interest must be avoided. 2. We are concerned about the manner in which the regulation describes the team process for preparing evaluations, again in the context of conflict of interest. In order to insure that conflict of interest is avoided, the external consultant needs to write the report and control the context of the analysis. Paragraphs 3, 5 and 6 of the Program Evaluation Procedures do not guarantee that the external expert will have these roles. Of course, if reports were prepared in the manner which we describe, there would be no bar to LRSD staff preparing comments to the Board with a differing interpretation of the evaluation results. 3. We continue to be concerned about the global, general manner in which the content of planned evaluations is described (page 7 of the document, first paragraph). For example, the Board has adopted a policy and two regulations dealing with remediation for students whose performance is below par. Studying the actual implementation of these standards (in all or a representative sample of schools) is of vital importance to the Intervenor class because class members are so much more likely than other students to exhibit unsatisfactory performance on the Benchmark and Stanford Achievement Tests. A satisfactory description by the School Board of the evaluations which it IPage Two October 23,2002 requires the staff to imdertake should make clear that the actual implementation of remediation activities in district schools is to receive careful consideration. This is surely an important contextual factor (see Accuracy Standards, para. 2). 4. We understand from the Plan that the LRSD plans evaluations of programs deemed to be particularly directed to achievement of African American students for the indefinite future, not .simply for the period necessary to satisfy the court. We would like to receive the Boards assurance that this is the case. We would appreciate your providing this letter to the Superintendent and the members of the school board. Sincere^, RifW. Walker JWW\nlp / cc: All Counsel Ms. Ann Marshall Judge Thomas RayOCT. 31.2802 3:19PN JOHN U WflLXER P A r).07E p.2 JOHNW. walker SH^ffN CHUDS Dr. T. Kenneth James Superintendait of Sc^s T.inla Rock School Kstnct 810 West Markham little Rock\nAR 72201 Dear Dr. James: JOHN W. Walker, PA- AttorneyAtLa^ 1723 Broadway Ltitle Kook, abka.*^ 7^06 Tp,i.rphonE (50U 374-3758 FAX (501) 374-4187 OF COUNSEL robeet mStoney. WNKi.MeHENRY 6210 HSSDEBSOH H* Tbokk C50M n^ienryasswlxillaw October 31,2002 dated October 29,2002. If I I am renewing my request for the has not utili^ any understand your response correctly, it is literacy prejects and that there s\" are so your poatioo, it seems edstence wherdjy the District has contTmy to youT reports to the Court. If you arc not aware who has fins information. of such dtx^cms,please forwardwr^P^^tothe proper perw^ imcerely, Joy C. Springer JCS/ cc\nMs. Ann MarshallLittle Rock School District OFFICE OF THE SUPERINTENDENT November 1,2002 Ms. Joy Springer Walker Law Firm 1723 Broadway Little Rock, AR 72206 Dear Ms. Springer: In response to your most recent request, you did not understand our response. It is not our position that we have not utilized consultants. However, our response remains the same. We do not have a document or documents to provide in response to your FOIA request, and we are not required to compile informabon or create a record in response to a FOIA request. Sincerely, T. Kenneth James, Ed.D. Superintendent of Schools TKJ/bjg cc: Chris Heller Clay Fendley Ann Marshall $10 West Markham Street  little Rock, Arkansas 72201 * (SOI) 447-1002 John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock\nArkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS November 1, 2002 OF COUNSEL ROBERT McHENRY. P.A. DONNA J. McHENRY 8210 Henderson Ro.ad Little Rock, Arkansas 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Email\nmchenryd^wbell.net The Honorable Judge William R. Wilson United States District Judge 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: LRSD v. PCSSD, et al. Case No. 4:82CV00866WRW Dear Judse Wilson: We are in receipt of your response dated November 1, 2002. You make reference to Mr. Pendleys October 14 query. Joshua has not been privileged to receive such. incerely, ohn W. Wallcer JWW:js cc: Ms. Ann Marshall All Counsel of R.ecord Judge Thomas Ray Cud/JOHN w. Walker SHAWNCHMS John w, Wilker, ea. ATtORNEVATLAW 1723 BrojOway Arkansas 72206 ^^3758 FAX (SOX) S74-4187 Via Facsimile November 1, 2002 aOBERTM^^^\nawiu mcheiuydgjwbelLaat Ms. Ann Brown Marshnli ODM  One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 Re\nLRSD V. PCSSD Dear Mrs. Marshall: LRSD, concerning S LRSDS)XS^S^S^ for the -ponseYso ur h.avie XreceiXved fr.om the 20C2,, - Mnmmcatiens dated October 10 and OteV2M2'31^  K,4,-------- -:..rcga,dingd,efoUogS\nc'i.',u*^'SX^^ containing the LRSDs 8.2.4 be carried out October 10 - numbers 1,2,3 (regardin' American achievement). g Oclobet24,2002-numbers 1,2, 3. programs significant with regard to African- ODM may have aMlioM poinis of coneem Thank you for your attention to this matter. W, Wailllkteerr JWW\nlp Cc: Chris HcUer/CIay Fendley Other Counsel NOV. 4.2002 3:57Pri jOHT-i w walker p n NO.136 p.2 o: JOHN W. WAUiER shawm CHILDS John W. Walker, RA. Attorney at Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (601) 374-3758 FAX (501) 374-4187 OF COUNSEL ROBERT McHENRY. PA DONNA J. McHENRY 8210 HenuESSOX Road LmLE Rock, A*KAN5.xs 72210 Pbone: (501) 372-3425  Fax (501) 372^3428 email mchciiry(iSewbeU.net Via Facsimile - 447-1159 November 4,2002 I I I Dr. T. Kenneth James Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 I I I Dear Dr. James\nPlease let me know the names, addresses and telephone of all persons (from January 1, 1998 through October 31,2002) that the District has consulted with respect to literacy C^^Zd^d^vdopmcnt). Alsopleaseletmehavex\u0026gt;piesoftheircometsaBdthepay ipvo'cy= that they have submitted along ^th evidence of payment to them. Sincerely, JCS/ cc: Mr. John W. Walker Ms. Atm Marshall Mr. Clay Fendley Mr. Chris Heller I John W. Walker, P,a. AttornetAtLaw 1723 Broadwa? Dttle Rock, Arkansas 72206 Tslephoni (501) dTA-STSS FAX (501) 374-4187 ^^^'S.^ALKSR Via Facsimile - 604-5149 November 4,2002  OFCOUNSEL ROBERT MeHtaaiY. Pj^ DONNAJ.lMffiNHY 6210 Hjmbsbsom BOaD Uthji Root, AjuuiiaAB 7^10 PHOW\n(501) 37S.3t25  Fas (SOI) 372.3428 EumX: mcheBiydgsvb^.net J'XE? WjHiana Z Wilson United Sutcs District Court \u0026lt;500 West Capitol, Suite 423 Little Rock, AR 72201 Ke: Litde Rock School District v. PCSSD, et aL Case No. 4:CV82-866 Dear Judge WQson\nOn October 31,2002, we filed a motion to enlarge the time in which to respond to a notion filed by the Pulaski County Special School Distridt. On October 31,2002. Mr. Sam Jones wrote the Court regarding foe matter. On November 1,2002, foe Court wrote all counsel a note which stated:  PD soon reply to Mr. Findlys October 14 query.... On that date, I wrote foe \"cal and stated that I had not received the October 14* query. At 4:26 p.m., November 1, ?2. \u0026gt;r. Fendley faxed me a copy of the October 14,2002 query. I am writing to object to the ex-parte communication between foe Friday Firm and His Honor. I am also writing to request copies of all communication between the Friday Firm and His Honor to whidi we have not been privy including any oral communication as well. Thank you for your attention to this matter. f JWW:js cc\nMt. Clay Fendley AU Counsel of Record Ms. Ann Marshall Judge Thomas Ray Sincerely JOHNW.WALKES SyAWN CHILDS JOHN w. Walker, RA. ' ATTomr ArUw 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 3745758 PAX (501) 374-4187 OPCOUNSEL ROBERT McHENKY. P-A DONNAJ.MdimY SilO HlNDEIiaON Rmd tmu Rock. Afausij 72210 PBONK (500 372-3426 ' Fm (501) 372-3423 IMNU achenqniesvbcUjiet Via Facsimile - 4SO4-S149 November 4,2002 Honorable Judge 5Oiam R. W3soa United States District Judge 60C West Capitol, Suite 423 Little Rock, AR 72201 Re: Case No. 4:MCV0866WRW/JTR LRSDv, PCSSD Dear Judge Wilson\nI am in recdpt of your letter of a few minutes ago. For your information, I verified that I did not receive a copy ofXfr. Fcndl^s letter. Moreover, the copy that I received from Mr. .TerxDey on Friday evemng is attached hereto with a second page. Please note the date and time which appears at the top of the fex. The fex that I received is dated November 1,2002, the same day I raisied the issue with you. (See attached fax) I have checked with Mr. Richard Roachell and Mr. Sam Jones and they have indicated that they received the letter on October 15,2002 and October 16,2002 respectivdy. If I am in error, I apologize, but my knowledge is what I stated eariier. rohnW. Walker n- JWWijs cc: AH Counsel of Record Ma. Ann Marshall Judge Thomas Ray J-iC'. NOV. 5.2002 5:20Pri JOHN W WALKER P A NO.156 P.2Z2 JOHN W. Walker, P.a. Attorney At Law 1723 Broadway LrtTLE Rock, Arkansas 72206 Telephone (5O1) 374-3758 FAX (501) 374-4187 I JOHN W. WALKER SHAWN CHILDS Via Facsimile - 447-1159 November 5,2002 OF COUNSEL ROBERT McHE.NHY. P.A. DONNAJ.MeHENRY 8210 HCNDExauu Road Lrmi Rock, Akkansas 72210 PHOWS: (501) 372-3425  P (601) 372-3428 Email mcheoryJ^wWlnct I I I Dr.T. Kenneth James Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 I Dear Dr. James\nan It is my understanding that Mr. Tommy Boley from the University of Engfish workshop for all secondary English teachers at Hall High School during tte 2^:^^ sdiool year. I have previously requested this information in my letters to you dated October 29 , November 1* and November 4*. Is it your position (including Dr. Lesleys) that no such workshop took place? Your attention to nqr previous requests is appreciated. (incerely, JoyC. Springer JCS/ cc\nMr. John W. Walker Ms. Ann Marshall Mr. Clay Fendley Mr. Chris HellerJOHN w. Walker, p.a. Attorney at Law 172S Broadway Little Rock, Ar\u0026amp;insas 72206 Telephone (501) 374.3758 PAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS Via Facsimile - 376-2147 November 6, 2002 OP COUNSEL ROBERT McHENRY. PA DONNAJ.McHENRY 8210 Henobbson Road Limo Rock, Ahkaksas 72210 Phone: (501) 372-3425  Eax (6OI) 372-3428 Email: mcKcsiyd^wbclLnct Mr. Clay Fendley Friday, Eldredge \u0026amp; Clark 2000 Regions Center 200 West Capitol Little Rock, AR 72201 RECEIVED NOV -6 2002 OFFICEOF DESEGREGATION MONITORING Dear Qay\nI am in receipt of your letter dated November 5, 2002. My request for information relates directly to the LRSDs proposed compliance plan, item 4\nPrepare a comprehensive program evaluation of each academic program implemented pursuant to Revised Wan  2.1 It is my understanding tiiat literacy programs are being utilized to improve Aftican American academic achievement and that the District commits to evaluating these programs. I would like to have a better understanding of the literacy programs being implemented including who provided the training, amount paid by the District mid the substance of the training provided. I also intend to inquire regarding the other programs identified in  2.7 in the future. Thank you for your attention to this request. Joy C. Spring) JCS/ cc: Mr. John W. Walker Dr. Ken James Ms. AnnNbrshallBILL WILSON JUDGE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 600 W. CAPITOL, ROOM 423 LITTLE ROCK, ARKANSAS 72201-3325 (501) 804-5140 Facsimile (501) 804-5148 RECEIVED NOV -6 2002 November 6, 2002 OFFICE OF DESEGREGATION MONITORING Mr. Clay Fendley 400 West Capitol Avenue, Suite 400 Little Rock, AR 72201 BY FAX Re\nLittle Rock School District v, Pulaski County Special School et al 4:82CV00866 Dear Mr. Fendley\nThank you for your lener of October 14 in which you ask direction with respect to what correspondence amongst counsel might be sent to me. It seems to me that it would be best if the lawyers follow the general procedure, i.e., do not provide me with routine correspondence among yourselves. As noted in the Memorandum Opinion of September 13 I encourage all counsel to work together to implement the remedy ~ and work with the office of ODM if problems arise. If something occurs which requires a motion, I would get involved at that point. If any of the lawyers involved in the case think this is not the best route, I would be happy to hear from you\notherwise, I think this is the way to go. Thank you very much for your inquiry. ) Wm. R. Wilson, Jr. cc\nThe Honorable J. Thomas Ray Other Counsel of Record Ms. Ann Marshall Mr. James W. McCormack 4^5 C/= JOHN W. WALKER SHAWN CHILDS Judge William R Wilson United States District Court 600 West Capitol, Suite 423 Little Rock, AR 72201 John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 Via Facsimile - 604-5149 November 4, 2002 OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Askans.as 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Email: mchenryd^wbell.net received NOV - 6 2002 Re: Little Rock School District v. PCSSD, et al. Case No. 4:CV82-866 OFFICE OF desegregation MONITORING Dear Judge Wilson: On October 31, 2002, we filed a motion to enlarge the time in which to respond to a motion filed by the Pulaski County Special School District. On October 31, 2002, Mr. Sam Jones wrote the Court regarding the matter. On November 1, 2002, the Court wrote all counsel a note which stated:  Ill soon reply to Mr. Findlys October 14 query. .. On that date, I wrote the Court and stated that I had not received the October M* query. At 4:26 p.m., November 1, 2002, Mr. Fendley faxed me a copy of the October 14, 2002 query. I am writing to object to the ex-parte communication between the Friday Firm and His Honor. I am also writing to request copies of all communication between the Friday Firm and His Honor to which we have not been privy including any oral communication as well. Thank you for your attention to this matter. Sincerely John W. Walker JWW:js cc: Mr. Clay Fendley All Counsel of Record Ms. Ann Marshall Judge Thomas Ray John w. Walker, PA. Attorney At Law 1723 Broadway Little Rock. Arkansas 72206 Telephone (501) 374-3768 FAX (601) 374-4187 JOHN W. WALKER SHAWN CHILDS Via Facsimile - 604-5149 November 4,2002 OP COUNSEL ROBERT McHENRY, PA. donna J. McHENRY 8210 Hsmubbson Road Lrrru\nRock, akkansas 72210 Phone\n(501) 372-3426  Fax (SOI) 372-3428 Ewaiu tocheniydJjswbelLaot Judge William R Wilson United States District Court 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: Little Rock School District v. PCSSD, et al. CaseNo.4:CVg2-866 i Dear Judge Wilson,' On Octobtf 31, 2002, we filed a motion to enlarge the time in which to respond to a motion filed by the Puladd County Special School District. On October 31,2002, Mr. Sam Jones wrote the Court regarding the matter. On November 1, 2002, the Court wrote all counsel a note which stated\n m soon reply to Mr, Findlys October 14 query.... On that date, I wrote the Court and stated that I had not received the October 14* query. At 4:26 p.m., Novenier 1, 2002, Mr. Fendley taxed me a copy of the October 14, 2002 query. I am writing to object to the ex-parte communication between the Friday Firm and IBs Honor. I am also writing to request copies of all communication between the Friday Firm and His Honor to which we have not been privy including any oral romTnunirafinn as well. Thank you for your attention to this matter. Sincerely, ohn W. Walker JWW\njs cc: Mr. Clay Fendley AH Counsel of Record Ms. Ann Marshall Judge Thomas Ray JOHN W. WALKER SHAWN CHILDS John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 OF COUNSEL ROBERT McHENRY, P.A DONNAJ.McHENRY'  8210 Hemjehson Ro.ad LiriLE Rock, Arkansas 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Email: mchenryd^wbell.net Via Facsimile - 604-5149 November 4, 2002 Honorable Judge William R. Wilson United States District Judge 600 West Capitol, Suite 423 Little Rock, AR 72201 received NOV -7 2002 Re: Case No. 4:82CV0866WRW/JTR LRSD V. PCSSD DESEGREgSn MONITORING Dear Judge Wilson\nI am in receipt of your letter of a few minutes ago. For your information, I verified that I did not receive a copy of Mr. Fendleys letter\nMoreover, the copy that I received from Mr. Fendley on Friday evening is attached hereto with a second page. Please note the date and time which appears at the top of the fax. The fax that I received is dated November 1, 2002, the same day I raised the issue with you. (See attached fax) I have checked with Mr. Richard Roachell and Mr. Sam Jones and they have indicated that they received the letter on October 15, 2002 and October 16, 2002 respectively. If I am in error, I apologize, but my knowledge is what I stated earlier. -yjohnW. Walker  i'' JWW:js cc: All Counsel of Record Ms. Ann Marshall Judge Thomas Ray ent 1.1/01/2002 a.t 16:27:08 from to 5013744187 p2/3 Friday Eldredge ,\u0026amp; Clark HERSCHEL n. FRIDAY (1922-1994) WILLIAM H. SUTTON. P.A. BYRON M. EISEMAN, JR. P.A JOE D. 3ELL. P.A. JAMES A aUTTRY. P..A FREDERICK S. URSERY, P.A. OSC.KR L DAVIS. JR. P.A. J.^UvfES C. :LARK. JR., F.X THOMAS P. LEGGETT. P.A. JOHN DEWEY WATSON. P .A. PAUL B. 3ENH.AM III. P.A. LARRY W. BURKS. P..A. A. 'WYCSLIFF NISBET. JR.. P..A. JAMES EDWARD HARRIS. P.A. J. PHILLIP MALCOM, P..A. JAMES M. SIMPSON. P..A. J.Af,\u0026lt;ES .M. SAXTON. P.A. J SHEPHERD RUSSELL Hl. P..A. DONALD H. BACON. P.A. WILLIAM THOMAS B.AXTER. P.A. RICKARD D. TAYLOR. P..^. JOSEKB. HURST. JR. P..A. ELIZABETH ROBBE14 MURRAY. .=.A. CHRISTOPHER HFtJ.FR. P..A. LAURA HENSLEY SMITH, P.A ROBERT S. SH.AfER, P.A WILLIAM M. GRIFFIN Hi. P.A. M1CH.AEL S. MOORE, P.A DIANE S. MACKEY. P.A W.ALTER M. EBEL Hi. P..A KEVIN A CRASS. P.A WILLLAM A. WADDELL. JR. P..A SCOTT J. LANCASTER. P.A ROBERT 3. BEACH. JR. P..A. J. LEE 3R0WN, P.A. JA\u0026gt;XS C. BAKER JR. P.A HARRY A. LIGHT. PJL SCOTT H. rUCKER, P..A. GUY ALTON WADE. P..A. PRICE C. G.ARDNER. TONT.A ?. JONES. P..A. DAVID D. WILSON. P .A JEFFREY K. MOORE. P..A DAVID M. GRAF. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP CARLA GUNNELS SPAINHOUR, ?.A. JOHN C. FENDLEY. JR., P.A. JOHANN zISABETH CONICLiO. P.A. wwrw.fridayfirm.com 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201-3493 TELEPHONE 501-373-2011 FAX 501-376-2147 3425 NORTH FUTRALL DRIVE. SUITE 103 FAYETTEVILLE. ARKANSAS 72703-4811 TELEPHONE 479-595-2011 PAX 479-895-2147 R CHRISTOPHER LAWSON. P..A FRAN C. HICXMAN. P.A BETTY J. DEMORY, P.A LYNDA M. JOHNSON. P.A JAMES W, SMirri. P.A. CLIFFORD W. PLUNKETT. P.A. DANIEL L. HERRINGTON. ..A MARVIN L. CHILDERS K. C0LSMAi4 WESTBROOK. JR .ALLISON J. CORNWELL ELLEN M. OWENS JASON B. HENDREN BRUCE 3. TIDWELL MICHAEL E. K.4RNEY KELLY MURPHY MCQUEEN JOSEPH P. MCK.*.Y .ALEXANDRA A IFR.AH JAY T. TAYLOR . MARTIN A KASTEN BRYAN V. DUKE JOSEPH C. NICHOLS ROBERT T. SMITH RYAN .A. BOWMAN TIMOTHY C. EZELL 7. MICHELLE .^TOR KAREN S. H.ALaZR7 SARAH M. COTTON PHILIP 3. .MONTGOMERY KRISTEN S. RIGGINS .ALAN G. BRYAN LINDSEY MITCHAM SLO.N XH.AYy.AM .M EDDINGS JOHN F. .3EISERICH .AMANDA CAPPS ROSE BRANDON J. HARRISON Honorable Wilham R. Wilson, Jr. United States District Court 423 U.S. Post Office \u0026amp; Courtiiouse 600 West Capitol Avenue Little Rock, Arkansas 72201-3325 RE: 208 NORTH FIFTH STREET BLYTHEVILLE, ARKANSAS 72315 TELE.HONE 870-752-2890 FAX 870-7S2-2318 October 14, 2002 RECEIVED NOV -7 2002 OffICEQF DESEGBEGATION MONITORING OrCOUHSEL 3.S. CLARK WILLIAM L. TERRY WILLIAM L. P.'^TTON. JR K.T. JOHN C. ECHOLS. P.A. A.D MCALLISTER JOHN C. FENDLEY. JR. UTTLS ROCK TEL SOI-370-3323 FAX 501-244-5341 fndieY(Sr6c.nt Little Rock School District vs^, Pulaski County Special School District et al. United States District Court, Eastern District, No. 4:82CV00866 WRW7JTR Dear Judge Wilson: We note that Ms. Marshall provided you a copy other October 10,2002, memorandum to Dr. James setting forth obserr^ations/questions related to the Little Rock School Districts Compliance Plan for complying with the Compliance Remedy set forth in the Courts Memorandum Opinion of September 13, 2002. We submitted a response to Ms. Marshall on October 11, 2002, but were uncertain whether we should provide a copy of that to the Court. While we would be happy to provide copies to the Court, it would be presumptuous on our part to presume that the Court wants to review all correspondence bet\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resoources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_317","title":"Compliance hearing exhibits, 47","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["2000/2001"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Little Rock School District","Education--Arkansas","Educational law and legislation","Education--Evaluation","School improvement programs"],"dcterms_title":["Compliance hearing exhibits, 47"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/317"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["exhibition (associated concept)"],"dcterms_extent":["267 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nSchool Improvement Plans Marian Lacey, Assistant Superintendent-.x ii\u0026gt; 7 'f if if ip (f t f  p J MIDDLE SCHOOLS j 0  't t '( / David Patterson, Principal Cloverdale Middle Level Academy if if e 'f 'f- f I I p f r i II ? f f I* * t '4 I t (P \u0026lt; p: t 4 Debbie Berry, Principal Dunbar Magnet Middle School Elouise Hudson, Principal Forest Heights Middle School Larry Buck, Principal Henderson Middle School Ann Blaylock, Principal Mabelvale Middle School Jim Fullerton, Principal Horace Mann Magnet Middle School Nancy Rousseau, Principal Pulaski Heights Middle School Jim Mosby, Principal Southwest Middle School if 'i f- r t 'if I f 'f t tf if t a 'i 'i i\u0026lt; ji n if ir if 'if 'f J 't f 4 t t f 't fCLOVERDALE MIDDLE LEVEL ACADEMY SCHOOL IMPROVEMENT PLAN 2000-2001MISSION STATEMENl The mission of Cloverdale Middle Level Academy is to prepare all of its students not only for the upcoming experiences of suture education, but to instill a love of learning which will follow them throughout their adult lives. The task will be accomplished through a partnership of dedicated administrators, teachers, staff, and parents. Every effort will be made to create a safe atmosphere for success in life's future travels. OUR CREED ON MY HONOR I WILL DO MY BEST TO OBEY THE SCHOOL RULES, TO HELP OTHER PEOPLE AT ALL TIMES, AND KEEP MYSELF PHYSICALLY STRONG MENTALLY AWAKE AND MORALLY STRAIGHT. J VISION STATEMENT The Cloverdale Middle Level Academy family makes a positive difference in the lives of its members by providing opportunities for success. OUR PLEDGE I WILL BE. . . COURTEOUS LOYAL OBEDIENT VITAL EFFICIENT RESPECTFUL DEPENDABLE ATTENTIVE LAWFUL ENTHUSIASTIC CMLA Population 350 300 250 200 150 100 50 0 :?a: 'it'. 06 07 08 T T Black Count Other Count TotalCMLA Percentage Chart 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% *4 I . I --iiv- '( T Wi '\"i t T 06 07 08 ?iW ! W fesi Sv I\u0026amp; Total  Black Percent  Other PercentAction Plan: Community Involvement Problem Statement: (summarize the problem indicated by data and background analysis\nstate the desired goals) Condition\n300 hours of community involvement during 1999-2000 school year. Goal: 3500 hours of community involvement within 2 years. Stretch Goal\n5000 hours of community involvement within 2 years. Strategy Mentor Program Kev Actions 1) Faculty meets with local chinch groups and neighborhood associations. 2) Compile lists of volunteers and hours/times available. Classroom Helpers 1) Volunteer enters classroom to assist classroom teacher 2) Teacher has specific guidelines to give to volunteer (resource box) PTSA 1) One team member at every PTSA meeting. 2) Develop strategies to encourage students to bring parents. Professional Dev, Mentoring Guidelines inservice l)Develop guidelines to give to volunteers. 2) Develop resource box with skill deficiencies and students' names. Introduce reward ideas for both teachers and teams to attend PTSA meetings. Timeline Meetings: Sept. Begin: Nov. 5,2000 Begin: Nov. 5, 2000 Begin: Sept. 1,2000 Person Responsible Ms. Brooks Team Leaders PTSA President Individual teachers Team Leaders Mr. Patterson PTSA President Resources Mentoring Guidelines and list of \"high-risk\" students Test scores Resource modifications Incentives (monetary as well as other types) Assessment Track academic improvements/discipline referral s/absenteeism Track academic improvements Increased numbers of teachers/parents/commun- ity members and students at meetings. Adult Spanish classes Recruit a community member to give adult Spanish lessons in the After School Program and provide stipend for teacher. Survey on interest of faculty in attending such a class. Survey: Sept. 1, 2(XM) Begin classes: Nov. 5, 2000 PTSA President Ms. Brooks Texts (?) Copier availability Increased number of faculty/community members speaking Spanish 1Strategy P.A.R.K. Fall Festival Open Mike at Night Form interdisciplinary units with all core classes Curriculum Mapping Analyze last year's scores Action Plan: Community Involvement Kev Actions Professional Dev. In-service on curriculum mapping Timeline (cont'd) Person Responsible P.A.R.K. staff Teachers Ms. Seabrook Ms. Brooks Staff Social Studies committee Parents Teachers Students Communitv Teachers Resources Assessment P.A.R.K. facilities PTSA 2 Action Plan: Science Problem Statement: (summarize the problem indicated by data and background analysis\nstate the desired goals) Condition: Goal: 75% of Sth grade students at or above the basic level on the Benchmark exam. Stretch Goal: 95% of Sth grade students at or above the basic level on the Benchmark exam. Strategy Kev Actions Professional Dev. Timeline Person Responsible Resources Assessment Increase use of act to enhance interpreting info from charts/ diagrams/illustra- tinnc Specified vocabulary list Reading/writing science articles Alternative innterpretation of science concents Science Olympiad Create vocabulary list of terms used to formulate questions_______________ Assign science articles to students who then read them and summarize them for the class.____________ Present opportunities for students to create skits/ commercials/raps________ Student demonstrates skill taught to parents/ business leaders and teachers None None None Science teachers Science teachers Science teachers Texts Magazines Newspapers Library books Science Fair Mentor Program Increase act of collecting/calcu- latinedata S.W. design/inter- pret charts/ graphs from data collected from exnerimento____ Increase use of word problems Science teachers Science teachers Science teachers Modules Modules ModulesAction Plan: Mathematics Problem Statement: (summarize the problem indicated by data and background analysis\nstate the desired goals) Condition: 11% of Sth grade students are at the basic and proficient level on the Benchmark Examination. Goal: 50% of Sth grade students reach the basic and above levels on the Benchmark Exam. Stretch Goal: 75% of Sth grade students reach the basic and above levels on the Benchmark Exam._________ Strategy Quiz Bowl practice Standardize Test Program________ Incentive Assemblies (small)__________ Tutoring Program Stronger Math Club____________ \"Math Counts\" Competition Kev Actions Create questions and distribute them to the math teachers_________________ Professional Dev. Mini-inservice during team meetings to go over Quiz SqvyI rulgs________ Timeline Begin: Oct. 2000 Person Responsible Ms. Nesmith Individual math tWfth.gI5_______ Dept. Chairs Team Leaders Teachers Math Teachers Math Teachers Resources Texts Teams Assessment Classroom testsAction Plan: Literacy Problem Statement: (summarize the problem indicated by data and background analysis\nstate the desired goals) Condition: 42% of Sth grade students are performing at basic and above on the Benchmark Literacy Test. Goal\n60% of Sth grade students performing at basic and above on the Benchmark Literacy Test within 2 years. Stretch Goal: 90% of Sth grade students performing at basic and above on the Benchmark Literacy Test within 2 years. Strategy Accelerated Reader Program Vocabulary banks Drop Everything And Read Mentor Program (Adopt-a-student) Literary Magazine (one/nine weeks) Book Club Story Time Kev Actions Installation of program in computers 1) Compile lists of 50 words from each discipline. 2) Three new words will be presented per day, schoolwide. 3) All faculty/staff will develop strategies to reinforce words. 10 mins of reading on Wednesday a.m. instead of Chaimel One. 1) Teams identify \"high- risk\" students to be assigned a mentor. 2) Teacher \u0026amp; community mentor volunteers are matched with students. Collect stories, poetry and essays from students Create a list of books and a schedule Professional Dev. Workshop on using A.R. (Aug. 15) Mini-inservice to brainstorm strategies. Miru-inservice at faculty meeting Mini-inservice at faculty meeting with Guidelines for Mentoring None None Contact elementary schools to partner with None Timeline Begin: Sept 1, 2000 Begin: Sept. 1, 2000 Begin: Sept. 1,2000 1) Identification 1^ end of Sept. 2) Matched to mentor by Nov. 5, 2000 Oct. 2000 Oct 2000 Oct. 2000 Person Responsible Ms. Firestone Ms. McMurray Team Leaders Ms. Schutte Mr. Patterson Ms. Lamb Ms. Grecnley Mr. Bennett Tnd Teachers Team Leaders Ms. Seabrook Ms. Stewart Ms. Brooks Ms. Wickliffe Ms. Poore Ms. McMurray Ms. Schutte____ Ms. Hudson Ms. Wickliffe Ms. B. Williams Resources A.R. Software Books Incentives Text books Personal book Guidelines for Mentoring Magazine software \u0026amp; paper Book-of-the- month Books appropriate to rsad-tg.skm. Assessment Printouts from software In-class tests Quiz bowls Spot checks on classrooms by APs and Principal Track academic improvements/discipline referral s/absenteeism Sale of magazines Attendance at club meetings Attendance at story time days. 1Strategy Computers in all English Classes Make novels more accessible to teachers/students School-wide Incentives______ Test Preparation (for standardized tests)__________ Action Plan: Literacy Kev Actions 1) Improve communication between teachers and IRC 2) Improve ability for teachers to get books inhouse Professional Dev, None (cont'd) timeline Aug. 2000 Person Responsible District personnel Mr. Patterson Dept, chairs______ Ms. Schutte Ms. Brandon (IRC) IRC Secretary Teachers Administrators Teachers Resources Millage Partners in Ed. Class sets of novels Counselors Assessment 2A6TaP Arkinsu CimprcheaHTt TeaiDR A AssemcM FfOATun GRADE 8 BENCHMARK EXAMINATION MATHEMATICS SCHOOL SUMMARY REPORT Page: 1 A11 Students Gender Female Male District Name\nLITTLE ROCK SCHOOL DISTRICT District Number: 60-01 Schoo) Name\nCLOVERDALE JUNIOR HIGH SCHOOL Schoo) Number\n061 Gracie\n08 Total Number of Students Tested: Date of Test: February 1999 Number ft Percentage of Students School Below Basic (BEL) 148 and below District Region State 138 Number of Students who did not attempt the Mathematics session\nNumber ft Percentage of Students Basic (BAS) 149-199 School District Region State 4 Ethnicity Asian/Pacific Islander African American Hispanic Native American White Gender/Ethnicity Feme 1e Asian/Pacif1c Islander African American Hispanic Native American White Gender/Ethnicity Male Asian/Pacif1c Islander African American Hispanic Native American White 122 sax 989 85X 2,388 45X 11.562 47X 13 gx 364 24Z 2,126 4OX 9,871 40X Nuaber 8 Percentage of Students Proficient (PRO) 200-249 Number ft Percentage of Students School 3 2Z District Region State School Advanced (ADV) 250 and above District Region State 133 9X 690 13% 2,822 1IX 0 OX 33 2X 121 2X 409 2t 67 93X 55 83X 0 ox 111 sox 3 loox 3 lOOX 1 SOX 0 OX 61 94X 2 10OX 2 lOOX 0 OX 0 OX 50 B5X 1 100X 1 100X 1 50X 516 6SX 473 64X 10 30X 814 81X 27 m 14 82X 106 26X 6 46X 429 BIX 15 75X 9 82X 51 26X 4 20X 385 SOX 12 SOX 5 83X 55 27X 1,245 45X 1,142 44X 4 13X 969 81X 33 49X 31 55X 1,323 34X 3 18X 482 82X 19 53X 18 BOX 709 35X 1 11 486 BOX 14 45X 13 BOX 614 33X 5,968 48X 5,587 46X 26 I7X 3,766 82X 214 57X 199 63X 7,247 38X 15 19X 1,937 B3X 110 BIX 86 BIX 3,776 39X 11 I6X 1,828 82X 103 54X 113 63X 3,471 37X 5 7X 8 12X 0 OX 11 9X 0 OX 0 ox 0 ox 0 OX 4 BX 0 OX 0 ox 0 ox 0 OX 7 12X 0 OX 0 ox 0 ox 184 24X 180 24X 11 33X 172 17X 6 I7X 3 I8X 168 42X 6 46X 88 17X 3 15X 2 18X 83 43X 5 25X 84 I7X 3 20X 1 I7X 85 4IX 1,079 39X 1,044 4OX 19 BIX 196 16X 32 48X 20 36X 1,848 47X 9 53X 90 15X 15 42X 9 30X 951 46X 10 71X 106 18X 17 55X 11 42X 895 47X 4,969 40X 4,889 4OX 73 48X 723 16X 134 36X 100 31X 8,797 46X 38 47X 351 I5X 54 30X 48 34X 4.458 46X 35 SOX 312 Ml 78 4IX 52 29X 4,333 46X 0 ox 3 5X 60 BX 13 10X 349 13X 341 13X 1.406 11X 1.415 12X 0 ox 0 ox 16 2X 17 21 64 2Z 57 2Z 181 IX 228 2X 0 OX 2 2X 0 OX 0 ox 1 BOX 9 27X 19 2X 2 6X 0 OX 103 26X 5 16X 23 2X 2 3X 5 9X 652 17X 39 26X 74 2X 23 6X 16 6X 2.661 14X 0 OX 0 ox 0 ox 0 ox 0 ox 3 9X 6 IX 0 ox 0 ox 24 BX 3 10X 5 OX 0 ox 0 ox 113 3X 14 9X 5 OX 2 IX 1 ox 385 21 0 ox 0 ox 0 ox 0 ox 0 ox 0 OX 2 3X 0 OX 0 ox 1 5OX 1 BX 9 21 2 1OX 0 ox 48 25X 8 40X 10 2X 0 OX 0 ox 55 27X 3 I8X 11 21 2 BX 3 1OX 328 16X 2 14X 12 2X 0 OX 2 8X 324 17X 22 27X 42 2X 14 8X 6 4X 1.319 14X 0 OX 0 ox 0 ox 0 ox 0 ox 0 OX 4 IX 0 ox 0 ox 12 SX 2 12X 4 IX 0 OX 0 ox 58 3X 6 11 4 OX 1 IX 0 ox 169 21 16 23X 32 IX 9 5X 12 7X 1.342 14X 0 OX 0 ox 0 ox 0 ox 0 ox 3 15X 2 OX 0 OX 0 ox 12 BX 1 11 1 OX 0 ox 0 ox 55 31 8 IIX 1 ox 1 IX 1 IX 216 21a^Tap Afkaimi ConprdiCRsnt TtainR 4 Aunneni Frounni GRADE 8 BENCHMARK EXAMINATION LITERACY SCHOOL SUMMARY REPORT Page: 2 A!! Students Gender Fema!e Male District Name: LITTLE ROCK SCHOOL DISTRICT District Number: 60-01 School Name\nCLOVERDALE JUNIOR HIGH SCHOOL Schoo) Number\n061 Grade: 08 Total Number of Students Tested: Date of Test\nFebruary 1999 Nunbar \u0026amp; Parcentage of Students School Below Basic (BEL) 163 and below District Region State 128 Number of Students who did not attempt the Literacy session\nNumber t Percentage of Students Basic (BAS) 164-199 Schoo! District Region State Number 8 Percentage of Students Proficient (PRO) 200-249 Schoo! District Region State 14 Number ft Percentage of Students Advanced (ADV) 250 and above Schoo! District Region State Ethnicity Asian/Pacific Islander African Anerican Hispanic Native American White Gender/Ethnicity Female Asian/Pacif1c Islander African American Hispanic Native American White Gender/Ethnicity Male Asian/Pacif1c Islander African American Hispanic Native American White 75 59X 31 47X 43 70X 0 OX 68 59X 1 33X 1 100X 1 sox 0 ox 31 SIX 0 ox 0 ox 0 ox 0 ox 37 69X 1 100X 1 100X 1 SOX 658 46X 285 38Z 372 5X 7 2IX 533 56X 19 sex 11 131 It 19X 3 23X 240 46X 7 311 1 78X 27 14X 4 20X 293 esx 12 sex 4 tit 49 24X 1.609 31X 593 22X 1,015 40X 2 ex 655 58X 19 29X 24 44X 890 23X 2 12X 281 49X 7 20X 8 29X 288 14X 0 ox 374 e7X 12 39X 16 62X 601 32X 7.962 33X 2.822 23X 5.133 43X 22 14X 2,592 58X 146 40X 142 46X 4,977 26X 5 ex 1, 121 49X 51 29X 34X 1,569 16X 17 24X 1,471 S9X 94 51X 95 56X 3,406 37X 42 33X 28 42X 14 23X 0 OX 39 34X 1 33X 0 OX 0 ox 0 ox 25 4IX 1 SOX 0 ox 0 ox 0 OX 14 26X 0 OX 0 ox 0 ox 497 34% 291 38X 206 30X 14 42X 319 34X 9 27X 3 2OX 145 37X 5 38X 208 4OX 7 311 1 11X 64 34X 9 45X 111 2 ex 2 14X 2 33X 81 40X 2.367 45X 1.260 46X 1.105 44X 16 52X 388 34X 34 52X 25 46X 1.888 48X 7 41X 228 40X 18 SIX 15 54X 983 48X 9 64X 159 28X 16 52X 10 38X 905 49X 10.881 45X 5,749 46X 5,122 43X 63 41X 1.489 . 