{"response":{"docs":[{"id":"pbs_pov_brotheroutsider","title":"Brother outsider : the life of Bayard Rustin","collection_id":"pbs_pov","collection_title":"Point of View","dcterms_contributor":["Point of view (Television program)","PBS Online"],"dcterms_spatial":["United States, 39.76, -98.5"],"dcterms_creator":null,"dc_date":["2002"],"dcterms_description":["Web site companion to a documentary examining the life of Bayard Rustin, one of the first \"freedom riders,\" an adviser to Dr. Martin Luther King, Jr. and A. Philip Randolph, and an organizer of the 1963 March on Washington. Rustin was forced to play a background role in landmark civil rights events because he was homosexual. The site includes classroom resources, a link to a trailer of the film, and other resource relating to the documentary.","The Civil Rights Digital Library received support from a National Leadership Grant for Libraries awarded to the University of Georgia by the Institute of Museum and Library Services for the aggregation and enhancement of partner metadata."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":null,"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["African American civil rights workers","Civil rights workers--United States","African American gay men","Gay men--United States"],"dcterms_title":["Brother outsider : the life of Bayard Rustin"],"dcterms_type":["Collection"],"dcterms_provenance":["Public Broadcasting Service (U.S.)"],"edm_is_shown_by":null,"edm_is_shown_at":["http://www.pbs.org/pov/pov2002/brotheroutsider/index.html"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["instructional materials","web sites","texts (document genres)","documentaries and factual works","study guides"],"dcterms_extent":null,"dlg_subject_personal":["Rustin, Bayard, 1912-1987"],"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1026","title":"\"Center for Research in Educational Policy's Response to RFQ #23-010,\" The University of Memphis, Memphis, Tennessee","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, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["2002"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. 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Center for Research in Educational Policy","Education--Evaluation","Educational planning","School integration","School improvement programs"],"dcterms_title":["\"Center for Research in Educational Policy's Response to RFQ #23-010,\" The University of Memphis, Memphis, Tennessee"],"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/1026"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["reports"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nRevised Desegregation and Education Plan Program Evaluation Consultant\nThis transcript was created using Optical Character Recognition and may contain some errors.\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 "},{"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","Walker, John W."],"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":null,"dcterms_medium":["correspondence"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\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_330","title":"Compliance court filings","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","School administrators","Education--Evaluation"],"dcterms_title":["Compliance court filings"],"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/330"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\n6: da vvu \u0026gt; 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 December 22, 2002 OF COUNSEL ROBERT McHENRY. PA. DONNA J. McHENRY  8210 Henderson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Emul: mcheni'yd@swbell.net Michael E. Gans, Clerk U.S. Court of Appeals 111 South 10th Street St. Louis, MO 63102 Room 24.329 RECEIVED DEC 2 6 2002 Re: 02-3867 Little Rock School District V . Joshua Intervenors OFFICE OF DESEGREGATION MONITORING Dear Mr. Gans, This letter addresses several issues in connection with this appeal. Transcripts All transcripts needed for this appeal earlier for counsel's use in the District Court. had been prepared Method of Preparation of Appendix The parties will submit separate appendices. Designation of Record (Appellant) Joshua Intervenors' designation is attached to this letter. Statement of Issues (Appellant) Joshua Intervenors' statement of issues letter. is attached to this cc Chris Keller (LRSD) other counsel of record in the District Court Appeal No. Q2-3867 Little Rock School Dist. V . Joshua Intervenors date Joshua Intervenors' Designation of the Record (1.) docket entries for the period from January 1, 1998 to (2.) Exhibits 543 to 872 (end of list} (all exhibits are marked court exhibits) (3. ) Pulaski County School Desegregation Case Settlement Agreement, March, 1989 (As Revised September 18, 1989) (4.) Joshua Opposition to Little Rock Compliance Report, 6-25- 01 (5. ) Order, 8-20-01 (6. ) Order 10-3-01 (7. ) Response by LRSD, 10-5-01 (8.) Order, 10-17-01 (item 3521) (9. ) Order, 11-13-01 (10.) Order, 11-13-Oi (11.) Order, 12-12-01 (12.) LRSD, Motion, Memorandum, and Statement of Facts Not in Dispute, 3-15-02 (13.) Order, 5-7-02 (14.) Order, 5-9-02 (15.) Order, 5-15-02 (16.) Joshua Intervenors' Opposition, 5-30-02 (17.) Order, 9-12-02 (18.) Order, 10-11-02 (19.) Order, 11-12-02(20.) Jotice of Appeal, 11-12-02 (21.) transcripts Substantive Hearings 7-5-01 7-6-01 8-1-01 8-2-01 11-19-01 11-20-01 7-22-02 7-23-02 7-24-02 Hearings on Procedural Matters 6-29-01 7-9-01 8-17-01 11-13-01 12-11-01 (22.) The Memorandum Opinion and Judgment, 9-13-02 and Order 10-11-02Appeal No. 02-3867 Little Rock School Dist. Joshua Intervenors V . Joshua Intervenors' Designation of Issues (1.) whether some of the District Court's findings of substantial compliance with the Revised Plan were induced by legal error in construing the Plan? (2. ) whether the district court made clearly erroneous findings of fact regarding student discipline, steps to improve and remediate the academic achievement of African American students, participation in extracurricular activities and advanced and enriched courses, guidance and counseling services, and plan compliance at Central High School? (3.) whether the Revised Plan required that the LRSD show progress in eliminating the racial achievement gap in order to establish substantial compliance with the Plan? (4.) whether in the course of assessing the LRSD's compliance with the Revised Plan the District Court failed to employ monitoring by the Office of Desegregation Monitoring (ODM) in the manner required by this Court in 1990? (5.) whether the District Court erred in holding the Joshua Intervenors to the requirement that they exhaust the Plan compliance remedies before they could contend that the LRSD did not substantially comply with a requirement of the Plan? (6.) whether the District Court erred in imposing anevidentiary burden on the Joshua Intervenors regarding the Joshua monitoring activities prior to March 15, 2001? Ir\"' received JAN 1 0 2003 OFFICE OF DESEGREGATION MONITORING FILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS JAN 0 7 2003 IN THE UNITED STATES DISTRICT COURT JAMES W. McCORMACK, CLERK EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION By:. DEP CLERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF CASE NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. LET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS NOTICE OF APPEAL The Joshua Intervenors give notice of appeal pursuant to Rule 3(a) of the Rules of Appellate Procedure with respect to Honorable William R. Wilson Jr.s order and the corresponding judgment, both entered herein on December 20, 2002. Respectfully submitted. Robert Pressman 22 Locust Avenue Lexington, MA 02421 781-862-1955 ^n W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 501-374-3758 501-374-4187 Rickey H. Hicks Attorney At Law 1100 North University, Suite 240 Little Rock, AR 72207 501-663-9900 John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 received JAN 29 20D3 OFFICE OF DESEGREGATION MONITORING JOHN W. WALKER SHAWN CHILDS January 28, 2003 OF COUNSEL ROBERT McHENBY. P.A. DONNA J. McHenry 8210 Henderson Ro.w Little Rock, Ark.ws.^ 72210 Phone: (501) 372-3425  F. (501) 372-3428 Email\nmcheiiiyd@swbell.net Michael E. Gans, Clerk U.S. Court of Appeals 111 South IO* Street - Room 24.329 St. Louis, MO 63102 Re: 03-1147 Little Rock School District v. Joshua Intervenors Dear Mr. Gans: This letter addresses several issues in connection with this appeal. Transcripts All transcripts needed for this appeal were prepared earlier for counsels use in the District Court. Method of Preparation of Appendix The parties will submit separate appendices. Designation of Record (Appellant) Joshua Intervenors designation is attached to this letter. Statement of Issues f Appellant) Joshua Intervenors statement of issues is attached to this letter ,, --Sincerely I John W. Walker JWW:js cc\nChris Heller Other Counsel of Record Appeal No. 03-1147 Little Rock School District v. Joshua Intervenors Joshua Intervenors Designation of the Record (1) LRSD Petition for Writ of Mandamus, 8-22-87 (2) LRSD Brief In Support of Petition for Writ of Mandamus, 8-24-87 (3) Letter from William R. Wilson, Jr. to Clerk, U.S. Court of Appeals, 9-8-87 (4) Response of the Honorable Henry Woods, United Sates District Judge for the Eastern District of Arkansas, to Petition for Writ of Mandamus (5) Motion for Hearing Regarding Relevance of 28 U.S.C. 455 to the Present Proceedings, 10-29-02 (6) Order Denying Motion for Hearing Regarding Relevance of 28 U.S.C. 455 to the Present Proceedings, 10-29-02 (7) Order, 11-12-02 (8) Motion for Recusal of District Judge and for Vacating of Orders, Ruling and Judgments, 11-25-02 (9) Memorandum from Hon. William R. Wilson, Jr. to Counsel, 11-26-02 (10) [LRSDs] Plaintiff s Response to Joshua Intervenors Motion for Vacating of Orders and Recusal, 11 -26-02 (11) Order, 12-20-02Appeal No. 03-1147 Little Rock School District v. Joshua Intervenors Joshua Intervenors Designation of Issues (I) Whether the District Court erred by holding that 28 U.S.C. Sec. 455(b)(2) did not require its recusal, in the light of his honor earlier appearance in the case as counsel while in private practice? (2) Whether the District Court erred by holding that it was not required to vacate the orders, opinions and judgments entered subsequent to its receiving this reassignment?United States Court of Appeals FOR THE EIGHTH CIRCUIT Nos. 02-3867EA, 03-1147EA Little Rock School District, Appellee, V. Alexa Armstrong\nKarlos Armstrong\nKhayyam Davis\nAlvin Hudson, Tatia Hudson, Lorene Joshua\nLeslie Joshua\nStacy Joshua\nWayne Joshua\nSarah Facen\nDerrick Miles\nJanice Miles\nJohn M. Miles\nNAACP\nJoyce Person\nBrian Taylor\nHilton Taylor\nParsha Taylor\nRobert Willingham\nand Tonya Willingham, Appellants. ' * * * * * * * * * * * * * * * * * * RECEIVED -3 2004 OFFICE OF DESEGREGATION MONITORING On Appeal from the United States District Court for the Eastern District of Arkansas. 7 Submitted: September 11, 2003 Filed: March 2, 2004 Before WOLLMAN, HEANEY, and RICHARD S. ARNOLD, Circuit Judges. RICHARD S. ARNOLD, Circuit Judge. !This case consolidates two appeals, both arising from the Little Rock School District's request for unitary status. First, the Joshua Intervenors' appeal from the District Court's^ denial of their Motion for Recusal of District Judge and Vacating of Orders, Rulings, and Judgments. We review a district court's denial of recusal for abuse of discretion. See In IS Hale, 980 F.2d 1176, 1178 (8th Cir. 1992)\nUnited States y. Walker, 920 F.2d 513, 516 (Sth Cir. 1990). We conclude that Judge Wilsons representation of Judge Henry Woods at a much earlier stage of the case. and on far different issues, did not involve the same \"matter in controversy\" for purposes of 28 U.S.C.  455(b)(2)\nthus, we affirm the denial of the Joshua Intervenors' Motion for Recusal. The Joshua Intervenors also appeal from the District Court's judgment granting the Little Rock School District (LRSD) partial unitary status. The Joshua Intervenors assert\n(1) that the District Court erred by not requiring and considering additional reports from the Office of Desegregation Monitoring (ODM)\nand (2) that the District Court's finding of substantial compliance with the Revised Desegregation and Education Plan was erroneous. We hold that the District Court did not err by failing to require new written reports from the ODM, and that the District Court's findings of fact are not clearly erroneous\nthus, we affirm the grant of partial unitary status. Because the facts relevant to each issue on appeal are different, we address them separately. In Part I, we address the issue of disqualification. In Part II. ., we address whether the District Court should have required new written reports from the 'This group of school children and parents are, as a practical matter, the plaintiffs in the case at its present juncture. The Little Rock School District, which actually initiated the case in appeal. 1982, is effectively the defendant for purposes of this The Honorable William R. Wilson, Jr., United States District Judge for the m n, A -.1_________  Eastern District of Arkansas. -2-March 9, 2004 LETTER-ORDER Mr. Christopher Heller Mr. Clay Fendley 400 West Capitol Avenue, Suite 400 Little Rock, AR 72201 Mr. Richard W. Floachell 11800 Pleasant Ridge Road Little Rock, AR 72222 Mr. Samuel Jones, III 200 West Capitol, Suite 2200 Little Rock, AR 72201 Mr. John Walker 1723 South Broadway LittIWIock, AR 72206 Mr. Stephen W. Jones 425 West Capitol Avenue, Suite 3400 Little Rock, AR 72201 Mr^S^hnis Hansen 1^1 Ce^r Street, Suite 1200 Llle Rock, AR 72201 Re\nLittle Rock School Districi 4:82CV00866 . Pul jTounty Special School, et al. Dear Counsel: As you know the September 11, lemorandum Order requires that the LRSD file a Compliance Report which documents its compliance with the obligations under 2.7.1 on or 15 fien, Joshua, or any other party, has thirty days (until April 15, 2004) within which to file objections to LRSD report. This missive is simply to notify all counsel that a request for any extension will likely be denied. If there are objections, they will be heard on April 26 and 27, 2004. Cordially, Wm, R, Wilson, Jr. cc: Original: The Honorable Thomas Ray Ms. Ann Marshall, ODM Mr. James W. McCormack, Clerk March 5, 2004IN THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT LITTLE ROCK SCHOOL DISTRICT VS. NOS. 02-3867 03-1147 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. MOTION FOR ADDITIONAL TIME TO FILE BRIEF AND RELATED MATERIALS CiA cuIuIl. received MAR -7 2003 OFFICE OF DESEGREGATION MONITORING APPELLEE DEFENDANTS APPELLANTS INTERVENORS The Joshua Intervenors respectfully move for an order extending the time for the filing of their consolidated brief, addendum and appendix for 14 days (with corresponding adjustments to the other element's of the schedule). The basis for this motion is as follows: Joshua Intervenors lead counsel John W. Walker began a trial, as defense counsel in Case No. CR 00:40, United States District Court, Eastern District of Arkansas, before the Honorable George Howard, Jr. on March 3, 2003. It appears that this trial will not conclude until March 14, 2003. Preparation for this trial and the trial have prevented lead counsel from working with co-counsel Robert Pressman, as well as Norman Chachkin, to complete the consolidated brief. WHEREFORE, the Joshua Intervenors respectfully pray that the Court grant the requested extension.Robert Pressman, Mass Bar No. 405900 22 Locust Avenue Lexington, MA 02421 (781) 862-1955 Respectfully submitted, Jmxn W~Walker, ARBar No. 64046 /OHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501) 374-4187 (Fax) Rickey Hicks, AR Bar No. 89235 Attorney at Law Evergreen Place 1100 North University, Suite 240 Little Rock, Arkansas 72207 (501)663-9900 CERTIFICATE OF SERVICE prepaid to the following counsel of record, on this I hereby certify that a copy of the foregoing has been sent bv fax and U.S. Mail, postage GdayofJIW^,2003: Mr. Christopher Heller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2000 Little Rock, Arkansas 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Ai'kansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, Arkansas 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Mr. Richard Roachell ROACHELL LAW FIRM 415 North McKinley, Suite 465 Little Rock, Arkansas hhn W.^Walker(2^-- IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION received MAR 1\n2004 desegregation monitoring LITTLE ROCK SCHOOL DISTRICT PLAINTIFF LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. l.ETAL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS LITTLE ROCK SCHOOL DISTRICT COMPLIANCE REPORT Plaintiff Little Rock School District (LRSD) for its Compliance Report states: 1. On September 13,2002, the District Court issued its Order finding that the LRSD had I substantially complied with all areas of the Revised Desegregation and Education Plan (Revised Plan), with the exception of Revised Plan  2.7.1. The Courts Order set forth a detailed Compliance Remedy as to Revised Plan  2.7.1. 2. On October 10, 2002, the LRSDs Board of Directors (Board) adopted a Compliance Plan designed to meet the requirements of the Courts Compliance Remedy. The LRSD filed the Compliance Plan with the Court on March 14, 2003, as Exhibit A to Plaintiffs Notice of Filing Program Evaluations Required By Paragraph C of the Courts Compliance Remedy. 3. Joshua initially raised concerns about the Board-approved Compliance Plan. The LRSD addressed these concerns in an October 25,2002 letter to counsel for Joshua, attached hereto Page 1 of 6as Exhibit A. Joshua invoked the Process for Raising Compliance Issues set for in Revised Plan  8.2, and the Joshua and the LRSD met with Ms. Ann Marshall to facilitate an agreement. The last meeting was February 28, 2003. At that meeting, the LRSD agreed to provide Joshua several documents. The last of these was mailed to Joshua on March 6, 2003. The parties never reached any agreement related to Joshuas concerns about the Board-approved Compliance Plan. Joshua waived any objections to the Board-approved Compliance Plan by failing to present them to the Court as required by Paragraph D of the Compliance Remedy. 4. The Board-approved Compliance Plan interpreted Paragraphs A and B of the Compliance Remedy as requiring the LRSD to: (1) continue to administer student assessments through the first semester of 2003-04\n(2) develop written procedures for evaluating the programs implemented pursuant to Revised Plan  2.7 to determine their effectiveness in improving the academic achievement of Afiican-American students\n(3) maintain written records of (a) the criteria used to evaluate each program, (b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elimination of any programs, and (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process\nand (4) prepare a comprehensive program evaluation of each academic program implemented pursuant to Revised Plan  2.7 to determine its effectiveness in improving the academic achievement of Afiican-American students and to decide whether to modify or replace the program. See Compliance Plan, p. 3. 5. Continue to administer student assessments through the first semester of 2003- 04. Page 2 of 6To meet this requirement, the LRSD implemented the 2002-03 Board-approved assessment plan. 6. Develop written procedures for evaluating the programs implemented pursuant to  2.7 to determine their effectiveness in improving the academic achievement of African-American students. The Board adopted regulation IL-Rl when it approved the Compliance Plan. Regulation IL- R1 set forth the written procedures for evaluating the  2.7 programs. 7. Maintain written records of (a) the criteria used to evaluate each program\n(b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process. Regulation IL-Rl outlined the criteria to be used to evaluate each program. As to the results of annual student assessments, the LRSD continues to maintain a computer database with the results of annual students assessments administered pursuant to the Board-approved assessment plan. Exhibit B attached hereto identified the members of each team. Exhibits C, D and E document informal modifications of the mathematics, elementary literacy and secondary literacy programs, respectively. 