3 160 44X 133 43X 8.974 47X 32 40X 902 39X 84 til 68 SOX 4.637 48X 31 44X 586 211 74 4OX 65 38X 4.336 tn 11 9X 7 11X 4 n 0 OX 8 11 1 331 0 OX 1 sox 0 ox 5 8X 1 SOX 0 ox 0 ox 0 OX 3 6X 0 OX 0 ox 1 sox 269 19X 166 22X 103 15X 12 36X 92 1OX 5 15X 1 11 157 4OX 5 38X 67 13X 5 26X 1 11X Bl 46X 7 35X 25 ex 0 ox 0 ox 70 35X 1, 164 221 5,196 2IX 0 OX 18 1X 82 2Z 314 1X 794 29X 369 15X 13 42X 85 8X 12 18% 5 9X 1.044 27X 8 47X 59 10X 9 26X 5 18X 708 35X 5 36X 26 5X 3 1OX 0 ox 335 18X 3.627 29X 1.565 13X 61 40X 349 8X 59 lex 31 1OX 4,682 25X 38 47X 269 12X 41 23X 22 lex 3.245 34X 22 3IX 80 4X 18 1OX 9 5X 1,434 16X 0 ox 0 ox 0 OX 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 0 ox 16 2X 2 OX 0 OX 6 IX 0 OX 0 ox 12 3X 0 OX 5 1X 0 ox 0 ex 11 6X 0 OX 1 OX 0 ox 0 ox 1 ox 63 2X 19 IX 0 OX 2 OX 1 2X 0 OX 79 21 0 OX 2 OX 1 31 0 OX 60 3X 0 ox 0 ox 0 ox 0 ox 19 IX 244 2X 70 1X 6 4X 10 OX 2 1X 0 OX 295 2X 6 7X 8 OX 2 1X 0 OX 227 2X 0 ox 2 OX 0 ox 0 ox 68 IX90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 81% 65% \" \u0026gt;4% 2% 17%.,.., Grade 8 Benchmark (2/99): Mathematics . .77%........ 82% 26' 42% 6%-- 30% 33% 17%-- H6\u0026lt;%--------- 0% I 18% 9% I0% 0%  Below Basic  Basic  Proficient Advanced  z is* z ^6 z z z 80% 70% 60% 56% - 50% -46% - 40% 30% - 20/,, - 10/o O/o M% M% 1/o Grade 8 Benchmark (2/99): Literacy 379! 40% 19/ 3% 58% 42% 16%...... 73%  Below Basic  Basic  Proficient S7%--------- \u0026gt; fl fc O/o  Advanced z ^3 '7 S' z xO'- z z z \u0026lt;4100% 90% 88% 80% 70% 63% 60% 50% 40% 30% :3% 20% 10% 0% )% 0% Cloverdale Dunbar Grade 8 Benchmark (2Z99): Math, All Students -....87% 73% 72% 65% :3% :3% 2 2% 52% 48%  Below Basic  Basic  Proficient Advanced\n3% :2% 7%-- 2% 2% }% Forest Heights Henderson Mabelvale Mann Pulaski Heights Southwest 70% 60% 59% 50%  40%  :3% 30% - 20% 10% - l% )% 0% Cloverdale 49% 5 3% 7% )% Dunbar Gracie 8 Benchmark (2Z99): Literacy, All Students 58% 51% 59% 40% 17% 1% % T : 4% 7%------- 1% Forest Heights Henderson 42% \u0026lt;7%-------------37J 35% 31^o2'*\u0026lt;il :3% 0% 1% Mabelvale 0% 2% 2% )% Mann Pulaski Heights Southwest  Below Basic  Basic  Proficient Advanced Dunbar Magnet Middle School a 2-a' i Im l^\\ jFtSS\u0026gt;3 M- 455 !V pfij s f- -li I- o / Tuning Up For Success On The Global Highway Gifted \u0026amp; Talented - International StudiesLITTLE ROCK SCHOOL DISTRICT MIDDLE SCHOOL PROGRAM MISSION STATEMENT The mission of the Little Rock School District Middle School Program is to meet the unique needs of all young adolescents, equipping them with the knowledge and the intellectual, physical, emotional, and social skills to successfully accomplish the transition to high school. This is achieved through: a developmentally appropriate curriculum that is challenging, integrated, relevant and exploratory\nspecially trained, nurturing educators using varied teaching and learning approaches within a flexible organizational structure\nstrong family and community partnerships\nprograms and policies that foster health, wellness, and safety\nand a faculty advocate for every student. -Adopted by LRSD Board of Directors March 26, 1998DUNBAR MAGNET MIDDLE SCHOOL MISSION STATEMENT The Dunbar Magnet staff acknowledges that the nations of the world becoming increasingly interdependent. To prepare for this are becoming increasingly uiiciucpcnwin- xv interdependence, we seek to develop thoughtful, creative individuals able to participate effectively as citizens of an international society. We plan to meet the needs of a diverse student body by offering a challenging curriculum, emphasizing creativity and higher order thinking skills. Dunbar Magnet students will develop awareness and understanding of various global issues. cultures and languages as a passport to the future.Administration Deborah Berry, Principal John Bacon, Assistant Principal Ryan Burgess, Assistant Principal Rhonda Dunn, Assistant Principal Campus Leadership Team Steering Committee Deborah Berry, Principal Linda Austin, Central Office Louise Gutierrez, Parent Charles Stewart, Business Lucious Powell, Community Gerald Talley, Community Beverly Harris, Non-Certified Staff Vickie Finney, Non-Certified Staff Edith Ax, Faculty Darrell Carr, Faculty Tyri Flynn, Faculty Arthur Olds, Faculty Dawn Terry, Faculty Francine Skotko, Faculty Oscar Dean, Designers Tyri Flynn, Corvette (8) Sara Gaines, Prowlers (7) Tina Jones, Infiniti (6) Karisa Nichols, Pathfinder (7) Arthur Olds, Renaissance Racers Susan Sloan, Explorer (6) Judy Warren, Navigator (8)School Improvement Plan School: Dunbar Magnet Middle School Year: 2000-2001 Priority: Improve Student Achievement in Mathematics Supporting Data: The Stanford 9 exam showed that 2 disaggregated groups of students were 64% and 35% above the lowest quartile but only 9% and 3%, respectfully, in the highest quartile. These same groups were at 21 and12 /o ** / __ ' ___________. ____nn and Miimhpr SVStemS Problem Solving - Estimation, and Number Systems above the 50th percentile. The lowest scores were in and Number Theory as well as in Procedures - Computation in Context and Rounding. Only 14% of the students were at or above the \"proficient\" level on the State Criterion-Referenced Mathematics Exam. Goal(s): 100% of a school's students shall perform at or above the \"proficient\" level on the mathematics exam (grade 8 on the State criterion-referenced test). 65% of a school's students in every sub-group of race and gender shall perform at or above the 50th percentile in mathematics (SAT9 - 7th grade). At least 30% of a school's students will perform at the highest quartile in mathematics (SAT9 - 7th grade). At least 90% of a school's students will perform above the lowest quartile in mathematics (SAT9 - 7th grade). 90% of a school's students shall perform at or above the \"proficient\" level in mathematics each semester (grades 6-8 on the LRSD criterion-referenced mathematics test). o    E  c w 0.  E o \u0026gt; o Q. E o o O (0 o o CM I O o o CM (0 (l\u0026gt; CM 0) O) . \u0026lt;0 u \u0026lt;0 E 0)  (Q  o \"S o Q C C  E c TO C  D C  \u0026lt;D  2\u0026gt;  4!\u0026gt; * 2J c c o .2 *0 0  .TZ o o    c tn o   j= o *- 4= C  o f-S co  E c o\u0026gt; m  a, \u0026gt;  c \u0026gt;1 .c o n   o IS. 'E \u0026lt;0 9 o O o c CJ (Z) 0)  c 0 E \u0026lt;D Q. O)  c   \u0026gt; \u0026gt; o P Ji m o Q. E 2-^ (0 c  0) O} s (0 Q  Q c o O 3 55 S p g 3^ (0 E 2 E o c m k. o o  o (Z) O Q. (0 \u0026gt; d\u0026gt; o O  j  c  X D 3 \u0026lt;D \u0026lt;/) o o c    E o =  w  0) \u0026gt; 2 Q. E i E (0 c Q\u0026gt; o 3 To o CM q)  o k_  Q. o m  tZ (0 UJ 2 m  S  UJ (0 h- \u0026lt;11 C7 V E 0. UJ OT CO x: _i I- C i z UJ CM J CM m 23 2 \u0026lt;  TO O O \u0026lt;D \u0026lt; * Is  \u0026gt;* IS (0 0 TO 2 o = \u0026gt; ? I (0 (0 b. c o  . Q ? c O 0) g  P o\u0026gt; = O. O\u0026gt; a\u0026gt; V c o o .2 TO  o o TO 5 TO .2 V  w i= CM TO ^ \u0026lt;\" Q SM  r 'S  e. o   to xP  2 Z E 0   o X  o .*2 TO O  TO CM O \u0026amp;\u0026gt; 0) o O o  cq co o 5 2 o  o. tn (0   E CM *0 o o  \u0026gt; O X}  o  o  k. O) 7 O t  Ui Q.^  o c   \u0026gt;1 S) y  CD Q) c ra J2  o n  o o\u0026gt; M- C o  Q. E 3  O \u0026gt; O) I Ji o Q. 2: -p 0) c c p tn 0) c  *- O -O p  (/\u0026gt; o  U X  E o \u0026lt;0 =  s I (Q O p o TO c o c 8 o\nTO CD 1 c c  u o     E  _ H $ TO E \u0026gt;  VO 3 t \u0026gt; e p w o. Q. = E CL t Q. . o 5 tn o  E  j: ra E c Q.  E o . O 2 - o ?\u0026gt; ill c Q. tn TO - I I 2 I O   TO - 2  TO  C C5 TO E  0) C S LL O)  X u TO m c Q- E \u0026lt;D 5 (0 3 O  2 S \u0026lt;u E  (0 \u0026lt;D r\u0026gt;  2 c n n 5 8 E g CD TO TO .. -   TO S Z - 8-  S  2 $ p g w s  ? 5 E g '  I c t/i 91 O V   .1= a\u0026gt;  ra  o O 7. COTO 5 2 -c- 1   p V \u0026gt; o 95 \u0026gt; 2 8 = 8 TO E I V 2 ? \u0026gt; O- TO 9 2 I Q-  liiE 1  5 O) re o (0 c E O) .c h c TO I Q. TO sz m co c TO c 2 -6 3 = 9 K -j i5 2 JO O C c _ a\u0026gt; 3  -o Q -5 (0 o O o O) 95  c c: TO  TO o -o c  = E i o  5 3  c S _ 2 ts ? \" O) o  M- to * c o  M- _ 2 TO CM  O 2 C I   C O o   5 -R \u0026gt; O 53- O  o o   a 2 \u0026amp;    2 2 - c TO TO S\n! tc f- \"5  o (0 \u0026lt; (0  tfi c o 2 c Ui O 1- 3  M  \u0026gt;1 O 5^ o  u  tn  o O  E  o  E   \u0026gt; Q- O  Q. E m i  c o w 8 *5 0) 11 c Ogo 3  .c 0) S o  2! 2 E 50?^ I c TO G C C _ TO 3 TO -D Q 'S =  -85 p 2  a -2 I tfi \u0026lt;=^  o Ci- CM 2 E TO  5  c co TO 9- .2*D c 0 Cw Q. C 0) E 0) \u0026gt; ko Q. E OO (Zo) o o \u0026lt;M Io o o CM (0 \u0026gt; o o o \u0026lt;Z) Q\u0026gt; $ Q\u0026gt; O\u0026gt; TO s TO -Q C a Q OO O (O qs -o CD CD O X CD o CD CD E O \"eg 5 eg o \u0026gt;p (0 \u0026lt;/)  o' D c ns D c 0 0) 0) o CD CD O X CD \u0026lt;*\u0026gt; TO TOO) TOO TO 5TO TO 5 C cTO e TO c o '\u0026lt;\u0026gt; c a\u0026gt; ^3 s co Q\u0026gt; P 2* 5 (0 E o \u0026lt;D m o D. (0 \u0026gt; 6o $ tn o ns E CD m E c CD ns o O tn CD 5 o CD CD CD \u0026gt; \"O o ns -Q E-ns O o\u0026gt; E '  O) 2. \u0026lt;2, (Z\u0026gt; t-c CD o 3 (/\u0026gt; ns CD \u0026gt; a ns CO CD o ns x: o  s o E o 5 8 P Q. .E CD -D x: c I ns co 0) \u0026gt; o \u0026amp; E o  2 i I 1 o co o CD O X CD CO i_ 0) o (0^0 eg o o O (0  o n c 0) o co 1C G) o  vO  (0 2 a\u0026gt; a. Q. S' 8 -i  eg jie o \u0026gt; CD P p  SP E- .i .i o o O tn m 15 ssn 11 - c  S n  TO \" C S  ? i c  E UCD- \u0026lt;0 tc uTO. co c S LL (0 s 91 CD c* \"o TO TO .0 5  2   -TO  1 m TO  O g 52 . 'to \u0026amp; $ - i 2! g s C S' p- -2   g a .i eq \u0026gt;2 Q. -i o _ g P 2 o TO c  E 1 3  11 I 1S1 I5l Il UH S 1i21O) c  CD e Q. CD CD qi Q. J 5 E o o O1 I 1 is  to TO 3 o 0) o 3 c eg TO \"S -  15 -  g I I 2 S  -2^ 2  0 -5  8 \"S O  -(6 eg  TO E 7 TO - 5  5  TO \"5 TO I - '52 TO  .2 O TO '2  C S  TO .2 i. E c C (Q CQ 5 .c  o eg eg 2 5 .2 = CD 5  .2 c  \"S E 0) u CD C  2 C \u0026lt;2 c CD -E \u0026gt;CD CD o  O o w  tx: 2 Q. CD = CD C \u0026gt; o oo O (O ra O tn V D ns ns OS i_ -E \u0026lt;D E w E CD Q. CO o Ui .c a c ns CD CD D U) co o O 2* c s CD c O o \u0026gt;- 0 CD \u0026gt; Q- O CD f E vi tn I Q. W i LU o CD CD E E a: $ (A \u0026lt;  .T2O  iiuns\n2 CD 10 c  0 or CD - O 1 ^ - \"L 'A D o  = ,rC S i  *- - z CM C01D n in IC-S \u0026gt; rs o c o US a: x: \u0026lt; tn CO IS^'S V) w  z CD O cE l3o {53 OO S 5 2 s o c Z Z TO t \u0026lt; 2 0\u0026gt;1 TO nj (/)  O- a: TO  Z O o fn c CD TO 0 2 (0 c Q_ Q LU 52 I ? CD 5^10 !s o CK 2 0) C r\u0026gt; W 8 s S -D CQ UI ? TO T2O II co 'xOs S \u0026lt;0 E CD CD o ns E tn -o CD CD T o CD c Q. CD co J) o  ? E o CD C .C CD ns o E |8 E 5 o 0) C E (0 o OS op 0X0 c: ns tn tn CD \"D ns c O) o E CD \"O CO ns CD \u0026gt;1 C o -(SD ns g o  CD o CD E   Q2. O\u0026gt; CD Q_ f S o c co 3 4C E n tfi (0 o O)  1 O) *c E T\u0026gt; (D I S) \u0026gt; c \u0026lt;i\u0026gt; \u0026gt; (0 tn 0)  E (0  0) .n \u0026amp;! o li c (I 11 0 C x:\nI f to o P 5* o  __ (0 C w 0. c 0) Ea\u0026gt; \u0026gt;o Q. E oo u W o o CM IO o o (0 \u0026gt; 0 (0 c '*iX Q. OQ ! s to p o 3 OQ to 5 a\u0026gt; .i2 g o 3 Q OQ \u0026lt;0 to 2 3 O (0 to a: to c \u0026lt;/\u0026gt; (0 c I O E 85io^  Q-  ~ S -\u0026gt;c w E 8w- 2  F  S  -5p E0 Qo . \u0026lt;to E E c 5 \u0026gt; E 5 to :c E S 5 2 2 -F d) ? c c u 0) to 5 Tj H Q  O \u0026lt; E E 3 C 0) \u0026gt; E (0 !S co o 2 9 M38 to g - c ? -S 9 to 2 2 E 2m to to 2 2 s  5 o un \"Oo WO CQ (Z) to (0 EE to to O o\u0026gt; (0 (0 0) X  O)  E P o i= 5 1 S E o ~ 5  (0 0) S 'Z. Vi (0 o c \u0026lt;1\u0026gt; O) \u0026lt; 0) Q. O I O. t/i Q, O I 0\u0026lt;. qI o o c o CZ) O is 0) c: o\u0026gt; TO (0 c 3 Q oo o (O C O o o j: 0 Vi p O Vi o TO E TO TO S c .2 *3 C CD V c C o to s to 5e co  Q. OL ) to o: to c p o O. to Vi Q. to CO Q-to Ui Q. to CO g o o\u0026gt; c O Q. to Vi to co to CO !2 to D (0 5 .2- S o O) . 3 _ CO a (0 M o . ji: c Q -Dc \u0026lt;/\u0026gt; 5 v) *2 0) =3 (0 ID Eif o  1- Q. 4S S I* E y E  S  -c  Q - I-tn o O) * c c s IS o g to C eIe E c   E E x: m  .f5f2t '0w)  o W 75 C UJ 0) Ci t. a\u0026gt; E 2 to to to c H P Ito 8 K to F \"S E -2 \"D CD \u0026lt; O OT C to T3 3 Io c o ? -C I 2 s o c C o3 S(02 E A (0 to c o 1  ro m \u0026lt;uD. O) O C C 0) co (0  to D (0 to E (0 to o c (0 (/) fl V \u0026amp; Z o o (0 c 0) 0)  CT) (0 c o S5 = 3 UJ . to 3 Tt -D O 2  S to -c 9 5 O E -c c  \u0026lt;0 O to Q. to  5 . 0) O Q 2  to E E 0) 3 s . E O 3 E S S I to 8s t fi 0 S I E o to c . toE lO TJ to  to to .C 2 O II $ a d S ao \u0026amp; ph to  Q. to  Xi p\u0026gt; 5^ 0 \u0026lt; CD 0.   9 5* o 3 0) c (0 QL C o E 0) \u0026gt; o Q. E o o u Vi o o CM I O o o CM (0 V \u0026gt; CM Q\u0026gt; O\u0026gt; (0 (Q Q. OQ 0) o a o 3 CQ .0 a\u0026gt; 5=  .fl 3 Q C\u0026amp; 10  3 o 0 w q: Qi E O Qi 8ST \nr w \u0026lt;1\u0026gt; 0 1 TO :3 - \"8 2 2 m Sa o 2   Q. o TO g 8 TO  Q. TO E 3 3 8 \"S E 0) (0 h O c 2 3 x\u0026gt; O JJ D. ti \u0026lt; (0 E I- .9 0. O o o c a TO D 5 -6 ) D X] 1 8 TO \u0026lt;!\u0026gt;  TO  i O) 8 \u0026lt; . (0 TO c 8 c TO c o (0 s C O 8. S s 0) o o o c u to 0) ) (ts 1 o o a\u0026gt; 4= Vi s o \u0026lt;0 o (0 Q (0 e Q\u0026gt;  (0 S Q o o u Vi c o \".z c V 0) *- c o .c E o o) 3 \u0026lt; 8*2 CD '8*2 CD iz CD V- 3. TO Oi o  I e o Q- 0.   q: , e m o m TO o g) u y \u0026gt;- \u0026lt; TO c 15 5 Ui 8 5  S I si 'to TO (0 E C o TO X X  TO 8 E  o TO /9 *0 O (0 8 TO E 0) 8 c o\u0026gt; c 0) 8 \" S TO Ui I- \"5 x: (/) 2 TO TO  3 TO V! = ? \u0026lt;0 TO C I 1$   2 c . B 8  E 0) C TOO Q 0. 0. O TO TO ip C c E  \u0026lt;3s o\u0026gt; c 0) 11 Ui I- TO 3 o .!= .   TO TO O sole\nX c - c c 8 3 8 E  J 15 c o \u0026gt;- 5 \u0026lt;  TO -:  O Q 5 tZ5 C .0 o  TO T5 TO TO t  E \"o c o \u0026lt;  z S E p \"   5 c  TO \" n TO 55 C ~ 5-  D O CT \"O C P TO  t is o O = C5\u0026gt; \"S t c  3 \u0026gt; o  fl S  5 -c  I S -8\nc c TO 0) \u0026gt;. W t5 15 35 8 8 8 8 I o  (0 06 E to 8.  E 588 0'^8 I\" 2 TO  f If S = TO 16 TO 8  TO m - c \u0026gt; E C   o c  C c C . 3\u0026gt;  i TO TO c si c TO o 3 55 -j E \u0026lt; s. 2 ? Qi O. (0 E Z 8 p tn TO 8-2 c c 5 O 8 TO D. i= P i O) C  Q TO S S  8^ oi  S.'B  8 iR c s\n\u0026lt;-\u0026gt; \u0026lt;0  \u0026gt; CL 8 o .TO *- 6 10 3 o TO  C O o I n D TO   15 .  S  TO .ti 5* P \u0026lt; 3 (/) TO w c 3 TO c 1 o  m V) 5 \u0026gt; C TO g Q TO c 'S. 8 CD o c TO   c: TO E  cf \"m - C Hl $ s.^.   d S 5  6 c TO E c B a m TO = \"O 3 TO x: - E p  -c : a 18- sl n C O o 8 c TO '8 D. 8  2 r c\\i c T-  TO o Q * O 3 (g Q. C (U E Q\u0026gt; O Q. E O o u (/) O O M O O o \u0026lt;M (0 \u0026lt;*\u0026gt; Q\u0026gt; D) to Q. 1 (0 (0 p 0. *c tn   o 3 tn o  5  .52 3 Q OQ   3 O   ft: Q\u0026gt; C O\u0026gt; C c ?o I  i 0. re o c P *3k \u0026lt; re o\u0026gt; A Is 2 6 3 /Il  a o re u. 0. ifi re D c 0) D\u0026gt; \u0026lt; a\u0026gt; I E re a\u0026gt; E (0  tn re O 0 D) m \u0026lt; l-i co S o o x: o \u0026lt;/) I c o o p .W to to p c o i2  E 2^  C o (S Q. Q.  c \"S. Si \u0026lt;D Sw CD in  5 re 'C $ 5 O E - t- -c a O) 5 12  C C J 5 co o\u0026gt; c o a\u0026gt; c O a 3 a\u0026gt; c o\u0026gt; tn (0 Xi c 3 Q o Vi o p E p  p c o  q: c o o O O u (Z\u0026gt; c a\u0026gt; \u0026lt;i\u0026gt; c c F  o 2 o- 2 E   5 S-i . G) 0 0 5 8 \"S E  11 x: 'C Vi 5 3-^ lU o I? C -F m S o 2 5 \u0026lt;s TO . 38  m e  o TO Q. 0) o re 0) P c 0) 2  o. E \u0026gt; 8 a\u0026gt; s c O -- (n 8 I = fS 8 i ^ i5  i ? E E o\u0026gt; 2  S o E -S-, =  S.2 0) re E s re E o c  \"O Ml c p  I re I..  2  c \u0026lt; 0) ^(0 0) S    lo ? w/ -si \u0026lt;6 3 El c 2 =3 ?2 -O c o m re 1 \u0026lt;l\u0026gt; 5 S E Q. TO - P X c .E  Vi 3 F E I s O H 0) JZ o  c O g * *X w S 2 E re . -  o u\n5S S 2 c \u0026gt;. TO  t: EES E  c E 2 y w 2 5S| c  \u0026lt;\u0026gt;  ^ Q. re3 :2  o u to 3 12 re I  reeS 3J5: 5 t3o \u0026gt; \u0026gt; q: o lWu Hq: III I m o 8 Q Z uj re re O re c U. 2 o co o O)  (0 c o f0c) = CO 2 P . \"o E *3) u c o Vi re m (0 O O   C :  1c f- f(f0l 0) R S X ra 2c =Q . X C 28 ? TO \u0026lt;Eu TO V \u0026gt; 0) E 2 Q. H \u0026lt;0 Mf 2 a (0 o 5 Q to te O  Q\u0026gt; re -J Q\u0026gt; C U -S (Q a\u0026gt; \u0026lt;0 \u0026gt; TO m ? c .\u0026amp;s S \u0026lt;2 (t to On  S 8 C (0 O E o v Di x:  oo 6 o o CM O m \u0026lt;-\u0026gt; \u0026lt;\nUJ _) \u0026lt; UJ \u0026gt; I \u0026lt; t~  UJ LU 0^  56 S X S H Q Q Hl Z O Q ui Z D Q H  z y I- \u0026lt; ? O UJ 5S _J UI t- UJ m z \u0026gt; I UJ UI f? 5 Sus 0^ \u0026gt; B 3 \"O 5 O B \u0026amp; -O e -b     \u0026gt; *- o -o .o o V v n s u Vi u 43 X U  es cn V H .w 'C n S X a s o 0S 01) O V) =  .S 0^ S E R O OD s S S on U S \u0026lt; -p *  e 2 S  V o \u0026amp;. OS5 cA I s o fi. (A u \u0026lt; \"i A \u0026gt; o fi. V e s .2 -S s tn e X GA t A .CS A J3  -S 2 s  Qi 5 3 X (O 4*- o u O Bi so fi o I K 5 s u o o Q IO N CM O CM CM o CM CM O o o CM O) c Q. CO  a I c' c I 3 M IO o JM CM IO o CM o o CM _ v\u0026gt; te c 5 Q S M o  tn It O _I  \u0026lt; \u0026lt; C UI (B $  O z S e .! V u u V O. V X eIT C c\\ fS bX c c c\\ IT C c\\ I CM 0^ 0^ \u0026gt; a\u0026gt; C \u0026lt;u s a\u0026gt; \u0026gt; 0^ cn V o u CZ) V \u0026amp; A a\u0026gt; \u0026gt; CD (1) o 2 O I D N 6^ ro (U O 2 O (D D g cc c\\ CT C c\\ o N \u0026lt;y x\u0026gt; D N Q c c\\ ^5 TtCMOOOCD'^CNOCOO^ ^^^00000050)0) CMCMCNCMCNCNCMCMv-'^'^\u0026gt; V s . 3 \"O o w u a. s v   V  \u0026gt; ** o -o a\u0026gt; H CA W CO V s X V Q a. Vw X i! w    a J-  O co .s a\u0026gt; s s  a o OD s eV o. I co  O  2S s   5 5 -a o. o A S .Ms V o u V aV X H E -ew s o a S V  o CM V OlC u s q a 05 CA I s _o 'u V u oCZ3 u fi Vi U e u ca es s 6A oX GA A U3 V GA IS o o o CM O\u0026gt; c *c a (0  35 5 s u fi e u Q O s M M o co CM IO CM CM o CM CM CM \u0026lt; I  C I IO T Ol O V CM IO o CM t- w n c (0 \u0026lt;3  Q s ton E .S Q \"D J S \u0026lt; C Ui (0  z s Oi o CM iD o CM OX c CM CZ5 I GA % 0^ 0^ \u0026gt; 0^ C 0^ s \u0026gt; \u0026lt;u u tf3 u o u iZ3 V \u0026amp; a \u0026gt; \u0026lt; o o (0 k. O JO  S o D (0 k. O q\u0026gt; o o a o o \u0026lt;M \u0026lt;M \u0026lt;M (O CM CM O) o CM ^9 cy xZ C*' CM r=F=i O CO CM in CM CM O CM CM m CM CM m o CM O O CM m Oi Q\u0026gt; c . *3 \"O c s o Q. -o e 0) 5    \u0026gt; ** o a o V cn V E v in V H u Of) -w V x: X \u0026lt;w es u  O R s V X 'W R o o o V o 5 \u0026lt;M S V .S E o Of) S c u s  S s E  ex V} u W5 ts \u0026gt; O V a. a (Z) I s .2 V QA u 9 \u0026gt; tn S .S 3 o J3 on c A J3 u .^ z 00 U Q U I = 3 *n E 4) 5 3 X fi. U Q S \u0026lt; s bJ Q O U ..j Q O a^ in in IM m *S c s .= 0^ u La 0^ ex. V 4= H o o o CM O) c Q. (0  \u0026lt;9 i M \u0026lt;\u0026gt; CM OMOIOOIOOMOM ^P\u0026gt;CMCMT-^pOO\u0026gt; CMCMCMCMCMCMCMCMCMt- i_ w ra c ra Q S (0 o  w .S a: \"5 -I JJ s \u0026lt; c UJ ra 5  o z sCM CM C CM CZ5 I V) vs \u0026lt;u \u0026gt; C s (U \u0026gt; 0^  4 u o u czs u 61 R u V \u0026gt; oo 0 \"D 5 O I co 0 O (0 o 0 O g CM 00 o CM 6^ CO CM O CM CM o CM o co CM % o in CM T CD O CM I I o m o o T o in o\u0026gt; V e *3 *0 e o n A o e V 5  \u0026gt; *- O *0 JS a V V VD a\u0026gt;  0^ t/D co V H (0 C es s V X -M ,o o X X w   u  o exi O s  .S O s  VD o ex) V y B y ec U B . -p d2 S S  a. S5 I 4\u0026gt; Q. 4\u0026gt; B ,2 \"p o a 5 \u0026gt;n ^  w 4\u0026gt; 5 5 x ta\u0026lt; Q C c .: a\u0026gt; u O) \u0026amp; V X H c y X a 'S  J. a C W -M o y = s y o u y  a co s O .2 S -o V B X y y e M 5 \u0026lt; u B y B a g  S t V A U 49  y e o .S  X u  s s Q -C =  M fi 4\u0026gt; X c e M C Q V JS H o y w .SP E \u0026lt;  27 * \u0026gt; c MD 00 S MD 'O'S. c 00 R *0 sin CM in CM \u0026lt;\u0026gt; 42 e bX e I 0^ cu \u0026gt; 0^ c E o \u0026gt; Q cn u O u z/:i V \u0026amp; a 0^ \u0026gt; \u0026lt; V o CO o I ro X2 (U CJ) Q O CM co c\\ in CM O CM u\u0026gt; CJ o CD CM R omomomo^ oor-h-cDcomin'M CMCMCMCMCMCMCMCM \u0026lt;p Q % Q \u0026lt;s \u0026lt;y '5 Q1 CM CM OX e CZ) I \u0026gt; 0^ C3 0^ s \u0026gt; \u0026lt;3^ V) V o u V b a \u0026gt; oo 0 D (0 i_ O I 03 X3 0 D) CZ3 lO CM co CM co in CM co in CM in CM CM in CM o X o o co o in CM o o CM o in o o o in o \u0026lt;?o o W) cs *C (S' I co 0^ \u0026gt; S 0^ E 0^ \u0026gt; a\u0026gt; Ou a6\u0026gt;1 tn. V\u0026gt; GO 0) D CLO_ oI o E o (D O S CM o o o o o Q s CM o o co o lO CM o o CM O to o o o lO o X. h 5 3 O u \u0026lt;0 -1 gj   E CQ 0 Q (0  \u0026gt; Ui CD o' V! co o\u0026gt; ro TO Q c a\u0026gt; (0 (0 m oe a 3 3 Vi \u0026gt;\u0026gt; a\u0026gt; o: (B O O e a (B u 5 a a CZ) \u0026lt; c co 0) II -O 8 I o co \u0026lt;o\u0026gt;\u0026lt; o J? 3  Q\u0026gt; O -J o C u S (B  \u0026lt;l\u0026gt; \u0026lt;0 \u0026gt;-  CO II \u0026lt;r2- E c 0 D 3 \u0026lt;: Io \u0026lt; co o u S' U. 0 E-^3  o cd 'oP H J2 2  3 1 rc U. 0) S = \u0026gt;p o 1? s 2 3 fs o o Stni II w - c II  ^ IQs. 18 \"rSe 8 = 18 2 \"9) eo \u0026lt; 'P O V S' U. c0 0. X5 3 '3) 0) \u0026gt; s (0 $ Ui \u0026gt;p \u0026lt;0 * **5 \u0026gt;P Jk JL H ? o 5 C Q \"e E ''   |\u0026lt;\u0026lt;jj w55$5xx\u0026lt;\u0026lt; \u0026gt;p jT 5 5 0? o II s. O) c  0)  S Vi  S S 3 O b iIl 8 0) 15 fi  Sl SEE (Q 00  6 8 -. (0 5 A E  c U) o V c 6 c V co 8is5?l Eto 2 = S -a  re   a 2 X I-t S co oo d) o\u0026gt; 0) \u0026gt; E m 8 U) 8 - b 16 8 Oil g 'E I b. 8. ? E -i J2 c c S =-i 2  I  -2 ? 16 ? 2 MZ^- VO c V JS Q. o 2 o 0) (D P- c j: \u0026gt; 5 0) -e -D o  8 8 S-SE S \u0026lt;2 qg Q\u0026gt; 5 I  Co .o_ 6O) 8 ii\u0026gt; re S A E Ui 8  c 6 SV 16 c (D si z -s c E re re  c    \"B  0. 2 tt I-co oo d) O) I I a\u0026gt; j= \u0026gt; joa o SI u a S s -s2 as u aV. 00 JS cn -O a u 0 S C 0^ o o \u0026gt;  Ji  -  'S S O .2 o U s C o -o u OS ^o. *o ' V ^ o o a a\u0026gt; m \"O V u s u V 0^ I s o La V  u V c u  S V \"S s V V H 5 \u0026lt;i0 55.2   es  U  Cl J!  -00 S I Qu \u0026lt; H U \u0026lt; a V w a V .\u0026lt;u v OSI a o a\u0026gt; q\u0026gt; OJD ew a o a aw u w s O\u0026lt; a a a 69 tn E -w a eac rMj u  ec ~ ec M 69 tn O JS cn t A US AT) o a IO  % o c a 5 o Q. o \u0026gt; o a O n o CM o  O) n c I *A o o o o o 00 o (O o a o CM o '\u0026lt;y e \u0026gt; 9 ^O. V  \u0026gt;K o V Q \u0026gt;\u0026lt;! The percent of students performing at or above the proficient\" level in mathematics on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Mathematics Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Hispanic Maies (n = 4) 120 100 80 60  Actuai  Goai 40 20 0 T 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the \"proficient\" level in mathematics on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8*'' Grade State Mandated Criterion-Referenced Mathematics Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Asian/Pacific Islander Females (n  4) 120 100 80 60  Actual  Goal 40 20 0 T 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the proficient level in mathematics on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Mathematics Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Asian/Pacific Islander Males (n = 7) 120 100 80 60 40 -- 20 -- 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009  Actual  GoalBaseline Data Baseline Grade Year Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 98-99 7 Performance on SATO, a Norm-Referenced Mathematics Test 65% of a school's students in every subgroup of race and gender shall perform at or above the 50th percentile in mathematics. Af-Am(F)=12% Af-Am(M)=21% WF=60% WM=53% Hisp=86% As/Pac=100% 0ther=100% Af-Am(F)=5% (4 students) Af-Am(M)=5% (4 students) WF=1% (1 Student) WM=1% (1 student) 23% 20% 77% 86% 6 -6 16 32 98-99 7 Performance on SAT9, a Norm-Referenced Mathematics Test The percent of students in every subgroup of race and gender performing at or above the 50th percentile in mathematics will meet or exceed the trend and improvement goals each year. See above See above65% of a schools students in every sub-group of race and gender shall perform at or above the 50 percentile in mathematics. Stanford 9 Exams - 7* Grade (1998 baseline year) This chart shows disaggregated data on Stanford 9 mathematics exams as percentages. % at or above 50th percentile 120% 100% 100100% 100% 86% 86% 80% 77% 10% 65*\u0026gt;5% 60/ 60%  -  1998  1999 337 40% - - 23% 217feo% 20% - - 0% a.i I GOAL Af-Am(F) Af-Am(M) WF (n = (n = 67) (n s 86) 42) WIVI(ns 36) Hisp. As/Pac (n Other (n = = 5) 2) T T T T LThe percent of students in every sub-group of race and gender performing at or above the 50* percentile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Females (n = 67) 70 60 50 40 30  Actual  Goal 20 10 -- 0 T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008The percent of students in every sub-group of race and gender performing at or above the 50* percentile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) 60 50 40 30 0 20 10 This chart shows disaggregated trend and improvement goals as percentages. 70 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Goal The percent of students in every sub-group of race and gender performing at or above the 50* percentile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Females (n = 42) 90 80 70 60 50 -- 40 --  Actual  Goal 30 -- 20 -- 10 -- 0 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 LThe percent of students in every sub-group of race and gender performing at or above the 50**' percentile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Males (n = 36) 100 90 80 70 60 50 --  Actual  Goal 40 -- 30 -- 20 -- 10 -- 0 T T T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Baseline Data Baseline Grade Year Levels LRSD Indicators Goal Your Results Grotvth Goa/ Your Growth Your Score 98-99 7 Performance on SAT9. a Norm-Referenced Mathematics Test At least 30% of a school's students will perform at the highest quartile in mathematics. Af-Am(F)=3% Af-Am(M)=9% WF=43% WM=33% Other=100% Af-Am(F)=3% (2 students) Af-Am(M)=2% {2 students) 98-99 7 Performance on SAT9, a Norm-Referenced Mathematics Test The percent of a school's students performing at the highest quartile in mathematics will meet or exceed the trend and improvement goals each year. See above See above 4% 5% -2 -6At least 30% of a schools students will perform at the highest quartile in mathematics. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated data on Stanford 9 mathematics exams as percentages. % in the highest quartile 120% 100% 100% 80% 80% 67% 60% 40% 30580% 20% - - 0% 3% 4% 9% i. Goal 61% 43/ 30% I T 0% Af-Am(F) Af-Am(M) WF (n = WM (n = Hisp. (n = As/Pac (n Other (n = (n = 67) (n = 86) 42) 36) 7) = 5) 6)  1998  1999The percent of a schools students performing at the highest quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - f** Grade (1998 baseline year) 30 25 20 15 10 5 0 This chart shows disaggregated trend and improvement goals as percentages. 35 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Goal The percent of a schools students performing at the highest quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. 35 30 25 20 15 10 0 5 African-American Males (n = 86) Goal 1998 1999 2000 2001 2002 Baseline Data Baseline Grade Year Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 98-99 7 Performance on SAT9, a Norm-Referenced Mathematics Test At least 90% of a school's students will perform above the lowest quartile in mathematics. Af-Am(F)=35% Af-Am(M)=44% WF=81% WM=81% Others=75% Af-Ann(F)=6% (4 students) Af-Am(M)=3% (2 students) WF=1% (1 student) WM=1% (1 student) 0=2% (1 student) 42% 44% 87% 95% 100% 98-99 7 Performance on SAT9, a Norm-Referenced Mathematics Test The percent of a school's students performing above the lowest quartile in mathematics will meet or exceed the trend and improvement goals each year. See above See above -1 -3 5 13 23At least 90% of a schools students will perform above the lowest quartile in mathematics. Stanford 9 Exams - V* Grade (1998 baseline year) This chart shows disaggregated data on Stanford 9 mathematics exams as percentages. % above the lowest quartile 120% 100% 100% 100% 9O/O% 87% 86% 81/ 81V 80%  - 60%  -  1998  1999 42% 44*/4% 40% - - 20%  - 0% T 1 T T T T T Goal Af-Am(F) Af-Am(M) WF (n = WM(n= Hisp. (n= As/Pac (n Others (n (n = 67) (n = 86) 42) 36) 7) = 5) = 6)The percent of a schools students performing above the lowest quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam -1^'' Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Females (n = 67) 100 90 80 70 60 50 40 30 20 10 0 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Goal The percent of a schools students performing above the lowest quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Maies (n  86) 100 90 80 70 60 50 40 -- 30 -- 20 -- 10 -- 0 T T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008  Actual  GoalThe percent of a school's students performing above the lowest quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Females (n = 42) 92 90 88 86 84 82 80 -- 78 -- 76 T T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008  Actual  GoalThe percent of a schools students performing above the lov^est quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7\" Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Males (n = 36) 100 95 90 85 80 -- 75 -- 70 ml 111111 !! Illi  Actual  Goal 11 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 LThe percent of a schools students performing above the lowest quartile in mathematics will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Others (n = 6) 120 100 80 60 -- 40 -- 20 -- 0 T T  Actual  Goal 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 School Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Priority: Improve Student Achievement in Reading Supporting Data: The Stanford 9 exam showed that 2 disaggregated groups of students were 46% and 32% above the lowest quartile but only 1% and 0% respectfully, in the highest quartHe^ These above the 50th percentile. The lowest scores were in Reading Comprehension, notably Recreational, Textual, Punctuation and Sentence Structure continue to be weak points. Initial Understanding and Interpretation. Only 18% of the students were at or above the \"proficient\" level on the State Criterion-Referenced Literacy Exam. Goal(s): 100% of a school's students shall perform at or above the \"proficient\" level on the reading and writing literacy exam (grade 8 on the State criterion-referenced test). 65% of a school's students in every sub-group of race and gender shall perform at or above the 50th percentile in reading (SAT9 - 7th grade). At least 30% of a school's students will perform at the highest quartile in reading (SAT9 - 7th grade). At least 90% of a school's students will perform above the lowest quartile in reading (SAT9 - 7th grade). 90% of a school's students shall perform at or above the \"proficient\" level in reading each semester (grades 6-8 on the LRSD criterion-referenced reading test).School Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Priority: Improve Student Achievement in Reading, page 2 One-Year Benchmark(s): The percent of students performing at or above the \"proficient- ievei in reading and writing iiteracs, on the criterion-referenced (grades 6-8 tests wiii meet or exceed the trend and improvement goais each year (grade 8 on the State criterion-referenced test). In 2000 - 2001 Dunbar students shall improve 8.2% to a total of 26.2%. This means that 17.5 students must improve to the \"proficient\" or above level this year. DATA NOT AVAILABLE UNTIL SEPTEMBER. The percent of students in every sub-group of race and gender performing at or above the 50th percentile in reading will meet or exceed the trend and improvement goals each year (SAT9 - 7th grade). In 2000 - 2001 Dunbar students shall improve at the following rates: Black Males need to improve 4%, to a total of 32% (this is a total of 4 students who need to improve)\nBlack Females need to improve 6%, to a total of 22% (this is a total of 6 students who need to improve). These are the rates of improvement needed to match the improvement goals\nmore growth, of course, is sought. The percent of a school's students performing at the highest quartile in reading will meet or exceed the trend and improvement goals each year (SAT9 - 7th grade). Dunbar students shall improve at the following rates: Black Males need to improve 3%. to a total of In 2000 - 2001 --------------------- 7% (this is a total of 3 students who need to improve)\nBlack Females need to improve 3%, to a total of 6% (this is a total of 2 students who need to improve). These are the rates of improvement needed to match the improvement goals\nmore growth, of course, is sought.School Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Priority: Improve Student Achievement in Reading, page 3 One-Year Benchmark(s): The percent of a school's students performing above the lowest quartile in reading will meet or exceed the trend and improvement goals each year (SAT9 - 7th grade). In 2000 - 2001 Dunbar students shall improve at the following rates: Black Males need to improve 4%, to a total of 54% (this is a total of 4 students who need to improve)\nBlack Females need to improve 6%, to a total of 44% (this is a total of 4 students who need to improve)\nWhite Males need to improve 1%, to a total of 85% (this is a total of less than 1 student who needs to improve): White Females need to improve 1 %, to a total of 80% (this is a total of less than 1 student who needs to improve). These are the rates of improvement needed to match the improvement goals\nmore growth, of course, is sought. The percent of students performing at or above the \"proficient\" level in reading will meet or exceed the trend and improvement goals each semester (grades 6-8 on the LRSD criterion-referenced reading test). \"Proficient\" levels have not yet been determined. Charts show NWEA Medians, District Medians, and Dunbar Medians by grade level and subject for the Spring 2000 test. District-wide school comparisons are also included. The percent of students demonstrating gains from the reading pre-test to the post-test will meet or exceed the improvement goal each year (grades 6-8 on the LRSD criterion-referenced reading test). The second series of tests have not yet been administered: growth goals are thus not available at this time. LSchool Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Intervention: Reading Across the Content Areas Actions Person Responsible Timeline Resources District Budget Title I Budget APIG/Other Budget 1. Establish block class scheduling to promote hands-on instructional techniques. Deborah Berry, Principal 1 Sept. Team study/block research. Development of a professional Library in the Media Center, Staff development in block scheduling/team teaching. $1,000 2. Establish common planning periods for each team in order to facilitate across the curriculum reading. Deborah Berry, Principal Team Leaders 1 Sept. See above, number 1. 3. Increase the amount of time students are engaged in on-task instruction. Administrative Team Calendar Coordinator 1 Sept. Bobcat Babble (Used to schedule announcements.) School calendar done monthly. 4. Establish the use of learning logs and daily use of agendas across the curriculum. Team Leaders 1 Sept. Agendas, Notebooks Money spent on the agendas will be reimbursed through agenda sales. 5. Increase the circulation of books, etc., in the Media Center. Martha James, Media Specialist Team Leaders Reading Teachers 15 Sept. Media Center, Media resources. Library Use instruction by Media Specialist. District Media BudgetSchool Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Intervention: Reading Across the Content Areas, page 2 Actions Person Responsible Timeline Resources District Budget Title I Budget APIG/Other Budget 6. Identify and plan remediation for those incoming 6th grade students who score in the bottom quartile in reading on last year's Sth grade Stanford 9 exams. Mr. Acre and Ms. Slater, Counselors Aug. 10 Individuals and their scores provided by Dr. Lesley's office. 7. Use curriculum mapping to ensure that reading will be stressed in all areas. Steering Committee Team Leaders Begin 1 Nov. Curriculum Maps, Professional Library 8. Design, in collaboration with representative parents, a plan that involves parents in the reading component of the content areas. Deborah Berry, Principal Parent Mathematics Committee Begin 1 Nov. PTSA, Parent Reading Committee 9. Design school, as well as individual team, incentives for improvement. Steering Committee Team Leaders Begin 1 Nov. Depends on the incentives developed. Again, the budget will depend on the incentives selected. 10. Discuss School Improvement (re: reading) in every faculty meeting. Deborah Berry, Principal Begin with Nov. Fac. Meeting Faculty Meeting Agendas, Professional Library 11. Monitor the entire plan and make needed adjustments to ensure Deborah Berry, Principal Ongoing Team Meeting Agendas improvement before the April Benchmark Team Leaders examinations.School Improvement Plan School: Dunbar Magnet Middle School Year: 2000-2001 Intervention: Reading Across the Content Areas, page 3 Actions Person Responsible Timeline Resources District Title I Budget Budget APIG/Other Budget 12. Conduct summative evaluations of the Campus Leadership June plan and its implementation\nmake adjustments for next year. Team Synthesis from Team Meeting AgendasBaseline Data Baseline Year Grade Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 2000-2001 all LRSD Criterion-Referenced The percent of students performing at or Reading and Language Usage above the \"proficient\" level in Reading and Tests Language Usage will meet or exceed the trends and improvement goals each semester. \"PROFICIENT' LEVELS HAVE NOT BEEN DETERMINED. THE SECOND SERIES OF TESTS HAVE NOT BEEN GIVEN, AND NO TREND DATA IS AVAILABLE. CHARTS SHOWING CURRENT DATA ARE INCLUDED, HOWEVER.The percent of students performing at or above the proficient level in Reading will meet or exceed the trend and improvement goals each semester. LRSD Criterion-Referenced Mathematics Test Spring, 2000 This chart shows Median Scores. READING - GRADE 6 218 212 216----- 214  212----- 210----- 208 ----- 2fla 211  Spring 2000 206 ----- 204 T NWEA LRSD Dunbar Medians Medians MediansLRSD Achievement Level Tests - Spring 2000 (Average Scores) Reading - Grade 6 220 215 215 210 209 211 210 203 205 -- 204 200  195 195 -- 190 -- 185 (0 c  Q c c ra CL in g  T T T T I 213 202 T T I T T oThe percent of students performing at or above the proficient level in Language Usage will meet or exceed the trend and improvement goals each semester. LRSD Criterion-Referenced Mathematics Test Spring, 2000 This chart shows Median Scores. LANGUAGE USAGE - GRADE 6 217 216 216 215----- 214----- 213----- 212----- 212 213  Spring 2000 211----- 210 T NWEA LRSD Dunbar Medians Medians Medians LLRSD Achievement Level Tests - Spring 2000 (Average Scores) Language Usage - Grade 6 250 212 200 1  213 219 215 212 210 204 209 150 -- 100  50  0 T T T T T T T T 6^'The percent of students performing at or above the proficient level in Reading will meet or exceed the trend and improvement goals each semester. LRSD Criterion-Referenced Mathematics Test Spring, 2000 This chart shows Median Scores. READING - GRADE 7 222 221 2ia 220 -  218----- 216----- 214----- 212----- 210----- 208 212  Spring 2000 T T NWEA LRSD Dunbar Medians Medians MediansLRSD Achievement Level Tests - Spring 2000 (Average Scores) Reading - Grade 7 220 219 216 215 210  205 -- 200 -- 195 211 210 210 209 206 T T T T T T T T xOThe percent of students performing at or above the proficient level in Language Usage will meet or exceed the trend and improvement goals each semester. LRSD Criterion-Referenced Mathematics Test Spring, 2000 This chart shows Median Scores. LANGUAGE USAGE - GRADE 7 223 222 221 220 1222 22e 219----- 218----- 217----- 216----- 215 -   Spring 2000 24^ 214----- 213 T T NWEA LRSD Dunbar Medians Medians MediansLRSD Achievement Level Tests - Spring 2000 (Average Scores) Language Usage - Grade 7 225 222 221 220 216 215T\"  210  205  200 T\" \u0026lt;\u0026lt; 217 209 212 O' XV / T T T T T T T oThe percent of students performing at or above the \"proficient level in Reading will meet or exceed the trend and improvement goals each semester. LRSD Criterion-Referenced Mathematics Test Spring, 2000 This chart shows Median Scores. READING - GRADE 8 226 22^ 224 ----- 222 -  220 ----- 218----- 216----- 214------ 212----- 210 211  Spring 2000 T 7TC T NWEA LRSD Dunbar Medians Medians Medians LLRSD Achievement Level Tests - Spring 2000 (Average Scores) Reading - Grade 8 250 216 217 222 218 212 214 208 211 200  150  100  50  0 T T T T T T T TThe percent of students performing at or above the proficient level in Language Usage will meet or exceed the trend and improvement goals each semester. LRSD Criterion-Referenced Mathematics Test Spring, 2000 This chart shows Median Scores. LANGUAGE USAGE - GRADE 8 224 223 222 -  221  220 ----- 219----- 218----- 217 -  216 -   Spring 2000 215 T T NWEA LRSD Dunbar Medians Medians MediansLRSD Achievement Level Tests - Spring 2000 (Average Scores) Language Usage - Grade 8 250 218 218 225 219 215 215 210 214 200  150  100  50 -- 0 T T T T T T T T 4^Baseline Data Baseline Grade Year Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 98-99 7 Performance on SAT9, a Norm-Referenced Reading Test 65% of a school's students in every subgroup of race and gender shall perform at or above the 50th percentile in reading. Af-Am(F)=10% Af-Am(F)=6% Af-Am(M)=24% (6 students) 21% 5 98-99 7 Performance on SAT9, a Norm-Referenced Reading Test WF=71% VVM=67% Others=80% Af-Am(M)=4% (4 students) 24% The percent of students in every subgroup of race and gender performing at or above the 50th percentile in reading will meet or exceed the trend and improvement goals each year. See above See above65% of a schools students in every sub-group of race and gender shall perform at or above the 50 percentile in reading. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated data on Stanford 9 reading exams as percentages. % at or above 50th percentile 120% 100% 100% 90% 81% 80% 80% 71^ 65/5% 67/ 71% 60%  -  1998  1999 40%  - [3%r 20% - - 0% Goal 21% 24%M% II T T 1 Af-Am(F) Af-Am(M) (n = 2) WM (n  Hisp. (n = As/Pac (n Others (n (n = 67) (n = 86) 36) 7) = 5) = 6)The percent of students in every sub-group of race and gender performing at or above the 50* percentile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Females (n = 67) 70 50 40 30 20 10 0 60 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008  Actual  Goal The percent of students in every sub-group of race and gender performing at or above the 50* percentile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7*'' Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Males (n = 86) 70 60 50 40 30  Actual  Goal 20 -- 10 -- 0 T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Baseline Data Baseline Grade Year Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 98-99 7 Performance on SAT9, a Norm-Referenced Reading Test At least 30% of a school's students will perfonn at the highest quartile in reading. Af-Am(F)=0% Af-Am(M)=1% WF=40% WM=39% Others=50% Af-Am(F)=3% (2 students) Af-Am(M)=3% (3 students) 7% 6% 4 2 98-99 7 Performance on SAT9, a Norm-Referenced Reading Test The percent of a school's students performing at the highest quartile in reading will meet or exceed the trend and improvement goals each year. See above See aboveAt least 30% of a schools students will perform at the highest quartile in reading. Stanford 9 Exam -1*'' Grade (1998 baseline year) This chart shows disaggregated data on Stanford 9 reading exams as percentages. /. in the highest quartile 80% 74% 70% 60% 60% 50% 50% 40/. 30/. 30/30% 40/ 39/  1998  1999 20/. 10/. 0/. 3% 0/. 04 T T T T Goal Af-Am(F) Af-Am{M) WF (n = WM (n = Hisp. (n = As/Pac (n Others (n (n = 67) (n = 86) 42) 36) 7) = 5) = 2)The percent of a schools students performing at the highest quartile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Females (n = 67) 35 30 25 20 15  Actual  Goal 10 5 0 T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 LThe percent of a schools students performing at the highest quartile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Males (n = 86) 30 25 20 15 10 5 0 35 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Goal L Baseline Data Baseline Grade Year Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 98-99 7 Performance on SATO, a Norm-Referenced Reading Test At least 90% of a school's students w/ill perform above the lowest quartile in reading. Af-Ani(F)=6% Af-Am(M)=46% (4 students) WF=78% 39% 1 WM=83% Af-Am(M)=4% 46% 98-99 7 Performance on SAT9, a Norm-Referenced Reading Test The percent of a school's students performing above the lowest quartile in reading will meet or exceed the trend and improvement goals each year. 0thers=100% (4 students) See above WF=1% (1 student) WM=1% (1 student) See above 84% 98% 5 14 LAt least 90% of a schools students will perform above the lowest quartile in reading. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated data on Stanford 9 reading exams as percentages. % above the lowest quartile 120% 100% 98% 100% 100% 90\u0026lt;y0% 80%  - 84% 78*/^ 83/ 86% 17% 60%  -  1998  1999 46\u0026lt;S6% 40% - - 39% 20% - - 0% T T T Goal Af-Am(F) Af-Am(M) WF (n = WM(n= Hisp. (n= As/Pac (n Others (n (n = 67) (n = 86) 42) 36) 7) = 5) = 2)The percent of a schools students performing above the lowest quartile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Females (n = 67) 100 90 80 70 60 50 40 30 20 10 0 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Goal The percent of a schools students performing above the lowest quartile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 1**' Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Males (n = 86) 100 90 80 70 60 50  Actual  Goal 40 - 30 -- 20 -- 10 -- 0 T T 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008The percent of a schools students performing above the lowest quartile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - T*** Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Females (n = 42) 92 90 88 86 84 82 80 78 76 74 72 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Goal The percent of a schools students performing above the lowest quartile in reading will meet or exceed the trend and improvement goals each year. Stanford 9 Exam - 7* Grade (1998 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Males (n = 36) 100 95 90  Actual  Goal 85 80 -- 75 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Baseline Data Baseline Grade Year Levels State Indicators Goal Your Results Growth Goal Your Growth Your Score 99-00 8 Performance on State- Mandated Criterion- Referenced Literacy Test 100% of a school's students shall perform at or above the \"proficient\" level in grade 8 reading and writing literacy. School=18% Af-Am(F)=4% Af-Am(M)=2% White(F)=53% School=8.2% (17.5 students) Af-Am(F)=9.6% White(M)=32.5% (6.8 students) Hisp(F)33% Hisp(M)=0% Af-Am(M)=9.8% As/Pac(F)=25% (5 students) As/Pac(M)=43% White(F)=4.7% (2.5 students) VVhite(M)=6.75% {2.7 students) Hisp(F)=6.7% (.2 students) Hisp(M)=10% (.4 students) As/Pac(F)=7.5% {.3 students) 99-00 8 Performance on State- Mandated Criterion- Referenced Literacy Test The percent of students performing at or above the \"proficient\" level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. See above Data not available until September. As/Pac(M)=5.7% (.4 students) See aboveM 100% of a schools students shall perform at or above the proficient level in grade 8 reading and writing literacy. ACTAP - S* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated data on State Criterion-Referenced Literacy Exams as percentages. % at or above \"proficient\" 120 100 100 80  60 -- 51 43  1999 40  11 20 -- 0 T 18 4 T 25 2 0 T T T T cP' n\u0026gt; A^^ V** / z Z ^3^ .s\u0026lt; The percent of students performing at or above the proficient level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. School (n = 214) 120 100 80 60  Actual  Goal 40 20 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the proficient level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Females (n = 71) 120 100 60 40 20 0 80 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009  Actual  Goal The percent of students performing at or above the proficient level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - S* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. African-American Males (n = 51) 120 100 80 60  Actual  Goal 40 20  0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the \"proficient\" level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Females (n = 30) 120 100 80 60  Actual  Goal 40 -- 20 -- 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the \"proficient\" level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. White Males (n = 40) 120 100 80 60  Actual  Goal 40 20 -- 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the \"proficient level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Hispanic Females (n = 3) 120 100 80 60  Actual  Goal 40 20 -- 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the \"proficient\" level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Hispanic Males (n = 4) 120 100 80 60  Actual  Goal 40 20 0 T 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the proficient level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - 8' Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Asian/Pacific isiander Femaies (n = 4) 120 100 80 60  Actual  Goal 40 20 -- 0 -l-LJ 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009The percent of students performing at or above the proficient\" level in reading and writing literacy on the criterion-referenced tests will meet or exceed the trend and improvement goals each year. ACTAP - S* Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated trend and improvement goals as percentages. Asian/Pacific Islander Males (n = 7) 120 100 80 60  Actual  Goal 40 20 -- 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009School Improvement Plan School: Dunbar Magnet Middle School Year\n2000-2001 Priority: Improve Student Success In Academic and Non-Academic Areas Supporting Data: In 1998 - 99 discipline reports were down to 48 from the previous year's total of 401. Further reduction is needed for male students (41 of the 48 reports). The Stanford 9 exams show below average scores .H in Thinking Skills and Listening Comprehension, with improvement needed in Total Study Skills. 18 students were reported as drop-outs last year. Only 18% of the students were at or above proficient on the State criterion-referenced Literacy Exam. Only 14% of the students were at or above \"proficient on the State criterion-referenced Mathematics Exam. Goal(s): At least 99% of secondary students will remain in school to complete the 8th grade. Average daily attendance rate will be at least 95%. 100% of a school's classes will be taught by an appropriately licensed teacher. 100% of a school's certified staff will complete at least 30 hours of approved professional development. Schools will be free of drugs, weapons, and violent acts. 65% of a middle school's students will be enrolled in at least one Pre-AP course each year. 90% of a middle school's students will be enrolled in Algebra I by grade 8. LSchool Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Priority: Improve Student Success In Academic and Non-Academic Areas, page 2 One-Year Benchmark(s): Secondary schools will improve the percentage of students who stay in school to complete the 8th grade (the State Indicator is 12th grade). Schools will improve their average daily attendance rate. Schools will improve the percent of classes taught by an appropriately licensed teacher. Schools will increase the percent of certified staff who complete 60 or more hours of approved professional development annually. The percent of students enrolled in at least one Pre-AP course each year will meet or exceed the trend goal. The percent of students enrolled in Algebra I by grade 8 will meet or exceed the trend goal each year.Baseline Data Baseline Grade Year Levels State Indicators Goal Your Results Growth Goal Your Growth Your Score 2000-2001 all School Dropout At least 99% of secondary students will remain in school to complete the 12th grade. 100% 0% 2000-2001 all Average Daily Attendance Average daily attendance rate will be at least 95%. 98% 0% 2000-2001 all Classes Taught by an Appropriately Licensed Teacher 100% of a school's classes will be taught by an appropriately licensed teacher. 97% 0.30% 2000-2001 all Professional Development 100% of a school's certified staff- will complete at least 30 hours of approved professional development. 100% 0% 2000-2001 all School Safety Schools will be free of drugs, weapons, and violent acts. 1 incident avoid 1 incidentBaseline Data Baseline Year Grade Levels LRSD Indicators Goal Your Results Growth Goal Your Growth Your Score 2000-2001 all Enrollment in Pre-AP Courses 65% of a middle school's students will be enrolled in at least one Pre-AP course each year. 63% 0.20% (1.4 students) 2000-2001 8 Enrollment in Algebra I by grade 8 90% of a middle school's students will be enrolled in Algebra I by grade 8. 12% 7.80% (56 students) LSchool Improvement Plan School: Dunbar Magnet Middle School Year: 2000 - 2001 Intervention: Students Shall Develop Positive Success Patterns Actions Person Responsible Timeline Resources District Budget Title I Budget APIG/Other Budget 1. Design, in collaboration with representative parents, a plan to increase student attendance. Campus Leadership Team, Parent Team 1 Dec. ERIC, Professional Library, Internet, NCA materials 2. Increase parent involvement in team counseling sessions. Team Leaders 15 Sept. 3. Increase the amount of time the counselors are directly involved with students. Mr. Acre and Ms. Slater, Counselors 1 Nov. 4. Establish incentives and rewards for positive behavior. Team Leaders Administrative Team 1 Dec. ERIC, NCA materials Depends on the incentives and rewards established. 5. Begin instruction in test-taking/study skills in each team and/or homeroom. Team Leaders, Home Room Teachers, Mr. Acre and Ms. Slater, Counselors 15 Sept. Videos, Internet, ERIC, NCA materials 6. Broaden the scope of the peer mediation program. 1 Dec. Peer Mediation Coordinator, Administrative Team Peer mediation materials and training for both students and faculty.School Improvement Plan School: Dunbar Magnet Middle School Year: 2000-2001 Intervention: Students Shall Develop Positive Success Patterns, page 2 Actions Person Responsible Timeline Resources District Title I Budget Budget APIG/Other Budget 7. Include special groups of students (ESL and Special Education) in established teams. Administrative Team Ms. Carr, ESL Coordinator, Ms. Davis and Mr. Shavers, Special Education 15 Sept 8. Discuss School Improvement (re: student success) in every faculty meeting. Deborah Berry. Principal Begin with Nov. Fac. Meeting Faculty Meeting Agendas, Professional Library 9. Monitor the entire plan and make needed adjustments to ensure continued growth and improvement toward positive success patterns. Deborah Berry, Principal Team Leaders Ongoing Team Meeting Agendas 10. Conduct summative evaluations of the plan and its implementation\nmake adjustments for next year. Campus Leadership Team June Synthesis from Team Meeting Agendas. L 100% of a schools students shall perform at or above the proficient level in grade 8 mathematics. ACTAP - 8* Grade State Mandated Criterion-Referenced Mathematics Test (1999 baseline year) This chart shows disaggregated data on State Criterion-Referenced Math Exams as percentages. % at or above \"proficient\" 120 100 100 80  60 -- 57.1  1999 39 40  20  14 1.6 1.4 eP' I  0 0 0 0 T T T T T 5$*  L . zACTAP - 8* Grade State-Mandated Criterion-Referenced Mathematics Test 1999 This chart presents the percentages disaggregated by race and gender as well as the total for Dunbar Magnet. The State goal for ff this test is 100% at or above \"proficient. Percentages 100 90 80 70 60 -n 50 - 40 - 30 - 20 - 10 - 0 BE I  Below Basic  Basic  Proficient  Advanced z z  55^ vS\" ' / ** V (S'- z rIt 100% of a schools students shall perform at or above the proficient level in grade 8 reading and writing literacy. ACTAP - 8*'' Grade State Mandated Criterion-Referenced Literacy Test (1999 baseline year) This chart shows disaggregated data on State Criterion-Referenced Literacy Exams as percentages. % at or above \"proficient\" 120 100 100 80  60 -- 52L 43  1999 40 -- 20 -- 0 T 18 2 4 T T 32A 31 25 T 0 T T T z  z z A'V IP z  z.ACTAP - 8* Grade State-Mandated Criterion-Referenced Reading and Writing Literacy Test 1999 This chart presents the percentages disaggregated by race and gender as well as the total for Dunbar Magnet. The State goal for this  test is 100% at or above \"proficient. Percentages 120 100 80 60 40 - 20 - lllll T\u0026gt; o* 'S'* 'S'* rr 4- SC'  Below Basic  Basic  Proficient  Advanced 0 T A T T Lv\"\" GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Reading Vocabulary (30 items) 60 50 40 as. 30-- 20 -- 10-- Below Average 56 56 Average 25 Above Average  1998/99 44  1999/00 0 Reading Vocabulary - Synonyms (16 items) 50 46 \u0026lt;5 44 40-- 30-- 20-- 10 -- 25 Above Average  1998/99  1999/00 Below Average Average 44 0 Reading Vocabulary - Context (7 items) 80 64-6fr 60 40 20 0 T Below Average Average JSL TT  1998/99  1999/00 Above Average Reading Vocabulary - Multiple Meanings (7 items) 60 50 40 30 20 10 0 46-21 Below Average 60.IT Average Above Average  1998/99  1999/00 ?\" GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Reading Comprehension (54 items) 50 40 35 30-- 20-- 10-- Below Average 47 47 Average TF Above Average  1998/99  1999/00 21 0 Reading Comprehension - Recreationai (18 items) 60 50 40 ee 30-- 20- - 10- Below Average 4-60. Average TT21 Above Average  1998/99  1999/00 0 Reading Comprehension - Textual (18 items) 50 40 30 20 10 0 47 jU. Average  1998/99  1999/00 Above Average Below Average Reading Comprehension - Functional (18 items) 50 40 30 20 10 0 46 Average  1998/99  1999/00 Below Average Above Average t\"\" grade students Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Reading Comprehension - Initial Understanding (12 items) SO 40 30 20 10 0 45 TT 36  1998/99  1999/00 Below Average Average Above Average Reading Comprehension - Interpretation (24 items) SO -42. 44^ 40-- 30-- 20-- 10-  1998/99  1999/00 0 Below Average Average Above Average Reading Comprehension - Critical Analysis (9 items) 60 50 40 30 20 10 0 tr 22. Below Average 56 57 Average Above Average  1998/99  1999/00 Reading Comprehension * Process Strategies (9 items) 60 50 40 sr 30- 20-- 10 -- Below Average 4 53 TT a  1998/99  1999/00 Average Above Average 0t\"\" grade students Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Math: Problem Solving (48 items) 50 40 37 46 137 30  20  - 10   1998/99  1999/00 17 0 Below Average Average Above Average Math: Problem Solving - Measurement (6 items) SO 40 3g-4e 36 30-- 20-- 10--  1998/99  1999/00 Below Average Average Above Average 1? 0 Math: Problem Solving - Estimation (6 items) 60 50 40 30 20 10 0 ee Below Average AS 33]  1998/99  1999/00 Average Above Average 40. Math: Problem Solving - Problem- Solving Strategies (5 items) 60 so 40 30 20 10 0 ST IT  1998/99  1999/00 Below Average Average Above Average M * 7\" GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total Sehool) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Math: Problem Solving - Number and No. Relationships (6 items) 50 40 30 20 10 0 Below Average Average Above Average  1998/99  1999/00 Math: Problem Solving - Number Systems and No. Theory (5 items) 60 50  51 40- - 30-- 20-- 10 -  1998/99  1999/00 0 Below Average Average Above Average Math: Problem Solving - Patterns and Functions (3 items) 100 80 60 40 20 0 *-|T I  1998/99  1999/00 Below Average Average Above Average Math: Problem Solving - Algebra (3 items) 80 60 40 20 0 Average  1998/99  1999/00 Above Average Below Average 7 GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Math: Problem Solving - Statistics (6 items) 60 SO 40 30-- 20-- 10 -- Below Average 2. 181  1998/99  1999/00 Average Above Average 0 Math: Problem Solving - Probability (3 items) 50 40 30 a- 25 47 381 20- - 10 --  1998/99  1999/00 Below Average Average Above Average SZ 0 Math: Problem Solving - Geometry (7 items) 80 60 40 20 0 66 16 46-  1998/99  1999/00 Below Average Average Above Average Math: Procedures (30 items) 50 47 46 40  - 30- 20-- 10-- 381  1998/99  1999/00 Below Average Average Above Average 0f GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total Sehool) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Math: Procedures - Computation/Symbolic Notation (10 items) 60 40 20 0 47 46 Average  1998/99  1999/00 Below Average Above Average Math: Procedures - Computation in Context (16 items) 50 40 44 M. 30-- 20  10  0 3-4\u0026amp;  1998/99  1999/00 T Below Average Average ' Above Average Math: Procedures - Rounding (4 items) 50 44 40  M 30  20 - - 10  4e-9  1998/99  1999/00 2? 0 Below Average Average Above Average Language (48 items) 60 w 50 40 30-- 20-- 10- 45 a* Below Average Average tb\nAbove Average  1998/99  1999/00 H. 0 7 GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Language - Capitalization (8 items) 80 60 40 20 0 55 2aJ2 XJ2  1998/99  1999/00 T Below Average Average Above Average Language - Punctuation (8 items) 60 50 40 30-- 20-- 42.  1998/99  1999/00 10 0 Below Average Average Above Average mT Language - Usage (8 items) 60 50 40 30 20-- 10-- Below Average 56 52 ---- 32 16,  1998/99  1999/00 Average Above Average 0 Language - Sentence Structure (12 items) 46 44 50 40 -3 I** 30- 20-- 10- 25 15i  1998/99  1999/00 Below Average Average Above Average 0 T*\" GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Language - Content and Organization (12 items) 50 40 30 20 10 0 46 3S -34-M  1998/99  1999/00 Below Average Average Above Average T Spelling (30 items) 60 50 40 30 20  - 10 -- w\n25  1998/99  1999/00 Below Average Average Above Average 0 Spelling - Homophones (5 items) 60 50 \"48----- r** 40- - 30-- 20-- 10-- 36 3jr TT a*  1998/99  1999/00 Below Average Average Above Average 0 Spelling - Phonetic Principles (10 items) 60 50 40 30 20 10 0 4e-tT Below Average -SC 31 Al  1998^9  1999/00 Average Above Average 42.7*'' GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Spelling - Structural Principles (10 items) 60 50 40 30 20 10 0 40-ee- Below Average 57 54 Average Above Average  1998/99  1999/00 Spelling  No Mistake (5 items) 60 50 40 30 20 10 0 56 Average  1998^9  1999/00 Above Average Below Average Study Skills (30 items) 60 50 40 30 20 10 0 aa 23 Below Average -64 .44 Average Above Average  1998/99  1999/00 Study Skills - Library/Reference Skills (17 items) 50 40 30 20 10 0 34 33. Below Average 45 -34 sr  1998/99  1999/00 Average Above Average 7* GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Study Skills - Information Skills (13 items) 80 60 40 20 0 57 I?  1998/99  1999/00 Below Average Average Above Average Science (40 items) 50 40 4 30- - 20-- 10 -- nr 45 4  1998/99  1999/00 137 0 Below Average Average Above Average Science - Earth \u0026amp; Space Science (12 items) eo 50 40 30 20 10 0 xr 22. Below Average -e-wr Average 2S' Above Average  1998/99  1999/00 JX Science - Physical Science (14 items) 50 40 sr 42. 