8. Prepare a comprehensive program evaluation of each academic program implemented pursuant to  2,7 to determine its effectiveness in improving the academic achievement of African-American students and to decide whether to modify or replace the program. The LRSD contracted with Dr. Steve Ross, an expert approved by Joshua, to prepare comprehensive evaluations of the Districts elementary and secondary literacy programs. These evaluations, combined in a single report, were completed and approved by the Board in November of 2003 and are attached hereto as Exhibit F. Dr. Don Wold, a program evaluator funded through I i Page 3 of 6a National Science Foundation (NSF) grant\nDenrus Glasgow, Interim Associate Superintendent for Curriculum and Instruction\nand Vanessa Cleaver, Director of the NSF Grant, authored the comprehensive mathematics and science evaluation. The comprehensive mathematics and science evaluation was completed and approved by the Board in December 2003 and is attached hereto as Exhibit G. 9. The LRSD substantially complied with the Revised Plan and the Courts Compliance Remedy by implementation of the Board-approved Compliance Plan. 10. By letter dated January 12, 2004, copies of the comprehensive evaluations were provided to counsel for the Joshua Intervenors, and counsel was asked to advise the District of any questions or concerns about these evaluations. In a fax dated March 8, 2004, counsel for the Joshua Intervenors wrote: I have reviewed your evaluations and find that they are grossly inadequate and incomplete. In addition to that I am still awaiting the evaluations of the other remaining programs which were contemplated by our agreement. Because we have already invoked the process required by the court, I am putting ODM on notice of our position. The LRSD denies that it agreed to prepare evaluations other than those described in the Board- approved Compliance Plan. WHEREFORE, the LRSD submits the program evaluations as required by paragraphs A and B of the Courts Compliance Remedy. The LRSD prays that the Court find that the LRSD has substantially complied with Revised Plan  2.7.1, as specified in the Compliance Remedy\nthat the LRSD is unitary with regard to all aspects of school operations\nand that it be released from all further supervision and monitoring of its desegregation efforts. I Respectfully Submitted, Page 4 of 6LITTLE ROCK SCHOOL DISTRICT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) 376-2OM---------- BYT Christopher Heller Page 5 of 6CERTIFICATE 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 March 12, 2004\nMr. 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 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Tim Gauger Mr. Mark A. Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Judge J. Thomas Ray U. S. District Courthouse 600 West Capitol Avenue, Suite 149 Little Rock, AR 72201 Mr. Clayton Blackstock Mr. Mark Burnett 1010 W. Third Street Little Rock, AR 72201 I Christodner Heller I Page 6 of 6 Friday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY (im-IPM) WILLIAM H. SUTTON. P.A BYRON M. EISEMAN. JR. P.A JOE D. BELL P.A JAMES A 8UTTRY. P.A FREDERICK S. URSERY, P.A OSCAR B. DAVIS. JR. P.A. JAMES C. CLARK JR. P.A. THOMAS P. LEGGETT. 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HARRISON OP COUNKL B.S. CLARK WILLIAM L TERRY WILLIAM L PATTON. JR H.T. f JOHN C ECHOLS. P.A. AD. MCALLISTER October 25,2002 JOHN C. FENOLEY. JR. LITTLE ROCK TEL SOI*370-3323 FAX 981.244-334*1 landlayQfac.ntt ( By Hand Delivery ) Mr. John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Bank of America Bldg. 200 West Cqjitol Little Rock, Arkansas 72201 Mr. Steve Jones Jack, Lyon \u0026amp; Jones, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm Plaza West Building 415 N. McKinley, Suite 465 Little Rock, Arkansas 72205 ( By Hand Delivery ) Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, Arkansas 72201 Mr. Dennis Hanson Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Arkansas 72201 RE\nCompliance Remedy Dear Counsel and Ms. Marshall: In our letter dated October 11,2002, we asked the parties to specifically identify in writing myperceived deficiency m the Board-approved Compliance Plan on or before Monday, October 21 9? October^ 1 n onno ^^^sed that Joshua would rely on the comments contained in Mr. Walkers October In ^2?? October 24, 2002, additional comments were received from Mr. Walker All of Mr. Walkers comments will be addressed in turn. - EXHIBIT AAll Counsel and Ms. Marshall October 25,2002 Page 2 October 10, 2002 Facsimile 1. More consideration is needed of the programs to be identified as implementatfed] pursuant to Section 2.7 ..., which are to be subjected to comprehensive program evaluation. . Your document at page 7 identifies three areas. We note the absence of specific reference and detail regarding interventions/ scaffolding - areas of vital importance given the achievement patterns of African-American students. We note also that the LRSD compliance report cited many more programs as designed to fulfill Section 2.7. Mr. Pressman clarified this concern during our October 21, 2002 telephone conversation. Mr. Pressman explained that Joshua was concerned that interventions designed to assist low achieving students, for example SAIPs, were not being fully implemented and wanted------ some assurance that the comprehensive evaluations would assess implementation of these programs. program LI^D RESPONSfr On October 24,2002, the Board approved the Division ofinstructions Plan P^gSchools,acopy ofwhichis enclosed for your review. Under that plan, the LRSD will conduct cumculum, instruction and classroom management audits at lowperfor^g schools. Data gathered through these audits and other monitoring under the plan may be proi^am evaluation team to identify possible causes of poor performance, includine used by a implementation of interventions such n * Tr. - - ---------------------- as SAIPs. The LRSD lacks the resources to implement this lx,-. --------ivDUluvcb LU uiipicnieni uus plm at every^hool Approximately 10 schools will receive the full compliment of services outlined in the plan. Those 10 schools will be identified based on the priority system set forth in the plan. 2. to a iscussion pnor to his testimony in the hearing [before] Judge Wilson, we understood Dr. Ross to mdicate that the existing evaluation of the PreK-2 literacy program was not ^equate. The notation on page 4 of your document of the changed use of the Observation S^ey and the DRA relates to part of the concerns he expressed. This undermines the f evaluation, upon Board approval, will satisfy a part of the Courts remedy. LRSD RESPONSE: As the LRSD understands this statement, Joshua objects to the LRSD considermg toe PreK-2 literacy evaluation to have been completed pursuant to Paragraph C of the omphmce Remedy. Attached are toe comments received by toe LRSD from Dr. Ross related that evaluation. As can be seen. Dr. Ross did not advise toe LRSD that toe evaluation , sense for toe LRSD to expend resources to have this evaluation completed by an outside expert while it also prepares to was of the same program with the assistance of an outside expert. anew, comprehensive evaluation iAll Counsel and Ms. Marshall October 25,2002 Page 3 3. ^eLRSDdiscussionaboutsatisIyingthecourtsorderregardingtheevaluationsmentioned h comphance report does not seem to take account of e material provided wninh OT\u0026gt; -.-.I__J.'___  which describes an adequate evaluation. LRSD RESPONSE: As the LRSD understands this completing the evaluations identified on statement, Joshua objects to the LRSD not page 148 of the Final Compliance Report in a manngr District Court simply wants the LRSD to do what understands Paragraph C of the Compliance Remedy^ the it said it did and complete the evaluations program evaluations as most prudent use of its limited true that those evaluations, even after being completed, may not be model envisioned by IL-Rl. The LRSD decided, however, that the iXTvrAfri^ to focus on the new, comprehensive evaluations' of programs desi^edto improve Afiican-Amencan achievement. 4. We question the period of implementation of a remedy which the therefore, the LRSD schedule. court has identified and, S'\" between the LRSD Joshua related to implementation of the Compliance Remedy will the District Courts September 13,2002, Memorandum Opinion and not prejudice Joshuas appeal of October 24. 2002 Facsimile I I 1 I 1. In using historical student assignment results, attention should be data. In the past, LRSD has used results on given to the quality of e the [D]RA and the Observation Survey in ways ^-twithtepurposesofthoseinsmunen^^ ^res fothen- oto students, the past use made of the data was in conflict withthe dislticfs ^oS  R=8ulation IL-Rl that Conflict of Interest\" must be use all available data in its evaluations. . . . .. ^^^^^^P^gP^^^^ComplianceRemedyrequirestheLRSDtoiva:\nava\niauic m Its It will be the responsibility of the evaluation team to weigh the reliabilitv and ahdity of the available data. The Arkansas Department of Education ZZis .O dcennme whete smdenm are learning dre essential T curriculum. As to the integrity of the data from those LRSD monitored student scores assessments, the to show improvement. Moreover, the ultimate year-to-year to discourage teachers from inflating scores in an effort success of the LRSDs early literacy program willAll Counsel and Ms. Marshall October 25,2002 Page 4 be judged by performance on the States Benchmark examinations, rather than the DRA Observation Surveys. 2. and We are concerned about the manner in which the regulation describes the team process for prep^g evaluations, again in the context of conflict of interest. In order to insure that conflict of mterest is avoided, the external consultant needs to write the report and control the -context of the analysis. Paragraphs 3, 5 and 6 of the Procedures do not guarantee that the external expert wiU 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. LRSD RESPONSE: The LRSD rejects the implication that LRSD Program Evaluation personnel cannot be trusted to wnte an honest program evaluation. The LRSDs commitment to improving student achievement IS second to none. To fulfiU that commitment, it is in the LRSDs best interest to effectively evaluate ite progr^s.. The success of the programs and program evaluations will ultimately be measured by the State s Benchmark evaluations. All evaluation team members wiU be actively mvolved in the evaluation process and are expected to provide a check against the self-interest of any one teammember. The evaluation team WiU decide who writes the report basedon the expertise team members will be actively of te^ members. The outside expert will be asked to take to the Superintendent any concerns about the evaluation not bemg addressed by the evaluation team. The outside expert will also be asked to be present when the evaluation is presented to the Board so that the Board can be advised of any concerns the outside expert may have about the final evaluation. 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 ^d 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 of schools) is of vital importance to the Intervenor class because . :so much more likely than other students to exhibit unsatisfactory class members are performance on the Benchmark and Stanford Achievement Tests. the whose A satisfactory description by e School Board of the evaluations which i, requires tire sufflo uud^e shortir^rZ mrplementation o(rentediatiort activities in district schools is to receive This is surely an important contextual factor (see Accuracy careful consideration. Standards, para. 2). LRSD RESPONSE\nAs the LRSD understands this comment, it is a restatement of the first number ?eZS ftere^ ** incorporates itsAll Counsel and Ms. Marshall October 25,2002 Page 5 4. We understand from the Plan that the LRSD plans evaluations of programs deemed partcularly directed to achievement of African-American students for the indefinite not simply for the penod necessary to satisfy the court. We would like to receive the Boards assurance that this is the case. LRSD RESPONSE: The Boards approval of IL-Rl was to be term, not limited to the term of the Compliance LL aner tne term nt the ' IL after the of Compliance Remedy, Conclusion The LRSD hopes that it has been able to address all of Joshua: o address aU of Joshuas concerns. If any party has y questions a^ut Ae LRSDs responses to Joshuas comments, we ask that those be submitted m wntmg, and the LRSD will nmmntlv _________ j\u0026gt;uuuuiiea writing, promptly provide a written response. LRSDs Compliance Plan, Joshua should noncompliance in accordance with Revised Plan  8- to Revised Plan  8.2.4, Joshua has 15 days of receipt of this letter to submit the issue to ODM for facilitation of an agreement. Thank you for your cooperation. Sincerely, ohn C. Fendley, Jr. John 'endley, cc\nDr. Ken James (via hand-delivery)Elementary Literacy PROGRAM EVALUATION TEAMS Underwood, Director of Early Childhood and Elementary LiteracyTeam Leader Pat Busbea, Literacy Specialist Judy Teeter, Literacy Specialist Judy Milam,, Literacy Specialist Mehnda Crone, Literacy Specialist Ann Freeman, Literacy Specialist Dr. Ed Wilhams, statistician Ken Savage (technician) Dr. Steve Ross, External Program Evaluator Secondary Literacy Suzi DavisDirector of Secondary English, Team Leader Sarah Schutte, Middle School Literacy Speciahst Dr. Karen Broadnax, Supervisor of ESL Eumce Smith, Supervisor, Special Education Dr. Mona Briggs, Safe Schools Grant Dr. Ed Williams, statistician Ken Savage (technician) Dr. Steve Ross, External Program Evaluator Mathematics and Science Vanessa CleayerTeam Leader Dennis Glasgow, Interim Associate Superintendent for Curriculum and Instruction I Marcelhne Carr Beth Clifford Annita Paul Dr. Ed Williams, statistician Ken Savage (technician) Dr. Don Wold, NSF Program Evaluator Dr. Steve Ross, External Program Evaluator EXHIBITProgram Modifications Based on Informal Program Evaluation Elementary Mathematics 2001-02  An item analysis of 4* Grade Benchmark Data for 2000-01 -----------1 reveals that students geometry strand. (Note-Tne State Math Framework and NCTM National Standards for Mathematics contain 5 strands: number sense. geon^try, probability and statistics, algebra, and measurement.) The analysis of data from the Benchmark Exam consisted of identifying the strand of each item rankmg the items from highest to lowest, and looking for trends in the data. w^^^ O! the low performance on geometry items \u0026gt; \u0026gt; Train teachers to do item analyses for their own schools. Work with teachers to discern reasons why students struggled with the \u0026gt; specific geometry items (the released items were O- available for review). Develop strategies for mcreasing the focus on geometry in the elementary TTlnPm2)tlPC cnmnnbfTM mathematics curriculum. School by school analysis of 4 Grade Benchmark Data for 2000-01 (and prior years) revealed different levels of achievement by schools that demographic^ly similar. Classroom observations in these schools by elementary math/science lead teachers confirmed that the level of implementation of the cumculum was different from school to school. Schools with a mgner level of implementation were having higher student achievement man schools who were not imnlementino- tbp ('iirrienhim ot t i__i were implementing the curriculum at that high level. A program modification made based on uneven achievement at similar schools was to have principals identify a lead person in their schools to and sustained training to serve as receive intensive Support Personnel for LRSD). a coach for other teachers (See list of Math  Sara Hogg, UALR Mathematics Specialist, was utilized to provide monthly coaches training so that additional implementation support would be available at each school. A variety of types of training has been provided by Ms. Hogg much of It directed at greater knowledge of strategies for implementing elementary mathematics curriculum. our Another program modification made as a result of uneven achievement schools was to begin a -------among process ofchanging the way professional development for ....  o J p* wxwwoiwxxttl Ul/ V VlUUlilCIll IO_ teachers is stmctured. In the past most professional development for elementary ma\u0026amp;ematics has-been district-led (e.g., all third grade teachers go to a district-led trai^gon theS grade mathematics curriculum). The modification has been shift more focus on site-based professional development. The Lesson Study and Study Group approach was begun with elementary mathematics teachers allow them more responsibility and accountability for their own training needs to to - exhibit2002-03  pie same item analysis was completed for 2001-02 4* grade Benchmark Data. Tu analysis showed that students had gained in the area of geometry Tn6 InUZAcf ___________V-VJV..______J The lowest strands were probability and statistics, XXXV, XU,.,,, audiius were proDaoility and statistics, measurement, and algebra. Staff and teachers reviewed the LRSD elementary mathematics curriculum to determine if there was a correlation between extend to strand coverage in the curriculum and student performance on ose strands on the Benchmark Exam, ^e cumculum analysis revealed that there were some gaps in the curriculum that likely resulted m low performance on certain items on the exam. Staff and teachers worked over the summer of 2003 use the Benchmark data to determme the big ideas or concepts students need to have a deen nnHrfitanHiT,n . - concepts students need to have a deep understanding about m ^ades K-5. Using several years worth of data, grade level teams of teachers in grades 1-4 (see list of teachers who worked on curriculum revision) revised the mathematics standards and benchmarks according to the five strands State Framework. Kindergarten and fifth grade ^11 do siimlar work during the summer of2004. Curriculum resources in grades were aligned to those standards assessed most frequently on the exam. Supplemental curriculum resources were identified from several sources for use to broaden the scope of the cumculum at certain grade levels. Maril^ Bums and Associates materials, and other materials compiled into a notebook for use by teachers. Internet resources, were identified and Benchmark results show that district students generally perform less well open-response test items compared to the multiple choice items. * Program modifications based on this data were\n\u0026gt; Developed packets of open-response items for teachers students. \u0026gt; Trained teachers to on the to use with score open-response items using a rubric. i --------------CLXLlL/llV. \u0026gt; Developed and administered District-developed end-of-quarter semester exams that included open-response items. or end-of- 4 grade Literacy and Mathematics Benchmark Results over a period of three ye^s caused some schools to be given School Improvement status by the Arkansas Department of Education (ADE). Schools in which the total population or one or more sub-populations (white, Afidcan-American, Hispanic, Limited English Proficient, Low Socioeconomic Status, and Special Education) did not meet Adequate Yearly Progress as defined by ADE were sanctioned with Year 1 not Year 2, or Year 3 School Improvement Status. * i detailed School Support Audit was done for schools in Year 2 or Year 3 School Improvement. (An attachment explains the school audit process) Ihe schools that were audited were Fair Park. Baseline.  Park, Baseline, Mabelvale Elementary^ Wakefield, and Southwest Middle School).  A variety of program modifications were made in schools on School Improvement as a result of the audit findings. One major common finding from the audits was that effective questions strategies were not being routinely used in the audited schools. The modification made las to brmg in an expert on questioning strategies (Dr. Lee Hannelauthor of HighlyEffective Questioning: Developing the Seven Steps of Critical Thinking) to lead a workshop for all LRSD principals. 2003-04  All grade level teachers were trained in the use of these new curriculum resources that were developed by the math staff and teachers during the August, 2003, school conference. pre-  Item analyses of the 4* Grade Benchmark Exam showed that the statistics and probability strand was the lowest area for students. s  A program modification made was to strengthen concept development in probabihty by added a replacement unit on probability fi-om Marilyn Bumss materials. Twenty-six primary teachers and coaches and twenty-five intermediate teachers and coaches participated in full-day training on the Marilyn Bums materials.  Three elementary schools on School Improvement Status collaborate to bring in Dr. Hannel to provide training for all teachers in the schools. * Hannel provided full day training for all elementary principals.  21 of 24 principals responded that they were interested in having the questioning strategies training for all faculty in their schools.  Additional schools received School Support AuditsChicot, Bale, Mitchell.  Program Modifications made by selected schools were to hire math coaches to assist with professional development and training related to implementation of the elementary mathematics curriculum.  Uneven achievement among schools was evident in the results of the 2002-03 4 Grade Benchmark Exam.  A Program Modification strategy used was to hire Dr. Linda Griffith to check the alignment of the mathematics curriculum, grades K-8, to the State Framework. The results of this alignment will include recommendations for improving the alignment in the curriculum.Program Modifications Based on Informal Program Evaluation Secondary Mathematics 2001-02  Item analyses of 6*, 8*, Algebra I, and Geometry Benchmark Data for 2001 . end-of-quarter tests for Algebra I - Pre-Calculus Uistnct-wide end-of-module tests for grades 6-8 calculator training provided for aU secondary math teachers * \u0026amp;r stazdards-based inabucdon/materiala in nndh teachers -02  District leveraged support of professional development for all math ux piuicbsionai aeveiopment for aU math teachers bv ^vrdmg funds to pay substitute teachers and stipends for teachers rec^ trainings  ^ad teach^ continued to provide technical assistance inside and outside the assroom by conductmg professional development workshops observations\nand classroom devd^n Umversity of Arkansas ac Litdc Rock develop and offer graduate courses based on the needs of the District The followmg course was developed and offered during the 2001 o Stratcsies for Tftflr.hino- at Little Rock (UALR) to Strategies Teaching Geometry -02 SY: distributed pacing guides for secondary mathematics and to address the issue of student mobility within the District  High school mathem Atics (---------'  courses courses (Algebra I - Precalculus) were revised to reflect a closer ahgnment with the national and state standards  The SMART (Summer Mathematii and fiameworks\nICS Sl^T, IS a Saturday academy for students currently enroUed in Algebra I These progr^ sr. ahgned wi the State Goals for Algebra I. ^Xl EQC \"ho participate in these programs are companaJ with if overall District results o SMART /Project THRIVE served more than 200 students in Algebra Calculus) are developed around the results of the benchmark concentrate on areas of weakness for students and work exams. Teachers on modifications in sturhed to measure the impact of instructional practices in the classroom SS? in all high odlUOlS o are 2002-03 Changed format of pre-school conference meeting to involve more teachers doinv presentations on standards-based activities  JST\" \u0026lt; high 1 Provided training from College Board Pacesetter for Algebra I - Pre-calculus teachers - over 80% of secondary math teachers were train eH  Continued District-wide end-of-quarter test for 6 grade - Calculus\n Continued to provide professional development for aU secondary mkth teachers on topics mcluding: o o Riverdeep Interactive Software TI-83 plus calculators o UALR Graduate Courses  Strategies for Teaching Algebra  Integrating the Graphing Calculator Revised and enacted procedures for ensuring that students who are Limited English Proficient (LEP) achieve the curriculum content standards and benchmarks established by the State of Arkansas and LRSD\n Continued to implement high-quality standards-based instruction for grades 6-12 mathematics\nContinued to hold monthly vertical team meetings for secondary math teachers Held horizontal team meetings (one per semester) for each secondary math course\n2003-04 Classroom sets of graphing calculators provided for all Algebra I - Calculus teachers\n Offered UALR graduate course on Using Handheld Technology to Enhance the Mathematics Classroom  used the TI-Navigator system\n Continued vertical and horizontal team meetings including 6 Wo^hop by Dr. Linda Griffith for calculus teachers on integrating calculator to teach calculus\nth -8  Continued end-of-quarter tests\n, th ' f X to reflect a closer alignment with the national and state standards and frameworks\nMarcelline Carr and Vanessa CleaverFY 2002-03 Actions of the LRSD Elementary Literacy Department related to Literacy Program Evaluation Elementary Literacy Department continued n-wvidv p. literacy, Reading Recovery) to all LRSD schools LRSD Pre-K-3 Literacy Plan. to provide professional development (ELLA, to support implementation of the Ihnnk examined the Spring 2002 CRT Literacy data to identify the schools most m need of assistance m the area of literacv with nartiniUr ____ of ^simnce in the area of literacy with particular attention to the academic achievement of Aft can Amencan students and their needs. The data indicated that the writinn program was the weak component of the literacy instructional ~ Department provided staff development related to writing instruction. program. The Elementary Literacy - and the writing programs in schools were modified to include best practices. Ihe Spring 2003 CRT L^'a schools reflected the schools efforts to improve their students academic achievement in writing The District used the assessment data to also provide the low performing schools with the oppo^mty to participate in the LRSD Reading First Project. The project, which is federally funded funding to schools to implement research-based instructional strategies Twelw cJhon ?? n  Project to begin in the fall of2003. The project requi^s the schools to follow an assessment schedule related to program improvement.^Because of lack of movement m smdent ^j-vem^t ,ools on school improvement decided to move 1 program to the research-based instruction recommended in Reading First. with the an from the Success for All FY 2003-04 August - December 2003 Response to the Literacy Program Evaluation Department reviewed the literacy program evaluation report developed by folln^ina developed a plan to continue program evaluation in the future which included the following\ngroups for each of the professional development ^LLA EflFeimve Literacy, Reading Recovery, Literacy Coaches, Success programs develop a table of the most and least effective elements. for All) and The information fi-om the XU A M, , . ------------------------------------ wawxxxwxxLQ. A lie lluul uiauon iToin rne focus groups will then be used to modify the Districts professional development plan Compare student data from the CRT and District asscssr/.v.\n. h. .aJ ' African-American students with others as related to the instru^onal program and provide specific professional development based Identified needs of the students. assessments in each school to compare on the EXHIBIT JX_T^e staff also reviewed the section of the report related to the most effective and least effective elements of each staff development offered by the District. The following actions were taken to address the weaknesses of the professional development\n Provided additional guided reading materials to all schools to support small groun instruction to ensure equitable instruction for all students. Provided a diverse collection of books to low performing schools to ensure that a variety of texts is available for independent reading.  Modified the testing schedule (except in Reading Excellence and Reading First schools) to accommodate the need for a more streamlined assessment plan. Literacy Achievement Data Review Dr. Ed Willies met with the Elementary Literacy Department regarding the 2003 Primary Literacy Rftnnnmflrir hyqtti o++an+i/\u0026gt;n j___i____v _ . Benchmark Exam with attention to the academic achievement of African American , , ---------- - J students \u0026amp;s compared to other students. Schools most in need were identified and assigned to specific Literacy Specialists who had the task of reviewing the testing data more closely with the assigned schools. ^e Elernentaiy Literacy Department employed the services of a consultant to discuss with the Literacy Specialists the most effective approach to use with the schools in examining their data and using It to make program modifications or changes. After the consultants visit, the staff developed a plan for working with the schools. Assistance provided to the schools was varied based on the needs of the school but included inservice on the Primary Benchmark Exam and data analysis. In some schools, the pnncipal and staff had already examined the data and outside assistance was not requested. on the Results of the data review confirmed that the professional development provided by the Elementary Llteracv DenartmAnt chmilrl in^lnzlA kAntp*. ____ Literacy Department should include heavy emphasis on addition to the professional development being offered content area reading and writing. In on an ongoing basis to teachers grades 2-4, T?! T  -------------- uaois LU Lcduiicis Hraaes z-h the Elementary Literacy Department and the Social Studies Department began working collaboratively to provide the training, resources, and materials for 5\"* grade teachers to integrate readmg and social studies mstruction. Three training sessions were held in January 2004 to model for teachers how to integrate the two areas. LRSD Reading First Project Schools Project Schools have been visited several times during the year (2003-04) bv the LSRD Readmg First Coor^ator, District Literacy Specialists, and the ADE Reading First Technical Assistant. J^e purpose of the visits is to provide assistance and to monitor the instructional program of the schools. Momtoring was done using a structured observation protocol and assistance was provided to schools in various ways such as the following:  Classroom demonstrations  Classroom observations with post observation conference  Colleague visits to exemplary classrooms  Sessions for problem-solving various aspects of the instructional program3 The Reading First Literacy Coaches and classroom teachers administered assessments in addition to those required by the district. In the fall of 2003 kindergarten students were given the DIBELS letter identification\nfirst grade students were given the letter identification and phoneme segmentation tests\nand the second and third grade students were given the oral reading fluency test. The coaches and classroom teachers used this information to determine students in need of intervention, .and intervention plans were developed for each school. Progress monitoring was conducted on those students considered at risk or some risk in order to evaluate the effectiveness of the interventions and to make needed changes. In January 2004 kindergarten students were given the DIBELS letter identification and phoneme segmentation, first grade students were given the DIBELS phoneme segmentation and oral reading fluency test\nand second and third grade students-------- ' -------  were given the DIBELS oral reading fluency test. The Developmental Spelling test was also administered to K-3 students in Tannary 2004. The Literacy Coaches entered all of the LSRD Reading First schools data and intervention plans into the Arkansas Reading First Data Bank. Pat Busbea and Renee Dawson, Reading First Technical Assistants monitored the data input and the development and implementation of the intervention plans. Because the Reading First Schools are predominantly Afncan Amencan, particular attention is being given to how the students are responding to the intervention and technical assistance is provided to schools when the data indicates it is needed. Professional Development Specialized Training Based on examination of CRT, DRA and Observation Survey data, as well as teacher observation, it w determined that support and services were needed in the following areas of literacy in the low- performing schools\nphonemic awareness/phonics, spelling, oral language and reading comprehension. Both local and nationally recognized experts in these areas of literacy were contracted to provide nmtAccinntjl *____1_______wnwv professional development to teachers of PreK through Grade 5. Ongoing Professional Development Ongoing professional development in literacy instruction is made available to all PreK - Grade 5 teachers. This professional development, a component of the State Smart Start Initiative, includes: Early Literacy Learning in Arkansas (ELLA) for grades K-2 Effective Literacy for grades 2-4 The LRSD Effective Literacy 5 for grade 5 Pre Early Literacy Learning in Arkansas (PreELLA) Pre-Kindergarten. Benchmark Preparation to response to requests from principals of the identified schools, District literacy specialists provided State Benchmark Exam preparation training to the teachers of grades 3-5 focused on the areas of Writing On Demand and Constructed Response \u0026gt;9I f. 4 Technical Assistance Literacy was provided to classroom teachers at the Elementary Schools id^ified for School Improvement. The focus and the intensity of the assistance were based on the instruction during the 2 /a hour Literacy Block - Reading Workshop, Writing Workshop and Word Study.  Reading Specialists visited each classroom in need of assistance to meet with the teacher The specialist and teacher identified the specific needs fi-om the following Physical Setting/Context for Instruction Explicit Phonics/Spelling/Word Study Literature Circles/Literature Discussion Groups Guided Reading Instruction Shared Reading Shared Writing areas\nStrategy-Based Mini Lessons Literacy Comers Teacher Read Aloud Writing Workshop Reading Workshop Independent Reading Benchmark Prep The specialists then addressed the areas identified, including: setting up Literacy Comers organrring and categorizing reading materials, teaching students in both  group modehng instmcUonal approaches, demonstrating the use of materials ^^ssing students and developmg mstmctional plans. Professional books, independent reading are als^^^^^ organizational materials and center supplies use of materials, employed literacy coaches to help support and accelerate change in literacy instruction to improve the achievement of all students in the area of literacy. iProgram Modifications Based on Informal Program Evaluation Secondary Literacy 2001-2002 1. 2. English faculty of each school 3. All building assistant principals at middle school program in order to provide for more------  were inserviced by director in literacv XXX tu proviae lor more consistent supervision and coordination hv including all administrators in literacy program. coordination by 4. Monthly collaboration sessions were held at all miHriix. i * i  with n 1 ,  ' -----------utcu Liaiu Dee Bench, consultant fi-om Denver Coalition of Business to lead staff development during s..n,n, Education was employed md instiuction^ Four weeks of training took place with tochers' an four core subjects m attendance. This summer of02 for teachers to modify reading strategies (approximately 75) fi-om 2002-2003 . Evaluation of current practice and able to consistently dXw quSty pro^^^^eTX\"^ for writing in order to be focus on optimum results were goals Spring - Summer 02 N w ^nd Committee of teachers for curriculum development\nBrenda Bankston, Mabelvale Middle School Barbara Brandon, Southwest Middle School Lisa Lewis, Pulaski Heights Middle School Sarah Schutte, Cloverdale Middle School Alison Hargis, Central High School Dr. Rhonda Fowler, Central High School Emily Lewis, Parkview High School Carol Carter, Hall High School Peggy Thompson, Fair High School Sandra Nichols, McClellan High School Karen Shofiier, McClellan High School morning sessions to introduce 2. Director met with building principals during early morning sessions tn introH,, b^sX for purposes of effectively evaluating classroom instruction and to SoX basis for collaborative program evaluation. Fall 02. of data from all tests and sessions with individual schools to modify areas of emphasis according to areas of need. It was discovered that our students do well on theA 4. 5. 6. mechanics and usage areas while the writing in content areas is weaker Strategies developed to practice and teach these skills. English office and distributed to ever, mid   noMcation of literacy program in tenns of test preparat  nexTstfJ^ \"7'^ comprehension for older riders next steps and current status of lowest achieving students. Summer literacy coaches m high school was determined and, a .co ' ' three lowest performing high schools , based on ACTAAP ) Teachers met during summer 2003 to evaluate and modify umculum producing an to all English teachers pnor to meeting and results discussed and useful for changes made. Committee Wes Zeigler, Southwest Middle School were to every middle school to evaluate 02-03. (Need for as a result, three are now in place to revise English Curriculum: Lisa Lewis, Pulaski Heights Middle School Billie Wallace, Parkview High School Beverly Maddox, Henderson Middle School Peggy Thompson, Fair High School Louisa Rook, Cloverdale Middle School Carol Carter, Hall High School Joan Bender, ALC Jennifer Moore, Forest Heights Middle School Alison Hargis, Central High School Cherry Robinson, McClellan High School 7. ESL Supervisor and director met to discuss and evaluate materials as they relate to program s effectiveness for ESL and low-level learners, these students as a result. Summer 03. 8. Consultant from Denver Coalition returned for instruction strategies for secondary students. Materials were purchased for one week of further training in reading 2003-2004 1. Based on being placed on School Improvement list. Associate Superintendent director met to discuss literacy program at low perfonning middle school and plan for improvement following detailed audit. 2. Director has met with middle school principals and high! ' ' discuss progress and evaluate future steps for increasing effectiveness nf ^eater achievement of lower-achieving students.. September03 and to write school principals separately to at 3. Personnel involved with audit of middle school met with building principal and vice princpal ,0 evaluate literacy progratp and dtscuss focus achievemf*nt thrnimk IfaroA,,_______  j\u0026gt;tLiucni achievement through literacy program. 4. Bi-Monthly meetings to evaluate programs and problems and collaborate -- t--------iUlU COIJ improvement held with director and high school literacy coaches. on strategies for August-October03. Five meetings held, 5. Session was held for disaggregating data - school by school recent performances on SAT 9 and ACTAAP and teacher by teacher - for to evaluate successes and areas and students and teachers needing improvement for high schools03.6. 7. 8. 9. 10. Meeting with department chairs and director to disaggregate data for midHU cnho i ev^te successes and denote areas needing imptovS''X\"S SREB consultant meetmg with literacy coaches to evaluate effectiveness of test preparation strategies and plan for improvements. Sept. 03. In response to data, sessions have been held open-ended responses. Teachers have made to at most schools with some or all of faculty in many modifications to classroom instruction xi_ . . , . ------*Ax**xxj ixivuiiiuiiuuns co Classroom mstmrtn on the expenential sessions involving reading, writing, and scoring with a rubric * thr^S intervention for lowest performing ninth andlighth graders at high schools and two middle schools began. One middle school intervention for sixth and seventh as well. uses same tafoimafion and evaluation session held February 04 for all building principals and kev admimsfrators on reading intervention with proposals for c ' 11. All middle schools have committed expansion of program in 04-05 to a day long mservice for their English teachers to review workshop structure for literacy program. April - May 04. On-going 1. 2. 3. Director and Middle School Specialist meet often to discuss and evaluate problems, and to set trainings, meetings, and interventions to correct and further progress Attention to bo\u0026amp; lowest achievers and highest achievers is focus of discussions Calendars are ahgned and coordinated at these meetings. Director and Middle School Specialist of literacy program strategies and progress, meet after school visits to evaluate implementation  ,, . , - content and to determine plans for improvement especially as it relates to lower-achieving students. Weekly at least --------------------O -viwixvo. rr tCM y ai icaSt. Director commumcates often and as requested to address individual problems in buildmgs with principals and teachers. prooiems in 4. Middle School Specialist works intensely with of curriculum and literacy program. 5. Continue to provide training in new teachers to improve implementation preparing teachers in ACTAAP open-ended 6. Middle School Specialist working closely with social studies dep'anment  1 PartSn?tr^ practice framing to assist in reading in social studies content. /. Participation in faculty meetings by director and implementation across curriculum. responses. department in providing specialist to modify program 8. tacrease efforts to provide literacy coaches in all secondary schools 9. Create, distribute and compile data from a survey evaluating the effectiveness of the literacy coaches. (In May 04 set date for survey June Ml   SpriSoM\" \"S\" EtSlisIt teachers 11. Department Chairs meet monthly to discuss hurdles, ioou commumcate openly about the literacy programs. These middle school and high school. These meetings ----- cumculum iteiK, special evenu, new developments, and reminders teachers from the distnct office as well as collaboration----------------------- issues, celebrations, and to meetings are separate for serve as a means of communicatingSecondary Literacy Evaluation Team January 16, 2004 Suzi Davis, Chair Program Modifications as a Result of Analysis of the CREP Report  Continue to provide training to whole faculties in ACTAAP open-ended responses and T_ _____________T7_1.___ r M rubric scoring. January, February, March, 2004  Continue cross-curricular unit development and training in workshops . Communicate with principals on the need for intense support for the literacy program January, 2004 j f   Increase efforts to provide literacy coaches for all secondary schools  Create, distribute and compile data from a survey evaluating the effectiveness of the literacy coaches. A date will be set in May for a June meeting to discuss the results of this survey.  