35 30- - 20- - 10 - -  1998/99  1999/00 Below Average Average Above Average 0v\"\" GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Science - Life Science (14 items) 50 40 30  20  10  rstr -at- 27  1998/99  1999/00 Below Average Average Above Average M 0 Science - Science Process Skills (30 items) SO 46 45 44 40-- 30-- 20- - 10-- T 25  19989  1999/00 50 40 Below Average Average Above Average Social Science (40 items) 38 36 30-- 20-- 10   1998/99  1999/00 Below Average Average Above Average 0 0 r Social Science - History (10 items) 50 40 38 3ff Mfr JI 30  20   1998/99  1999/00 10 -- 0 Below Average Average Above Average 7\"* GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Social Science - Geography (9 items) 50 40 30-- 20-- -40 47 a* 16  1998/99  1999/00 10 -- 0 Below Average Average Above Average Social Science - Civics \u0026amp; Government (8 items) 60 50 40 30 20 10 0 Average  1998/99  1999/00 Above Average Below Average Social Science  Economics (8 items) 60 50 40 30 20 10 0 53 46-^  1998/99  1999/00 Below Average Average Above Average 14 75^ Social Science - Culture (5 items) 70 60 50 40 30 20 10 0 62.6* Average Above Average  1998^9  1999/00 Below Average 7 GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Listening (40 items) 60 50 40 30 20 10 0  1998/99  1999/00 Below Average Average Above Average Listening: Vocabulary (10 items) 60 50 40 30 20 10 0 25   1998/99  1999/00 Below Average Average ' Above Average ^8^ Listening: Comprehension (30 items) 80 60 40 20 0 34 Below Average 54 to Average 12 TV  1998/99  1999/00 Above Average Listening: Comprehension - Recreational (10 items) 80 60 40 20 0 32 ----- Below Average -es JL. 14  1998/99  1999/00 Average Above Average I7\"* GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Listening: Comprehension - Informational (10 items) 50 40 35 44 43 30-- 20-- 10-  1998/99  1999/00 Below Average Average Above Average 44 4i 0 T Listening: Comprehension - Functional (10 items) 80 60 40 20 0 r aj\u0026gt; 11 12  1998/99  1999/00 Below Average Average Above Average ,3iL. Listening: Comprehension - Initial Understanding (10 items) 80 60 40 20 0 32 Below Average srT Average 17 Above Average  1998/99  1999/00 Listening: Comprehension - Interpretation (14 items) 50 40 30-- 20- - 10 -- Below Average 44*5 Average Above Average  1998/99  1999/00 1? 0?\" GRADE STUDENTS Stanford 9 Exams - Content Clusters (Total School) These charts show NCE percentages. 1998-99 N = 236 1999-00 N = 198 Listening: Comprehension - Critical Analysis/Strategies (6 items) 80 60 40 20 0 3T 3Z. Below Average 9- 68 Average Above Average  1998/99  1999/00 Using Information (69 items) 60 50 40 30 29 29 20-- 10 -- Below Average Average se- Above Average  1998/99  1999/00 4? 1^ 0 Thinking Skills (229 items) 50 40 38 45 4T 1? 30-- 20- 10 -- \u0026gt;7  1998^9  1999/00 0 Below Average Average Above Average7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING VOCABULARY (30 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 45 ----- 55 55 40  30  20   1998/99  1999/00 10 - 0  7 Below Average Average Above Average African-American Males 80 60 551 SB 40T 20  Below Average Average Above Average  1998/99  1999/00 0 White Females 80 Vt- 60 40 20 -10- Below Average PIS' 55  1998/99  1999/00 Average Above Average 0 0 White Males 60 50 40 30 20 10 0 ee 45 55  1998/99  1999/00 Below Average Average Above Average  GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING VOCABULARY - Synonyms (16 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36), 1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 80 -6fr 60- - IfiL 40- -  1998/99  1999/00 20- - 0 T 0 T Below Average Average Above Average African-American Males 60 56 50-- 40- - 30- - MM 20-- 10 --  1998/99  1999/00 Below Average Average Above Average  T 0 White Females 70 60 50 40 30 20 10 0 -IS J. Below Average S2. Average  1998/99  1999/00 Above Average White Males SX 0 20- 10-- 60 50 40 30 55 Below Average Average Above Average  1998^9  1999/00 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING VOCABULARY - Context (7 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 80 60 40 37 81 11  1998/99  1999/00 20.- 1 T 0 Below Average Average Above Average African-American Males 80 76 60 40 20 35 120 Below Average 62l Z~T Average Above Average  1998/99  1999/00 0 White Females 80 6^ 60 40 20 17 e Below Average 55 Average 39 Above Average  1998/99  1999ffm 0 White Males 70 60 50 40 30 20 10 0 -14- a2. Below Average 64 48-  19989  1999/00 Average Above Average 7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING VOCABULARY - Multiple Meanings (7 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50 40 30 20 10 0 3r 241  1998/99 21  1999/00 Below Average Average Above Average African-American Males 60 50 40 30 20 10 0 Below Average Average  1998/99  1999/00 Above Average White Females 60 50 40 30 20 10 0 45 55 55  19989  1999/00 Below Average Average Above Average T  White Males 60 50 40 30 20 10 0 Average 01998/99  1999/00 Below Average Above Average 7^** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING COMPREHENSION (54 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36), 1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 -61 I*\" 56 40- - 30-- 20-- 10 --  1998/99  1999/00 0 Below Average Average Above Average African-American Males 60 50 42 40-- 30-- 20-- 10 -- 0 -fT  19989  1999/00 Below Average Average Above Average White Females 70 60 SO 40 30 20 10 0 41  1998^9  1999/00 21 Below Average Average Above Average White Males 60 50 40 30 20 10 0 2. Below Average ee 45 Average 42 Above Average  1998/99  1999/00 JA7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. [1998/99 n READE^G COMPREHENSION - Recreational (18 items) = African-American Female (67), African-American Male (84), White Female (42) Wte Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 jnr 46 -as 40-- 30- - 20- - 10- 6^  1998/99  1999/00 0 Below Average Average Above Average African-American Males 60 50-- 40._ 30- 20- -Wf 45  19989  1999/00 10-- 0 Below Average Average Mioye Kyorago White Females 60 50 40 30 20 10 0 57 Average Above Average  1998/99  1999/00 Below Average White Males 60 50 40 30 20 10 0 IT Below Average 53 6a A3. Above Average  1998^9  1999/00 AMoraga GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING COMPREHENSION - Textual (18 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 40-- 30-- 20 -- 10- 135 Below Average 56 r  1998/99  1999/00 Average Above Average 0 African-American Males 60 50 40 47 30- 20- 10 -- 0  1998^9  1999/00 Below Average Average Above Average White Females 80 40 20 0 60 Average  1998^9  1999/00 Below Average Above Average White Males 70 60 50 40 30 20 10 0 Al jbz  19989  1999/00 Below Average Average Above Average i. 7^** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING COMPREHENSION - Functional (18 items) [1998/99 n - African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 tr 40- - 30- - 20- -   1998/99  1999/00 10- 0 Below Average Average Above Average African-American Males I 60 50 40 30- - 20-- 10 - Below Average JS i* 43. 16  1998/99  1999/00 Average Above Average 0 White Females n 60 50 40 30 20 10 0 -4 res  1998/99  1999/00 Below Average Average Above Average ss ^4 13 White Males 60 50 40 30 20 w 55 44 AS 36^  1998^9  1999/00 4. 10-- 0 Below Average Kyenge Above Average7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READB^G COMPREHENSION - Initial Understanding (12 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50 40 30 20 10 0 se  1998/99  1999/00 Below Average Average Above Average African-American Males 60 50 40 MeTe- 30-- 20--  1998/99  1999/00 10-- 0 Below Average Average Above Average White Females 80 60 40 33 |1  1998/99  1999n\u0026gt;0 20 Below Average Average Above Average 2L11 0 White Males 70 60 50 40 30 20 10 0 64  1998ra9  1999/00 41 T r21 Below Average Average Above Average7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READE^G COMPREHENSION - Interpretation (24 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 se 50-- 40-- 30-- 20  - 144 AS  1998/99  1999/00 10- zz Below Average Average Above Average 0 T African-American Males 60 54 55 50-- 40-- 30- 42. 20-- 10 -  1998^9  1999/00 Below Average Average Above Average T 0 White Females 70 60 50 40 30 20 10 0 ini Below Average Average se Above Average White Males  1998/99  1999nX) 60 50 40 30 20-- 10- SO-JB- 32 Average  1998/99  1999/00 Above Average Below Average 0 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READESG COMPREHENSION - Critical Analysis (9 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50 40 30- - 20-- 10- - Below Average 54 -e 1S Average Above Average  1998/99  1999/00 0 African-American Males 70 60 50 40 30 20 10 0 st se T-r  1998ra9  1999/00 Below Average Average Above Average . I-M t White Females 60 50 40 30 20 10 0 45 ee 45  1998/99  1999/00 Below /kyarage Average Above Average 6 White Males 70 60 50 40 30 20 10 0 -8- D 3. Below Average se IT  1998/99  1999/00 Average Above Average7** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. READING COMPREHENSION - Process Strategies (9 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 se 54 50- - 40- - 30- - 20- - 10- -  1998/99  1999/00 Below Average Average Above Average  0 African-American Males 60 50 40 30-- 20-- 10 -- Below Average 55 -64- a Average Above Average  1998/99  1999/00 vr 5 0 White Females 60 50 40 30 20 10 0 60 50 40 30 20 57 26 Ji Below Average Average 10- sr Above Average White Males IT Average  1998/99  1999/00 Above Average Below Average  1998/99  1999/00 0 TF 7^ GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEMSOLVING (48 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 56 4^ SO- AO 30  20- - 10 --  1998/99  1999/00 0 Below Average Average Above Average African-American Males 60 SO 46 i*- 40  30  20  10   1998/99  1999/00 0 Below Average Average Above Average White Females 80 21 60 40 20 14 1 Below Average 40 51  1998/99  1999/00 Average Above Average 41 0 White Males 70 60 SO 40 30 20 10 0 -U- 2. Below Average Average 64 31 Above Average  19989  1999/007^ GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Measurement (6 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 se-w 50-- 40- - 30  20  10  TB-sr  1998/99  1999/00 0 Below Average Average Above Average African-American Males 70 60 50 40- 30- 20  10  Below Average 4 14  1998/99  1999/00 Average Above Average [31 T 0 T White Females 60 50 40 30 20 10 0 J3. 55  1998/99  1999/00 Below Average Average Above Average H 13 White Males 60 50 40 30 20 10 0 w 3i  1998/99  1999/00 Below Average Average Above Average T? 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Estimation (4 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 sx 50- - 40- - 30- 20- 44  19989  1999/00 T 10- 0 Below Average Average Above Average African-American Males 60 50 40 30-- 20 -- 10 - Below Average 55 145 16  1998/99  1999/00 Average Above Average 5 0 White Females 50 40 30 20 10 0 Average  1998/99  1999/00 Above Average Below Average White Males 70 60 50 40 30 20 10 0 Average  1998/99  1999/00 Below Average Above Average 7^^ GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Problem Solving Strategies (5 items) 11998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 ^8^ 40- - 30-- 20-- 10- 0  1998/99  1999/00 Below Average Average Above Average African-American Males 70 60 50 40 30 20 10 0 -S9-  1998/99  1999/00 Below Average Average Above Average W7 41 T 2. White Females 60 50 40 30 20 10 0 57 Average  1998/99  1999/00 Below Average Above Average White Males 70 60 50 40 30 20 10 0 64 Average  1998/99  1999/00 Above Average Below Average 7** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVK4G - Number \u0026amp; No. Relationships (6 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36), 1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females so 48 40- - 30- 20- - 36 18 18  1998ra9  1999/00 10 -- 0 Below Average Average Above Average African-American Males 50 40 30- 20-- 10- - 46 47  1998/99  1999/00 0 Below Average Average Above Average White Females 70 60 50 40 30 20 10 0 .14 11 Below Average 44. IT Average Above Average  1998^9  1999/00 44 White Males 80 60 40 20 0 74 Average  1998/99  1999/00 Below Average Above Average 7**' GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Number Systems \u0026amp; No. Theory (5 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 61 SB 50-- 40-- 30-- 20-- 10--  1998/99  1999/00 Below Average Average Above Average 3r3T 0 African-American Males 60 S4 53 SO-AO- - 40-62. 30- - 20 -- 10-- White Females  1998/99  1999/00 60 50 40 30 20 10 0 55 24 IT OX Average  1998/99  1999/00 Above Average 80 60 40 20 Below Average White Males 76 58 22 19 19  1998/99  1999/00 Below Average Average Above Average 0 0 I 5 s \u0026gt; a 5e 5 \u0026amp; S a A  T 7*^ GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Patterns \u0026amp; Functions (3 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 80 71 70 60 40 20 asaa.  1998/99  1999/00 Below Average Average Above Average 0 0 0 T African-American Males 100 80 60 40 20 0 76 78 TT Below Average Average Above Average  1998/99 e* 22  1999/00 T White Females 100 80 60 40 20 0 9-fr Below Average 95 94 DO Average Above Average  1998/99 a  1999/00 White Males 120 100 80 60 40 20 0 T7 Below Average -BA toe Average Above Average  1998/99  1999/00  1 7^** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Algebra (3 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 80 zo. 60 40 20 Below Average Average Above Average  1998/99  1999/00 0 W African-American Males 60 40 20 0 80 Average  1998/99  1999/00 Above Average Below Average White Females 70 60 50 40 30 20 10 0 22 4W sr  1998/99  1999/00 Below Average Average Above Average ZZi White Males 70 60 SO 40 30 20 10 0 S8- IS 22.  1998^9  1999/00 Below Average Average Above Average U-T 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Statistics (6 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50  40  30  20  10  0 4* 44.  1998/99  1999/00 T Below Average Average Above Average African-American Males 60 50 17 40  30  20-- 10  0 4S  1998/99  1999/00 Below Average Average Above Average White Females 60 50 40 30 20- -T\" 55 46l a* 4a  1998/99  1999/00 21 A 10- - 0 Below Average Average Above Average White Males 60 50 40 30 43. 55 a* 20  10   19989  1999/00 Below Average Average Above Average 0 77*^ GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Probability (3 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 50 40  30  20  10  0 38  1998/99  1999/00 SO 40 Below Average Average Above Average African-American Males 36 W 34. 30  20  10  Below Average Average Above Average  1998/99  1999/00 1^ 0 White Females 100 80 60 40 20 0 ----- .13 62] 77  1998/99  1999/00 Below Average Average Above Average White Males 80 60 40 20 0 74 Average  1998/99  1999/00 Below Average Above Average 7*^ GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROBLEM SOLVING - Geometry (7 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 80 73 60 40 20 -s  1998/99  1999/00 Below Average Average Above Average Tra T 0 African-American Males 70 JB2. 60 50 40 30 20 10 0 Below Average  1998Z99  1999/00 Average Above Average w White Females 60 50 40 30 20 10 0 57 Average  1998/99  1999rao Above Average Below Average White Males 70 60 50 40 30 20 10 0 I**' 01998/99  1999/00 9S Below Average Average Above Average 7**' GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROCEDURES (30 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 64 60-- 50-- 40-- 30-- 20-- 10 - Al  1998/99  1999/00 Below Average Average Above Average 1x0 I_5 0 African-American Males 60 56 50- - 40-- 30-- 20-- IT 45 10 -- LT  1998/99  1999/00 Below Average Average Above Average 0 White Females 60 50 40 30 20 10 0 IO' Below Average 45 Average Above Average  1998/99  1999/00 21 42. White Males 60 50 40 30 20 10 0 55 Below Average Average  1998/99  1999/00 Above Average 7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROCEDURES - Computation/Symbolic Notation (10 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 4S44 40-- 30-- 20-- 2a.  1998/99  1999/00 10-- 0 60 50 Below Average Average Above Average African-American Males 45 45 40-- 30- 20- 10- 16  1998/99  1999/00 Below Average Average Above Average White Females 70 60 50 40 30 20 10- Below Average A2. T Average  1998/99  1999/00 Above Average White Males 70 60 SO 40 30-4 20 - 10  - Below Average 64 IF Average Above Average  1998/99  1999/00 sa  0 0 0 JX 7 31 7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROCEDURES - Computation in Context (16 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 57 64 50-- 40-- 30-- 20-- IO - - J.  1998/99  1999/00 T 0 Below Average Average Above Average African-American Males 60 50 M 49 40- 30-- 20 -- 10  - 0  16  1998/99  1999/00 T Below Average Average Above Average White Females 70 60 50 40 30 20 10 0 40- AZ.  1998/99  1999/00 Below Average Average Above Average 4* White Males 70 60 50 40 30 20 10 0 64 Average Above Average  1998/99  1999/00 Below Average 7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. MATH: PROCEDURES - Rounding (4 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50  40  30  20  10   1998/99  1999/00 0 Below Average Average Above Average African-American Males 60 ex 50  40  30  20  10   1998/99  1999/00 0 Below Average Average Above Average White Females 70 60 50 40 30 20 10 0 65  1998/99  1999/00 Below Average Average Above Average White Males 60 50 40 30 20 10 0 KT Below Average Average 55 Above Average  19989  1999/00 m7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. LANGUAGE (48 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 40  - 30-- 20  10  ee ,48  1998/99  1999/00 , r-M-j Below Average Average Above Average 8 8 0 African-American Males 60 50 4^ 40  30  20  10  0 T  1998/99  1999/00 T 4 Below Average Average Above Average White Females 70 60 50 40 30 20 10 0 J2_U. Below Average Average 65 Above Average  19989  1999/00 White Males 70 60 50 40 30 20 10 0 Below Average Average Above Average  1998/99  1999/00 GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. LANGUAGE - Capitalization (8 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50 40 30 20 10 0 2. 2. Below Average Average Above Average  1998/99 I  1999/00 i  African-American Males 60 50 40 W se sar 30  20  10  0  1998/99  1999/00 T a Below Average Average Above Average White Females 80 21sr 60 40 20 12. 17| 80 60 40 20 J2.  1998/99  1999/00 Below Average Average Above Average White Males 17 la  1998/99  1999/00 Below Average Average Above Average 0 0 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. LANGUAGE - Punctuation (8 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 45 45 90 90 40-- 30-- 20-- 10 --  1998/99  1999/00 5 5 0 Below Average Average Above Average African-American Males 70 60 SO 40 30 20 10 0 61 69  1998/99  1999/00 Below Average Average Above Average * ? White Females 70 60 50 40 30 20 10 0 64 65 TT 23.  1998/99  1999/00 Below Average Average Above Average White Males 60 40 20 0 80 Average  1998/99  1999/00 Above Average Below Average 7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. LANGUAGE - Usage (8 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 ee- 56 |46 AO- SO 20  10  4  1998/99  1999/00 0 Below Average Average Above Average African-American Males 70 60 50 40 30  20  10  Below Average SI *-4  1998/99  1999/00 Average Above Average 0 White Females 60 50 40 30 20 10 0 \"W 45 361  1998/99  1999/00 80 60 40 20 Below Average Average Above Average White Males 74 20  1998/99  1999/00 Below Average Average Above Average TT 6 2 0 \"W 4fr7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. LANGUAGE - Sentence Structure (12 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 so-w 40  30  20  - 10  0 T 4+  1998/99  1999/00 S Below Average Average Above Average African-American Males 60 50-- 40-- 30-- 20  10  0 T-r  1998/99  1999/00 Below Average Average Above Average White Females 60 SO 40 30 20 10 0 Si 38 Si  1998/99  1999/00 Below Average Average Above Average 14 \u0026lt;3 White Males 60 50 40 30 20 1 10  Below Average 57 46  1998/99  1999/00 Average Above Average 0 57\"* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. LANGUAGE - Content \u0026amp; Organization (12 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50 40 30 20 10 0 as Below Average se-5T Average TT 11 Above Average  1998/99  1999/00 African-American Males 60 50 \"WAl \u0026lt;e  40  30  20  10  43.IT  1998/99  1999/00 Below Average Average Above Average 0 White Females 70 60 50 40 30 20 10 0 64 Average  1998/99  1999/00 Below Average Above Average White Males 60 50 40 30 20  10  Ml 46  1998/99  1999/00 Below Average Average Above Average 0 A 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. SPELLING (30 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), WWte Male 06), 1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)J African-American Females 70 60 50 40 30 -M- 20-- 10 - -S Below Average st r** Average Above Average  1998/99  1999/00 4-41 0 T African-American Males 60 50 4f 451 56 41 40  30  20  10   1998/99  1999/00 T 4 0 Below Average Average Above Average White Females 70 60 50 40 30 20 10 0 TT Below Average Average 61 Above Average  1998/99  1999/00 W White Males 60 50 40 30 20 10 0 56 Average  1998/99  1999/00 Below Average Above Average 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. SPELLING - Homophones (5 items) r 1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50  40  30  20  10  -41  1998/99  1999/00 Below Average Average Above Average 3F 0 African-American Males ! 70 65 SI 60  50  40  30  20  10  Is 9-  1998/99  1999/00 Below Average Average Above Average 0 I White Females 50 40 30 ST so  1998/99  1999/00 lo-- 0 Below Average Average Above Average White Males 60 50 40 30 20 10 0 56   1998/99  1999/00 42. S \u0026amp; o SI 1 S7^** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. SPELLING - Phonetic Principles (10 items) 11998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-A\u0026lt; me_r.ic_a__n__ MKa-Kle (/5f 4), AWizhui:t*e-. Female (Z3'1 11 \\) , WWVhksitfeA Male f(42)] African-American Females 70 60 SO 40 30 20 10 0 Average  1998/99  1999/00 Above Average Below Average African-American Males 60 SO 40 30  20  10  26 Below Average 46 Average Above Average  1998/99 86   1999/00 0 White Females 100 80 60 40 20 0 62 TO 77  1998/99  1999/00 Below Average Average Above Average I White Males 70 60 SO 40 30 20 10 0 ,2. Below Average e-sfr Average Above Average  1998/99  1999/00 41 7*** GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. SPELLING - Structural Principles (10 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 70 60 50 40 30 20 10 0 \u0026lt; Below Average se-Sf Average e Above Average  1998/99  1999/00 4 African-American Males I 70 60 50 40 .52. St li rl J   30  20  - 10  Below Average Average Above Average  1998/99  1999/00 0 White Females 60 50 40 30 20 10 0 55 Average  1998/99  1999/00 Below Average Above Average White Males 80 -es 60 40 20 14 14 Below Average Average 36 Above Average  1998/99  1999/00 0 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. SPELLING - No Mistake (5 items) [1998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), White Male (42)] African-American Females 60 50 40 30 20 10 0 Average  1998/99  1999/00 Below Average Above Average African-American Males 50 40 nF 30- 20- 28 ar  1998/99  1999/00 TT 10  - 0 Below Average Average Above Average White Females 100 80 60 40 20 0 2a. |13 80 60 40 20 77 55  1998/99  1999/00 Below Average Average Above Average White Males 74 21 48-  1998/99  1999/00 Below Average Average Above Average 2Lia 19 0 T 7* GRADE STUDENTS STANFORD 9 EXAMS - CONTENT CLUSTERS These charts show disaggregated data as NCE percentages. STUDY SKILLS (30 items) 11998/99 n = African-American Female (67), African-American Male (84), White Female (42), White Male (36)\n1999/2000 n = African-American Female (56), African-American Male (54), White Female (31), 'White Male (42)] African-American Females M 63 70 60 50 40 30 20 10 0 9  1998/99  1999/00 Below Average Average Above Average African-American Males 60 50 40 3\nThis project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resoources.\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n \n\n\n   \n\n  \n\n \n\n   \n\n \n\n  \n\n\n   \n\n \n\n  \n\n\n\n   \n\n  \n\n  \n\n\n   \n\n   \n\n  \n\n \n\n \n\n\n   \n\n  \n\n \n\n\n\n\n\n\n\n\n\n   \n\n \n\n\n\n  \n\n\n   \n\n\n\n  \n\n\n\n "},{"id":"bcas_bcmss0837_1769","title":"Court filings regarding motion to extend time, Little Rock School District (LRSD) compliance report, and Arkansas Department of Education (ADE) project management tool.","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2006-10"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Education--Arkansas","School districts","Little Rock School District","Arkansas. Department of Education","Project management","Education--Evaluation","African Americans--Education","Office of Desegregation Monitoring (Little Rock, Ark.)"],"dcterms_title":["Court filings regarding motion to extend time, Little Rock School District (LRSD) compliance report, and Arkansas Department of Education (ADE) project management tool."],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1769"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["filing"],"dcterms_extent":["44 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\u003c?xml version=\"1.0\" encoding=\"utf-8\"?\u003e\n\u003citems type=\"array\"\u003e  \u003citem\u003e   \n\n   \n\n   \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n   \n\n\n   \n\n   \n\n\n   \n\n   \n\n\n\n\n\n\n\n\n\n\n\n   \n\n \n\n \n\n \n\n\n   \n\n   \n\n   \n\n\n   \n\n  \n\n   \n\n\n   \n\n  \n\n   \n\n\n   \n\n \n\n\u003cdcterms_description type=\"array\"\u003e   \n\n\u003cdcterms_description\u003eCourt filings: District Court, motion to extend time; District Court, Little Rock School District (LRSD) compliance report; District Court, order; District Court, Little Rock School District's (LRSD's) revised compliance report; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool    This transcript was create using Optical Character Recognition (OCR) and may contain some errors.    U,/63/2666 10: 51 5016045321 USDC Case 4:82-cv-00866-WRW Document 40481 Filed 10/02/2006 PAGE 01 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LI'ITLE ROCK SCHOOL DISTRICT v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATiiERINE KNIGHT, ET AL MOTION TO EXTEND TIME For its Motion, Plaintiff Little Rock School District states: ~1\\-\u0026lt;9t00 F~ PLAINTIFF oEFENDANTS INIERVENORS INTERVENORS 1. In accordance with the June 30, 2004 Compliance Remedy in this case, LRSD has engaged experts to prepare four Step 2 program evaluations for 2005-06 school year. The progress of those evaluations !las been reported to the Court and the parties in quarterly updates filed by LRSD. The evaluations are due to the Court on October 15, 2006. ' 2. Three of the four Step 2 program evaluations, A+, 21st Century Community Learning Centers and Read 180, were previously delayed due to the unavailability of Benchmark Examination results, but it now appears that those evaluations will be filed by the current due date of October 15~ 2006. Sec email from lt,/t,::l/ 2f:l06 10; 51 5016045321 USDC PAGE 02 Case 4:82-cv-00866-WRW Document 4048-1 Filed 10/02/2006 Page 2 of 4 Aaron McDonald, attached as Exhibit A. 3. The fourth Step 2 program evaluation, Pre-K Lileracy, requires data from the Qualls Early Learning Inventory (QELI), which has also been delayed. NORMES, which contracts with the Arkansas Department of Education to store and facilitate access to test data, originally projected posting the QELI data in early July. The NORMES data proved not to be sufficiently detailed to meet the evaluators' needs for the Pre-K Literacy Evaluation, and LRSD has contracted with Riverside Publishing to provide that data. PRE is now in the process of working with Riverside in an effort to get usable QELI data to CREP within the next few days. 4. Dr. Ross, in an email which was provided to the Court on September 29, 2006, says that CREP \"will try, by making extraordinary efforts, to complete [ the PreK Literacy] Report by November 15th .\" 5. The requested extension of time is necessary to insure the delivery of a useful Pre-K Literacy Program Evaluation which will fulfill the purposes of the compliance remedy. The requested extension of time will not delay any decisions ' about whether to continue, expand, modify or discontinue programs. 6. Mr. Walker's letter to the Court of September 26, 2006 indicates that he understands the need for the requested extension, but counsel for LRSD was unable to 2 10/03/2006 10: 51 5016045321 USDC PAGE 03 Case 4:82-cv-00866-WRW Document 4048-1 Filed 10/02/2006 Page 3 of 4 contact him today to confirm that. WHEREFORE, for the reasons set forth above, Plaintiff Little Rock School District requests an extension of time within which it must file the draft Step 2 Program Evaluation of the Pre-K Literacy Program to and. including November 15, 2006. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRlCT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) Khayyam M. Eddings (#02008) 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 (501) 376-2011 Isl Christopher Heller CERTIFICATE OF SERVICE I certify that on October 2, 2006, I have electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which shall send notification of such filing to the following: mark.hagemeier@ag.state.qr.us sjones@mwsgw.com sjones@jlj .com johnwaJkeratty@aol_.com 3 10/03/2006 10: 51 5016045321 USDC PAGE 04 Case 4:82-cv~00866-WRW Document 4048-1 Filed 10/02/2006 Page 4 of 4 and mailed by U.S. regular mail to the following addresses: Gene Jones Office of Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock. AR 72201 Mr. Clayton Blackstock Mr. Mark Burnett 1010 W. Third Street Little Rock, AR 72201 Judge J, Thomas Ray U. S. District Courthouse 600 West Capitol Avenue, Suite 149 Little Rock, AR 72201  Isl Christopher Heller 4 l t:l/ t:J;j/ :Lt:lt:lb l !:I: 51 5016045321 US0C PAGE 05 Case 4:82-cv-00866-WRW Document 4048-2 Filed 10/02/2006 Page 1 ~ 1 of 4 Chris Heller - .RE: three evatuatfoas From: To: Date: Subject: CC: Chris, \u0026lt;ajmcdnld@memphis.edu\u0026gt; \u0026lt;smross@memphls.edu\u0026gt;, \u0026lt;HELLER@fcc.net\u0026gt; 10/2/2006 9:16 AM RE: three evaluations \u0026lt;dslawson@memphis.edu\u0026gt; ~ a follow-up to our phone conversation on Friday, I wanted to let you know that we are-planning on sending the drett READ 180 and 21.t CCLC reports to the dlsbid on the 1st\". The 21 st CCLC sd1ool that had attendance data anomallee will be excluded from the anafyaia. We are still In the procesa of revleWtng the PreK deta wttt, Jim Wohlleb. Beatrrd, Aaron McOoneld ......... ____________ .....-____ -_______ l'l'Offll Steven M Ross (sml'0$S) Sent: Friday, September 29, 2006 4:39 PM To: Chris Heller Cc: Aaron Jeffrey Mcdonald (ajmatnld) - subject: RE: three evaluations Steven M. Ross. Ph.D. Faudree Professor and Director Center for Research in Educational Policy The University of Memphis 325 Browning Hall Memphis, 'IN 38152-3340 file://C:\\Document5%20and%20Settina\\Brendak\\Local%20Settinas\\Temo\\GWl00002;H... 10/1./2006 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 1 of 30 IN THE UNITED STATES DISTRICT coURJAECEIVED EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION OCT 1 7 2006 OFFICE OF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRJCT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KA THERINE KNIGHT, ET AL DEFENDANTS INTERVENORS INTERVENORS LITTLE ROCK SCHOOL DISTRICT'S COMPLIANCE REPORT For its Compliance Report, the Little Rock School District (LRSD) states: 1. This Compliance Report is filed pursuant to paragraph K of the Compliance Remedy contained in this Court's June 30, 2004 Memorandum Opinion. 