All eight middle schools have committed to a day long inservice for their English teachers to review the ReadAVrite Workshop structure. During this inservice, plans will be made for collaborations among schools for next year. April, 2004  Develop an action plan for providing specific inservices for high school English teachers Spring 2004IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. LET AL MRS. LORENE JOSHUA, ET AL RECEIVED MAR 1 4 2003 DEFENDANTS KATHERINE KNIGHT, ET AL OFFICE OF DESEGREGATION MONITORING INTERVENORS INTERVENORS PLAINTIFFS NOTICE OF FILING PROGRAM EVALUATIONS REQUIRED BY PARAGRAPH C OF THE COURTS COMPLIANCE REMEDY Plaintiff Little Rock School District (LRSD) for its Notice of Filing Program Evaluations Required by the Courts Order of September 13, 2002 states: 1. On September 13, 2002, the District Court issued its Order finding that the LRSD had substantially complied with all areas of the Revised Desegregation and Education Plan (Revised Plan), with the exception Revised Plan  2.7.1. The Courts Order set forth a detailed Compliance Remedy as to Revised Plan  2.7.1. Paragraph C. of the Compliance Remedy stated\nLRSD must use Dr. Nunnerly or another expert from outside LRSD with equivalent qualifications and expertise to prepare program evaluations on each of the programs identified on page 148 of the Final Compliance Report. I will accept all pro^am evaluations that have already been completed by Dr. Nunnerly or someone with similar qualifications and approved by the Board. All program evaluations that have not yet been completed on the remaining programs identified on page 148 of the Final Compliance Report must be prepared and approved by the Board as soon as practicable, but, in no event, later than March 15, 2003. In addition, as these program evaluations are prepared, LRSD shall use them, as part of the program assessment process, to determine the effectiveness of those programs in improving African-American achievement and whether, based on the evaluations, any changes or modifications should be made in those programs. In addition, LRSD must use those program evaluations, to the extent they may be relevant, in assessing the effectiveness of other related programs.1. On October 10, 2002, the LRSD Board of Directors adopted a Compliance Plan designed to meet the requirements of the Courts Compliance Remedy. A copy of the Compliance Plan is attached hereto as Exhibit A. 3. As to Paragraph C of the Compliance Remedy, the LRSD concluded that the following evaluations had already been completed as required by Paragraph C and only needed to be submitted to the Board for approval: Early Literacy, Mathematics and Science, Charter School, English-as-a-Second Language, Southwest Middle Schools SEDL Program and Collaborative Action Team. The Charter School and Early Literacy evaluations were approved by the Board on October 24, 2002. The Southwest Middle Schools SEDL Program, 2000 and 2001 ESL and Collaborative Action Team evaluations were approved by the Board on November 21, 2002. The Math and Science and the 2002 ESL evaluations were approved by the Board December 19, 2002. These evaluations are bound together in volumes I and II attached. on 4. The LRSD concluded that the following evaluations needed to be completed by an outside expert before being submitted to the Board for approval\nExtended Year Schools, Middle School Implementation, Elementary Summer School, HIPPY, Campus Leadership Teams (CLT), Lyceum Scholars Program, Onward to Excellence and Vital Link. The LRSD sought guidance from Dr. Steven Ross, a desegregation and education expert approved by Joshua. Dr. Ross prepared, Guidelines for Completing Eight Program Evaluations in the Little Rock School District, attached hereto as Exhibit B. The LRSD subsequently contracted with experts, including Dr. Ross, to complete the evaluations in accordance with Dr. Ross guidelines. The Onward to Excellence, CLT, Vital Link and HIPPY evaluations were approved by the Board on February 13, 2003. The Lyceum Scholars Program, Elementary Summer School, Extended Year Education were approved by the Board on February 27, 2003. These evaluations are bound together in volumes III and IV attached. 2WHEREFORE, the LRSD submits to the Court program evaluations on each of the programs identified on page 148 of the Final Compliance Report as required by Paragraph C of the Compliance Remedy. 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: Christopher 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 March 14, 2003: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm Plaza West Building 415 N. McKinley, Suite 465 Little Rock, Arkansas 72205 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 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Collette D. Honorable Assistant Attorney General 323 Center Street, Suite 1100 Little Rock, AR 72201 e. istopher F:\\HOME\\FENDLEY\\LRSD 2001Vdes-unitary-Marchl 5-2003.wpd 3 Little Rock School District Compliance Plan Revised Plan  2.7.1 Approved by the Board on October 10, 2002 : exhibit I 5 I AB. C. F. LRSD must maintain written records regarding its assessment of each of those programs. These written records must reflect the following information: (a) the written criteria used to assess each program during the 2002-03 school year and the first semester of the 2003-04 school year\n(b) the results of the aimual assessments of each program, including whether the assessments resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the assessment of each program, as well as at least a grade level description of any teachers who were involved in the assessment process {e.g., all fourth grade math teachers\nall eighth grade English teachers, etc.). LRSD must use Dr. Nunnerly^ or another expert from outside LRSD with equivalent qualifications and expertise to prepare program evaluations on each of the programs identified on page 148 of the Final Compliance Report. I will accept all program evaluations that have already been completed by Dr. Nunnerly or someone with similar qualifications and approved by the Board. All program evaluations that have not yet been completed on the remaining programs identified on page 148 of the Final Compliance Report must be prepared and approved by the Board as soon as practicable, but, in no event, later than March 15, 2003. In addition, as these program evaluations are prepared, LRSD shall use them, as part of the program assessment process, to determine the effectiveness of those programs in improving African-American achievement and whether, based on the evaluations, any changes or modifications should be made in those programs. In addition, LRSD must use those program evaluations, to the extent they may be relevant, in assessing the effectiveness of other related programs. * * * On or before March 15, 2004, LRSD must file a Compliance Report which documents its compliance with its obligations under  2.7.1. Any party, including Joshua, who wishes to challenge LRSDs substantial compliance with  2.7.1, as specified above, may file objections with the court on or before April 15, 2004. Thereafter, I will decide whether the LRSD has substantially complied with  2.7.1, as specified in the Compliance Remedy, and should be released from all further supervision and monitoring. ^The Court is clearly referring to Dr. John Nunnery. 2Board-Approved Compliance Plan On October 10, 2002, the Board adopted this Compliance Plan to meet the requirements of the District Courts Compliance Remedy. Pursuant to this Compliance Plan, the LRSD will: 1. Continue to administer student assessments through the first semester of 2003-04\n2. Develop written procedures for evaluating the programs implemented pursuant to Revised Plan  2.7 to determine their effectiveness in improving the academic achievement of African-American students\n3. Maintain written records of (a) the criteria used to evaluate each program\n(b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process\n4. Prepare a comprehensive program evaluation of each academic program implemented pursuant to Revised Plan  2.7 to determine its effectiveness in improving the academic achievement of Afiican-American students and to decide whether to modify or replace the program\nand 5. Submit for Board approval the program evaluations identified on page 148 of the LRSDs Final Compliance Report that have been completed, and complete, with the assistance of an outside expert, the remaining evaluations identified on page 148 of the LRSDs Final Compliance Report. Each element of the Compliance Plan is discussed in more detail below. 1. Continue to administer student assessments through the first semester of 2003-04. The LRSD will implement the 2002-03 Board-approved assessment plan. The 2002-03 Board-approved assessment plan calls for the administration of the following student assessments in English language arts and mathematics: Kindergarten Grade 1 Grade 2 Observation Surveys (5) Developmental Reading Assessment Observation Surveys (5) Development Reading Assessment Observation Surveys (3) 3Grade 4 Grade 5 Grade 6 Grade 7 Grade 8 Grades 7-10 Grades 9-11 Grade 10 Grade 11 Development Reading Assessment Norm-referenced test to be identified for gifted/talented screening Benchmark Literacy examination Benchmark Mathematics examination SAT9 Total Battery Benchmark Literacy examination Benchmark Mathematics examination SAT9 Total Battery Benchmark Literacy examination Benchmark Mathematics examination End-of Course Algebra I examination End-of Course Geometry examination SAT9 Total Battery End-of-Level Literacy examination All of these assessments are administered in the spring. Consequently, the final student assessment before March 15, 2004, will be administered in the spring of 2003. 2. Develop written procedures for evaluating the programs implemented pursuant to  2.7 to determine their effectiveness in improving the academic achievement of African-American students. The Board approved IL-Rl in conjunction with approving this Compliance Plan. IL-Rl sets forth the written procedures for evaluating the  2.7 programs. 3. Maintain written records of (a) the criteria used to evaluate each program\n(b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process. IL-Rl mandates that the criteria used to formally evaluate a program be identified as the research questions to be answered, the first of which will be, Has this curriculum/instruction program been effective in improving and remediating the academic achievement of Afncan- American students?. Recommended program modifications and the members of the evaluation team are routinely included in formal evaluations. The Compliance Committee originally proposed IL-R2 to cover informal evaluations not 4The District Courts Compliance Remedy On September 13, 2002, the District Court issued its Memorandum Opinion (hereinafter Opinion) finding that the Little Rock School District (LRSD) had substantially complied with all areas of the Revised Desegregation and Education Plan (Revised Plan), with the exception Revised Plan  2.7.1. Section 2.7.1 provided: LRSD shall assess the academic programs implemented pursuant to Section 2.7* after each year in order to determine the effectiveness of the academic programs in improving African-American achievement. If this assessment reveals that a program has not and likely will not improve Afncan-American achievement, LRSD shall take appropriate action in the form of either modifying how the program is implemented or replacing the program. The District Courts Opinion set forth a detailed Compliance Remedy to be implemented by the LRSD. The Opinion first stated: Because LRSD failed to substantially comply with the crucially important obligations contained in 2.7.1, it must remain under court supervision with regard to that section of the Revised Plan until it: (a) demonstrates that a program assessment procedure is in place that can accurately measure the effectiveness of each program implemented under 2.7 in improving the academic achievement of Afncan-American students\nand (b) prepares the program evaluations identified on page 148 of the Final Compliance Report and uses those evaluations as part of the program assessment procedure contemplated by  2.7.1 of the Revised Plan. The Opinion then outlined the details of the Compliance Remedy as follows: A. For the entire 2002-03 school year and the first semester of the 2003-04 school year, through December 31, 2003, LRSD must continue to assess each of the programs implemented under  2.7 to improve the academic achievement of Afncan-American students. LRSD now has over three years of testing data and other information available to use in gauging the effectiveness of those programs. I expect LRSD to use all of that available data and information in assessing the effectiveness of those programs and in deciding whether any of those programs should be modified or eliminated. 'Revised Plan  2.7 provided, LRSD shall implement programs, policies and/or procedures designed to improve and remediate the academic achievement of African-American students, including but not limited to Section 5 of this Revised Plan. 1covered by IL-R2, However, the administration decided that IL-R2 was unnecessary and would be redundant of information to be included in the evaluations prepared pursuant to IL-Rl. Rather than a separate written record, the program description in evaluations prepared pursuant to IL-Rl will include a description of program modifications made during each year of implementation satisfying the requirements of Paragraph B of the Compliance Remedy. As to the results of annual student assessments, the LRSD will continue to maintain a computer database with the results of annual students assessments administered pursuant to the Board-approved assessment plan. 4, Prepare a comprehensive program evaluation of each academic program implemented pursuant to  2.7 to determine its effectiveness in improving the academic achievement of African-American students and to decide whether to modify or replace the program. The District will prepare the following new, comprehensive evaluations: (a) Elementary Literacy, (b) Middle and High School Literacy and (c) K-12 Mathematics and Science. Each evaluation will be prepared in accordance with proposed Regulation IL-Rl and will incorporate all available student assessment data relevant to the program being evaluated. These evaluations will be submitted to the District Court on or before March 15, 2004. 5. Submit for Board approval the program evaluations identified on page 148 of the LRSDs Final Compliance Report that have been completed, and complete, with the assistance of an outside expert, the remaining program evaluations identified on page 148 of the LRSDs Final Compliance Report. The following evaluations will be submitted for Board approval without additional work: Early Literacy, Mathematics and Science, Charter School, ESL, Southwest Middle Schools SEDL Program and CAT. If approved by the Board, they will be submitted to the District Court on or before March 14, 2003. The following evaluations will be completed by an outside expert and then be submitted for Board approval: Extended Year Schools, Middle School Implementation, Elementary Summer School, HIPPY, Campus Leadership Teams (CLTs), Lyceum Scholars Program, Onward to Excellence and Vital Link. These evaluations will be completed as follows\nExtended Year Schools. An outside expert will be retained to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Middle School Implementation. An outside expert will be retained to rewrite the report 5and, if possible, prepare an evaluation based on the existing data. Elementary Summer School. An outside expert will be retained to review the report and, if possible, draw conclusions and make recommendations based on the existing data. HIPPY. An outside expert will be retained to review the report and, if possible, draw conclusions and make recommendations based on the existing data. CLTs. An outside expert will be retained to review the CLT survey data and, if possible, prepare an evaluation based on the existing survey data. Lyceum Scholars Program. An outside expert will be retained to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Onward to Excellence. An outside expert will be retained to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Vital Link. An outside expert will be retained to review the report and, if possible, draw conclusions and make recommendations based on the existing data. 6Action Plan Timeline The Compliance Plan will be implemented in accordance with the following timeline. B it 1, Place 2002-03 Program Evaluation Agenda on the Boards agenda for review and approval. 2. Place on Board agenda for approval two previously presented program evaluations (early literacy, and charter school). 3. Place on Board agenda for approval the evaluations of Southwest Middle Schools SEDL program and the Collaborative Action Team (also conducted by SEDL). 4. Place on Board agenda for approval the previously presented ESL program evaluations for 1999-2000 and 2000-01, plus the new evaluation for 2001-02. 5. Place on Board agenda for approval the three previously presented program evaluations for the NSF-funded CPMSA program, plus the new Year 4 report for 2001-2002. 6. Issue Request for Proposals (RFPs) from available external experts to review and complete the eight remaining program evaluations listed on page 148. October 24, 2002 October 24, 2002 November 2002 November 2002 December 2002 Mid-October 2002 Ken James Bonnie Lesley Bonnie Lesley Linda Watson Bonnie Lesley Bonnie Lesley Karen Broadnax Bonnie Lesley Vanessa Cleaver Dennis Glasgow Bonnie Lesley Darral Paradis 7\"UtetiSBiK\" 7. Form a screening team to determine recommendations to the Superintendent for designating external experts to review and complete the eight remaining program evaluations listed on page 148._____________________ 8. Select and negotiate consulting contracts with designated external experts. 9. Assign appropriate staff to each external expert to provide needed information, data, access to program staff, etc. 10. Monitor the work to ensure timely completion. 11. As each paper is completed and ready for circulation, send copies to ODM and Joshua for their review and comments. 12. As each paper is completed, place on the Boards agenda the item to be reviewed and approved. 13. Write Interim Compliance Report relating to programs on page 148 to be completed. 14. Establish staff teams for each of the three programs on the Boards Program Evaluation Agenda to be completed for 2002-2003 (Elementary Literacy, Secondary Literacy, and K- 12 Mathematics/ Science). J, Late October 2002 Mid-November 2002 Mid-November 2002 Mid-November 2002February 2003 December 2002February 2003 December 2002February 2003 March 15, 2003 March 1, 2003 Ken James Compliance Team Bonnie Lesley Ken James Bormie Lesley Bonnie Lesley Bonnie Lesley Ken James Boimie Lesley Attorneys Compliance Committee Bonnie Lesley 81^. TrLviitiiYTT* ir ...... 15. Publish RFPs to identify external experts to serve on each of the two staff teams for the Boards Program Evaluation Agenda (K-12 mathematics/science external experts are provided by NSF). 16. Establish consulting contracts with the two external experts required for the Elementary Literacy and Secondary Literacy program evaluations. 17. Train each program evaluation team, including the external expert, on the requirements of the approved Compliance Plan and IL-R. 18. Monitor the completion of the work on all three program evaluations required in the Boards Program Evaluation Agenda. 19. Send copies of the completed Elementary Literacy program evaluation to ODM and Joshua for information. 20. Complete the evaluation of the Elementary Literacy program and place on the Boards agenda for approval. March 1, 2003 Late March 2003 May 2003 MayOctober 2003 With October 2003 Board agenda packet October board meeting, 2003 Bonnie Lesley Darral Paradis Bonnie Lesley Bonnie Lesley Bonnie Lesley Ken James Bonnie Lesley Bonnie Lesley Pat Price 9'! ISnicalirc-    I W3J\nj I fOTjstihTPf.i \u0026amp;' I 21. Send copies of the Secondary Literacy program evaluation to ODM and Joshua for information. 22. Complete the evaluation of the Secondary Literacy program and place on the Boards agenda for approval. 23. Send copies of the completed CPMSA program evaluation to ODM and Joshua for information. 24. Complete the five-year evaluation of the CPMSA project (science and mathematics) and place on the Boards agenda for approval. 25. Write Section 2.7.1 Final Compliance Report for federal court and file with Court. With November 2003 Board agenda packets November board meeting, 2003 With December 2003 Board agenda packet December board meeting, 2003 March 15,2004 10 Ken James Bonnie Lesley Bonnie Lesley Pat Price Ken James Bonnie Lesley Bonnie Lesley Vanessa Cleaver Dennis Glasgow Ken James Attorneys Compliance Team1 Guidelines for Completing Eight Program Evaluations in Little Rock School District Prepared by Steven M. Ross, Ph.D. The present guidelines are based on my review of the Revised Compliance Plan, the LRSD standards for program evaluation, and evaluation report drafts and associated materials related to the eight programs identified as requiring final evaluation reports. My analysis of this material, combined with my experiences as an educational researcher and familiarity with the Joshua case as it affected LRSD, was influenced by the following assumptions:  Invalid or questionable evaluation results can be much more detrimental than helpful to efforts to improve educational practices, and should not be disseminated without strong cautions and qualifications. Accordingly, studies that lack proper controls against bias or contamination from extraneous factors (e.g., differential sampling, history, diffusion of treatments) have limited value for guiding policies.  Program evaluations that focus predominately on student achievement outcomes while lacking sufficient implementation data have reduced value due to inability to determine the nature of the treatment. The study will also fail to inform policymakers about the practicality of the program, how it was used and reacted to by stakeholders, or whether and/or how it needs to be improved to impact at- risk learners.  Evaluations of programs that have been discontinued in the district are of much less interest relative to ones that are presently being implemented or informing ongoing practices.  To raise the achievement of African American students in LRSD, attempting to resuscitate existing studies that have insufficient data available, limited relevance to current practices, or require substantial time and resources with little promise of yielding useful information for policy decisions would be less productive than employing the lessons learned from the prior evaluation work to support high quality and informative future studies. One such lesson is that the LRSD research department (formerly PRE) was understaffed to perform evaluations of the quality and quantity needed. Based on the above assumptions, I will recommend below a basic strategy for the third-party evaluators to use in preparing the eight identified evaluations for approval by the school board. Four of the evaluations concern programs that are no longer in use by LRSD and have limited or no relevance to programmatic decisions (Lyceum Scholars, Elementary Level Summer Schools, Vital Link, and Onward to Excellence). Of the remaining four evaluations, two have limited available data (Middle School Transition and Campus Leadership Teams) that, even with supplementary analyses, would not permit confident (valid) decisions to be made about program effectiveness : exhibit 32 in general or about African American student achievement resulting from program participation. A seventh evaluation (Extended Year Education) could possibly yield informative evidence about an ongoing program, but to be sufficiently refined would require time and resources extending significantly beyond the current conditions for project completion. An eighth evaluation (HIPPY) also deals with an ongoing program, but unlike the others could possibly provide useful evidence through revisions completed within the available time frame. Accordingly, the HIPPY report is currently being rewritten by Dr. Ed Williams from LRSD. The suggested plan for the third-party evaluators is presented below followed by a brief review of each evaluation. A. B. C. D. Submit the current evaluation report as an attachment to a supplemental document as described in B-D. The supplement should begin with an expanded description of the program, its goals, and its history in LRSD. It should then describe the evaluation methodology and summarize and interpret the key findings. Most importantly, the supplement should discuss the limitations (and any strengths where indicated) of the evaluation with regard to: (a) informing current practices in LRSD\n(b) using appropriate methodology\nand (c) addressing student achievement effects, especially in reference to African American students. Finally, the supplement should present suggestions for conducting stronger studies of similar programs in future evaluation studies. 1. Middle School Transition (Moore) This evaluation is in near-completed form and needs mostly editing and expansion. Because the middle school program is current and continuing, this evaluation study can be useful (mostly for guiding professional development and implementation improvement) for informing district strategies. The achievement results are fairly minimal and uninformative, but at the time of the evaluation (1999-2000), only baseline data existed. Thus, aside from providing additional description of the results (the tables and the narrative are sparse) and a more meaningful interpretation of trends (especially with regard to Afiican American vs. Caucasian students), there is probably little more that needs to be done for this essentially baseline time period. The survey data appear to be reasonably analyzed and reported, but the interpretation and discussion should be extended to provide more meaningful conclusions and recommendations. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section.3 2. Lyceum Scholars (McNeal) The Lyceum Scholars High School Program, which was evaluated in 1998-99 and 1999- 2000, is no longer being implemented in LRSD. The latter consideration, coupled with the obvious limitations of the evaluation design with regard to rigor, depth, and meaningfulness of the data, substantially reduce the value of the study and the need for devoting more than minimal resources to it, beyond perhaps a supplemental summary and explanation. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section. 3. Elementary Level Summer School (McNeal) Similar to the Lyceum Scholars High School Program (#2 above), the Elementary Level Summer School program is no longer being implemented in LRSD. In addition, the evaluation study conducted in the summer of 2001 is limited in its design and methodology. Among the major concerns are the lack of: (a) implementation data to describe the program strategies and the degree to which they were actually used by teachers, (b) an adequate control group or norms to which the achievement scores of summer school students could be compared, and (c) qualitative data to describe the experiences of students and teachers in the program. Due to differential sampling the multiple tables provided are neither overly meaningful nor informative regarding the progress of summer school students in general and African American summer school students in particular. Seemingly, there is little useful information to be gained for informing future policies by investing substantive resources in revamping the study. While more suitable control samples might be established using archival data, the absence of implementation assessments would still make the treatment essentially unknown. Therefore, suggestions similar to those made for the Lyceum Scholars program are also offered here. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section. 4. Vital Link (Ross) The Vital Link program, designed to provide students with on-the-job experiences, was offered to 394 middle school students in the summer of 1999. Because the program was of very limited duration (only one week) and is not focused on either academic curriculum or learning strategies, it is highly xmlikely to have affected students academic achievement. Although such a program would still potentially serve a useful purpose for fostering student motivation to achieve and complete school, it is no longer being implemented in LRSD. Further, the evaluation study conducted was so limited (a brief post-test only, closed-ended survey) that the policy implications of the results are minimal and even potentially misleading if derived. Therefore, suggestions similar to 4 those made for the Lyceum Scholars Program and the Elementary Level Summer School Program (#s 2 and 3 above) are again offered here. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section. 5. Onward to Excellence CSRD Program (Ross) The OTE model was implemented at Watson Elementary School for several years, starting in 1999. It has since been discontinued and was never formally evaluated, except for achievement data reports sent by the principal to ADE. Thus, in essence, there is no longer any program in LRSD to evaluate and no evaluation report to revise, expand, or redraft. It would seem wasteful of resources to reexamine historical data from this program, especially since implementation data are lacking. That is, if positive or negative results were found, it would be impossible to determine whether OTE or numerous others factors were the main cause. Suggestions, therefore, are similar to those for #s 2-4 above. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section. 6. HIPPY (Ross) Because HIPPY is a continuing program, this evaluation can be potentially useful to LRSD by providing initial program results on student achievement and benefits to African American children. A limitation of the study, which unfortunately cannot be remedied retroactively, is the lack of implementation data to describe the fidelity with which HIPPY program components were actually used. The quantitative achievement results must therefore be viewed cautiously, but should still be at least suggestive regarding program influences. Substantive expansion and revision, however, are needed to increase the readability and meaningfulness of the report. For example, there is inadequate description of the program, context, methodology, and analysis design. Tables and findings need to be presented in a more readable (user-friendly) manner. Suggestions: A. Reorganize and expand the introduction and methodology to be in line with district evaluation standards (i.e., more context, more detailed methodology, clearer questions and organization). B. Ed Williams needs to run the revised analysis and write up results by January 31, 2003. A program description needs to be provided. Results need to be disaggregated, if possible, for African American and Caucasian students. Expand the Results sections to provide more informative reporting of outcomes, clearer tabular presentations, etc.5 C. Expand the Conclusions section to: (a) directly address whether there are implications for the achievement of African American and other disadvantaged groups (there probably are not at this stage), (b) more fully discuss implications and recommendations associated with the findings, and (c) propose further evaluation research that will validly determine both implementation quality and influences of HIPPY on student achievement. D. The third-party evaluator should follow the basic strategy in expanding this report. 7. Extended Year Education (EYE) Report (Moore) The EYE program is relevant to LRSDs current interests in improving academic achievement of its students. Unfortunately, the present evaluation design does not seem sufficiently sensitive to detect effects that might be attributable to EYE. Specifically, usage of whole-school data compared descriptively to district norms gives only a very surface examination of the schools progress, with susceptibility to contamination by student mobility, differences in SES, etc. A more precise analysis would match students at the three schools to similar students at comparable schools not using EYE, and then examine progress using a multivariate-type (regression or MANOVA) analysis. It is questionable, however, that such analyses could be completed in the time remaining for the required submission of the final report. Also, the findings would be limited by having only two years of post-program data. Aside fi-om the design limitations, the organization of the report is difficult to follow due to the many tables and brief but not very informative narrative descriptions. The survey data might be interpretable, but also need a much clearer and better organized presentation. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section. 8. Campus Leadership Teams (Ross) This initiative seems highly relevant to current and future goals of LRSD. However, the evaluation data collected to date consist of only results from two district-wide surveys that assessed team members reactions to various activities. No information exists to verify the representativeness of the samples, the validity of the data collection in general, or the implementation of the CLTs at the various schools. The aggregate survey results on the 24 combined items (14 in the team member survey\n10 in the certified/non- certified staff member survey) do not appear overly interesting or meaningful with regard to informing practice. Suggestions: The third-party evaluator should follow the basic strategy outlined in the introductory section. 12/3/021 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 Overnight Delivery OF COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Henderson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  F.AX (501) 372-3428 Email\nmchenryd@swbell.net March 20^ 2003 Mr. Michael E. Gans, Clerk United States Court of Appeals for the Eighth Circuit Thomas F. Eagleton Courthouse Ills. lO'h St., Room 24.329 St. Louis, MO 63102 Re: received MAR 2 0 J003 OFFICE OF DESEGREGATION MOMITORING Little Rock School District, Appellee v. Pulaski County Special School District No.l, Defendants, Mrs. Lorene Joshua, et al.. Appellants, Katherine Knight, et al.. Intervenors\nAppeal Nos. 02-3867, 03-1147 Dear Mr. Gans: Enclosed you will find ten copies of Brief of Mrs. Lorene Joshua, et al. and Addendum and three copies of the Appendix of Mrs. Lorene Joshua, et al. for filing in the above matter. Also enclosed you will find a diskette as required by the rales. Sincerely, W. Walker JWW:lp cc: All Counsel of RecordB IN THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT I APPEAL NOS. 02-3867, 03-1147 fl fl LITTLE ROCK SCHOOL DISTRICT, APPELLEE V. received 20 2003 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL., DEFENDANTS MRS. LORENE JOSHUA, ET AL., APPELLANTS I KATHERINE KNIGHT, ET AL., INTERVENORS Appeal from the United States District Court For the Eastern District of Arkansas I Honorable William R. Wilson, Jr. I BRIEF OF MRS. LORENE JOSHUA, ET AL. a a a Elaine R. Jones President \u0026amp; Director-Counsel Theodore Shaw Norman Chachkin NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street, Suite 1600 New York, NY 10013-2897 212-965-2200 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Ark. 72206 501-374-3758 Robert Pressman 22 Locust Avenue Lexington, Mass. 02421 781-862-1955 Rickey H. Hicks 1100 North University Suite 240 Little Rock, Ark. 72207 501-663-9900 aN IN THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT APPEAL NOS. 02-3867, 03-1147 LITTLE ROCK SCHOOL DISTRICT, APPELLEE V. received M PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL., DEFENDANTS MRS. LORENE JOSHUA, ET AL., APPELLANTS MAR 20 2003 OFFICEOF DESEGREGATION MONITORING fl KATHERINE KNIGHT, ET AL., INTERVENORS Appeal from the United States District Court For the Eastern District of Arkansas Honorable William R. Wilson, Jr. BRIEF OF MRS. LORENE JOSHUA, ET AL. Elaine R. Jones President \u0026amp; Director-Counsel Theodore Shaw Norman Chachkin NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street, Suite 1600 New York, NY 10013-2897 212-965-2200 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Ark. 72206 501-374-3758 Robert Pressman 22 Locust Avenue Lexington, Mass. 02421 781-862-1955 Rickey H. Hicks 1100 North University Suite 240 Little Rock, Ark. 72207 501-663-9900I I IN THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT APPEAL NOS. 02-3867, 03-1147 I I LITTLE ROCK SCHOOL DISTRICT, APPELLEE V. RECEIVED I PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL., DEFENDANTS MAR 2 0 2003 I OFFICE OF DESEGREGATION MONITORING MRS. LORENE JOSHUA, ET AL., APPELLANTS I KATHERINE KNIGHT, ET AL., INTERVENORS I I Appeal from the United States District Court For the Eastern District of Arkansas I Honorable William R. Wilson, Jr. ADDENDUM OF MRS. LORENE JOSHUA, ET AL. I I I Elaine R. Jones President \u0026amp; Director-Counsel Theodore Shaw Norman Chachkin NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street, Suite 1600 New York, NY 10013-2897 212-965-2200 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Ark. 72206 501-374-3758 Robert Pressman 22 Locust Avenue Lexington, Mass. 02421 781-862-1955 I R Rickey H. Hicks 1100 North University Suite 240 Little Rock, Ark. 72207 RI IN THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT I APPEAL NOS. 02-3867, 03-1147 LITTLE ROCK SCHOOL DISTRICT, APPELLEE V. RECEIVED I I PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL., DEFENDANTS MAR 2 0 2003 n OFFICE OF I MRS. LORENE JOSHUA, ET AL., APPELLANTS DESEGREGATION MONITORING KATHERINE KNIGHT, ET AL., INTERVENORS I Appeal from the United States District Court For the Eastern District of Arkansas Honorable William R. Wilson, Jr. I APPENDIX OF MRS. LORENE JOSHUA, ET AL. I I Elaine R. Jones President \u0026amp; Director-Counsel Theodore Shaw Norman Chachkin NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street, Suite 1600 New York, NY 10013-2897 212-965-2200 I I John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, Ark. 72206 501-374-3758 Robert Pressman 22 Locust Avenue Lexington, Mass. 02421 781-862-1955 Rickey H. Hicks 1100 North University Suite 240 Little Rock, Ark. 72207 501-663-9900nrr,, :? ^OHi1 JUMI '1 W WHLKt-K H H NO.097 P.2 IN THE UNITED STATES DISTRICT COURT iiwS EASTERN DISTRICT OF ARKANSAS' WESTERN DIVISION APR Ma LITTLE ROCK SCHOOL DISTRICT JAMES W, MeCORMACK, GLERK Byx_________ PLAINTffiP]P-?RX 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 The Joshua Intervenors' Comments on the Submission of Paoe lae \"Evaluations\" The Joshua Intervenors comment as follows on the *[LRSD] Notice of Filing Rrogran Evaluations Required by Paragraph C o the Court's Compliance Remedy and the accompanying \"evaluations. This court held that the LRSD did not substantially comply with Sec. 2.7.1 of the Revised Plan, addressing \"Program Assessment/Prograrn Evaluation [at ISO].\" [At 168] The court noted the importance of this commitment. I find that the purpose of Sec. 2.7.1 was to make sure that the programs promised under Sec. 7   ' improve the academic achievement of African-American students. 2.7 actually worked to I further find that LRSD's substantial compliance with Sec. 2.7.1 was crucial to its commitment to improve the academic achievement of African-American students\ntor. without performing a rigorous annual assessment of each of the many dozens of programs implemented under Sec. 2.7, it would be impossible to determine which programs were working and should be continued and which programs were not working and should be discontinued, modified, or replaced with new programs. [At ISO] The court's \"Compliance Remedy\" for the Sec. 2.7.1 violation 1 1 JUHII JUHM W WHLKLH P a HO.097 P.3 addxe\u0026amp;Bed in part program evaluations identified in page 148 of on each of the programs 171] The court discuseed the the Final Compliance Report.\" [At 17O, completion of these evaluations and their submission to the court and the parties, by March 15, after their approval by the LRSD school board. 2003, [At 171-72] The court also required, in effect, additional evaluations of \"each of the programs ia^lemented under Section 2.7 to improve the academic achievement of African-American students.\" are to be submitted on or before March 15, [^t 170] These materials 2004. [At 172] This court also discussed the criteria to exiting court supervision. govern the LRSD's substantially comply with the C^cxally important obligations contained i,, ==.... vr with regard to th^ in Sec. 2.7.1, it section of the Revised Plan Gntil it\" fa BTooram asBeeftmonf- .flJ- tnat a ^flgram aesessment nrocedure is in oTaoe program implemented under wSCt 417 inIraprovino_achievemn* .i.7 in improving the academic American students\n\" ntfAPan Hrt^. lo. i::k3t3^ n The LRSD \"Notice of Piling\" describes the LRSD's plan to prepare \"comprehensive program evaluationfs]\" as follows\n. District will prepare the followinq nen Elementary Literacy, (b) Middle and (C] K-12 Mathematics and Science, ach evaluation will be prepared in accordance with proposed Regulation IL-Ri and will incorporate all available st^ent assessment data relevant to the program being evaluated. These evaluations will be submitted to the District before March 15. 2004. [Exhibit A at S] student Court on or Joshua Interveners have raised an issue about the scope of this plan pursuant to Section 8 of the Revised Plan. The page 148 \"evaluations\" were, as noted, submitted on March 14, 2003. A review of these materials and other relevant documents 2NO.097 p.4 Show that if LRSD is to \"[demonstrate] that a program assessment procedure is in place that can of each program implemented accurately meaaure the effectiveness under Sec. in improving the I H 2.1 academic achievement of African-American students\"  it will have to be by a future submission, were either not evaluations, In general, the documents submitted or very deficient evaluations. Joshua Intervenors offer the following examples of deficiencies identified in the page 154 \"evaluations.