2. LRSD has substantially complied with the Compliance Remedy. This compliance is documented below, as well as in the eight Quarto/,lY Updates which were filed between December 1, 2004 and September 1, 2006, the evaluations of Compass Learning, Smart/Thrive, Reading Recovery and Year-Round Education which were previously. filed, and the evaluations of A+, 21st Century Community Page 1 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 2 of 30 Learning Centers and READ 180 which are filed with this Compliance Report. 3. The progress ofLRSD's efforts to comply with the requirement for an eighth step 2 program evaluation, the Pre-K Literacy evaluation, has been shown in LRSD's Quarterly Updates and status reports to the Court. The final evidence of LRSD's compliance with that requirement will be the evaluation itself, which the evaluator, Dr. Ross, expects to have completed on or before November 15, 2006. 4. LRSD will separately describe below its compliance with each of the requirements of the Compliance Remedy except those which set out the responsibilities of the Joshua  Intervenors and the Office of Desegregation Monitoring. 5. The requirements of paragraph A of the Compliance Remedy are: A. LRSD must promptly hire a highly trained team of professionals to reinvigorate PRE. These individuals must have experience in: (a) preparing and overseeing the preparation of formal program evaluations; and (b) formulating a comprehensive program assessment process that can be used to detennine the effectiveness of specific academic programs designed to improve the achievement of African-American students. I expect the director of PRE to have a Ph.D.; tq ,have extensive experience in designing, preparing and overseeing the preparation of program evaluations; and to have a good understanding of statistics and regression analysis. I also expect LRSD to hire experienced statisticians and the other appropriate support personnel necessary to operate a first-rate PRE Department. Page 2 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 3 of 30 6. LRSD met the requirements of paragraph A by adding to the PRE team three new professionals who have knowledge and experience in assessment, evaluation, and statistical analysis. The qualifications of the seven people who were employed by PRE as of November 1, 2004 are shown at pages 3 through 5 of the December 1, 2004 Quarterly Update. The resumes of PRE Director Dr. Karen DeJarnette and statisticians Maurecia Malcolm Robinson, James C. Wohlleb and Dr. Ed Williams are found in Appendix A to the December 1, 2004 Quarterly Update. This highly trained team of professionals has the qualifications required by paragraph A of the Compliance Remedy. 7. There have been a few changes in personnel since the first Quarterly - Update, but PRE has maintained a . highly trained team of professionals. Administrative Assistant Irma Shelton took medical leave in May of 2005. The Administrative Assistant position was eliminated on July 1, 2005. Testing Coordinator Yvette Dillingham left PRE in August, 2005. Dr. Ed Williams temporarily assumed her responsibilities until she was replaced in November 2005 ' ' by Arthur Olds. Olds' resume can be found in Appendix A to the March 1, 2006 Quarterly Update. As reported in the June 1, 2006 Quarterly Update, Olds sought reassignment to a teaching possession at Dunbar Magnet Middle School on April 14, 2006. Dr. Williams again temporarily assumed the Testing Coordinator Page 3 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 4 of 30 - responsibilities. LRSD posted the Testing Coordinator position in June, 2006 and interviews were scheduled for August, 2006. See September l, 2006 Quarterly Update, p. 3. A new testing coordinator, Danyell Cummings was hired October 1, 2006. Her resume is attached as Exhibit A to this Compliance Report. 8. The current PRE staff has all of the qualifications listed in paragraph A of the Compliance Remedy. LRSD complied with paragraph A of the . Compliance Remedy. 9. The requirements of paragraph B of the Compliance Remedy are: B. The first task PRE must perform is to devise a comprehensive program assessment process. It may take a decade or more for LRSD to make sufficient progress in improving the academic achievement of African-American students to justify discontinuing the need for specific  2.7 programs. For that reason, the comprehensive program assessment process must be deeply embedded as a permanent part of LRSD's curriculum and instruction program. Only then will I have the necessary assurance that LRSD intends to continue using that process for as long as it is needed to determine the effectiveness of the various key  2. 7 programs in improving the academic achievement of African-American students. Part of LRSD's proof, at the next compliance hearing, must include evidence that it has devised and implemented a comprehensive program assessment process, which has been deeply embedded as a permanent part of its curriculum and instruction program. I suggest that LRSD use Dr. Ross to assist in developing this comprehensive program assessment process; then be sure that he approves that process before it is finalized and implemented. 10. LRSD has devised and deeply embedded a comprehensive program Page 4 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 5 of 30 assessment process in accordance with paragraph B of the Compliance Remedy. LRSD used Dr. Ross to assist in developing the comprehensive program assessment process. By the time of the first Quarterly Update on December 1, 2004, PRE and Dr. Ross had \"developed and shared with ODM and the Joshua Intervenors a program assessment process to be deeply embedded in LRSD's educational operations.\" December 1, 2004 Quarterly Update, p. 6. The final draft of that process is found at Appendix B of the December 1, 2004 Quarterly Update. This final draft was furnished to ODM and the Joshua Intervenors more than a month in advance of its consideration by the LRSD Board of Directors. December 1, 2004 Quarterly Update, p. 11. The comprehensive program - assessment process was approved by the LRSD Board on December 16, 2004. March 1, 2005 Quarterly Update, p. 3. 11. The comprehensive program assessment process has become deeply embedded as a permanent part of LRSD's curriculum and instruction program. The embedding of the comprehensive program assessment process has included the development of school portfolios. \"School portfolios assemble comprehensive data about classrooms, schools, and districts from disparate sources into data bases that are accessible and informative particularly to teachers and administrators as well as to board members, parents, and other stakeholders.\" September 1, 2005 Page 5 of 19 ' Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 6 of 30 Quarterly Update, p. 3. School portfolios are useful for formative evaluations of student achievement and educational programs. LRSD began implementing school portfolios during the 2005-06 school year.. Id. As part .of the process of the development and implementation of portfolios, four PRE department members attended an institute for data analysis during the summer of 2005, and a consultant \"visited LRSD and reviewed its data collection procedures and resources.\" Id. 12. LRSD has continued to develop the infrastructure to support its comprehensive assessment process. School and district data portfolios are an important part of this infrastructure. These portfolios \"allow PRE staff as well as others to more easily analyze data and intersect various types of data sets to answer - research questions about comprehensive school improvement efforts.\" December 1, 2005 Quarterly Update, p. 3. During April of 2006, an expert on school portfolios provided professional development for LRSD principals, administrators, and the PRE staff regarding the creation and use of school portfolios. June 1, 2006 Quarterly Update, p. 3. 13. As of December 1, 2005, PRE had identified the data to be included in the district portfolio and had designed a draft district portfolio. Id. District administrators and principals were making use of the portfolio and steps were being taken \"to allow a more efficient collection of data related to educational Page 6 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 7 of 30 - processes.\" Id. Dr. Catterall used data from LRSD's portfolio in his step 2 evaluation of the Year-Round Education program. March 1, 2006 Quarterly Update, p. 3. 14. The development of portfolios is a continual process. As new data becomes available ( e.g. new test results) they are added to the data base. The infrastructure is in place, and LRSD continues to expand and update its portfolios. See March 1, 2006 Quarterly Update, p. 3. 15. LRSD has also sought to deeply embed the comprehensive program assessment process by hmng a consultant, the Janis Group, to help develop a \"data warehouse.'~ The Janis Group has \"expertise in storing, integrating, and efficiently - accessing data.\" March 1, 2006 Quarterly Update, p. 3. The data warehouse will support frequent updates of the portfolio and allow timely data reports for purposes of planning, research, evaluation and developing policy. Reports can be generated by program, classroom, school, grade, or district-wide. Id. 16. There was some debate within LRSD about whether to purchase an internet-based data warehouse from a company called TetraData or to continue the in-house design and construction of a data warehouse using the Business Objects software and the database already available to LRSD. LRSD decided, with some dissent from PRE, to continue to use and improve the Business Objects software. Page 7 of 19 Case 4:82~cv-00866-WRW Document 4050 Filed 10/16/2006 Page 8 of 30 - Business Objects is state of the art software which can be effectively used in the assessment of academic programs. The capabilities of the Business Objects data warehouse, including updating and reporting student data, are shown in the \"Business Objects Reporting Tools\" document attached as Exhibit B to this Compliance Report. 17. The process of developing school and district portfolios, and creating . a data warehouse, has revealed the need for LRSD to take steps to insure that the data entered into its database is accurate. The accuracy of the data would be a concern whether the district used the Business Objects system, the TetraData system or some other software system. To improve the accuracy of data reporting - within LRSD, LRSD has increased the number of \"error checking routines\" in its computer software. LRSD also has a full time training coordinator whose job it is to train school registrars and other LRSD personnel in the proper entry of student data, to work with those people to identify and correct recurring data entry errors, and to generally assure the accuracy and completeness of student data within the ' . . LRSD database. The accuracy of the data in LRSD's database, including its portfolios, continues to improve. 18. Finally, as another part of embedding the comprehensive program assessment process, PRE has designed \"feasible, ongoing assessments of the four Page 8 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 9 of 30 programs which Drs. Catterall and Ross subjected to step 2 evaluations last year.\" June 1, 2006 Quarterly Update, p. 3. LR.SD also plans to have PRE conduct ongoing assessments of the programs currently being evaluated by Drs. Ross .and Catterall. 19. LR.SD has devised a comprehensive program assessment process as required by paragraph B of the Compliance Remedy. That process has been deeply embedded as a permanent part of LRSD's curriculum program. LRSD has complied with paragraph B of the Compliance Remedy. 20. The requirements of paragraph C of the Compliance Remedy are: C. During each of the next two academic school years (2004-05 and 2005-06), LR.SD must hire one or more outside consultants to prepare four ( 4) formal step 2 evaluations. Each of these step 2 evaluations must cover one of the key  2. 7 programs, as it has been implemented in schools throughout the district. Thus, over the course of the next two academic school years, LRSD must hire outside consultants to prepare a total of eight (8) formal step 2 evaluations of key  2.7 programs. During the recent compliance hearing, Dr. Ross made it clear that LR.SD must conduct these formal step 2 evaluations of the key  2.7 programs in order to continue to make progress in improving the academic achievement of AfricanAmerican students. Again, I suggest that LRSD hire Dr. Ross -- to perform the following tasks: (1) identify the four key 2.7 programs that should be formally evaluated during the 2004-05 school year and the four key  2. 7 programs that should be formally evaluated during the 2005-06 school year; and (2) prepare as many of the eight step 2 evaluations as possible. If Dr. Ross cannot prepare all eight of the step 2 evaluations, I recommend that LRSD hire someone that Dr. Ross recommends as possessing the experience and ability necessary Page 9 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 10 of 30 to prepare those evaluations. 21. In accordance with paragraph C, LRSD hired Dr. Ross to \"identify the four key  2. 7 programs that should be formally evaluated during the 2004-05 school year and the four key  2.7 programs that should be formally evaluated ;. during the 2005-06 school year,\" and to \"prepare as many of the eight step 2 evaluations as possible.\" 22. Dr. Ross was provided a copy of the Compliance Remedy and he endorsed the first Quarterly Update \"as representing an accurate portrayal of accomplishments to date and a viable plan for addressing the requirements of the Remedy.\" December 1, 2004 Quarterly Update, Appendix C (p. 45). Dr. Ross - assumed responsibility for preparing six of the required eight fonnal step 2 evaluations. Three of those cover the 2004-05 school year and were filed on February 6, 2006. Two others are for the 2005-q6 school year and will be filed today. The sixth step 2 evaluation being prepared by Dr. Ross, Pre-K Literacy, has been delayed due to the unavailability of necessary data and is expected to be completed no later than November 15, 2006. 23. Two of the required eight formal step 2 evaluations were prepared by Dr. James Catterall. One covered the 2004-05 school year and was filed on February 6, 2006. The other will be filed today. Page 10 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 11 of 30 24. PRE, in collaboration with Dr. Ross, selected Reading Recovery, Smart/Thrive, Compass Learning and Year-Round Education to be fonnally evaluated during the 2004-05 school year. December 1, 2004 Quarterly Update, pp. 7-9. Those evaluations have been completed. 25. Dr. Ross initially identified the following four  2. 7 programs for step 2 evaluations in the 2005-06 school year: Arkansas A+ School Network; KnowledgePoints; PLATO Learning and Pre-Kindergarten Literacy Development. June 1, 2005 Quarterly Update, pp. 3-4. At the request of the Joshua Intervenors, and with the agreement of Dr. Ross, 21st Century Community Learning Centers was substituted for PLATO Learning as the subject of an evaluation for the 2005- - 06 school year. Sept~mber 1, 2005 Quarterly Update, pp. 3-4 and Appendix C, (pp. 19-21). KnowledgePoints was also replaced as the subject of evaluation by the READ 180 program because the supplier of KnowledgePoints withdrew its support of the program in Arkansas. December 1, 2005 Quarterly Update, pp. 3-4. 26. Dr. Ross and Dr. Catterall possess the experience and ability necessary to prepare the eight required step 2 evaluations. Their qualifications are found in Appendix C to the first Quarterly Update (pp. 46-54). They are both familiar with the requirements of the Compliance Remedy and have agreed to prepare their evaluations in accordance with those requirements. LRSD has Page 11 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 12 of 30 - complied with the requirements of paragraph C of the Compliance Remedy. 27. The requirements of paragraph D of the Compliance Remedy are: D. Each of the eight step 2 evaluations must answer the following essential research question: \"Has the  2. 7 program being evaluated improved the academic achievement of African-American students, as it has been implemented in schools . throughout the district?\" The eight step 2 evaluations may also answer as many other research questions as the designers of each evaluation deem necessary and appropriate. Each of the step 2 evaluations must be organized and written in such a way that it can be readily understood by a lay person. I will allow the outside experts preparing each of these evaluations to decide on the appropriate number of years of test scores and other data that need to be analyzed in preparing each evaluation. PRE must: ( 1) oversee the preparation of all eight of these step 2 evaluations; (2) work closely with Dr. Ross and any other outside consultants hired to prepare these step  2 evaluations; and (3) provide the outside consultants with any and all requested assistance and support in preparing these step 2 evaluations. 28. Each of the eight step 2 evaluations answers the essential research question of whether the program being evaluated improved the academic achievement of African-American students, as it has been implemented in schools throughout the district. Each of the eight step 2 evaluations also answers other important research questions. Each is organized and written so that it can be readily understood by a lay person. fu each case, the outside experts and the evaluation teams determined the evaluation design, including the appropriate . number of years of test scores and other data necessary to the utility of each Page 12 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 13 of 30 evaluation. 29. PRE has overseen the preparation of all eight step 2 evaluations and worked closely with Drs. Ross and Catterall, and those associated with them, to support their work and provide any and all requested assistance. See June 1, 2005 Quarterly Update, pp.6-7; March 1, 2006 Quarterly Update, p. 4; June 1, 2006 Quarterly Update, pp. 5-6; September 1, 2006 Quarterly Update, p. 6 and Appendix A. LRSD has met the requirements of paragraph D of the Compliance Remedy. 30. The requirements ofparagraphE of the Compliance Remedy are: E. In order to streamline LRSD's record-keeping obligation, I am going to require that each of the eight step 2 evaluations contain, in addition to the traditional information and data, a special section which: ( 1) describes the number of teachers and administrators, at the various grade levels, who were interviewed or from whom information was received regarding the effectiveness of the key 2.7 program being evaluated; (2) lists each of the recommended program modifications, if any, that were deemed necessary in order to increase the effectiveness of each of the  2. 7 programs in improving the academic achievement of African-American students; and (3) briefly explains how each of the recommended modifications is expected to increase the effectiveness of the  2.7 program. This requirement is intended to relieve LRSD of any independent record-keeping obligations under  2. 7 .1 of the Revised Plan and the Compliance Remedy. 31. In accordance with paragraph E of the Compliance Remedy, each of the eight step 2 evaluations contains a section concerning data collection which Page 13 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 14 of 30 describes the number of teachers and administrators at various grade levels who were interviewed or from whom information was received regarding the effectiveness of the program being evaluated. Each of the -eight evaluations also contains recommended program modifications and explains how the recommended modifications can be expected to increase the effectiveness of the program. See March 1, 2006 Quarterly Update, pp. 4-5. 32. On April 18, 2006, LRSD convened the four evaluation teams which worked on the 2004-05 evaluations to consider the feasibility and the timeframe for implementing the external evaluators' recommendations. June 1, 2006 Quarterly Update, p. 3. A summary ofLRSD's commitments to the modifications - recommended by the external evaluators is found in Appendix A (pp. 7-11) to the June 1, 2006 Quarterly Update. LRSD will follow the same process of reviewing the evaluators' recommended modifications following receipt of the evaluations for the 2005-06 school year. LRSD has complied with the requirements of paragraph E of the Compliance Remedy. 33. The requirements of paragraph F of the Compliance.Remedy are: F. As soon as PRE and Dr. Ross identify the eight  2.7 programs targeted for step 2 evaluations, PRE must notify the ODM . and Joshua in writing of the names of those eight programs. In addition, after PRE and Dr. Ross have formulated a comprehensive program assessment process and reduced it to a final draft, PRE must Page 14 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 15 of 30 provide a copy to the ODM and Joshua at least thirty days before it is presented to the Board for approval. I expect the Board to approve LRSD's comprehensive program assessment process no later than December 31, 2004. 34. In accordance with paragraph F of the Compliance Remedy, PRE notified ODM and Joshua in writing of the names of.the_ eight  2.7 programs targeted for step 2 evaluations. See June 1, 2005 Quarterly Update; p. 8. PRE also provided to ODM and Joshua a final draft of the comprehensive program assessment process more than thirty days before it was presented to the Board for approval. December 1, 2004 Quarterly Update, pp. 6 and 11. The LRSD Board of Directors approved the comprehensive  program assessment process on December 16, 2004, in advance of the December 31, 2004 deadline. March 1, 2005 Quarterly Update, p. 3. LRSD has met the requirements of paragraph F of the Compliance Remedy. 35. The requirements of paragraph G of the Compliance Remedy are: G. PRE must submit quarterly written updates on the status of the work being performed on the four step 2 program evaluations that will be prepared during the 2005-06 school year. The~e quarterly updates must be delivered to the ODM and Joshua on December l, March 1, June 1, and September 1 of each of those two academic school years. As soon as each of the eight step 2 evaluations has been completed and approved by the Board, LR.SD must provide a copy to the ODM and Joshua. 36. In accordance with paragraph G of the Compliance Remedy, Page 15 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 16 of 30 - LRSD submitted quarterly written updates to the Court and delivered them to ODM and Joshua on or before December 1, 2004, March 1, 2005, June 1, 2005, September 1, 2005, December 1, 2005, March 1, 2006, June 1, 2006 and September 1, 2006. Those quarterly written updates reported \"the status .. of the work being performed on the four step 2 program evaluations\" prepared during the 2004-05 and 2005-06 school years. The quarterly updates also provided information on the status of compliance with other components of the Compliance Remedy. 36. As soon as the four step 2 evaluations for the 2004-05 school year were completed and approved by the LRSD Board, LRSD provided - them to ODM and Joshua. Three of the four step 2 program evaluations for the 2005-06 school year will be filed with the Court and provided to ODM and Joshua on October 16, 2006. The fourth will be filed with the Court and provided to ODM and Joshua on or before November 15, 2006. As soon as the four step 2 program evaluations for  the 2005-06 school year are approved by the LRSD Board, LRSD will provide final copies of those evaluations to ODM and Joshua. LRSD has complied with paragraph G of the Compliance Remedy. 37. The requirements of paragraph J of the Compliance Remedy are: Page 16 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 17 of 30 J. The four step program evaluations for the 2004-05 school year must be filed with the Court no later than October 1, 2005. The four step 2 program evaluations for the 2005-06 school year must be filed with the Court no later than October 1, 2006. 38. The four step 2 program evaluations for the 2004-05 school year were filed with the Court on February 6, 2006 in accordance wjth extended deadlines approved by the Court. Three of the four step 2 program evaluatiohs for the 2005- 06 school year will be filed on today in accordance with extended deadlines approved by the Court. Dr. Ross requires additional time to complete the Pre-K Literacy evaluation because of the delayed availability of necessary testing data. LRSD has requested an extension of time for the filing of that step 2 evaluation to and including November 15, 2006, and expects to file that evaluation by that date. LR.SD has substantially complied with paragraph J of the Compliance Remedy. 39. The requirements of paragraph K of the Compliance Remedy are: K. On or before October 15, 2006, LRSD must file a Compliance Report documenting its compliance with its obligations under  2.7.1 of the Revised .Plan, as specified in this Compliance Remedy. If Joshua wishes to challenge LRSD' s substantial compliance, they must file objections on or before November 15, 2006. Thereafter, I will schedule a compliance hearing and decide whether LRSD has met its obligations under the Compliance Remedy and should be released from all further supervision and monitoring. 40. LRSD is filing this Compliance Report on October 16, 2006 m accordance with paragraph K of the Compliance Remedy and the Court's July 12, Page 17 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 18 of 30 2006 letter to the parties ( docket no. 4027). WHEREFORE, for the reasons set forth above and in the eight Quarterly Updates which have been filed with the Court, and on the basis of the completion of eight step 2 program evaluations by Drs. Ross and Catterall, LRSD prays for an order finding it to be in substantial compliance with the Compliance Remedy contained in the Court's June 30, 2004 Memorandum Opinion, declaring LRSD to be a unitary school district, and releasing LRSD from all supervision and monitoring by the Court. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) Khayyam M. Eddings (#02008) 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493 (501) 376-2011 Isl Clrristopher Heller CERTIFICATE OF SERVICE I certify that on October 16, 2006, I have electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which shall send notification of such filing to the following: Page 18 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 19 of 30 mark.hagemeier@ag.state.ar.us sjones@mwsgw.com sjones@jlj.com iohnwalkeratty@aol.com and mailed by U.S. regular mail to the following addresses: .. Gene Jones Office of Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Clayton Blackstock Mr. Mark Burnett 1010 W. Third Street Little Rock, AR 72201 - JudgeJ.ThomasRay U. S. District Courthouse 600 West Capitol Avenue, Suite 149 Little Rock, AR 72201 Isl Christopher Heller Page 19 of 19 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 20 .\u0026lt;?_t 3Q _ . Career Objective: Prefeuional Experience: 1998-Prcaent Educadon: May,2005 December, 1998 May, 1997 Prof ess.lonally Related Activities: Danyell CrutchfleJd Cummlnp S Ben Hopn Cove Little Rock, Arkansas 7221G (501) 407-8097 (501) 447-1737 To utilize proven academic and professional experience to obtain a challenging position as an administrator that will allow for growth and an opportunity to contribute to a progrcssi ve educational environment. High Schools That Work Coordinator J. A. Fair Systems Magnet High School Little Rock, Arkansas 72210 Randy Rutherford, Principal Ens]iah Tcacbor !. A. Fair Systems Magnet High School Little Rock, Arkansas 72210 Randy Rutherford, Principal Educational Specialist, Educational Administration and Supervi:iion, University of Arkansas at Little Rock Master of Education, Secondary Education, University of Arkansas at Little Rock Bachelor of Arts, English, University of Arkansas at Little R.Qck Acting Assistant Principal Section 504 Coordinator CoW1cil of Secondary Education Stakeholder Southern Regional Education Board Literacy Team member Teacher of the Year Educational Specialist Case 4:82-cv-00866-WRW Document 4050 References: Linda Young Grants Coordinator (501) 447-3372 work (501) 225--$439 home Jill Brooks Principal David O'Dodd Elementary (,Ol) 447-4300 work (501) 680-3767 home William Broadnax, Ed.D Student Hearing (501) 447-3582 work (501) 407-0817 home Sharon Cauley, Ed.D Assistant Principal J.A. Fair Systems Magnet High School (501) 447-1700 ext. 1710 work (501)666-621_6 home Filed 10/16/2006 ~~1:1 .. ~ ?..! . .O.I. ~0 . ____Ca_se_ _4:8_2-_cv-_00 866-WRW Document 4050 Filed 10/16/200~ge 22 ~!}0_ _ ,. .. _______ , . ., .. _ , _________ , Career Objective: Profeuioul Experience: 2004-Present 1998-Prcscnt Educadon: May,2005 December, 1998 May, 1997 Profea,Jonally Related ActMdes: Danyell CrutcbReld Cumminp 5 Ben Hogan Cove Little Rock, Arkanau 72210 (!01) 407-8097 (501) 447-1737 To utilize proven academic and professional experience to obtain a challenging position as an administrator that will allow for growth and an opportunity to contribute to a progressive educational environmmt. High Schools That Work Coordinator J. A. Fair Systems Magnet High School Little Rock, Arkansas 72210 Randy Rutherford, Principal English Teacher J. A. Fair Systems Magnet High School Little Rock, Arkansas 72210 Randy Rutherford, Principal Educational Specialist, Educational Administration and Supervision, University of Arkansas at Little Rock Master ofEducatioo, Secondary Education, University of Arkansas at Little Rock Bachelor of Arts, English, University of Arkansas at Little R~k Acting Assistant Principal Section S04 Coordinator Council of Secondary Education Slakeholder Southern Regional Education Board Literacy Team member Teacher of the Year Educational Specialist Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 P_9ge g~_qf 30 . References: Linda Young Grants Coordinator (501) 447-3372 work (501) 225-5439 home Jill Brooks Principal David O'Dodd Elementary (S0l) 447 ... 300 work (501) 680-3767 home William Broadnax, Ed.D Student Hearing (501) 447-3582 work (SO 1) 407-0817 home Sharon Cauley, Ed.D Assistant Principal J.A. Fair Systems Magnet High School (501) 447-1700 ext. 1710 work (S01) 666-6216 home Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 24 of 30 81 Platform Little Rock School District Business Objects Reporting Tools Business Objects Enterprise is a scalable, adaptive platform that delivers insight and corporate infonnation to all your end users. With a platform designed to help you confidently deploy and manage your Business Intelligence (BI) implementations, Business Objects provides the Little Rock School District with the extreme insight you need to extend your competitive advantage. . . The BI Platform provides a set of common services to simplify deployment and management of BI tools, reports, and applications. The reporting system at the Little Rock School District includes information delivery in subject areas including Student Demographics, Student Performance, Budget and Finance, Employee Attendance, Child Nutrition, Human Resources, Accounts Payable, Payroll, Procurement, and Procurement Warehouse, to name a few. Flexible Services-Oriented Platform By building the Little Rock School District's BI solutions with Business Objects Enterprise, we have the  flexibility to deploy a solution for a single information challenge, while being able to simultaneously expand the deployment as our needs evolve. Designed for Scalability and High Performance Business Objects Enterprise is designed for scalability, reliability, fault-tolerance, extensibility, and 24/7 availability. This platform recognizes the importance of diverse global deployments, supports Unicode, and -~s compliant with Microsoft Windows, Sun Solaris, IBM AIX, HP-UX, and Linux. So you can start with a single BI project on one platform, and easily grow to support an enterprise-wide standardization initiative on multiple platforms. With BI content now being delivered via intranet and extranet, BI platfonn scalability is a key issue. Business Objects Enterprise has the scalability you need to accommodate increasing numbers of users, process growing volumes of information, and scale on a single machine-or clusters of machines- . while maintaining high performance.  