\" Early Literacy [vol. 1-2]' Dr. Ross described the report as \"one of the best written reports from LRSD i^ve read. [At 2] He also discussed \"a number of weaknesses . . - [Id-] Dr. Ross* critique includes the following content: \"Of greatest concern overall is the writer's obvious efforts to 'prove' gap reduction even where the data support is weak or spurious.\" [At 3] \"Statistically, a very serious weakness is the lack of validity of the 'Percent Improvement' (Pl) index. [At 3 ] \"Another major statistical weakness is emphasizing the comparison of growth ratios (GR) between B and KB students. . . The reason is the obvious ceiling effects on most of the measures.\" [At 4] \"Not surprisingly, on the two literacy tests that do ngx have low ceilings  Writing Vocabulary and DRA  Ratios are much less supportive of gap reduction [e.g.. the Growth see p. 54, bullet 4), and could even be used by critics as showing extensions of the gap in a number of places.\" [At 5] \"The present data are , This segment is based upon a critique by Dr. Ross, titled Review of Year 2 Evaluations.\" It was submitted to counsel a^d Mrs. Marshall of QDM, by counsel for the LRSD, on October 25, 2002. 3. C.VJCJO r?* ozwi i. jut-in w wHL_r.t.K r h NO.097 p.5 suggestive of definite xU. students' literacy performance. early progress made by lrsd in improving e^e also indicators some progress in gap reduction in certain skills. of However, given that we are dealing with teacher-administered tests having very ceiling levels, the overall evidence low conveys. There is is weaker than this report no reason to reduce the findings by presenting them credibility of the [At 7] \"Conduct more studies that with such an obvious positive bias. and impacts on the school and Charter schog-[ [Vol. 1-2} \"Performance data for examine implementation quality the classroom.\" [At 8] the program evaluation were disaggregated by African American. not race. The student body, however, was 87 percent N [Vol. 1-2 at 1\nDr. Lesley] Southwest Middle school's smni. Program [Vol. The \"evaluation\" documents produced by 1-2] the Southwest Educational Development Lab contain of the program implemented at Southwest Middle achievement data. [Vol. 1-2 at 243-63] neither a detailed description School, nor student C\u0026lt;? 1 labor at ive Action Plan [Vol, 1-2] \"Although the 249-page study produced by SEDL that evaluated the project included student achievement data, those data were not disaggregated by race, and LRSD's short-term [one year) in the project would not predict that the involvement this relatively small of parents and community vo)ynte^rs would result in improved student performance. Dr, Lesley] N [Vol. 1-2 at 528\n4 I. C-WtJO 3  COMI'I JUMU W whlklh h h HO.097 P.6 Bctended Year Schools [Vol. Vol. 4] \"Unfortunately, the present evaluation sufficiently sensitive to detect effects that design does not seem might be attributable . to BYE. Specifically, usage of whole^school data compared descriptively to district examination of the schools' norms gives only progress. a very surface with susceptibility to contamination by student mobility, differences in SES, etc.\" [Exh, B at 5\nDr. Ross] \"The external evaluator's conclusion was that 'Unfortunately, the limited nature of the original design and existing data do not afford us an opportunity to answer in a rigorous manner the key evaluation question of the extent of impact of the initiative on black student performance.'\" [Vol. 4 at 1732\nDr. Lesley\nsee also Vol. 4 at 1813 (Youth Policy Research Group, Inc.] Middle School Imnlementatien [Vol. 4] \"The study conducted by the external evaluator did not attempt to draw any conclusions related to this research question [impact on African-American achievement] since the student performance data available for the study were 'baseline'. and there are serious questions about the appropriateness of the achievement measures and about the validity of some of the other performance outcome measures.\" [Vol. 4 at 1870\nDr. Lesley] \"The data presented in the original report does not support the interpretation of program effects on student performance. It provides a baseline for examining future effects, but needs to be extended and verified.\" [Vol. 4 at 1911\nYouth Policy Research 5 MtiHi'i JUI-iri W WHLK.t.K h' H NO.097 ' P.7 Group\u0026lt; Inc.] Elementary Summar SehonT [Vol. 3] There is a lack of implementation data to describe the i program strategies and the degree to which they were actually used by teachers.\" There is not \"an adequate control group or norms to which the achievement scores of the summer school students could be compared.\" [Eh. B at 3\nDr. Ross] \"unfortunately, there are no additional details in the evaluation that describe the precise treatment afforded the students in the program. Missing is any indication of precisely how much of the curriculum was delivered. how and when it was delivered. and neither by whom, nor its relationship to the previously identified objectives.\" [Vol. at \"] \"No adequate control group or norms . . [Vol. at -J (By Quality Education and Management Associates, Inc.] Hippy [Vol. 3] \"A limitation of the study, which unfortunately cannot be remedied retroactively. is the lack of implementation data to describe the fidelity with which Hippy program components were actually used. [Eh. B at 4\nOr. Ross] M \"Conclusions are difficult due to limitations of the study.\" [Vol. 3. at 1554\nDr. Lesley] \"A third weakness is the gap between the HIPPY experience and the achievement scores analyzed. ... By that time, several years had elapsed subsequent to the HIPPY interventions.\" [vol. 3 at 1567\nDr. Ross] 6 -ttJMI I J s-'ni W H NO.097 p.8 gamPUS T.\u0026lt;adez-Rh\u0026lt;o T)ms [Vol. 3] consist of only . However, the 'evaluation data' collected to date results from two district-wide assessed team nenbers surveys that reactions to various information exists to activities. No the validity of verify the representatives of the samples t the data collection in implementation of the CLTs Dr. Ross] general, or the at the various schools.\" [Eh. B at S\n\"These surveys were not intended although they to he a program evaluation., Vere mistaKenly characterized as District's Compliance such in the report to the court. data were collected, and, therefore, No student performance no conclusions could be drawn as to whether the improved academic achievement African American students. campus Leadership Teams' work has resulted in for any students, nor specifically H [Vol. 3 at 1256\nwas no formal evaluation Dr. Lesley] of CLT by the LRSD.\" [vol. at 1259\nDr. Ross] Lyceum scholars Program [Vol. 3 4] \"Approximately one-half of the students small participating in this program (8 to 10 students total) were African American. Because the numbers were so small, neither performance data nor survey data were disaggregated by race. Neither the staff study nor that of the external evaluator could determine whether this had any positive benefit on the academic performance program of African American students.\" [Vol.4 at 1607\n(inadequate description of treatment Dr. Lesley\nsee also at 1635 provided students in program\n7\u0026lt;1 jurrn w WHUKt-K k h NO.097 P.9 Dr. Ross)] Qnwara to Exceiieneg fvoi. 3] The program \"was never formally evaluated. achievement data except for reports sent by the principal to ADE.\" As \"i iaplejnentation data are lacking, It n if positive or negative results were found, it would be impossible to determine whether OTE or numerous other factors were the main cause. [Eh. B at 4\n\"In view of these factors, Dr, Ross] is no basis for evaluating the 'study,' since none existed.\" [Vol. 3 at 1217\nDr. Ross] Vital Link [Vol. 3] ^Drthar, the evaluation study conducted was so limited (a h brief post-test only, closed-ended survey) that the policy implications of the results are minimal and even potentially misleading if derived.\" [Eh- B at 3\nDr. Ross] There is [iInsufficient description of the program and its N implementation.* There is a \"[l]ack of pre-program (pretest).data for judging change following program completion.\" \"Mo examination of results for different subgroups (e.g., by ethnicity).\" [Vol.3 at 1542\nDr. Ross] 8 1 i_?  CJMl I J 1 w wHL-\\c.r\u0026lt; H NO.097 P.10 sonciueion The need for high quality evaluations, court supervision, is clear. if XJISD IS to exit Respectfully submitted. Robert Pressman 22 Locust Avenue Lexington, MA 02421 781-862'-1S55 Mass. 405900 'J in W. Iker John w. Walker, p.a. 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 Ricky Micks Attorney at Law 1100 North University, Suite 240 Little Rock, AR 72207 501-663-9900 9 jvmi w wHLrLr r H NO.097 P. 11 CERTmCATE OF SERVICE I hereby certify that a copy of the foregoing pleadi pre-paid, to all the counsel of record this day of has been mailed, postage ohn W, Walker IMrr,, 1^. iiukUO cJtJHI'i JUm W WHLKLK H W \" NO. 097------P. 1 JOHN IV WALKIR, P.A. 7 Date: Attorney at Law 1723 Broadwey Little Rock. Arkansas 72206 Telephone (501) 374-3758 Fax (501) 374-4187 FAX TRANSMISSION COVER SHEET To: Fax: Re: Sender: YOU SHOULD RECEIVE [JJ(mduixni sheet)] PACE(S), INCLUDING THIS COVER 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 i^onnation intended only for the use of the individual or entity named above. If the reader of tlus message is not the 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, please immec^w not^ us by telephone, and return the original message to us at the above address via atcomey privileged and confidential the U.S. Postal Service. Tliank yoi lU-BN district AW\" EAST^NOist^' IBAS IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS.ygsW. WESTERN DIVISION _____ APR 15 2W MCCORMACK. CLERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEIVED DEFENDANTS MRS. LORENE JOSHUA, ET AL. APR 1 9 2004 INTERVENORS KATHERINE KNIGHT, ET AL. OFFICE OF DESEGREGATION MONITORING INTERVENORS The Joshua Intervenors' Opposition to the Motion of the LRSD to Be Released from Further Supervision and Monitoring of Its Desegregation Efforts The \"LRSD has [not] substantially complied with [Plan] Section 2.7.1, as specified in [the court's] Compliance Remedy.\" [Mem. Opin. , September 13, 2002, at 172] Therefore, the LRSD must continue to be subject to further supervision and monitoring of its implementation of the court-ordered remedy, until it demonstrates substantial compliance with that remedy. The LRSD motion should be denied and supervision and monitoring should continue for a minimum of two additional years. 1 The Intervenors' Opposition is based upon record in the case. the accompanying memorandum. and evidence (including expert ^This two year period of time will afford the^LRSD the minimum time it needs to achieve compliance with t'he remedy/ and, as well, give the Joshua Intervenors and the ODM the time to determine whether compliance is not merely transitory. 1testimony) and arguments to be submitted at the hearing scheduled by the court. (esmectfu y suj^itted, Robert Pressman Ro: 'W. Walker 22 Locust Avenue Lexington, MA 02421 781-862-1955 Mass, 405900 fe^key Hicks YJohn W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 o Elaine R. Jones President \u0026amp; Director-Counsel Norman Chachkin Theodore Shaw N7\\ACP Legal Defense and Educational Fund, Inc. 99 Hudson Street New York, NY 212-965-2200 10013-2897 2 JCERTIFICATE OF SERVICE day of April, 2004 by placing on I do hereby state that a copy of the foregoing has been served all counsel of record on this IS*^ a copy of same in the United States mail postage prepaid. 3s filed district court eastern district ARKANSAS IN THE UNITED STATES DISTRICT COURT ADD 1 5 gflfli EASTERN DISTRICT OF ARKANSAS ' WESTERN DIVISION JAMES W. McCORMACK, CLERK By:_____________________________ LITTLE ROCK SCHOOL DISTRICT DEP CLERK PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. received DEFENDANTS MRS. LORENE JOSHUA, ET AL. APR 1 9 2004 INTERVENORS KATHERINE KNIGHT, ET AL. OFFICE OF DESEGREGATION MONITORING INTERVENORS The Joshua Intervenors' Memorandum in Support of Their Opposition to the Motion of the LRSD to Be Released from Further Supervision and Monitoring of Its Desegregation Efforts The LRSD has [not] substantially complied with [Plan] Section 2.7.1, as specified in [the court's] Compliance Remedy [Memorandum Opinion, September 13,2002,at 172, para. F]. Therefore, the LRSD   must continue to be subject to further supervision and monitoring of its implementation of the court-ordered remedy, until it demonstrates substantial compliance with that remedy. The retention of jurisdiction should be for a new period of two school years . This court's September, 2002 opinion identified the purpose of Section 2.7.1, the importance of substantial compliance with its terms, and the capacity which the LRSD must demonstrate as one element of its burden to justify the termination of the court's 1supervision. This court wrote: . I find that the purpose of 2.7.1 was to make that the programs under 2.7 actually worked to improve sure the academic achievement of African-American students. I further find that LRSD's substantial compliance with 2.7.1 was crucial to its commitment to improve the academic achievement of African American students\nfor, without performing a rigorous annual assessment of each of the many dozens of programs implemented under 2.7, it would be impossible to determine which programs were working and should be continued and which programs were not working and should be discontinued, modified, or replaced with new programs [at 150\nemphasis in original] . . . . I conclude that the court should continue supervision and monitoring of LRSD's compliance with this crucially important section of the Revised Plan in order to ensure that LRSD has in place an effective assessment program that will allow it identify and improve those programs that are most effective to in remediating the academic achievement of African American students, [at 168] These elements of the court's opinion help to frame the issues presented by the Joshua Intervenors' opposition to the LRSD motion. A. The Lack of the Capacity of the LRSD to Perform the Reouisite Assessments and Evaluations (1. ) For the reasons set forth in paragraphs 2 through 14, the LRSD has failed to \"[demonstrate] that a program assessment procedure is in place that can accurately measure the effectiveness of each program implemented under Section 2.7 in improving the academic achievement of African-American students: . . [\"Compliance Remedy,\" Mem. Opin., at 170\nsee also id. at 168] (2.) In its ruling of September 13, 2002, the court cited the recognition of the school board and upper echelon administrators that the LRSD had been without the capacity to prepare what the court termed \"in-depth and analytic program evaluations. T1 [Mem. 2Opin. at 156\nsee id. at 153 (Dr. Lesley)\nat 156-57 (school board)\nat\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_325","title":"Compliance court filings","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","School administrators","Educational law and legislation","Education--Evaluation"],"dcterms_title":["Compliance court filings"],"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/325"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nC. 1 F!^ 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 FILED U.S. DIS FRICT COURT EASTERN DISIRICI ARKANSAS SEP 2 4 2002 JAMES W. McCORfviAGK. CLERK By\n. September 23, 2002 i-OE-COUNSEL ROBERT McHENRY, P.A. DONNA J. McHENRY 8210 Hendesson Road Little Rock, Arkansas 72210 Phone: (501) 372-3425  F.ax (501) 372-3428 Email: mchenryd@swbell.net Honorable Judge William R. Wilson United States District Court 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: LRSD v. PCSSD, et al. Case No. LR-C- 82-866 received SEP 2 4 2002 desegregation MOMnOBlMB Dear Judge Wilson: Today we filed a motion for reconsideration. We found several errors in it and wish to correct them. We are hand delivering a substituted Motion for Reconsideration to the Court. The substitute motion does not alter or modify the substance of the motion filed today. It has been hand delivered to Judge Ray, the Little Rock School District counsel, the ODM and other counsel. Sincerely, -\u0026lt;fohn W. Walker f JWW:js Enclosure- Motion for Reconsideration cc: United States District Court Clerk All Counsel of RecordRECEIVED SEP 2 4 2002 OmCEOF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT y. NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO.1,ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL filed eastern^', SEP 2 4 2002 JAMES w. McCormack, CLERK Dtp CLERK PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS JOSHUA INTERVENORS MOTION FOR RECONSIDERATION The Joshua Intervenors respectfully request the Court to reconsider the following findings of fact and conclusions of law which it has reached. In making this request, Joshua has been time limited because of the exceeding length of the Courts Opinion and the fact that the Court has sought to address issues that were not the subject of the evidentiary presentation for which the Joshua Intervenors had the burden of proof. Joshua notes that the subject of the hearings, as determined by the Honorable Susan Webber Wright, then presiding Judge of this case, was for Joshua to present the areas of its greatest strength from among the various objections which Joshua had made to the Compliance Report of March 15, 2001. The Court did not indicate that she would allow Joshua to present evidence on matters other than those which were the subject of the hearing before the Court. We make this notation because the successor Court Judge, the Honorable William R. Wilson, has faulted Joshua for not presenting evidence beyond the issues on which evidence was taken. Joshua also notes that there was no issue that Joshua assumed the 1burden of proof upon with respect to Joshuas obligations and undertaking with respect to compliance. Joshua had no power to impose any particular compliance upon the school district. Furthermore, Judge Wright made it clear that the agreement between the State of Arkansas with respect to the loan forgiveness of the $20 million dollars which was loaned by the Arkansas Department of Education to the Little Rock School District was not to be the subject of these hearings. Her reasoning was that the matter was premature because all the parties to that agreement were not before the Court, Joshua had not signed off upon it and that it had nothing to do with whether or not Little Rock had substantially complied with meeting the requirements of the Revised Desegregation and Education Plan which the parties agreed upon in January of 1998. The Court has also addressed the issue of the involvement of the ODM with respect to the issues which were litigated before Judge Wright and Judge Wilson. The competence of the ODM, quality of the ODM: reports, the budget of the ODM and the relationship between ODM and Judge Susan Webber Wright, were not before the Court in evidentiary form. Those matters had nothing to do with Joshuas burden of proof in demonstrating that the LRSD had not substantially complied with the obligation of the Revised Desegregation and Education Plan. Nor was the issue of overall counsel fees with respect to the duration of the litigation and the payments to lawyers, and the public perception of those fees a matter of evidence to be considered when Judge Wright formulated the issues. The issue of attorneys fees has no relevance to the issue of whether LRSD has substantially complied with its obligations. The Court, Judge Wilson, has recited history regarding his perception of the fee event and made assumptions regarding those matters. In due respect to the Court, the assumptions are not valid and represent a predisposition which could only have come from previous attitudes regarding the 21 role of lawyers in this long standing case. The Joshua Intervenors were not informed at the time that this matter was reassigned to the Honorable William R. Wilson of the Courts negative attitude toward lawyers who were involved with and associated with this case. While Judge Wright may have had such attitudes, they were not expressed and do not form the basis for any judicial ruling. The attitude of the late Honorable Judge Henry Woods was well known. He disapproved of certain payments to certain counsel, i.e., counsel for Joshua and the legion of predecessor and associate counsel who were involved in this case when it was first filed as Aaron V. Cooper in 1956. I The parties are entitled, we submit, to have facts found upon the record which means a record which is developed in open Court. The fee issue is particularly sensitive because the Court has proceeded to make assumptions regarding fees and costs. In doing so, the principal erroneous finding is that the Joshua counsel, including the Legal Defense Fund counsel, were paid more than $3,750,000 for their work between 1987 and the present time. Joshua requests that the Court either delete its references to payments to counsel or afford the issue to be revisited in a manner which establishes the fact and does not further cloud public perception, a point to which the Court appears most sensitive. The Court also seems to disregard the role of Joshua because the Court makes no reference to how Joshua became involved in this case in the first place and why it was necessary for the school district to seek an interdistrict remedy in the first place. Those matters were not before the Court and we submit should be excised from the Courts Opinion. It is important to note that the late Honorable Judge Henry Woods refused to allow the Joshua Intervenors to intervene in the first place. It was His ruling that the Black plaintiffs did not need their own advocate or representative because the Court would protect the interests of the Black J Lchildren. That position was overturned by the Court of Appeals and from that point on, Joshua has been the real plaintiff seeking to validate and protect the Constitutional rights of African American children which the LRSD set out to accomplish through counsel who have since been discharged.