Proven Reliability This platfonn's key attributes-performance, reliability, and scalability-are proven by extensive, realworld testing and third-party certification. Enterprise is the only BI platform to achieve Microsoft Windows 2003 Datacenter certification. Business Objects Enterprise- covered by a 24/7 technical customer support-has demonstrably installed and run on a 32-processor system, remained stable through rigorous stress testing, and stayed available after being subject to extensive failover conditions. We also continually conduct extensive benchmarking and performance testing to ensure our platform scales to meet the needs of the Little Rock School District today and tomorrow. I. EXHIBIT I ______-.; ;;__i 13----~ LRSD BI Tools ....!,____ .... Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 25 of 30 Reporting Fundamentals The fundamental requirements of any reporting system are a normalized database and a reporting tool. Data from disparate systems and formats is collected in a centralized database platform and transformed into a consistent, well organized reporting database. Many reports have been created and delivered from this reporting database using Crystal Reports as the reporting tool. Normalized Data This data, securely housed at the Little Rock School District Technology Center, has been normalized to 3rd normal form on a Microsoft SQL Server database server. The original database management software is DB2 residing on an IBM AS/400 application server, which hot1ses a majority of the studentbased data. Other student data resides in Microsoft Access or is provided fo the CIS department via Microsoft Excel spreadsheets. Automated processes have been developed and scheduled to update the student data nightly, where required. Processes have also been designed and implemented to update data in key financial, human resources and accounting subject areas. Business Objects provides the industry's leading suite of integrated business intelligence products. The products are categorized into three groups: Reporting allows all levels of the Little Rock School District to access, format, and deliver data as meaningful information to large populations of information consumers like teachers and school administrators both inside and outside the organization. This is provided through detailed reports created using Crystal Reports and accessed via a web browser using the Business Objects Enterprise - Info View application. Query and Analysis tools allow end users to interact with District information and answer ad hoc questions, without advanced knowledge of the underlying data sources and structures. This is provided through a product called Web Intelligence or WEBI. This allows users to create dynamic reports from their desks with little or no required knowledge of the underlying database schema. In-depth analysis is performed using OLAP Intelligence, a powerful OnLine Analytic Processing tool that provides detailed, fast, multidimensional data for sophisticated comparative analysis and reporting. Performance Management products help users align with strategy by tracking and analyzing key business and educational metrics and goals via management dashboards, scorecards, and alerting. This is provided through Performance Manager and Dashboard Manager products that present Key  Performance Indicators in user-friendly, interactive graphical tools. Crystal Reports A world standard for enterprise reporting, Crystal Reports is an intuitive reporting solution that helps customers rapidly create flexible, feature-rich, high-fidelity reports and tightly integrate them into web and Windows applications.   The Crystal Reports enterprise reporting solution consists of: LRSDBIToou Pagel o/7 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 26 of 30  Powerful report design: Report authors can use the visual report designer (with a complete set of layout and design controls), to design highly formatted, interactive, and professional-looking reports. And they can design within the leading .NET and Java development tools without having to step out of their chosen development environment.  Flexible application development: Developers can leverage cross-platform support for Java, .NET, and COM development technologies. HTML is generated directly by Crystal Reports, allowing developers to focus on application business logic, rather than tedious, time-intensive hand coding. Separation of application development and report design tasks allow developers to focus on application development, while the report authors can focus on report design.  Report management and delivery: Reports are easily published to the web, for better business decisions in all areas of the Little Rock School District. Reports can be exported and repurposed to the electronic fonnats used by most end users ( e.g. PDF and Excel). IT can centralize the management of operational reporting while distributing the report authoring function out to departments of the District that need them. The following themes are an overview of what features are available in Crystal Reports XI:  Powerful data access and report design  Enhanced productivity and maintenance  Report management and delivery Dynamic and Cascading Prompts Report prompts can be based on dynamic values. This means that report designers no longer have to maintain static prompt value lists within individual reports. Instead, they can reuse existing prompts stored in the repository. HTML Preview The iterative report design/view process is streamlined, with a new HTML preview that allows report authors to see how reports will look when published to the web. Editable RTF Format This new feature is ideal for report export editing. It delivers reports to end users in a new RTF format, so they can easily make their own document modifications. Report Export Configuration The report designer can save report export configuration information within the report itself so that the end user forgoes the time and trouble of reconfiguring the export each time a report is run. Dependency Checker With the new dependency checker, report authors can quickly find broken links, formula errors, and dependency issues. Tiris greatly reduces the time spent on QA. Business Views Speed Report Design and Maintenance Cycles  Crystal Enterprise Business Views helps you better manage reporting across multiple data sources and applications by simplifying data access, change management, and data-level security processes. An lRSD Bl Tools Pnge J o/7 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 27 of 30 optional service in Crystal Enterprise, Business Views allow you to integrate data from disparate sources, handle promotion/demotion between development and production environments, and control security at both the row and column level. Simplified Data Access Data access is one of the most fundamental, yet difficult aspects of designing a report. Locating the right data, joining tables appropriately, and filtering the data to focus on a specific subject area requires an indepth knowledge of the underlying data structures. The Business View Manager allows you to simplify data access for your report designers by insulating them from the raw data structures. You can build connections to multiple data sources, join tables, alias field names, create calculated fields, and then surface this simplified structure as a .Business View in Crystal Enterprise. Your report designers can then connect to Crystal Enterprise and use the Business View as the basis for their report, rather than accessing the data directly and building their own queries. Business Views helps administrators pull data together from disparate sources. Data Connections (created visually or with complex SQL statements) can be integrated into a Data Foundation. Once the Data Foundation is built, Business Elements (a collection ofrelated fields from the Data Foundation) can be created and combined into a Business View. The modular architecture of Business Views also allows you to readily re-use various components of one Business View to build other Business Views. A single, broad data foundation can serve as the basis for multiple, specialized Business Views. Used carefully, these capabilities allow you to minimize the number of changes required to introduce new data, fields, or formulas into your system. Granular Data-level Security Many reporting scenarios involve complex security requirements. Each user is entitled to see a slightly different slice of District data, based on their School, Department or level of seniority. Data in the Little Rock School District is commonly segregated by School and Teacher-based information. Business Views allow teachers to view data regarding their students and prevents them form seeing data regarding students that are NOT assigned to them. Rather than creating a number of different reports to meet this need, we can create a single report and use the security features ofBusiness Views to filter data appropriately for each user. Using the Business View Manager, you can set up row- or column-level filters and map these filters to users or user groups stored in your existing LDAP, Active Directory, or Windows authentication provider. This security is   then consistently applied at the data level, ensuring that any report design based on a Business View will respect the underlying data security. You can then choose to schedule the report to run regularly. Or you can allow users to refresh it on demand. Regardless, Crystal Enterprise can generate a master instance of the report (with all the data included if you run the report under an administrator context) and then filter the report every time a user views it. All exporting, printing, and report modification requests will also return only the data the user is entitled to see. LRSD Bl Tools Pag~4of7 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 28 of 30 Change Management and Re-use Maintaining a large set ofreports is often more time-consuming and complex than new development. Activities such as making small changes in response to user needs, updating business calculations, changing fonnatting, and moving your reports between development and production data sources all delay you from addressing new requirements. Business Views includes two key features to help you spend less time on report maintenance. First, you can use Dynamic Data Connections to store connections to multiple instances of the same database (e.g., development, test, and production). By passing a parameter when you're designing (or scheduling) the report, you can select which data source the report runs against. Second, you can store commonly-used functions, text objects, and logos directly in your data foundation. This allows you to easily roll changes across multiple reports by changing the object once. Business Objects Enterprise Info View Business Objects Info View is a completely redesigned web interface that enables user to navigate, create, and interact with District information. Integrated search and navigation tools allow users to easily find the infonnation they need. Users can also personalize their interactions to simplify consumption of District information. Info View is built to support Java and Microsoft based web servers, to easily fit within you're the Little Rock School District IT infrastructure. Web Intelligence Many organizations find it difficult to access information not contained in standard reports. And requests to IT for new infonnation simply add to the report backlog. Even when ad hoc query capabilities are available, they're typically difficult to use and don't provide your non-technical users with a simple method of exploring information, to really understand the business issue at hand. With Business Objects Web Intelligence, both self-service access to information and data analysis are available in one product, helping your users turn educational analysis into effective decisions. Users can create a query from scratch, format the information retrieved, and analyze it to understand underlying trends and root causes. If the full power of query capabilities is not required, users can simply analyze information in existing reports-formatting and exploring them to meet specific needs.  CLAP Intelligence Business Objects OLAP Intelligence is a powerful and easy-to-use tool that allows you to access and analyze data stored in the leading OLAP servers. It uniquely satisfies the analysis requirements of both information analysts (power users) and less sophisticated knowledge workers (business users). With OLAP Intelligence, power users can slice and dice, drill, rank, sort, filter, create calculations on the fly, and perform speed-of-thought data exploration. And business users can interact with pre-built OLAP workbooks that contain highly intuitive, graphical views of educational activity, guided navigation and worktlows, and flexible ad hoc analysis. Its advanced analysis capabilities, shared security, and relational drill-through allow you to standardize on Business Objects for all of your BI needs. OLAP Intelligence delivers:  Best-of-breed ad hoc OLAP  Managed OLAP authoring and distribution  Integration with the market leading, trusted BI platform LRSD Bl Tools Page5 of7 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 29 of 30 Best-of-Breed Ad Hoc OLAP The primary driver for implementing an OLAP database is to provide users with fast access to multidimensional data. IT develops focused OLAP cubes to provide users with a structured data environment, optimized for analysis. But in order for users to take advantage of the pre-aggregated data within an OLAP cube, they require an interface that allows them to drill, slice, and dice while leveraging the response times that the predefined OLAP cube environment offers. Speed-of-Thought Analysis OLAP Intelligence provides an intuitive, web-based interface that allows users to select dimensions and members from a query panel as well as perform similar analysis from integrated Windows, Microsoft Excel, and ActiveX client interfaces. Users can interact with their data and ask sp\u0026lt;;mtaneous questions to uncover trends and identify anomalies. And because OLAP Intelligence talces advantage of the power of the OLAP cube, users are guaranteed speed-of-thought response time. Intuitive. Function-Rich Interface The OLAP Intelligence interface is both intuitive and function-rich. Common functions such as ranking, filtering, highlighting, quick calculations, zero suppression, and axis swapping are available with a single click of the mouse. More advanced analyses are only a few mouse clicks away and provide an uncluttered, intuitive user interface that requires minimal training. With OLAP Intelligence, users can also asymmetrically display data and hide specific dimensions that are irrelevant to data exploration. Deep. Open Access to Microsoft, Hyperion, and SAP OLAP Servers With OLAP Intelligence, you get best-of-breed, ad hoc OLAP for today's leading, multidimensional database servers-Microsoft SQL Server Analysis Services, Hyperion Essbase, IBM DB2 OLAP, and SAP BW. For example, native Hyperion Essbase 7.x support for free-fonn calculations and cube actions means that organizations are maximizing their OLAP server investments and taking advantage of key enhancements and optimizations. Managed OLAP Authoring and Distribution OLAP Intelligence goes further than most OLAP clients on the market today by not only providing powerful ad hoc analysis, but also delivering a flexible, managed OLAP environment. With OLAP Intelligence, you can easily create sophisticated workbooks that exploit the power of the underlying OLAP server, and enable users to build in predefined navigation paths and workflows. Then you can securely deploy and deliver the workbooks live to business users who don't necessarily fit the powerdata analyst profile. These OLAP workbooks may contain custom buttons and multi-page reports that  .recipients can view and interact with over the web. Publish Live OLAP Workbooks to Business Users When users view an OLAP Intelligence workbook over the web, it may appear as a dashboard with custom functionality specific to one area of the business, or as an ad hoc interface that allows them to perform advanced analysis. Because OLAP Intelligence has a flexible design and was created to meet powerful ad hoc and managed analysis needs, the deployment possibilities are limitless.  . Built-In Guided Navigation and Data Exploration LRSD Bl Too/3 Page6of7 Case 4:82-cv-00866-WRW Document 4050 Filed 10/16/2006 Page 30 of 30 With OLAP Intellj,gence you can guide users through the OLAP data navigation and exploration process. For example, a user can highlight a group of cells in a report, click a custom analysis button, and view a new graph that has drilled down on the chosen group, displaying variances as a worksheet and chart. A show trend analysis button could then be made available that displays a new page in the workbook with a year-over-year comparison. Open drill-through capabilities in OLAP Intelligence empower users to drill from aggregated OLAP data down to relational details. This means that users can navigate and explore summarized information, and drill through and pass context to more detailed Crystal Reports or Business Objects Web Intelligence documents. This contextual drill-through technology pro:Vides users with intelligent navigation without the need to understand the complexities of underlying data and metadata structures. LRSD Bl Toois Page 7 o/7 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. I, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. ORDER RECEIVED OCT 2 o 2006 OFACEOF DESEGREGATION MONITORING PLAINTIFF DEFENDANTS  INTERVENORS INTERVENORS LRSD's Motion for an Extension of Time (Doc. No. 4048) is GRANTED. Accordingly, LRSD's draft Step 2 Program Evaluation of the Pre-K Literacy Program must be filed by 5 p.m., Wednesday, November 15, 2006. IT IS SO ORDERED this 18th day of October, 2006. Isl Wm. R.Wilson Jr. UNITED ST A TES DISTRJCT JUDGE New York, NY 10013 Timothy Gerard Gauger \u0026amp;-kansas Attorney General ' s Office Wi,tlett-Prien Tower Building 323 Center Street Suite 200 Little Rock , AR 72201-2610 James M. Llewellyn , Jr Thompson \u0026amp; Llewellyn , P.A. Post Office Box 818 Fort Smith , AR 72902-0818 Office of Desegregation Monitor One Union National Plaza 124 West Capitol Suite 1895 Little Rock , AR 72201 William P. Th ompson Thompson \u0026amp; Llewel lyn , P .A. Post Office Box 818 Fort Smith , AR 72902-0818 MIME-Version:1.0 From:ecf_support@ared . uscourts.gov To:ared_ecf@ared.uscourts . gov A:~~age-Id :\u0026lt;767706@ared . uscourts.gov\u0026gt; ~ bject:Activity in Case 4 : 82-cv-00866-WRW Little Rock School , et al v . Pul aski Cty School, et al \"Order on Motion to Extend Time \" Content-Type : text/plain***NOTE TO PUBLIC ACCESS USERS*** You may view the filed documents once without charge . To avoid l ater charges , download a copy of each document during this first viewing . U. S. District Court Eastern District of Arkansas Notice of Electronic Filing The following transaction was entered on 10/19/2006 at 9 : 55 AM CDT and filed on 10/18/2006 Case Name: Little Rock School , et al v . Pulaski Cty School , et al Case Number: 4 : 82-cv-866 http : / /ecf . a red . us courts. gov/ cgi-bin/DktRpt . pl ?2 6052 WARNING : CASE CLOSED on 01/26/1998 Docume nt Number : 4053 Copy the URL address from the line below into the location bar of your Web browser to view the d ocument : http : //ecf . ared. uscourts . gov/cgi-bin /show_case_ doc?4053 , 26052 , , MAGIC ,,, 2005489 Docket Text: ORDER granting [4048] Motion to Extend Time ; LR$D ' s draft Step 2 Program Evaluation of the Pre-K Literacy Program must be filed by 5 p.m. , Wednesday, November 15 , 2006 . Signed by Judge William R. Wi lson Jr. on 10/18/06 . (mkf, ) The following documen t (s) are associated with this transaction: Document description: Main Document Original filename: n/a a lectronic document Stamp : - STAMP dcecfStamp_ ID=l095794525 [Date= l 0/19/2006] [FileNumber=767705-0] [b3ec8779c91ae546773eb22665c07b6afe5b 95858074548ablf66cdblb0e7c7bcafb4796bdlde8a 537ae2ba51becd736a5c7340c96eeef5323b45b8d3lb59545]] 4 : 82-cv-866 Notice will be electronically mailed to: Clayton R . Blackstock cblackstock@mbbwi . com Mark Terry Burnette mburnette@mbbwi . com John Clayburn Fendley , Jr clayfendley@comcast . net , yeldnef@yahoo.com Mark Arnold Hagemeier mark . hagemeier@arkansasag.gov, a ngela . dover@arkan sasag.gov Christopher J. He ller heller@fec . net , brendak@fec.net ; tmiller@fec.net M. Samuel Jones , III sjones@mwsgw . com, aoverton@mwsgw.com Stephen W. Jones sjones@jlj . com, kate . jones@jlj . com; linda . calloway@jlj . com Philip E. Kaplan pkaplan@kbmlaw.net , nmoler@kbmlaw.net Sharon Carden Streett scstreett@comcast . net , scstreett@yahoo.com John W. Walker johnwalkeratty@aol . com, lorap72297@aol.com; jspringer@gabriel mail.com -4 : 82-cv-866 Notice will be delivered by other means to : Norman J . Chachkin NAACP Legal Defense \u0026amp; Educational Fund , Inc . - New York 99 Hudson Street Suite 1600 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 1 of 30 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION RECEIVED OCT 2 7 2006 Qffl:Eff llUBATIONIO'-IU\"\"\"maG-LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINEKNIGHT,ET AL DEFENDANTS INTERVENORS INTERVENORS LITTLE ROCK SCHOOL DISTRICT'S REVISED COMPLIANCE REPORT  For its Re;,visectC0mpliance'Report, the Little Rock School District (LRSD) states: 1. This Compliance Report is filed pursuant to paragraph K of the Compliance Remedy contained in this Court's June 30, 2004 Memorandum Opinion. The reason for revising the Compliance Report is to correctly reflect the fact that school portfolios, as opposed to the district portfolio,  have not been implemented in LRSD. The substantive changes from the initial Compliance Report are found in paragraphs eleven through sixteen. 2. LRSD has substantially complied with the Compliance Remedy. This Page 1 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 2 of 30 compliance is documented below, as well as in the eight Quarterly Updates which were filed between December 1, 2004 and September 1, 2006, the evaluations of Compass Learning, Smart/Thrive, Reading Recovery and Year-Round Education which were previously filed, and the evaluations of A+, 21 st _Century Community Learning Centers and READ 180 which are filed with this Compliance Report. 3. The progress ofLRSD's efforts to comply with the requirement for an eighth step 2 program evaluation, the Pre-K Literacy evaluation, has been shown in LRSD's Quarterly Updates and status reports to the Court. The final evidence of LRSD's compliance with that requirement will be the evaluation itself, which the evaluator, Dr. Ross, expects to have completed on or before November 15, 2006. 4. LRSD will separately describe below its compliance with each of the requirements of the Compliance Remedy except those which set out the r~sponsibilities of the Joshua Intervenors and the Office of Desegregation Monitoring. 5. The requirements of paragraph A of the Compliance Remedy are: A. LRSD must promptly hire a highly trained team of professionals to reinvigorate PRE. These individuals must have experience in: (a) preparing and overseeing the preparation of formal program evaluations; and (b) formulating a comprehensive program assessment process that can be used to determine the effectiveness of specific academic programs designed to improve the achievement of African-American Page 2 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 3 of 30 students. I expect the director of PRE to have a Ph.D.; to have extensive experience in designing, preparing and overseeing the preparation of program evaluations; and to have a good understanding of statistics and regression analysis. . I also expect LRSD to hire experienced statisticians and the other appropriate support personnel necessary to operate a first-rate PRE Department. 6. LRSD met the requirements of paragraph A by adding fo 1 th,e PRE team three new professionals who have knowledge and experience in assessment, evaluation, and statistical analysis. The qualifications of the seven people who were employed by PRE as of November 1, 2004 are shown at pages 3 through 5 of the December 1, 2004 Quarterly Update. The resumes of PRE Director Dr. Karen DeJarnette and statisticians Maurecia Malcolm Robinson, James C. Wohlleb and Dr. Ed Williams are found in Appendix A to the December 1, 2004 Quarterly Update. This highly trained team of professionals has the qualifications required by paragraph A of the Compliance Remedy. 7. There have been a few changes in personnel since the first Quarterly Update, but PRE has maintained a highly trained team of professionals. Administrative Assistant Irma Shelton took medical leave in May of 2005. The Administrative Assistant position was eliminated on July 1, 2005. Testing Coordinator Yvette Dillingham left PRE in August, 2005. Dr. Ed Williams temporarily assumed her responsibilities until she was replaced in November 2005 Page 3 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 4 of 30 by Arthur Olds. Olds' resume can be found in Appendix A to the March 1, 2006 Quarterly Update. As reported in the June 1, 2006 Quarterly Update, Olds sought reassignment to a teaching possession at Dunbar Magnet Middle School on April 14, 2006. Dr. Williams again temporarily assumed . the :resting Coordinator responsibilities. LRSD posted the Testing Coordinator position in June, . 2p96 and interviews were scheduled for August, 2006. See September 1, 2006 Quarterly Update, p. 3. A new testing coordinator, Danyell Cummings was hired October 1, 2006. Her resume is attached as Exhibit A to this Compliance Report. 8. The current PRE staff has all of the qualifications listed in paragraph A of the Compliance Remedy. LRSD complied with paragraph A of the Compliance Remedy. 9. The requirements of paragraph B of the Compliance Remedy are: B. The first task PRE must perform is to devise a comprehensive program assessment process. It may take a decade or more for LRSD to make sufficient progress in improving the academic achievement of African-American students to justify discontinuing the need for specific  2.7 programs. For that reason, the comprehensive program assessment process must be deeply embedded as a permanent part of LRSD's curriculum and instruction program. Only then will I have the necessary assurance that LRSD intends to continue using that process for as long as it is needed to determine the effectiveness of the various key  2. 7 programs in improving the academic achievement of African-American students. Part of LRSD's proof, at the next compliance hearing, must include evidence that it has devised and implemented a comprehensive Page 4 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 5 of 30 program assessment process, which has been deeply embedded as a permanent part of its curriculum and instruction program. l suggest that LRSD use Dr. Ross to assist in developing this comprehensive program assessment process; then be sure that he . approves that process before it is finalized and implemented. 10. LRSD has devised and deeply embedded :i coII1prehensive program assessment process in accordance with paragraph B of the Compliance . Remedy. LRSD used Dr. Ross to assist in developing the comprehensive program assessment process. By the time of the first Quarterly Update on December 1, 2004, PRE and Dr. Ross had \"developed and shared with ODM and the Joshua Intervenors a program assessment process to be deeply embedded in LRSD's educational operations.\" December 1, 2004 Quarterly Update, p. 6. The final draft of that process is found at Appendix B of the December 1, 2004 Quarterly Update. This final draft was furnished to ODM and the Joshua Intervenors more than a month in advance of its consideration by the LRSD Board of Directors. December 1, 2004 Quarterly Update, p. 11. The comprehensive program assessment process was approved by the LRSD Board on December 16, 2004. March 1, 2005 Quarterly Update, p. 3. 11. The comprehensive program assessment process has become deeply embedded as a permanent part of LRSD's curriculum and instruction program. The embedding of the comprehensive program assessment process has included Page 5 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 6 of 30 the development of a school district portfolio. As part of the process of the development and implementation of the portfolio, four PRE department members attended an institute for data analysis during the summer of 2005, and a consultant \"visited LRSD and reviewed its data collection procedures anq resources.\" Id. 12. LRSD has continued to develop the infrastructure to 'supP.ort its comprehensive assessment process. A district portfolio is an important part of this infrastructure. The portfolio will \"allow PRE staff as well as others to more easily analyze data and intersect various types of data sets to answer research questions about comprehensive school improvement efforts.\" December 1, 2005 Quarterly Update, p. 3. 13. As of December 1, 2005, PRE had identified the data to be included in the district portfolio and had designed a draft district portfolio. Id. District administrators and principals were making use of the portfolio and steps were being taken \"to allow a more efficient collection of data related to educational processes.\" Id. Dr. Catterall used data from LRSD's portfolio in his step 2 evaluation of the Year-Round Education program. March 1, 2006 Quarterly Update, p. 3. 14; The development of the district portfolio is a continual process. As new data becomes available (e.g. new test results) they are added to the data base. Page 6 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 7 of 30 The infrastructure is in place, and LRSD continues to expand and update its portfolio. See March 1, 2006 Quarterly Update, p. 3. 15. During April of 2006, an expert on school portfolios provided professional development for LRSD principals, adminis_trators, and the PRE staff regarding the creation and use of school portfolios. June 1, 2006 _Qll;arterly Update, p. 3. LRSD expects to begin the creation of school portfolios during the 2007-08 school year. 16. LRSD has also sought to deeply embed the comprehensive program assessment process by hiring a consultant, the Janis Group, to help develop a \"data warehouse.\" The Janis Group has \"expertise in storing, integrating, and efficiently accessing data.\" March 1, 2006 Quarterly Update, p. 3. The data warehouse will support frequent updates of the portfolio and allow timely data reports for purposes of' planning, research, evaluation and developing policy. The data warehouse will allow reports to be generated by program, classroom, school, grade, or districtwide. Id. 17. There was some debate within LRSD about whether to purchase an internet-based data warehouse from a company called TetraData or to continue the in-house design and construction of a data warehouse using the Business Objects software and the database already available to LRSD. LRSD decided, with some Page 7 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 8 of 30 dissent from PRE, to continue to use and improve the Business Objects software. Business Objects is state of the art software which can be effectively used in the assessment of academic programs. The capabilities of the Business Objects data warehouse, including updating and reporting student. data, are shown in the \"Business Objects Reporting Tools\" document attached as Exhibit . B, to this Compliance Report. 