^ With those points in the foreground and in context, Joshua respectfully asks the Court to reconsider its lengthy Memorandum Opinion of September 13, 2002 with respect to issues which were not before the Court or for which the Court may have made mistakes. 1. On page 2, the Court indicates that the Settlement Agreements of 1989 were to be implemented under the supervision of. . . the Office of Desegregation Monitoring. We believe the terminology to be inappropriate because Judge Wright never entered an Order determining the ODM to be the supervisor of any district. Furthermore, there is no evidence that the ODM ever performed in that role. 2. As stated preliminarily. Judge Wright required Joshua to develop the facts surrounding what Joshua believed were their strongest grounds for challenging the school districts request for release from Court supervision. The Court did not afford LRSD the opportunity to establish its case because the burden of proof rested with the Joshua Intervenors. Accordingly, Joshua requests that any facts that were found beyond the submitted grounds identified as subject areas for evidentiary hearings should be excised. In this respect, there was no burden imposed upon Joshua to demonstrate its own actions or conduct and no party requested that Joshua make such a demonstration. Moreover, the Agreement did not call for such a demonstration. The record will reflect that the District hired Philip Kaplan, P.A. Hollingsworth, Janet Pulliam and their associates to pursue the interdistrict litigation which resulted in the 1989 Settlement Agreement but which Settlement Agreement was reached without those counsel. 43 The Court notes on page 7 the role of Judge Wright with respect to Her supervision of this overall case. The Court omits, however, reference to the fact that the LRSD filed a motion seeking to have Judge Wright recused from the case. Although she reflised to recuse, her withdrawal made the recusal issues moot for purposes of appeal. The Court appears to have adopted LRSDs reasoning set forth in its motion for recusal when it addresses the role of the Office of Desegregation Monitoring. We believe that is inappropriate, with all deference to the Court, and we believe that it tends to denigrate the significance of Judge Wrights work in seeking to implement through use of the ODM the dictates of the 8\"' Circuit. 4. When the ground rules were set by Judge Wright, she indicated that the Joshua Intervenors should present nonciimulative evidence regarding the areas which Joshua most strongly regarded from the among the many areas to which it objected. Page 7, footnote 12. By ruling that cumulative evidence would be disallowed, the Court narrowed the hearing time and the presentation of evidence. The focus of the Court was upon brevity and substance. The successor Court agreed to follow the procedure set forth by Judge Wright. 5. In footnote 15, page 9, the Court notes that this action was filed on November 30, 1982, but it later gives the impression that Joshua counsel have been involved in this case since that time. Joshua requests that the Court, if it must address the history at all again, acknowledge that Joshua did not participate before the Honorable Henry Woods in the liability phase of the case as it is now styled and it only intervened at the remedy stage in 1987. Although this matter is not the subject of the evidentiary hearings, the Court may make this correction by reference to the docket entries and by reference to the Court of Appeals Decision which allowed Joshua to intervene for purposes of remedy. Joshua further notes that the 1989 Settlement Agreement 5effectively merged the captioned case with, inter alia, Clark v. The Board of Education of the Little Rock School District. Clark was the continuation of Aaron v. Cooper. Accordingly, this is a 46 year old case rather than a 20 year old case because the liability rulings of Clark remained and because, despite the beliefs of the late Judge Bill Overton, there was never a determination that the LRSD had achieved unitary status. 6. In footnote 30, page 16, the Court indicates that the claims for relief and remedies differed from those being sought in Oark. Joshua requests that the Court clarify those differences for as Joshua reads Judge Woods later Opinion, Judge Woods, himself, found the school districts to be faulted for both interdistrict and intradistrict violations of the rights of African American children and he determined that consolidation with a resulting desegregation plan for the consolidated district would be necessary. Judge Woods appointment of Special Master Aubrey McCutcheon is not mentioned. Mr, McCutcheon made findings during the remedial process that the districts were continuing to implement their policies by engaging in practices which tended to discriminate against African American school children. We believe that if history is to be written it cannot be fair unless the myriad hearings and other developments before Mr. McCutcheon are placed into perspective Mr. McCutcheon is a necessary connection to legacy of Judge Henry Woods who the Court acknowledges to be the Courts mentor. 7. In footnote 47, pages 26 and 27, the Court makes reference to the evolution of the ODM and its budget. That matter was not before the Court. While Judge Wrights approval of the ODM budget is a matter of public record, we believe the Court may wish to excise these figures because they are inaccurate. Joshua is aware that the ODM budget was never fully spent. Joshua submits that the Court may wish to readdress this issue also because Judge Wright 6approved the budgets and the manner in which Your Honor treats the budget seems to be at least an implicit criticism of Judge Wrights actions and of the Court of Appeals for requiring the creation of the office in the first place. We submit that the ODM and its budget are not fair issues for the instant proceedings and that the Courts attitude regarding the merits of plaintiff s objections may be clouded by the belief expressed that too much money has been spent on the professional group. In making the request tor the reconsideration on this point, we note that all of the governmental parties have resisted in one form or another the ODM activities. We also note that the Court may be signaling that it wants to end the role of the ODM as that role was established and created by the 8\" Circuit. There is no evidentiary basis for doing that or for allowing that inference to publicly flow. On many occasions, Judge Wright commended the ODM work as being useful, helpful and even important in helping the districts achieve desegregation goals. 8. On page 38, the Court notes that on December 27, 1996, Judge Wright held that LRSD would benefit from a temporary hiatus from monitoring. We have searched the record and do not find that she ever lifted that Order. Accordingly, LRSD has not been monitored as contemplated since 1997. Instead, it has been in advisory position to the LRSD. The Court has to also note with reference to the budget of ODM which it set forth on page 27 that monitoring for LRSD when done by the ODM, a 35% cost for LRSD, would have been approximately $250,000 per year. There surely cannot be an inference that Joshua was to take over the role of ODM with respect to monitoring at a rate of approximately $49,000 per year, a point the Court refers to at least five times. (Pages 39, 42, 43, 88 and 90). 9. On page 38, the Court heads a discussion the perplexing final resolution of Joshuas 7request for still more attorneys fees from LRSD Joshua requests the Court excise this section for several reasons. First, it indicates a bias or hostility toward Joshua counsel. Second, it implies\nests that the terms of the Settlement were not made collusion between the lawyers. Third, it suggi known to Judge Wright, a conclusion not supported by any evidence. Fourth, it complains unfairly that a matter on appeal should not be resolved by the parties. The Court criticizes an Agreement without evidence about, or without inquiring into, it. The implication that LRSD and Joshua entered into an attorney client relationship suggests professional misconduct on the part of the attorneys. Finally, there is nothing to indicate that for the monthly amount of $4,000+ Joshuas counsel agreed to undertake all the monitoring aspects, including the ODMs role, of LRSDs implementation of the plan. The Court takes issue with Joshua counsels approved 1997 hourly rate of $250. Nonetheless, counsel has been awarded even greater fees than that as was His Honor awarded greater fees while in private practice. Surely, the Court understood that Joshua did more than 16 hours per month in monitoring this case. There is no record to establish this fact, however, and if it is important for public perception or otherwise, Joshua is prepared to demonstrate the hundreds of meetings held with school district officials during the three year period\nnumerous meetings with the ODM\npublic confrontations during monitoring occasions where Joshua counsel were threatened with arrest and where because of the persistence and vigor of Joshuas monitoring, the district revised its policies. We, therefore, believe that it is important for the Court to address the issue by hearing, affording appropriate and reasonable time for developing the issues, or, that the matter be removed from the Courts Opinion because it is based only upon speculation and conjecture. Joshua notes here that the process requires lawyers. For instance, Steve Jones, representing the NLRSD and Sam Jones representing the PCSSD basically 8sat in Court throughout these proceedings and were paid fees and costs while Joshua counsel have not been paid a dime. But the process affords the districts the right of counsel and the districts have had no reluctance in paying their counsel on a contemporaneous basis and they are not held to public or Court contempt for being paid. .In page footnote 58, the Court guesses that all attorneys have been paid at least $8 million dollars. A guess is inappropriate for a Court, we submit, when the facts are more easily ascertainable and the facts establish that the payment for Joshua in 1990 represented payments for 34 years of work and costs during that time. There is no estimate for the amounts which the districts paid their counsel to forestall desegregation before 1990. On the other hand, this issue has already been addressed and we submit has no place in this Opinion because it does not contribute to the issues which the Court heard. Undersigned counsel Walker does not accept the Courts conclusion that he has directly benefitted from the perpetuation of this case. On the other hand, the three districts have received almost one billion dollars from the State of Arkansas since 1990 because of the various actions undertaken by counsel. Careful inquiry by the Court would disclose that the annual desegregation amounts from the State to the three school districts is in the range of $50 million or more per year. Were this a contingent fee case, plaintiffs counsel would have indeed benefitted. 10. The Court makes reference on page 46 to the achievement disparity goals approved by the Court of Appeals as being unreachable citing the testimony of Drs. Walburg and Armor which was given in 1996. That testimony came after the original Settlement Agreement in 1989 and then preceded the 1998 Settlement Agreement. Accordingly, whatever views Walburg, Armor and even Judge Wright had about the elimination of the achievement gap, the parties 9agreed to address it in the manner set forth in the Plan. The Courts comments regarding Walburg and Armor are inapposite to the hearing which the Court held and should play no part in the Courts ruling. 11. On pages 47 and 48, the Court refers to the failure of objection by the ODM and Joshua to the Interim Compliance Report. There is no record basis for this, i.e., no witness testified to this effect and there is no evidence that Joshua was silent at any time. The only evidence is that Joshua was continually involved and seeking to be involved in the devisation of policies and procedures and was continually meeting with district officials regarding compliance issues. See Court Exhibits 553 through 569. 12. On page 48, the Court chastises ODM for its report of disciplinary sanctions which was filed on June 14, 2000. The report was made to Judge Wright before she relinquished her jurisdiction and before the March 15 report seeking release from Court supervision was filed by LRSD. She was aware and there are many cites in the record to reflect that ODM presented its report in such a way as to inform the district of the facts it found and to make recommendations regarding those facts within the context of discussions which followed subsequent to the submissions of the reports. Had Judge Wright found criticism with the ODM reports, we believe the Court was obliged to share those criticisms with the parties prior to LRSD having filed its report seeking relief from Court supervision. See pages 48 through 50. On page 49, the Court acknowledges that the March 15 report of the school district failed to adequately address the disproportionality of African American student discipline. The report is not evidence, as Mr. Chris Heller acknowledged. This failure by itself demonstrates that the issue of discipline was not ripe for objection or release at the time the report was made. If the data 10 were not available and were not presented there would be no basis for an objection from Joshua regarding the matter. ODM should not be faulted, nor should Joshua, for failing to object to data which did not exist at the time. 13. On pages 52 through 54, the Court notes that Joshua did not present evidence or arguments that LRSD was not in substantial compliance with its obligations regarding faculty and staff, student assignment, special education and related programs, parental involvement, and school construction and closing. The Court had previously instructed Joshua not to present any of that evidence. The Court now states that Joshuas failure to present any of that evidence requires a finding that they have abandoned those arguments. Joshua finds it incongruent for them not to be allowed to present any evidence on certain matters and upon compliance with a no evidence presentation then receive a finding that they abandoned their position. Surely, the Court will not hold it against Joshua when it did not present evidence that the Court refused to let in in the first place. 14. On page 58, the Court appears to chastise Joshua counsel for never raising a compliance issue under Section 8.2 of the Plan. The Plan did not require Joshua to raise the specific compliance issue in order for them to oppose release from Court supervision. Furthermore, as pointed out above, there was no place in this hearing on the issues as formulated for this issue to be addressed. Furthermore, there is much evidence that Joshua regularly brought matters of compliance to the attention of the school district administrators. See Court Exhibits 553-569. 15. The Court interprets footnote 2 of the Revised Plan (Opinion page 60) as not being the intention of the parties to have the remediation goal fully achieved within three years. 11Joshuas evidence did not say that it did. For Joshuas evidence was that certain goals were to have been frilly met while others would be ongoing. Surely, the goal of remediation of achievement disparities would be ongoing but elimination of disparities in discipline need not be, for example. The Court makes an assumption regarding the reason for this footnote. There is no basis for the assumption from the record. 16. In footnote 67, page 60, the Court seems to be uncomfortable with the practicality of the goals in the 1990 Plan regarding achievement disparities. Judge Wright also had some discomfort with that goal as previously noted but the achievement goals were agreed to and. contrary to the opinion of the Court, they must be implemented. The question is not whether they should have been agreed to by the LRSD, for they were, but whether they must deliver on those goals or promises. There is a presumption that there is a correlation between student achievement and money expenditures by school districts. Twelve years after the money began to flow and between one half billion and a billion dollars more spent in this district than which otherwise would have been spent, the achievement disparities remain. The only conclusion to be drawn is that the substantial monies expended were not used for the purpose of remediating achievement disparities between African American and white students The beneficiaries of the monies have primarily been white students who have seen their achievement rise in ways to cause the gap to remain if not increase between and their still less fortunate brethren. 17. Beginning on page 63, the Court makes an analysis regarding the Green factors. We submit that the Green factors do not apply to this Settlement Agreement and that those factors should be excised. The Court takes the position that LRSD went beyond what it was required to do and voluntarily assumed desegregation obligations. We submit that these were 12 not voluntarily entered into, they were the result of negotiation brought about by the strength of the Joshua litigation position They constitute benefits to the class of minority children which were bargained for by their counsel. The district was not doing the children a favor\nrather, it was meeting an obligation which has been unaddressed during the 46 years of this litigation. 18. On page 72, the Court emphasizes that LRSD has never been adjudicated to be a constitutional violator. We ask that the Court reconsider that position if for no other reason than that the settlement did not address fault. The Court discusses Judge Overtons Opinion and makes reference to the appellates decision affirming Judge Overton at 705 F.2d 265. The Court of Appeals approved Judge Overtons Decision because the Plan before the Court represented the school boards attempt to temporarily reorganize attendance patterns while the school board pursued longer ranged plans to ensure an integrated school system citing this case. In other words, had this case not been filed, the Court of Appeals Decision arguably would have been otherwise. On page 74, the Court noted that LRSD operated under the 1990 Settlement Plan for 8 years,  a long time. The Court fails to note that during that long time Judge Wright found considerable disenchantment with the manner of operation and even required the school board members to come to Court to hear the evidence on many occasions. The Court even found the school district to be in contempt during this time. The Court disregards that history and seeks to demonstrate that LRSD has been a model of compliance during the Judge Wright years. That simply is not the case. This Court recognized as much on pages 30-32 of its own Opinion. The Court is requested to explain on the one hand the findings of Judge Wright and on the other hand its compliments of the district for these 8 years. 19. On pages 77 through 85, the Court appears to take issue with the concept that LRSD 13specifically agreed to narrow the achievement gap between African American and other students. This lead the Court to impose an obligation upon Joshua to demonstrate that minority student achievement was a vestige of de jure desegregation. The Court thus imposed a liability concept upon Joshua during the hearing without any notice and without any cause. The Settlement Agreement is a remedy and as such may address issues other than those for which there has been a specific violation. But when the Settlement Agreement is approved by the Court it becomes the law of the case and the parties do not have to readdress at each hearing the underlying basis for the remedy being provided. 