18. The process of developing school and district portfolios, and creating a data warehouse, has revealed the need for LRSD to take steps to insure that the data entered into its database is accurate. The accuracy of the data would be a concern whether the district used the Business Objects system, the TetraData system or some other software system. To improve the accuracy of data reporting within LRSD, LRSD has increased the number of \"error checking routines\" in its computer software. LRSD also has a full time training coordinator whose job it is to train school registrars and other LRSD personnel in the proper entry of student data, to work with those people to identify and correct recurring data entry errors, and to generally assure the accuracy and completeness of student data within the LRSD database. The accuracy of the data in LRSD 's database, including its portfolios, continues to improve. 19. Finally, as another part of embedding the comprehensive program Page 8 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 9 of 30 assessment process, PRE has designed \"feasible, ongoing assessments of the four programs which Drs. Catterall and Ross subjected to step 2 evaluations last year.\" June 1, 2006 Quarterly Update, p. 3. LRSD also plans to have PRE conduct ongoing assessments of the programs currently being evaluat~d by Drs. Ross and Catterall. 20. LRSD has devised a comprehensive program assessment process as required by paragraph B of the Compliance Remedy. That process has been deeply embedded as a permanent part of LRSD's curriculum program. LRSD has complied with paragraph B of the Compliance Remedy. 21. The requirements of paragraph C of the Compliance Remedy are: C. During each of the next two academic school years (2004-05 and 2005-06), LRSD must hire one or more outside consultants to prepare four (4) formal step 2 evaluations. Each of these step 2 evaluations must cover one of the key  2. 7 programs, as it has been implemented in schools throughout the district. Thus, over the course of the next two academic school years, LRSD must hire outside consultants to prepare a total of eight (8) formal step 2 evaluations of key  2. 7 programs. During the recent compliance hearing, Dr. Ross made it clear that LRSD must conduct these formal step 2 evaluations of the key  2.7 programs in order to continue to make progress in improving the academic achievement of AfricanAmerican students. Again, I suggest that LRSD hire Dr. Ross -- to perform the following tasks: (1) identify the four key 2.7 programs that should be formally evaluated during the 2004-05 school year and the four key  2. 7 programs that should be formally evaluated during the 2005-06 school year; and (2) prepare as many of the eight step 2 evaluations as possible. If Dr. Ross cannot prepare all eight of the Page 9 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 10 of 30 step 2 evaluations, I recommend that LRSD hire someone that Dr. Ross recommends as possessing the experience and ability necessary to prepare those evaluations. 22. In accordance with paragraph C, LRSD hired Dr. Ross to \"identify the four key  2.7 programs that should be formally evaluated _ during the 2004-05 school year and the four key  2. 7 programs that should be formally. F-Y~uated during the 2005-06 school year,\" and to \"prepare as many of the eight step 2 evaluations as possible.\" 23. Dr. Ross was provided a copy of the Compliance Remedy and he endorsed the first Quarterly Update \"as representing an accurate portrayal of accomplishments to date and a viable plan for addressing the requirements of the Remedy.\" December 1, 2004 Quarterly Update, Appendix C (p. 45). Dr. Ross assumed responsibility for preparing six of the required eight formal step 2 evaluations. Three of those cover the 2004-05 school year and were filed on February 6, 2006. Two others are for the 2005-06 school year and will be filed today. The sixth step 2 evaluation being prepared by Dr. Ross, Pre-K Literacy, has been delayed due to the unavailability of necessary data and is expected to be completed no later than November 15, 2006. 24. Two of the required eight formal step 2 evaluations were prepared by Dr. James Catterall. One covered the 2004-05 school year and was filed on Page 10 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 11 of 30 February 6, 2006. The other will be filed today. 25. PRE, in collaboration with Dr. Ross, selected Reading Recovery, Smart/Thrive, Compass Leaming and Year-Round Education to be formally evaluated during the 2004-05 school year. December L: 2004 Quarterly Update, pp. 7-9. Those evaluations have been completed. 26. Dr. Ross initially identified the following four  2.7 programs for step 2 evaluations in the 2005-06 school year: Arkansas A+ School Network; KnowledgePoints; PLATO Leaming and Pre-Kindergarten Literacy Development. June 1, 2005 Quarterly Update, pp. 3-4. At the request of the Joshua Intervenors, and with the agreement of Dr. Ross, 21 st Century Community Leaming Centers was substituted for PLATO Leaming as the subject of an evaluation for the 2005- 06 school year. September 1, 2005 Quarterly Update, pp. 3-4 and Appendix C, (pp. 19-21). KnowledgePoints was also replaced as the subject of evaluation by the READ 180 program because the supplier of KnowledgePoints withdrew its support of the program in Arkansas. December 1, 2005 Quarterly Update, pp. 3-4. 27. Dr. Ross and Dr. Catterall possess the experience and ability necessary to prepare the eight required step 2 evaluations. Their qualifications are found in Appendix C to the first Quarterly Update (pp. 46-54). They are both familiar with the requirements of the Compliance Remedy and have agreed to Page 11 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 12 of 30 prepare their evaluations in accordance with those requirements. LRSD has complied with the requirements of paragraph C of the Compliance Remedy. 28. The requirements of paragraph D of the Compliance Remedy are: D. Each of the eight step 2 evaluatio:q.s must answer the following essential research question: \"Has the  2. 7 program being evaluated improved the academic achievement of African-Americ~ students, as it has been implemented in schools throughout the district?\" The eight step 2 evaluations may also answer as many other research questions as the designers of each evaluation deem necessary and appropriate. Each of the step 2 evaluations must be organized and written in such a way that it can be readily understood by a lay person. I will allow the outside experts preparing each of these evaluations to decide on the appropriate number of years of test scores and other data that need to be analyzed in preparing each evaluation. PRE must: (1) oversee the preparation of all eight of these step 2 evaluations; (2) work closely with Dr. Ross and any other outside consultants hired to prepare these step 2 evaluations; and (3) provide the outside consultants with any and all requested assistance and support in preparing these step 2 evaluations. 29. Each of the eight step 2 evaluations answers the essential research question of whether the program being evaluated improved the academic achievement of African-American students, as it has been implemented in schools throughout the district. Each of the eight step 2 evaluations also answers other important research questions. Each is organized and written so that its findings and recommendations can be readily understood by a lay person. In each case, the outside experts and the evaluation teams determined the evaluation design, Page 12 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 13 of 30 including the appropriate number of years of test scores and other data necessary to the utility of each evaluation. 30. PRE has overseen the preparation of all eight step 2 evaluations and worked closely with Drs. Ross and Catterall, and thos~ associated with them, to support their work and provide any and all requested assistance. See Jun~, 1, 2005 Quarterly Update, pp.6-7; March 1, 2006 Quarterly Update, p. 4; June 1, 2006 Quarterly Update, pp. 5-6; September 1, 2006 Quarterly Update, p. 6 and Appendix A. LRSD has substantially complied with the requirements of paragraph D of the Compliance Remedy. 31. The requirements of paragraph E of the Compliance Remedy are: E. In order to streamline LRSD's record-keeping obligation, I am going to require that each of the eight step 2 evaluations contain, in addition to the traditional information and data, a special section which: (1) describes the number of teachers and administrators, at the various grade levels, who were interviewed or from whom information was received regarding the effectiveness of the key  2. 7 program being evaluated; (2) lists each of the recommended program modifications, if any, that were deemed necessary in order to increase the effectiveness of each of the  2.7 programs in improving the academic achievement of African-American students; and (3) briefly explains how each of the recommended modifications is expected to increase the effectiveness of the  2. 7 program. This requirement is intended to relieve LRSD of any independent record-keeping obligations under  2.7.1 of the Revised Plan and the Compliance Remedy. 32. In accordance with paragraph E of the Compliance Remedy, each of Page 13 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 14 of 30 the eight step 2 evaluations contains a section concerning data collection which describes the number of teachers and administrators at various grade levels who were interviewed or from whom information was received regarding the effectiveness of the program being evaluated. Each of.the ejght evaluations also contains recommended program modifications and explains how the reConm,iended modifications can be expected to increase the effectiveness of the program. See March 1, 2006 Quarterly Update, pp. 4-5. 33. On April 18, 2006, LRSD convened the four evaluation teams which worked on the 2004-05 evaluations to consider the feasibility and the timeframe for implementing the external evaluators' recommendations. June 1, 2006 Quarterly Update, p. 3. A summary of LRSD's commitments to the modifications recommended by the external evaluators is found in Appendix A (pp. 7-11) to the June 1, 2006 Quarterly Update. LRSD will follow the same process of reviewing the evaluators' recommended modifications following receipt of the evaluations for the 2005-06 school year. LRSD has complied with the requirements of paragraph E of the Compliance Remedy. 34. The requirements of paragraph F of the Compliance Remedy are: F. As soon as PRE and Dr. Ross identify the eight  2.7 programs targeted for step 2 evaluations, PRE must notify the ODM and Joshua in writing of the names of those eight programs. In Page 14 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 15 of 30 addition, after PRE and Dr. Ross have formulated a comprehensive program assessment process and reduced it to a final draft, PRE must provide a copy to the ODM and Joshua at least thirty days before it is presented to the Board for approval. I expect the Board to approve LRSD's comprehensive program assessment process no later than December 31, 2004. 35. In accordance with paragraph F of the Compliance Remedy, PRE ..  . notified ODM and Joshua in writing of the names of the eight  2.7 programs targeted for step 2 evaluations. See June 1, 2005 Quarterly Update, p. 8. PRE also provided to ODM and Joshua a final draft of the comprehensive program assessment process more than thirty days before it was presented to the Board for approval. December 1, 2004 Quarterly Update, pp. 6 and 11. The LRSD Board of - Directors approved the comprehensive program assessment process on December 16, 2004, in advance of the December 31, 2004 deadline. March 1, 2005 Quarterly Update, p. 3. LRSD has met the requirements of paragraph F of the Compliance Remedy. 36. The requirements of paragraph G of the Compliance Remedy are: G. PRE must submit quarterly written updates on the status of the work being performed on the four step 2 program evaluations that will be prepared during the 2005-06 school year. These quarterly updates must be delivered to the ODM and Joshua on December 1, March 1, June I, and September I of each of those two academic school years. As soon as each of the eight step 2 evaluations has been completed and approved by the Board, LRSD must provide a copy to the ODM and Joshua. Page 15 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 16 of 30 37. In accordance with paragraph G of the Compliance Remedy, LRSD submitted quarterly written updates to the Court and delivered them to ODM and Joshua on or before December 1, 2004, March 1, 2005, June 1, 2005, September 1, 2005, December 1, 2005, March 1, 2006; June 1, 2006 and September 1, 2006. Those quarterly written updates reported \"the status of the work being performed on the four step 2 program evaluations\" prepared during the 2004-05 and 2005-06 school years. The quarterly updates also provided information on the status of compliance with other components of the Compliance Remedy. 38. As soon as the four step 2 evaluations for the 2004-05 school year were completed and approved by the LRSD Board, LRSD provided t11:~m to ODM and Joshua. Three of the four step 2 program evaluations for the 2005-06 school year will be filed with the Court and provided to ODM and Joshua on October 16, 2006. The fourth will be filed with the Court and provided to ODM and Joshua on or before November 15, 2006. As soon as the four step 2 program evaluations for the 2005-06 school year are approved by the LRSD Board, LRSD will provide final copies of those evaluations to ODM and Joshua. LRSD has complied with paragraph G of Page 16 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 17 of 30 the Compliance Remedy. 39. The requirements of paragraph J of the Compliance Remedy are: J. The four step program evaluations for the 2004-05 school year must be filed with the Court no later than October 1, 2005. The four step 2 program evaluations for the 2005-06 ~choo~ year must be filed with the Court no later than October 1, 2006.   40. The four step 2 program evaluations for the 2004-05 schooi year were filed with the Court on February 6, 2006 in accordance with extended deadlines approved by the Court. Three of the four step 2 program evaluations for the 2005- 06 school year will be filed on today in accordance with extended deadlines approved by the Court. Dr. Ross requires additional time to complete the Pre-K Literacy evaluation because of the delayed availability of necessary testing data. LRSD has requested an extension of time for the filing of that step 2 evaluation to aJ?:d including November 15, 2006, and expects to file that evaluation by that date. LRSD has substantially complied with paragraph J of the Compliance Remedy. 41. The requirements of paragraph K of the Compliance Remedy are: K. On or before October 15, 2006, LRSD must file a Compliance Report documenting its compliance with its obligations under  2.7.1 of the Revised Plan, as specified in this Compliance Remedy. If Joshua wishes to challenge LRSD's substantial compliance, they must file objections on or before November 15, 2006. Thereafter, I will schedule a compliance hearing and decide whether LRSD has met its obligations under the Compliance Remedy and should be released from all further supervision and monitoring. Page 17 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 18 of 30 42. LRSD is filing this Compliance Report on October 16, 2006 in accordance with paragraph K of the Compliance Remedy and the Court's July 12, 2006 letter to the parties ( docket no. 4027). WHEREFORE, for the reasons set forth above and in the eight Quarterly Updates which have been filed with the Court, and on the basis of the completion of eight step 2 program evaluations by Drs. Ross and Catterall, LRSD prays for an order finding it to be in substantial compliance with the Compliance Remedy contained in the Court's June 30, 2004 Memorandum Opinion, declaring LRSD to be a unitary school district, and releasing LRSD from all supervision and monitoring by the Court. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) Khayyam M. Eddings (#02008) 400 West Capitol, Suite 2000 Little Rock, AR 72201-3493, (501) 376-2011 Isl Christopher Heller Page 18 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 19 of 30 CERTIFICATE OF SERVICE I certify that on October 25, 2006, I have electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which shall send' .. \" notification of such filing to the following: mark.hagemeier@ag.state.ar.us sjones@mwsgw.com sjones@jlj.com johnwalkeratty@aol.com and mailed by U.S. regular mail to the following addresses: - Gene Jones Office of Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Clayton Blackstock Mr. Mark Burnett 1010 W. Third Street Little Rock, AR 72201 Judge J. Thomas Ray U.S. District Courthouse 600 West Capitol Avenue, Suite 149 Little Rock, AR 72201 Isl Christopher Heller Page 19 of 19 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 20 of 30 Career ObJecttve: Pnd'euJonaJ Experience: 2004-PIOSCD! 1998-Proent Edacadon: Danyell Crufchffeld CuDIIDIDil S Bm Hopn Cove Little Rock. ArbDIU 7211G {501) 407-8497 (501) 447-1737 To utillzo proven academic and profoaiOJW oxpienco to obtain a . : , chUcrnging po1itioa as an admiailltrator that will allow fer growth and an opportuni1)' to contribute to . proareqivo educatiooal environmcm. High Schools That Wo'fk Ccordinafor J. A. Fair Sytcml Magnet Higb School Little Rock. Arbmas 72210 Randy Rlahc,dord, Principal Bqliah Tcadior 1. A. Fair Symim Masaet Hi\u0026amp;h Sohool Little .Rookt Arbnsu 72210 Randy Ruthafo:d, Principel May, 2005 Educational Specialist, Educ.atiou.l Administration and Supcmion, University of .Amnsas at Little Rock Docomba', 199! Muter of Education, Scoondary Edue\u0026amp;tioo. Univel'lfty of Aibmal at Utde Ro\" May, 1997 Bichel of Ans, English, Univc:rafty of Arlamsu at Little Rook ProtN.lloPally .R.elattcl .Acdvitfa: Actina Aasiatant 'Principal Scetioa 504 Coordinator Council ofSecondaey Edacatlon Slakcbolder Southern Realoaal Education Board U\u0026amp;eracy Team mombcr Teacher oftbe Year Bdu(lational Spul!st Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 21 of 30 ----- -------- ..  --- --. -. - Refcreuca: Linda Young Granta Coo.rdilultor (501) 447-3372 work (501) 225-$439 home Till Brooks Principal David O'Dodd Bl.cmcutary (501)447-4300 work (501) 680-3767 home William Broadnax, Ed,D -Student Hearillg . (SO]) 447-3582 work (501) 4070817 homo Sharon Cawcy, EdJ\u0026gt; Assistant Prin0ipal  1.A. Fair Syscems Magnet High School (SOl) 447-1700 ~ 1710 work (501)6~6-6216 homo Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 . Page 22 of 30 -------- \"------~----------- Educailon: DaayeU Crutchfilld Cummlap 5 Bea Hogan Cove Llttle Rock, Aruu,u 72210 (501) 407--8897 (501) 447-1737 To utilize proven academic and p-ofossional cxpericncc lo obcain a   ' challenging position u an administrator that will allow (or growth and an opportunity to contnl,utc w a pl'OjJ'Cluivc educational onvinimncut. High Schools That Work Coordinator 1. A. Pair Sy1lcms Mapet Hlgb School Little Jlgok, Arb.mu 72210 Randy Rutherford. Principal EnsJish Tcachet J. A. Fair Syn:ms Magnet Bish School Littlo Rode, Arwsu 12210 Randy Ruthcrford,_Priuclpal May, 2005 Educational Spec!llist, Educational Administration and SUpezviaio,; University of Arbnsa1 at Little R.oclc D'\"mber, 1998 , M..t ofBducatioa, Sooonday ROJCation, Univonlty of Arbasas at Little Rook May, Im Bachelor of Art,, Bnglllh, l'rvleu!onaDy Rtlated ActMtlu: University of Arkansai at Little Rode ActiJJa Auismit Prillcipll Section 504 Comlioator Couocil of Secondary Education S1akcboldet Southom Regional Bducatioa Board Lkenlcy Team member Teacher oflhe Year BduoadOllll Spoclalist Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 23 of 30 __ .. ,, .. ---- llercraca: LindaY01111g Gram Coordinator (501) 447-3372 work (501) 225-5439 homo mi Brooks PrincJpal David O'Dodd Elementary (-'01) 447-4300 work (501) 680-3767 home William Bt0adnlx, Bd,D Student Hearinl (501) 447.3532 work (501)4-07.0817 homo SbaroD Cauley, Bd.I) Aasiatant .Principal J.A. Fair S)'ICcml ~ot High School (501)4471700 c:xt. 1710 W0C'k (SOI) 666-621.6 home Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 24 of 30 Bl Platform Little Rock School District Business Objects Reporting Tools Business Objects Enterprise is a scalable, adaptive platform that delivers insight and corporate infonnation to all your end users. With a platform designed to help you confidently deploy and manage your Business Intelligence (BI) implementations, Business Objects provides the Little Rock School District with the extreme insight you need to extend your competitive advantage. The Bl Platform provides a set of common services to simplify deployment and management ofB[ tools, reports, and applications. The reporting system at the Little Rock School District includes infoanation delivery in subject areas including Student Demographics, Student Performance, Budget and Finance, Employee Attendance, Child Nutrition, Human Resources, Accounts Payable, Payroll, Procurement, and Procurement Warehouse, to name a few. Flexible Services-Oriented Platform By building the Little Rock School District's BI solutions with Business Objects Enterprise, we have the flexibility to deploy a solution for a single infonnation challenge, while being able to simultaneously expand the deployment as our needs evolve. Designed for Scalability aod Hlgll Performance Business Objects Enterprise is designed for scalability, reliability, fault-tolerance, extensibility, and 24n availability. This platfonn recognizes the importance of diverse global deployments, supports Unicode, and is compliant with Microsoft Windows, Sun Solaris, mM AIX, HP-UX, and Linux. So you can start with a single BI project on one platfonn, and easily grow to support an enterprise-wide standardization initiative on multiple platfonns. With BI content now being delivered via intranet and extranet, BI platfonn scalability .is a key issue. Business Objccta Enterprise has the scalability you need to accommodate increasing numbers of users, process growing volumes of infonnation. and scale on a single machine-or clusters ofmachineswhile maintaining high performance. Proven RellabUlty This platfonn's key attributes-performance, reliability, and scalability-are proven by extensive, real world testing and third-party certification. Enterprise is the only BI platform to achieve Microsoft Windows 2003 Datacenter certification. Business Objects Enterprise- covered by a 24/7 technical customer support-has demonstrably installed and run on a 32-processor system, remained stable through rigorous stress testing, and stayed available after being subject to extensive failover conditions. We also continually conduct extensive benchmarking and perfonnance testing to ensure our platfomi _:_:_~_/'/i_~_m_ee_t_th_e_n_ced__o_f_th_e_Li_tt1_c_R_oc_k_S_c_hoo_l_D_is_tn_c_t-to_da_y_an_d_to_m_o_rr_o_w_. ___,.( _I _B _EXHI_M _r ) Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 25 of 30 Reporting Fundamentals The fundamental requirements of any reporting system arc a normalized database and a reporting tool. Data from disparate systems and formats is collected in a centralized database platform and transformed into a consistent, well organized reporting database. Many reports have been created and delivered from this reporting database using Crystal Reports as the reporting tool. Nonnalized Data This data. securely housed at the Little Rock School District Technology Center, has been nonnalized to 3rd nonnal form on a Microsoft SQL Server database server. The original database management software is DB2 residing on an IBM AS/400 application server, which houses a majority ofti,.e studentbased data. Other student data resides in Microsoft Access or is provided to the CIS department via Microsoft Excel spreadsheets. Automated processes have been developed and scheduled to update the student data nightly, where required. Processes have also been designed and implemented to update data in key financial, human resources and accounting subject areas. Business Objects provides the industry's leading suite of integrated business intelligenco products. The products are categorized into three groups: Reporttnz aUows all levels of the Little Rock School District to access, format, and deliver data as meaningful information to large populations of information consumers like teachers and school administrators both inside and outside the organization. This is provided through detailed reports created using Crystal Reports and accessed via a web browser using the Business Objccta Enterprise Info View application. Query and Analysis tools allow end users to interact with District infonnation and answer ad hoc questions, without advanced knowledge of the underlying data sources and structures. This is provided through a product called Web Intelligence or WEBI. This allows users to create dynamic reports from their desks with little or no required .knowledge of the underlying database schema. In-depth analysis is pcrfonncd using OLAP Intelligence, a powerful OnLine Analytic Processing tool that provides detailed, fast, multidimensional data for sophisticated comparative analysis and reporting. Performance Management products help users align with strategy by tracking and analyzing key business and educational metrics and goals via management dashboards, scorecards, and alerting. This is provided through Perfonnance Manager and Dashboard Manager products that present Key Performance Indicators in user-friendly, interactive graphical tools. CrystaJ Reports A world standard for enterprise reporting, Crystal Reports is an intuitive reporting solution that helps customers rapidly create flexible, feature-rich, high-fidelity reports and tightly integrate them into web and Windows applications. The Crystal Reports enterprise reporting solution consists of: LBSDB/To1 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 26 of 30  Powerful report design: Report authors can use the visual report designer (with a complete set of layout and design controls), to design highly formatted, interactive, and professional-looking reports. And they can dciign within the leading .NET and Java development tools without having to step out of their chosen development environment.  Flexil\u0026gt;le application development: Developers can leverage crossplatform support for Java, .NET, and COM development technologies. HTML is generated directly by Crystal Reports, allowing developers to focus on application business logic, rather than tedious, time-intensive hand coding. Separation of application development and report design tasks allow developers to focus on application development, while the report authors can focus on report design.  Report management and delivery: Reports arc easily published to the web, for better busip.ess decisions in all areas of the Little Rock School District Reports can be e,cported and repurposed to the electronic formats used by most end users (e.g. PDF and Excel). IT can centralize the management of operational reporting while distributing the report authoring function out to departments of the District that need them. The following themes are an overview of what features are available in Crystal Reports XI:  Powa-ful data access and report design  Enhanced productivity and maintenance  Report management and delivery Dynamic apd Cascading Prompts Report prompts can be based on dynamic values. This means that report designers no longer have to maintain natic prompt value lists within individual reports. Instead, they can reuse existing prompts stored in the repository. HTML Preview The iterative report design/view process is streamlined, with a new HTML preview that allows report authors to sec how reports will look when published to the web. Editable RTF Format This new feature is ideal for report export editing. It delivers reports to end users in a new RTF format, so they can easily ma1ce their own document modifications. Report Ewort Copflguntlon . The report designer can save report export configuration infonnation within the report itself so that the end user forgoes the time and trouble of reconfiguring the export each time a report is run. Dependency Checker With the new dependency checker, report authors can quickly find broken links, formula cm\u0026gt;rs, and dependency i,sues. Thia greatly reduces the time spent on QA. Buslness Views Speed Report Design and Maintenance Cycles Crystal Enterprise Business Views helps you better manage reporting across multiple data soun:es and applications by simplifying data access, change management, and data-level secwity processes. An LIISD Bl Tool# Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 27 of 30 optional sc:rvicc in Crystal Enterprise, Busim:ss Views aUow you to integrate data from disparate sources, handle promotion/demotion between development and production environments, and control security at both the row and column level. Simplified Data Access Data access is one of the most fundamental, yet difficult aspects of designing a report. Locating the right data, joining tables appropriately, and filtering the data to focus on a specific subject area requires an indepth knowledge of the underlying data structures. The Business View Manager allows you to simplify data access for your report designers by ~ulating them from the raw data structures. You can build connections to multiple data sources, join tables, alias field names, create calculated fields, and then surface this simplified structure as a Business Viow in Crystal Enterprise. Your report designers can then connect to Crystal Enterprise and use the Business View as the basis for their report, rather than accessing the data directly and building their own queries. Business Views helps administrators pull data together from disparate sources. Data Conncctipns (created visually or with complex SQL statements) can be integrated into a Data Foundation. Once the Data Fo1D1dation is built, Business Elements (a collection of related fields from the Data Foundation) can be created and combined into a Business View. The modular architecture of Business Views also allows you to readily ro-use various components of .one Busmcss View to build other Business Views. A single, broad data foundation can acrve as the basis for multiple, specialized Business Views. Used carefully, these capabilities allow you to minimize the number of changes required to introduce new data, fields, or formulas into your system. Granular Data-level Security Many reporting scenarios involve complex security requirements. Each user is entitled to see a slightly different slice of District data, based on their School, Department or level of seniority. Data in the Little Rocle School District is commonly segregated by School and Teacher-based information. Business Views allow teachers to view data regarding their students and prevents them form seeing data regarding students that arc NOT assigned to them. Rather than creating a number of diff ercnt reports to meet this need, we can create a single report and use the security features ofBusiness Views to filter data appropriately for each user. Using the Business View Manager, you can set up row- or column-level filters aIJd map these filters to users or user groups stored in your existing LDAP, Active Directory, or Windows authentication provider. This security is then consistently applied at the data level, ensuring that any report de.sign based on a Business View will respect tho underlying data security. You can then choose to schedule the report to run regularly. Or you can allow users to refresh it on demand. Regardless, Crystal EntCIJ)rise can generate a master instance of the report (with all the data included if you run the report under an administrator e-0ntext) and then filter the report every time a user views it All exporting, printing, and report modification requests will also return only the data the user is entitled to see. UISDBITPou Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 28 of 30 Change Management and Re--use Maintaining a large set of reports is often more time-conswning and complex than new development. Activities such as making small changes in response to user needs, updating business calculations, cluipging fonnatting, and moving your reports between development and production data sources all delay you from addressing new requirements. Business Views includes two key features to help you spend less time on report maintenance. First, you can use Dynamic Data Connections to store connections to multiple instances qfthe same database (e.g., development, test, and production). By passing a parameter when you're designing (or scheduling) the report, you can select which data source the report runs against. Second, you can store ~nly-used functions, text objects, and logos directly in your data foundation. This allows you to easily roll changes across multiple reports by changing the object once. Business Objects .Enterprise InfoVfew Business Objects Info View is a completely redesigned web interface that enables user to navigate, create, and interact with District information. Integrated search and navigation tools allow users to easily find the infoID1ation they need. Users can also personalize their interactions to simplify consumption of District infonnation. Info View is built to support Java and Microsoft based web servers, to easily fit within you're the Little Rock School District IT infrastructure. Web lntelllgence Many organizations find it difficult to access information not contained in standard reports. And reque\u0026amp;ts to IT for new infonnation simply add to the report backlog. Even when ad hoc query capabilities are available, they're typically difficult to use and don't provide your non-technical users with a simple method of exploring information, to really understand the business issue at hand. With Business Objects Web Intelligence, both self-service access to information and data analysis are available in one product, helping your users tum educational analysis into effective decisions. Users can create a query from scratch, format the infonnation retrieved. and analyze it to understand underlying trends and root cawes. If the full power of query capabilities is not required, users can simply analyze information in existing reports-fonnatting and exploring them to meet specific needs. OLAP lntellf gence Busin=is Objects OLAP Intelligaice is a powerful and easy-to-use tool that allows you to access and analyze data stored in the leading OLAP servers. It uniquely satisfies the analysis requirements of both information analysts (power users) and less sophisticated knowledge workers (business users). With OLAP Intelligence, power users can slice and dice, drill, rank, sort, filter, create calculations on the fly, and perform. speed-of-thought data exploration. And business users can interact with pre-built OLAP workbooks that contain highly intuitive, graphical views of educational activity, guided navigation and worktlows, and flexible ad hoc analysis. Its advanced amlysis capabilities, shared security, and relational drill-through allow you to standardize on Business Objects for all of your BI needs. OLAP Intelligence delivers:  Best-of-breed ad hoc OLAP  Managed OLAP authoring and distribution  Integration with the market leading, trusted BI platform I.RSD II Tool, Pq,So/7 Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 29 of 30 Best-of-Breed Ad Hoc OLAP . The primary driver for implementing an OLAP database is to provide users with fast access to multidimensional data. IT develops focused OLAP cubes to provide users with a structured data environment, optimized for analysis. But in order for users to take advantage of the pre-aggregated data within an OLAP cube, they require an interface that allows them to drill, slice, and dice while leveraging the response times that the predefined OLAP cube environment offers. Speed-of-Thought Analysis QI.AP Intelligence provides an intuitive, web-based interface that allows users to selcct-dimep.sions and members from a query panel as well as perfonn similar analysis from integrated Windows, Microsoft Excel, and ActiveX client interfaces. Users can interact with their data and ask spontaneous questions to uncover trends and identify anomalies. And because OL.AP Intelligence takes advantage of the power of the OLAP cube, users are guaranteed speed-of-thought response time. Intuitive, Function-Rieb Interface The OLAP Intelligence interface is both intuitive and function-rich. Common functions such as ranking, filtering. highlighting, quick calculations, zero suppression, and axis swapping are available with a single click of the mouse. More advanced analyses are only a few mouse clicks away and provide an 1D1cluttered, intuitive user interface that requires minimal training. With OLAP Intelligence, users can also asymmetrically display data and hlde specific dimensions that are irrelevant to data exploration. Deep. Open Access to Microsoft, Hyperion, and SAP OLAP Servers With OLAP Intelligence, you get best-of.breed, ad hoc OLAP for today's leading, multidimensional database servers-Microsoft SQL Server Analysis Services, Hyperion Essbase, WM DB2 OLAP, and SAP BW. For example, native Hyperion Essbasc 7.x support for free-form calculations and cube actions means that organizations are maximizing their OLAP server investments and taking advantage ofkey enhancements and optimizations. Managed OLAP Authoring and Dlstn'\"bution OLAP Intelligence goes further than most OLAP clients on the market today by not only providing powerful ad hoc analysis, but also delivering a flexible, managed OLAP environment. With OLAP Intelligence, you can easily create sophisticated workbooks that exploit the power of the underlying OLAP server, and enable users to build in predefined navigation paths and worldlows, Then you can securely deploy and deliver the workbooks live to business users who don't necessarily fit the powerdata analyst profile. These OLAP workbooks may contain custom buttons and multi-page reports that recipients can view and interact with over the web. Publish Live OLAP Workbooks to B.usJoess Users When users view an OLAP Intelligence workoook over the web, it may appear as a dashboard with custom functionality specific to one area of the business, or as an ad hoc interface that allows them to perfomi advanced analysis. Because OLAP Intelligence has a flexible design and was created to meet powezful ad hoc and managed analysis needs, the deployment possibilities are limitless. Built-In Guided Navigation and Data Emloratlon LJISD BJ TOIIU Case 4:82-cv-00866-WRW Document 4055-1 Filed 10/25/2006 Page 30 of 30 With OLAP Intelligence you can guide users through the OLAP data navigation and exploration process. For example, a user can highlight a group of cells in a report, click a custom analysis button, and view a new graph that has drilled down on the chosen group, displaying variances as a worksheet and chart. A show trend analysis button could then be made available that displays a new page in the workbook with a year-over-year comparison. Open drill-through capabilities in OLAP Intelligence empower users to drill from aggregated OLAP data down to relational details. This means that usen can navigate and exj:)lore-.summariz.ed infoonation, and drill through and pass context to more detailed Crystal Reports or Business Objects Web Intelligence documents. This contextual drill-through technology provides users with intelli~t navigation without the need to understand the complexities of widerlying data and metadata structures. LRSDBJTooJ, l'qa7o/7 uFILi=o -.-, E4sret DISrRt~ co   .: IN THE UNITED ST A TES DISTRICT COURT DISTRICT AA~SAs -} EASTERN DISTRICT OF ARKANSAS 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  DCT27 2CQ; .: JA~ M By~\u0026lt;~~~~.gL,,_ ~AINTIFF\"2:Jge',i, DEFENDANTS INTERVENORS INTERVENORS Before the Court is the request of the Magnet Review Committee (\"MRC'') for approval of the interdistrict magnet schools' final figures for the 2005-2006 school ~ear and proposed budget for the 2006-2007 school year. The MRC communicated the budget to the Court in a letter dated September 28, 2006 ( attached). I have attached a copy of the budget to this order, and ifthere are any objections, parties must respond within five days; otherwise, the MRC's final budget for the 2005-2006 school year and proposed 2006-2007 budget will be accepted as presented and become effective immediately. IT IS SO ORDERED this~ay of October, 2006. A1~  -:::::::;;2.-\u0026lt;---- ~ DISTRICT JUDGE Magnet Review Committee 1920 North Main Street, Suite 101  North Little Rock, Arkansas 72114 (501) 758-0156 {Phone} (501) 758-5366 {Fax}  magnet@magnetschool.com {E-mail} September 28, 2006 The Honorable W11Iiam R. Wllson. Jr. Judge, U. S. District Court Eastern District of Arkansas 600 West Capitol Little Rock, AR 7220 I Dear Judge Wtlson: On September 26, 2006, Marte Milhollen, Chief Financial Officer, Little Rock School District, provided the Magnet Review Committee with the actual expenditures for 2005-06, as well as the proposed budget for the 2006-07 school year. The information is contained in the attachment (Draft 2) and was presented to MRC members for their review on Tuesday, September 26, 2006. The Magnet Review Committee, by formal motion and vote of 6-0, approved the final budget (actual expenditures) for the 2005-06 school year but are withholding their vote for approval of the proposed 2006-07 budget until all parties have been given the opportunity to review the proposed budget. The Magnet Review Committee has scheduled their next meeting for October 17, 2006 to vote on the proposed budget at that time. Listed below is a recap of the budget information which is now being presented to the Court for approval: FINAL 2005-2006 STIPULATED ORIGINAL MAGNET SCHOOLS BUDGET The total amount originally budgeted, $28,849,578 .00, was based on a per-pupil expenditure of$7,468.00, calculated from a projected three quarter average enrollment of 3,862.90 students. Once the actual attendance (3,831.12) and expenditure ($29,224,702.00) numbers were determined, the final per pupil amount was calculated to be $7,628.00, which was $160.00 more than originally budgeted. This increased cost is primarily attributable to the adjustments in the school funding formula as a result of the recent Lakeview decision. A Funding By Source schedule is shown on Page 2 of the attachment presenting the costs allocated to each of the four ( 4) parties. \"Pursue the Possibilities of Magnet School Enrollment\" The Honorable William R. Wilson. Jr. September 28, 2006 The Magnet Review Committee respectfully requests the Court's review and approval of the 2005-2006 finalized budget in the amount of $29,224,702.00, with a per pupil expenditure of $7,628.00, attached herewith. Even though the budget Draft 2 contains figures for the proposed 2006-2007 budget, the Magnet Review Committee is not asking the Court's approval at this time. The proposed 2~2007 budget will be submitted to the Court after representatives ftom each party bring their recommendations to the Magnet Review Committee meeting on October 17, 2006.   .. , The Magnet Review Committee is committed to maintaining the quality of the Stipulation magnet schools. We will continue to work with the host district as we exercise stringent oversight of the magnet schools' budget in an effort to achieve and ensure efficient management and cost containment to the greatest extent possible. Sincerely, ~~ Sadie Mitchell, Chairperson Magnet Review Committee SM/DGC:sJ Attachment: Final 2005-2006 Stipulation Magnet Schools Budget Actual Expenditures (Draft 2) -..oc: Office ofDesegregation Monitoring Magnet Review Committee '.:- : ;;:~r~;..;1~:[~~~:m ~~~:~v~r:~ti:m 1:r:~~ !~~~~~m~: CERTIFIED 01 Principal 6.0 $577,006 $590,057 6.0 $605,528 STAFF 02 Asst. Prin. 10.0 $704,187 $719,586 10.0 $739,257 03 Soecialists 40.2 $2,060,208 $2,095,071 40.2 $2,178,546 04 Counselors 13.5 $745,758 $755,548 13.5 $819,990 05 Media Spec. 6.5 $333,386 $342,566 6.5 $369,766 06 Art-Perf./Prod. 3.0 $135,929 $138,721 3.0 $147,146 07 Music 0.0 $0 $0 0.0 $0 08 Forei~in Lanq. 0.0 $0 $0 0.0 $0 09 Vocational 7.9 $442,679 $452,002 7.9 $506,912 10 Soecial Education 15.5 $621,519 $624,198 16.5 $700,071 11 Gifted 5.4 $296,023 $302,527 6.4 $353,735 12 Classroom 202.9 $9 892,360 $10,105,508 201 .9 $10,247,836 13 Substitutes o.o $293,000 $347,950 0.0 $310,000 14 Other-Kindergarten 15.0 $729,204 $782,522 15.0 $772,934 TOTAL CERTIFIED SALARY 325.9 $16,831,258 $17,256,256 326:9 $17,751,721 SUPPORT 15 Secretaries 21.4 $621,784 $640,002 21.4 $686,358 STAFF 16 Nurses 6.0 $273,520 $280,670 6.0 $292,918 17 Custodians 28.9 $572,555 $576,668 28.9 $612,444 18 Information Seivices 1.0 $65 554 $66,547 1.0 $68,780 19 Paraorofessionals-Other 4.0 $176,869 $182,943 3.0 $163,884 20 Other-Aides 26.0 $490,064 $474,617 28.2 $560,984 21 FrinoeBenefits(20 \"' $0 $5,189,424 '''''' \"'  $5,830,809 TOTAL SUPPORT SALARY 87.3 $7,744,958 $7,410,871 88.5 $8,216,177 TOTAL(10-20l ,    ,,,, ,,, $24576,216 $24,667,128  $25967,898 PURCHASED 22 Utilities ' -- .,., $ 589 700 $ 719,885 .,., ., \" ,, , ' $798 500 SERVICES 1-2::::3:-+.:T:-\"ra\"'\"v\"\"'e:-\"I- -------fiii.:. i.'m- \"m:~: /  $ 40,000 $ 46,655 ' .. , ., , ., . $35,500 po) 24 Maintenance Aareements . ~ - _:, $0 $0 , --~ ,. .... , $0 MATERIALS, SUPPLIES (40) ' CAPITAL OUTLAY (50} OTHER (60) 25 Other '  ' $ 285 368 $ 259,970 '-' \" ,, :: ' $237, 130 TOTAL(30) 26 Princioal's Office 27 Regular Classroom 28 Media 29 Other TOTAL(40) 30 Equioment 31 Buildina Reoalr etc. 32 Other TOTAL (50) 33 Dues and Fees 34 Other -. . $ 915,068 $ 1 026510 \"\"'':'\"''\" $ 1071,130 ;:~ : !~:E~ : a:::E ltll s::~:~ ., ._,, ,, ''  $ 24,273 $ 27,819  .\";w. '. $ 28,873 \"'\" $ 881,653$ 916,962 ''.:' . . , .... '. $ 749,125  , \" $ 70,315 $ 215,126 :--,. ' ' $ 57 200 ,  . , . , '' '' $0 $0 .,  , ... , '' '\" . $0 ., ....... ... , ., $0 $0 .,,. ,, $0 '.\"''\" .: , \";\" $ 70,315 $ 215,126 : $ 57,200  : . ,.,, , $ 7,800 $ 3,390 , $ 4,856 .. ,., '  . - . $0 $0 ' '  \"., ....... ' $0 TOTAL (60) '' .,., \"'  ,,.,, $ 7,800 $ 3,390 \"\" \"\" \"'  $ 4,856 TOTAL (30-60) =-~,~t- ~r ~i  - $ 1,874,836 $ 2 161 988 S 1,882,311 TOTAL (10-60} 413.1 $ 26,451,052 $ 26,829,116 415.3 $ 27,850,209 ro.TAL LINE ITEMs ttl~~~!~=~irAU\\llt~l~Ji,fJ:: - ri,: 1111~~:;i:~;:: i1:;:it1:iJ;: 1:;;;,;, ,.,  :?::;::: r: mi~~i:,i MAGBK07A ~i,i~ijf~ttt'hJ,~f,',f~J iftte.1Q~1stl ~if #fJf4t~Iit;l~:tl~ ij~f : .' :~~~:.:, ,,,. ,'ij ~rb:fi;iai,Vk~ii~~~I~tm4ll~l~t~~-i~ 2005-06 2005-06 2006-07 Stipends $29,600 $52 951 $41,250 Other Obiects $0 $0 $0 Indirect Costs $2,194,000 $2 227,287 $2,312,522 Vocational $32,800 $32,712 $32,800 Athletics $101,626 $60,936 $65,799 Gifted Proorams $500 $500 $500 Plant Services $32,000 $13,201 $32,000 Reading $500 $500 $500 Science $0 $0 $0 English $1,500 $1,500 $1.500 Soecial Education $4,000 $4,000 ~ .000 Curriculum $2,000 $2,000 $2,000 )00()()()( )()()()00( Total Line Items $2,398,526 $2,395,586 $2 492,871 Rii.!;:_ : .:~t~~~-i li~P~t -_' .. : .}  ..:~ ~!~ ,862.90 3 3,831.00 E~~J~'.B~'.~~i~!$(1!~liji ~1~.t~~~'f.\\i~r, rb':iiM~af.lJt,11i): f~Ji:ieffi'~ ~l~ $'.!i~m'.Billl.:!J,~tt1~:if~~~!~i)]@!)~. 2005-06 2005-06 2006--07 Slate of Arkansas $14 424 069 $14,611,930 $15,171,275 LRSD $9,248,057 $9,260,815 $9,614,975 PCSSD $3 443,532 $3,567,768 $3,704,342 NLRSD $1 733,920 $1,784,189 $1,852,488 Total Costs $28,849,578 $29,224,702 $30,343,080 MAGBK07A - t0~~1J~ l~l~~t(~S~h}fm! O!t~t~fsll.t:i~ (i'.,i${%\\:.t; 1!:l';b,,6~~ ~~~i~{ij)pt(l~}\\,fmfi _ ;.,p.r.~ei~t1ik~i~~~iw JWt~~~a~Ht.;}:a,, ~tf'~I::~ r~~~ffiJ.tiojii1:iJtttJ CERTIFIED 01 Principal 1.0 $ 93,186 $ 95 068 1.0 S 97,930 STAFF 02 Asst. Prin. 1.0 $ 70,837 $ 72,120 1-0 $ 74,401 03 Specialists 8.0 $ 405 782 $ 419,228 8.0 $ 434,292 04 Counselors 2.0 $ 107,304 S 109,708 2.0 S 115,886 05 Media Soec. 1.5 $ 59,967 S 67,117 1.5 $ 70,377 06 Art-Perf./Prod. 0.0 0.0 07 Music 08 Foreign Lang. 0.0 0.0 09 Vocational . 0.0 0.0 10 Soecial Education 1.0 $ 51,587 $ 52,678 1.0 $ 11 Gifted 77,720 $ 78,956 1.4 $ 12 Classroom 937,752 $ 949,474 21 .5 $ 13 Substitutes $ 38,000 s \"45,797 0.0 $ 14 other-KinderQarten 246,467 $ 254,281 5.0 S TOTAL CERTIFIED SALARY $2,088,601 $2, 144 426 42.4 SUPPORT 15 Secretaries 82,152 $ 84,582 3.0 $ STAFF 16 Nurses 41,328 $ 42,204 1.0 $ 17 Custodians 75,503 $ 74,193 4.0 $ 18 Jnfonnation SeMoes 10,928 $ 11 ,093 0.2 $ 19 Paraprofessionals-other $0 $0 I 0.0 20 other-Aides 97,165 $ 92,145 5.2 $ 21 708,611 $ TOTAL SUPPORT SALARY 13.2 $1 ,015,687 $1,009,939 13. TOTAL(10-20) '\" ,,,. $3,104,289 $3,154,365 ., ... , ._,._, 58,500 $ 7,000 $ $0 PURCHASED Z2 Utilities  .. $$ 69,185 ,, \" .,. ,~ $ SERVICES 23 Travel 14,276  ,.,. ,. \"  $ (30) 24 Maintenance Agreements $0 .,, ...... '.\"'.  25 other . . : _. $ 30,013 $ 29,566 ., .,,, '  - $ TOTAL(30) ' , ' $ 95,513 $ 113,027 _,,., ,, ., $ i--,-MA-:-:-::TE=R.,.,IAL,..,..,,S,.., ..,...,26=-t::p,-ri,..nci\"\"'i-p,a\"\"'r,..s-=o\"'ffi:-ce-\"-''--~----m! $0 ;, '\"~\":'. : . SUPPLIES 27 Reqular Classroom \" . -~ $ (40) i-;2~8+M;;;edw,;i;.;;a:;;,_;;==~----f,, ~;r.,;,-t: '. $ 29 other '.' :', ... . '\"' $ CAPITAL OUTLAY (50) OTHER (60) TOTAL (40) 30 Equipment 31 Building Repair, etc: 32 other TOTAL(SO) 33 Dues and Fees 34 Other TOTAL(60) TOTAL (30-60) TOTAL (10-60) TOTAL LINE ITEMS - (SECOND PAGE) .,,,.,,.,-,: :': : ', $ __ ,,; ._,.,,,., $ ,.: ; P'V ;.,, . . ~ ....... ..  .. ,. -; .. , ... ,,,, $ :ii,;,}~ $ ,, ,.,,., ,, '. $ 55.6 $0 77,500 7,500 3,125 88,125 8,500 $0 $0 8,500 1,000 $0 1,000 $193,138 $3,297,427 $293,462 $ $ $ $ $ $ $ $ 77,766 '\" '.:'/\"? '' $ 4,915 . ,, $ 4,206 ,_::: .... :. $ 86,888 \"  \"   $ 2,747 '.  ::''.' $ $0 : ,:: ' ' '' $0 .... ,, -\",, ,; 2,747 .: .. : ' __ ' $ 680 , , . '.',' ' $ $0 ::\"'~ -~, 680 :~:'.'. ' \" ,,,. $ $203,342  ' ,... ,. '. ' $3,357,707 55.8 $298,017 ,,,, ................ ,,., 55,473 82,401 912,879 45,000 282,919 $2,171,558 89,904 44,784 81,606 11,466 $0 102,011 739,450 $1,069,220 $3,240 778 75 800 5000 $0 20,113 100,913 $0 87,057 5,500 3,827 96,384 6,000 $0 $0 6,000 1,000 $0 1,000 $204,297 $3,445,075 $314,693 ~ ~~l~*r,{l~~fifi';t.'t{~,,~m~1t 2005-06 2005--06 2006--07 Stipends $4,250 $5,336 $8,750 Other Obiects $0 $0 $0 Indirect Costs $283,903 $269,788 $300,610 Vocational $0 $0 . $0 Athletics $0 $0 $0 Gifted Proarams $133 $134 $134 Plant Services $4141 $1,716 $4,160 Reading $85 $65 $85 Science SO $0 SO Enqlish $194 $195 $195 Special Education $518 $520 $520 Curriculum $259 $260 $260 )00()()()( XXXlOOC Total Line Items $293,462 $298,017 $314,693 655 724 $3,759,769 - ~ -ffC!~~$jI 1:tit~~1ff'l)${11JirmwR IJtil'~llU@J~m,;:~;f))i ]1!'.~ ~ i. ii~~}~'M1rrt~~~ - WF;tTs~ ri \\7,~~~~ri;,'p~~t{1I1tmmt~iiU\\tm,f\u0026gt;f~ 'i'*~i1:~ ~g~P,ffi~mi$ CERTIFIED 01 Principal 1.0 $ 93,172 $ 96,557 1.0 $ 97,781 STAFF 02 Asst Prin. 0.0 $0 $0 0.0 $0 03 Specialists 6.8 $ 329,753 $ 291,812 6.8 $ 330,833 04 Counselors 1.0 $ 53,465 $ 56,201 1.0 $ 57 448 05 Media Spec. 1.0 $ 61,583 $ 63 000 1.0 $ 64,947 06 Art-Perf./Prod. 0.0 0.0 07 Music 0.0 o.o 08 FOfeign Lang. 0.0 0.0 09 Vocational 0.0 0.0 10 Special Education 1.5 $ 68,322 $ 69 765 1.5 S 73,956 11 Gifted 1.0 $ 54,561 $ 55 932 1-0 $ 57,557 12 Classroom 16.2 $ 728,828 $ 719,117 152 $ 703,820 13 Substitutes 0.0 $ 28000 $ 27,763 0.0 $ 25000 14 Other-Kinder\u0026lt;1arten 2.0 $ 105,715 $ 106 393 98,338 TOTAL CERTIFIED SAL.ARY 30.5 $1,523 399 $1486541 $1,509,680 SUPPORT 15 Secretaries 1.4 $ 30,736 $ 27 792 1.4 $ 33,016 STAFF 16 Nurses 1.0 $ 34 548 $ 36,886 1.0 $ 39,046 17 Custodians 3.0 $ 67,314 $ 68,316 3.0 $ 70,869 18 Information Services 0.2 $ 10,928 $ 11,093 0.2 $ 11,466 19 Paraprofessionals-Other 0.0 so $0 0.0 $0 20 Other-Aides 4.3 $ 60,630 $ 65,456 4.3 $ 62,761 21 TOTAL SUPPORT SALARY 9.9 $714,972 $676,423 9.9 $730,034 TOTAL (10-20\\ ... ,. $2,238 372 $2,162,963 ,, ' : ' _ $2,239,714 PURCHASED 22 Utllities ... . :: .  $ 34 000 $ 47,642 '\" ' \" ,,.,.. $ 49,000 SERVICES 23 Trawl ~:.:;,..,_,. $ 7 000 $ 12 457 ' ,, $ 5,000 (30} 24 Maintenance Agreements ~ ' :iciii'' $0 $0 ,, H-.-: $0 25 MATERIALS, 26 ~:::: . ~:Ill. .~:;: ~ : :  ' \" $ 35 8~~ $ 40 :,~ . ::' :~ ,,, ' $ 36,:S Other .....  ' $ l-,----c==.,,...,...,,,.,_.,....,,..,,4,,,-,--,---,,-.:.'f.,:::O,:..:TA..::L:..J(..::;30;;,Jl\\:._ _ -m_ :: Principal's Office SUPPLIES 27 (40) 28 29 CAPITAL 30 OUTLAY 31 Regular Classroom Media Other TOTAL(40) $ 2,500 $ 1 604 \"' \" ~'. ' ,...  $ 2,500 $ 1,953 $ 2581 \" '\"' _.,,. $ 3,174 $ 40,253 $ 45,091 . . .  $ 42,262 EQuipment '..: ' ,,. $ 16,904 $ 141288 ' \"\" ,,  , $ 11,500 Building Repair, etc. .,.,,  /'! ,, . $0 $0 i ' ~ ~ 1 .~ $0 {50) 32 OTHER 33 (60) 34 ---=-,.,....,..=---.---+Oth-,----er---=T_O_TA_L_(._50__.1)~..-.-.,1\". ...... ....- -.. $$ 16,~ $ 141,2: ~ ~'~ $ 11,5: Dues and Fees 1,000 $ 499 '.'.::.~ .. \u0026gt; $ 500 Other . . ... . $0 $0    :':' : $0 TOTAL(60) ,.,  , \"  s 1,000$ 499 , .. ,, .,.,  , $ 500 TOTAL (30-60) ' : ..  ' $127,057 $269,824 ' ... .. ,, ,~ $132,000 TOTAL (10-60) 40.4 $2,365,429 $2,432,788 39.4 $2,371,714 TOTALUNEITE    This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.\u003c/dcterms_description\u003e\n   \n\n\u003c/dcterms_description\u003e   \n\n  \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n  \n\n \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n  \n\n  \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n   \n\n   \n\n   \n\n\n\n\n\n   \n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n\n   \n\n   \n\n   \n\n   \n\n\u003c/item\u003e\n\u003c/items\u003e"}],"pages":{"current_page":12,"next_page":13,"prev_page":11,"total_pages":27,"limit_value":12,"offset_value":132,"total_count":319,"first_page?":false,"last_page?":false},"facets":[{"name":"educator_resource_mediums_sms","items":[{"value":"lesson plans","hits":8},{"value":"teaching guides","hits":5},{"value":"learning modules","hits":1},{"value":"timelines (chronologies)","hits":1}],"options":{"sort":"count","limit":16,"offset":0,"prefix":null}},{"name":"type_facet","items":[{"value":"Text","hits":292},{"value":"Sound","hits":20},{"value":"MovingImage","hits":13},{"value":"StillImage","hits":6}],"options":{"sort":"count","limit":16,"offset":0,"prefix":null}},{"name":"creator_facet","items":[{"value":"United States. District Court (Arkansas: Eastern District)","hits":41},{"value":"Arkansas. Department of Education","hits":21},{"value":"Little Rock School District","hits":16},{"value":"United States Court of Appeals for the Eighth Circuit","hits":6},{"value":"Bushman Court Reporting","hits":4},{"value":"Bell, Lorenzo, 1925-2001","hits":2},{"value":"Brown, Myers; Johnson, Ahnekii","hits":2},{"value":"Joshua Intervenors","hits":2},{"value":"Pulaski County Special School District","hits":2},{"value":"William Gordon Associates","hits":2},{"value":"Abernathy, Juanita, 1929-","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"subject_facet","items":[{"value":"Education--Arkansas","hits":254},{"value":"Little Rock School District","hits":210},{"value":"Little Rock (Ark.)--History--20th century","hits":166},{"value":"Education--Evaluation","hits":127},{"value":"Educational law and legislation","hits":105},{"value":"Educational planning","hits":88},{"value":"Little Rock (Ark.)--History--21st Century","hits":74},{"value":"School integration","hits":65},{"value":"School improvement programs","hits":64},{"value":"School management and organization","hits":64},{"value":"Arkansas. Department of Education","hits":52}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"subject_personal_facet","items":[{"value":"King, Martin Luther, Jr., 1929-1968","hits":6},{"value":"Kennedy, John F. (John Fitzgerald), 1917-1963","hits":3},{"value":"Walker, John W.","hits":3},{"value":"Abernathy, Ralph, 1926-1990","hits":2},{"value":"Baker, Augusta, 1911-1998","hits":2},{"value":"Bond, Julian, 1940-2015","hits":2},{"value":"Shuttlesworth, Fred L., 1922-2011","hits":2},{"value":"Young, Andrew, 1932-","hits":2},{"value":"Abernathy, Juanita, 1929-","hits":1},{"value":"Barnes, Billy E. (Billy Ebert), 1931-2018","hits":1},{"value":"Barnett, Ross R. (Ross Robert), 1898-1987","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"name_authoritative_sms","items":[{"value":"King, Martin Luther, Jr., 1929-1968","hits":7},{"value":"Abernathy, Ralph, 1926-1990","hits":2},{"value":"Bond, Julian, 1940-2015","hits":2},{"value":"Kennedy, John F. (John Fitzgerald), 1917-1963","hits":2},{"value":"Shuttlesworth, Fred L., 1922-2011","hits":2},{"value":"Young, Andrew, 1932-","hits":2},{"value":"Abernathy, Juanita, 1929-","hits":1},{"value":"Barnes, Billy E. (Billy Ebert), 1931-2018","hits":1},{"value":"Barnett, Ross R. (Ross Robert), 1898-1987","hits":1},{"value":"Bell, Griffin B., 1918-2009","hits":1},{"value":"Borders, William Holmes, 1905-1993","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"event_title_sms","items":[{"value":"Martin Luther King, Jr.'s Nobel Prize","hits":6},{"value":"Housing Act of 1961","hits":2},{"value":"Integration of Clemson University","hits":2},{"value":"Little Rock Central High School Integration","hits":2},{"value":"University of Georgia Integration","hits":2},{"value":"Brown versus Board of Education","hits":1},{"value":"Freedom Rides","hits":1},{"value":"Freedom Summer","hits":1},{"value":"Montgomery Bus Boycott","hits":1},{"value":"Selma-Montgomery March","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"location_facet","items":[{"value":"United States, 39.76, -98.5","hits":263},{"value":"United States, Arkansas, 34.75037, -92.50044","hits":257},{"value":"United States, Arkansas, Pulaski County, 34.76993, -92.3118","hits":249},{"value":"United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959","hits":233},{"value":"United States, Georgia, 32.75042, -83.50018","hits":9},{"value":"United States, Southern States, 33.346678, -84.119434","hits":5},{"value":"United States, Alabama, Montgomery County, Montgomery, 32.36681, -86.29997","hits":4},{"value":"United States, Georgia, Atlanta Metropolitan Area, 33.8498, 84.4383","hits":4},{"value":"United States, North Carolina, Guilford County, Greensboro, 36.07264, -79.79198","hits":4},{"value":"United States, Alabama, 32.75041, -86.75026","hits":3},{"value":"United States, Alabama, Jefferson County, Birmingham, 33.52066, -86.80249","hits":3}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"us_states_facet","items":[{"value":"Arkansas","hits":258},{"value":"Georgia","hits":15},{"value":"North Carolina","hits":10},{"value":"Alabama","hits":9},{"value":"Mississippi","hits":5},{"value":"","hits":4},{"value":"District of Columbia","hits":3},{"value":"Florida","hits":3},{"value":"Illinois","hits":3},{"value":"Louisiana","hits":3},{"value":"Tennessee","hits":3}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"year_facet","items":[{"value":"2000","hits":73},{"value":"1999","hits":69},{"value":"2001","hits":67},{"value":"2002","hits":65},{"value":"1996","hits":62},{"value":"1994","hits":58},{"value":"1995","hits":58},{"value":"1997","hits":55},{"value":"1992","hits":53},{"value":"1993","hits":53},{"value":"1998","hits":53},{"value":"2003","hits":46},{"value":"1991","hits":44},{"value":"2004","hits":43},{"value":"2006","hits":34},{"value":"2005","hits":32},{"value":"1990","hits":24},{"value":"1989","hits":19},{"value":"2007","hits":14},{"value":"2013","hits":14},{"value":"2008","hits":11},{"value":"2014","hits":11},{"value":"1980","hits":10},{"value":"2010","hits":10},{"value":"2012","hits":10},{"value":"2016","hits":10},{"value":"1983","hits":9},{"value":"1984","hits":9},{"value":"2009","hits":9},{"value":"2011","hits":9},{"value":"2015","hits":9},{"value":"2017","hits":9},{"value":"2018","hits":9},{"value":"1975","hits":8},{"value":"1978","hits":8},{"value":"1988","hits":8},{"value":"1967","hits":7},{"value":"1970","hits":7},{"value":"1974","hits":7},{"value":"1977","hits":7},{"value":"1979","hits":7},{"value":"1981","hits":7},{"value":"1982","hits":7},{"value":"1985","hits":7},{"value":"1986","hits":7},{"value":"1960","hits":6},{"value":"1962","hits":6},{"value":"1964","hits":6},{"value":"1965","hits":6},{"value":"1968","hits":6},{"value":"1971","hits":6},{"value":"1972","hits":6},{"value":"1973","hits":6},{"value":"1976","hits":6},{"value":"1987","hits":6},{"value":"2019","hits":6},{"value":"1959","hits":5},{"value":"1961","hits":5},{"value":"1966","hits":5},{"value":"1969","hits":5},{"value":"2022","hits":5},{"value":"1945","hits":4},{"value":"1950","hits":4},{"value":"1951","hits":4},{"value":"1952","hits":4},{"value":"1953","hits":4},{"value":"1954","hits":4},{"value":"1955","hits":4},{"value":"1956","hits":4},{"value":"1957","hits":4},{"value":"1958","hits":4},{"value":"1963","hits":4},{"value":"2020","hits":4},{"value":"2021","hits":4},{"value":"1900","hits":3},{"value":"1901","hits":3},{"value":"1902","hits":3},{"value":"1903","hits":3},{"value":"1904","hits":3},{"value":"1905","hits":3},{"value":"1906","hits":3},{"value":"1907","hits":3},{"value":"1908","hits":3},{"value":"1909","hits":3},{"value":"1910","hits":3},{"value":"1911","hits":3},{"value":"1912","hits":3},{"value":"1913","hits":3},{"value":"1914","hits":3},{"value":"1915","hits":3},{"value":"1916","hits":3},{"value":"1917","hits":3},{"value":"1918","hits":3},{"value":"1919","hits":3},{"value":"1920","hits":3},{"value":"1921","hits":3},{"value":"1922","hits":3},{"value":"1923","hits":3},{"value":"1924","hits":3},{"value":"1925","hits":3}],"options":{"sort":"count","limit":100,"offset":0,"prefix":null},"min":"1860","max":"2033","count":1494,"missing":0},{"name":"medium_facet","items":[{"value":"documents (object genre)","hits":143},{"value":"filing","hits":63},{"value":"exhibition (associated concept)","hits":18},{"value":"reports","hits":18},{"value":"oral histories (literary works)","hits":14},{"value":"transcripts","hits":13},{"value":"correspondence","hits":12},{"value":"sound recordings","hits":12},{"value":"lesson plans","hits":8},{"value":"photographs","hits":8},{"value":"web sites","hits":8}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"rights_facet","items":[{"value":"http://rightsstatements.org/vocab/InC-EDU/1.0/","hits":263},{"value":"http://rightsstatements.org/vocab/InC/1.0/","hits":31},{"value":"http://rightsstatements.org/vocab/CNE/1.0/","hits":10},{"value":"http://rightsstatements.org/vocab/NKC/1.0/","hits":6},{"value":"http://rightsstatements.org/vocab/InC-RUU/1.0/","hits":4},{"value":"http://rightsstatements.org/vocab/NoC-US/1.0/","hits":2},{"value":"http://rightsstatements.org/vocab/UND/1.0/","hits":1}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"collection_titles_sms","items":[{"value":"Office of Desegregation Management","hits":255},{"value":"Oral Histories of the American South: The Civil Rights Movement","hits":7},{"value":"Teaching with Historic Places","hits":6},{"value":"John Burrison Georgia Folklore Archives Collection","hits":4},{"value":"Historical Manuscripts and Photographs","hits":3},{"value":"Veterans History Project: Oral History Interviews","hits":3},{"value":"Alabama History Education Materials","hits":2},{"value":"Augusta Baker papers, 1911-1998","hits":2},{"value":"Butler Center for Arkansas Studies Audio Collection","hits":2},{"value":"Civil Rights Clippings from Guilford College Publications","hits":2},{"value":"Civil Rights Papers","hits":2}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"provenance_facet","items":[{"value":"Butler Center for Arkansas Studies","hits":257},{"value":"Atlanta History Center","hits":8},{"value":"University of North Carolina at Chapel Hill. Documenting the American South (Project)","hits":7},{"value":"United States. National Park Service","hits":6},{"value":"University of Southern Mississippi. Libraries","hits":3},{"value":"Alabama. Department of Archives and History","hits":2},{"value":"Atlanta University Center Robert W. Woodruff Library","hits":2},{"value":"Guilford College. Library","hits":2},{"value":"Historically Black Colleges and Universities (HBCU) Library Alliance","hits":2},{"value":"John F. Kennedy Presidential Library and Museum","hits":2},{"value":"Richard B. Russell Library for Political Research and Studies","hits":2}],"options":{"sort":"count","limit":11,"offset":0,"prefix":null}},{"name":"class_name","items":[{"value":"Item","hits":311},{"value":"Collection","hits":8}],"options":{"sort":"count","limit":100,"offset":0,"prefix":null}},{"name":"educator_resource_b","items":[{"value":"false","hits":312},{"value":"true","hits":7}],"options":{"sort":"count","limit":100,"offset":0,"prefix":null}}]}}