20. On page 87, the Court makes a finding of fact (No. 3) that Joshua did not pursue the compliance issues by use of the correct procedures before objecting to the report as a whole. As stated before, Joshua was not obliged under the plan to do so. 21. In addressing the findings of fact pages 87 through 160, the Court appears to have adopted the LRSDs proposed findings. While the Court has great discretion, we make the following notations inter alia: a) on page 87, the Court speculates regarding resolution between Joshua and the school districts\nb) the Court speculates that Dr. Lacey would take appropriate action if she perceived any race based treatment despite the absence of any record of her past actions on this issue, page 93\nc) on page 94, the Court found that since 1989, LRSD had a good record of acting in good faith (see paragraph 18 supra)\nd) on page 96, the Court accepted the belief by Dr. Linda Watson that both Joshua 14e) f) g) h) i) J) k) and ODM were provided with copies of a compliance plan and did not require any evidence\non page 96, the Court without any record basis, concluded that Joshua counsel and staff have free access to LRSDs offices and schools and routinely received copies of any requested documents\non page 100, the Court excuses the districts failure in excluding Joshua from planning and other meetings that the district had regarding compliance\non pages 103 through 107, the Court does not address the elimination of disparities as being intended by the Plan\nrather, the Court addresses overall 1 reduction in suspensions where the racial disparities remain\non page 106, the advisory ODM Report is criticized by His Honor with respect to discipline but Judge Wright did not make the same criticism. Had she done so, a duty to address the issue would have been created\non page 109 a suspension index was created without any explanation (see finding 30), i.e. no witness explained it. The Court accepted the calculation by LRSD that there was no diminishing of disparity in discipline between 1997 and 2000\nthe Court on page 1 10 imposed upon Joshua a burden to prove that disproportionality in discipline was a result of racial discrimination. Joshua submits that that is the wrong legal standard to be applied under the law of this case. The issue is relief, not causation\non page 111, the Court disregarded the incidents of discrimination presented in 151) m) n) o) P) discipline. (See footnote 108) In doing so, the Court disregarded the admonition by Judge Wright not to present cumulative evidence regarding any matter and then held that the presented incidents were too isolated to allow judgment regarding the entire school system\non page 112, the Court may wish to reconsider the word probable in finding 38 in discussing the testimony of Dr. Watson. A review of her testimony establishes that environmental factors may be - not probably were the explanation for racial disproportionality\non page 113, the Court notes that Dr. Watson indicates that African American teachers suspended African American students more than white teachers. That appears to be a finding of racial treatment by African American teachers toward African American students. This establishes continuation of systematic discrimination toward African American students as well as perpetuation of disparities\non page 115, at footnotes 111-112, the Court seems to condone disparities in sports activities by noting on page 1 16 that students tend to gravitate toward sports that they have grown up playing. That in itself we submit is racial, i.e., whites-golf, tennis, soccer\nblacks - football, basketball and track\non pages 116-117, in addressing the testimony of Ray Gillespie, the Court does not address the inferences to be taken when white coaches publicly mistreat Black athletes nor the reasonable perceptions which are influenced by those actions\non page 118, the Court in finding 9, accepts a means test for participation in 16extra-curricular activities but this flies in face of the reality that most African American children in the LRSD - in contrast to its white students- cannot meet the means tests imposed\nq) with respect to advanced placement courses, the district has increased the enrollment of white students to a point to where the preexisting disparity has been extended. The programs undertaken by the district which are cited by the Court are minuscule. For example (SMART involved a summer number of 200 pupils and Teachers of Color could only involve six teachers per year in being prepared for AP. This program was started in January, 2001, less than two months before the Report herein), r) the Court disregarded the testimony of Jason Mercer who presented multiple incidents of unfair treatment at famed Little Rock Central High School and the Court entirely disregarded the testimony regarding of parent Romona Hortons travails regarding her precocious children who were also enrolled at Little Rock Central High School, s) the Court accepts a means test for participation in the University Studies Program despite the obvious conclusion that it will disqualify the great preponderance (90%) of African American students who attend Hall High School. The Court also concluded that in one instance, LRSD solicited a private donation to pay tuition for an African American student to take a course offered under the University Studies Program. The testimony does not identify that the race of that student. The Court is requested to correct this finding\n17t) with respect to counseling services, finding no. 24, page 133, the Court may wish to revisit this finding because it seems at odds with Ms. Watsons testimony\nu) with respect to academic achievement, the Court notes the obligation of the LRSD to be to approve the academic achievement of African American students. The issue is not simply to improve the achievement of African American students, rather, it is to bring their achievement levels to a range within reasonably proximity of the achievement levels of white and other students\nv) with respect to page 146, finding no. 16, there is no evidence of what Joshua counsel knew. Indeed, the 8\"' Circuit said that the parties should not retreat from the concept of eliminating the achievement gap\nand w) on page 114, finding 18, the Court again speculates regarding the loan provision forgiveness by the State of Arkansas toward LRSD. The Court then goes ahead and gives LRSD two more years in order to comply with the State agreement without there being joinder of, or a hearing upon the issue. The Court faults Joshua for not raising that issue but fails to acknowledge that when it was raised by Joshua, Judge Wright chose not to address it for the reasons set forth on pages 1 and 2, supra. This finding was not made upon any evidence regarding the Joshua objections to LRSDs Motion for Release from Court Supervision. CONCLUSION The Joshua Intervenors respectfully submit that there are compelling reasons for the Court to revisit the record in order to determine whether the Courts Findings of Fact and Conclusions of Law are supported by the evidence presented during the hearings before Judge Wright and His 18Honor. We also note that it is appropriate for the Court to again consider the context of the evidentiary presentations and withdraw its conclusions regarding those areas of compliance that the Court did not allow evidence to be developed regarding'g- Respectfully submitted, Robert Pressman, Mass Bar No Joh^V^Walker, AR Bar No. 64046 22 Locust Avenue Lexington, MA 02421 (781) 862-1955 IN W. WALKER, P. A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501)374-4187(Fax) J Rickey Hicks, AR Bar No. 89235 Attorney at Law Evergreen Place 1100 North University, Suite 240 Little Rock, Arkansas 72207 (501)663-9900 19 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been sent L prepaid to the following counsel of record, on this day of F ncfU.S 4,2c S. Mail, postage 2002: Mr. Christopher Heller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Sam Jones ' WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Mr. Richard Roachell ROACHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 John^. Walker 20 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS OCT 0 1 2002 JAMES W CORMACK, ERK LITTLE ROCK SCHOOL DISTRICT, Plaintiff, vs. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al.. Defendants, MRS. LOREN JOSHUA, et al.. Intervenors, KATHERINE KNIGHT, et al.. Intervenors, * * * A * *  it * ie ii k * 4:82CV00866 RECEIVED OCT - 3 2002 OFFICE OF DESEGREGATION MONITORING ORDER Attached is a copy of a letter from Mr. Walker dated October 1, 2002. I presume it should be treated as a motion of some kind. Accordingly other counsel of record may respond within the time permitted by the Federal Rules of Civil Procedure. IT IS SO ORDERED. Dated this 1day of October, 2002. U ED S' ES DISTRICT JUDGE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE AND'OR CoY.__ 6 8 0OCT. 1.2002 11:12AM JOHN M WALKER PA\" NO.667 p.2 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 October 1,2002 OP COUNSEL ROBERT McHENRY.PJL DONNA J McHENRY 3210 Hendeoison Hoad Little Rock, Arkansas 72210 Phone (5OI) 372-342B  Fax (5O1) 372-8428 Email: mcheniyd^wbelLnet Honorable Judge WSliam 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 Wflson: 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 inposed 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 feet 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 forsce or require a continued responsibility for monitoring of the intensity which the Court of Appeals for the 8* Circuit required. In this respect, we note that the Court created the ODM and expected the ODM to carefully monitor on a daily basis, fiill-time, the activities of the Little RockOCT. 1.2002 11:12AM JOHN W WALKER P A NO.667 p.3 Page 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, W. WalkCT JWW\njs cc: All Counsel of Record Ms. Ann MarshallIN 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,ETAL RECEIVED DEFENDANTS MRS. LORENE JOSHUA, ET AL OCT -8 2002 INTERVENORS KATHERINE KNIGHT, ET AL OFRCEOF DESEGREGATION MONITORING INTERVENORS PLAINTIFFS RESPONSE TO JOSHUA INTERVENORS MOTION FOR RECONSIDERATION AND MOTION FOR NEW TRIAL Plaintiff Little Rock School District (hereinafter LRSD) for its Response to Joshua Intervenors (hereinafter Joshua) Motion for Reconsideration and Motion for New Trial states: The LRSD will respond to each numbered paragraph of Joshuas Motion for Reconsideration in turn. 1. The Courts use of the term supervision on page 2 its September 13, 2002, Memorandum Opinion (hereinafter Opinion) was appropriate. It is common for a school district implementing a court ordered desegregation decree to be referred to as being under court supervision. See Freeman v. Pitts. 503 U.S. 467, 471 (1992)(The DCSS has been subject to the supervision and jurisdiction of the United States District Court for the Northern District of Georgia since 1969 . . . (emphasis supplied)). The Office of Desegregation Monitoring (ODM) acted under the authority of the Court to supervise the LRSD. 2. Evidence related to Joshuas failure to raise compliance issues during the term of the LRSDs Revised Desegregation and Education Plan (hereinafter Revised Plan) was relevant to the Boards good faith, to assist the Court in interpreting the Revised Plan, and to the Boards estoppel defense.3. The ODM works for the Court, and it is entirely appropriate for the Court to define its role and for the Court to take into account the LRSDs position with regard to ex parte contact between the Court and ODM. 4. Joshua cannot blame their failure to come forward with evidence on the Courts focus on brevity and substance. In any event, Joshua agreed to narrow the issues and the time limits imposed by the Court and cannot now be heard to complain. See Tr. Dec. 11, 2001, pp. 36-37. 5. The LRSD denies that footnote 15 on page 9 gives the impression that Joshua counsel have been involved in this case since 1982. The record is clear that Joshua intervened only after the LRSD prevailed in this case. While the 1989 Settlement Agreement did also resolve the Clark and Cooper cases, the Court is correct that this is a 20 year-old case. 6. The Court correctly noted that the claims for relief and remedies sought differ in the present case from Clark. Clark was simply a continuation of the Cooper case filed in 1956 asking that an injunction be issued against continued segregation of the races in the Little Rock public school system. Aaron v. Cooper. 243 F.2d 361, 362 (8* Cir. 1957). The LRSD filed this case in 1982 seeking consolidation of the three Pulaski County school districts based on interdistrict constitutional violations by the other districts and the State of Arkansas. Sec LRSD V. PCSSD. 584 F.Supp. 328 (E.D. Ark. 1984). The LRSD denies that either the late Honorable Henry Woods or Special Master Aubrey McCutcheon found that the LRSD continued to unlawfully discriminate against African-American students. 7. The LRSD denies that the information in footnote 47 on pages 26 and 27 is inaccurate. It is entirely appropriate for the Court to evaluate and comment on ODMs productivity. Nothing in the Courts opinion suggests that the Court has violated or intends to violate the Eighth Circuits mandate. 8. The LRSD denies that the ODM has been in an advisory position to the LRSD since December 27, 1996. The ODM returned to its monitoring role at the conclusion of the 2Revised Plans transition period. See Revised Plan,  10. Nothing in the Courts opinion suggests that counsel for Joshua was to take over the ODMs monitoring responsibilities. Counsel for Joshua was obligated to monitor the LRSD based their ethical duty to their clients and their implied contractual duty to the LRSD. 9. The LRSD denies that the Courts discussion of Joshuas 1996 request for attorneys fees indicates bias or hostility toward counsel for Joshua, implies collusion between the lawyers, suggests Judge Wright did not know the terms of the settlement, complains unfairly that a matter on appeal should not be resolved by the parties, suggests that Joshuas counsel agreed to assume the role of ODM, or holds counsel for Joshua to public contempt for being paid. As to counsel for Joshuas attempt to justify the monitoring fees paid by the LRSD, the LRSD denies that counsel for Joshua attended hundreds of meetings with school District officials, that counsel for Joshua was ever threatened with arrest, and that the LRSD revised its policies because of counsels persistence and vigor. The LRSD also denies the implication that counsel for Joshua was responsible for the additional funding the three Pulaski County districts receive from the State by virtue of litigation related to the 1989 Settlement Agreement. While the discussion of professional fees is not directly related to the issues before the Court, the Court was free to include this discussion in its opinion. 10. The LRSD denies that the testimony of Drs. Walberg and Armor was inapposite to the issues before this Court. Their testimony provides the context in which the LRSD and Joshua agreed to the Revised Plan and the basis on which the Court approved the Revised Plan, both of which are relevant to interpreting Revised Plan  2.7. 11. The LRSD denies that there is no evidentiary basis for the Courts finding that ODM and Joshua did not object to the LRSDs Interim Compliance Report. Dr. Bonnie Lesley testified to this fact (Tr. Nov. 19, 2001, p. 287), and it is stated in the introduction to the LRSDs Final Compliance Report (CX 870, p. iv.). 312. The LRSD denies that the Court was required to share with the parties any criticisms it had of ODMs June 14, 2000, discipline report. The LRSDs Interim Compliance Report was admitted into evidence as CX 869. The LRSD denies that the issue of discipline was not ripe for objection after the LRSD filed its Interim Compliance Report. Dr. Linda Watson testified that ODM and Joshua were regularly provided copies of the Districts Disciplinary Management Reports. See Tr. Nov. 19, 2001, p. 83. 13. The Court is correct that Joshua failed to present any evidence that the LRSD was not in substantial compliance with its obligations regarding faculty and staff, student assignment, special education and related programs, parental involvement and school construction and closing. Joshua did not present any evidence on these issues precisely because it abandoned those arguments. See Tr. Dec. 11, 2001, pp. 36-37. Joshua cannot now be heard to complain that the Court did not allow Joshua to present evidence on those issues. 14. The Court found that Revised Plan  8.2 did not expressly require Joshua to raise compliance issues pursuant to the process set forth therein. See Memorandum Opinion, p. 89. Even so, evidence of Joshuas failure to raise compliance issues was relevant to the Boards good faith, to assist the Court in interpreting the Revised Plan, and to the Boards estoppel defense. The LRSD denies that there was much evidence that Joshua regularly brought matters of compliance to the attention of the school district administrators. 15. Footnote 2 of the Revised Plan is unambiguous, and the Court correctly interpreted the plain language of the footnote. The LRSD denies that Joshua introduced evidence that certain goals were to have been fully met while others would be ongoing. 16. The LRSD denies that the Court must presume that there is a correlation between student achievement and money expenditures by school districts. The LRSD also denies that only conclusion to be drawn from any continuing racial disparity in achievement is that the beneficiaries of desegregation funding have been white students. Joshuas argument ignores the fact that the racial disparity in achievement exists when students arrive for their first day of 4school. As Drs. Walberg and Armor explained, it would be impossible for the LRSD to eliminate the racial disparity in achievement given the current racial disparity in socioeconomic status. 17. The LRSD denies that the Court improperly refened to the Green factors. The Revised Plan constituted an agreement voluntarily entered into by the LRSD. The LRSD entered into that agreement because it believed implementation of the Revised Plan was in the best interest of African-American students, and indeed, all students in the District. 18. The Court is correct that in this case the LRSD has never been adjudicated a constitutional violator. The LRSD denies that it was held in contempt during the implementation of the 1990 settlement plan. 19. The Court correctly interpreted Revised Plan  2.7 as not requiring the LRSD to eliminate or reduce the racial disparity in achievement. Joshua sought to use the racial disparity in achievement to establish the LRSDs noncompliance with Revised Plan  2.7, and the Court correctly placed the burden of proof on Joshua to establish a causal connection between the current racial disparity in achievement and the LRSDs alleged noncompliance. 20. The Court acknowledged that the Revised Plan did not expressly require Joshua to raise an issue pursuant to Revised Plan  8 before it could object to the LRSDs final report. Sc^c Memorandum Opinion, p. 89. 21. The LRSD will respond to each subparagraph of paragraph 21 in turn: (a) The Court drew a reasonable inference from the fact that Joshua failed to further pursue these issues and from Baker Kurruss testimony that he asked Dr. Camine to work with Joshua to resolve these issues. See Tr. July 24, 2002, p. 751. (b) Dr. Lacey so testified (Tr. July 24, 2002, p. 777), and no record of past actions is required for the Court to credit the testimony of a witness. (c) Joshua points to nothing in the record which would indicate that the Courts characterization is erroneous. 5(d) In fact, Junious Babbs testified that ODM and Joshua were provided copies of the Compliance Plan and Compliance Handbook.Court. See Tr. July 5, 2001, pp. 73, 77 and 78. Moreover, ODMs August 11, 1999 report establishes that ODM received both. See pp. 39 and 40. Counsels suggestion on cross-examination that Joshua did not receive them is not evidence. See Eight Circuit Model Jury Instructions (Civil) 1.02 (2001). Thus, the only evidence before the Court was testimony that ODM and Joshua did receive the Compliance Plan and Compliance Handbook. (e) The record in this case includes motions by the LRSD after Joshua filed its objections to stop counsel for Joshua from entering the offices of LRSD staff members unexpectedly and from using the Freedom of Information Act (FOIA) to conduct discovery. Joshuas opposition to these motions provides ample support in the record for the Courts finding. (f) The Revised Plan did not prohibit the LRSD from holding meetings without Joshua being present. Thus, there was no failure for the Court to excuse. (g) The Court conectly found that Revised Plan  2.5 did not require the LRSD to eliminate or reduce the racial disparity in discipline. (h) The criticisms offered by the Court were readily apparent from the report itself, and Joshua cannot blame the Court for failing to put it on notice of these shortcomings. (0 The suspension index is a well-recognized statistic and has been explained in numerous desegregation cases. See, e^, Hoots v. Pennsylvania, 118 F.Supp.2d 577, 608 n.25 (W.D. Pa. 2000). The Court was free to accept the LRSDs calculations which were admitted into evidence without objection. Sec CX 743. (j) The Court correctly interpreted Revised Plan  2.5 as not requiring the LRSD to eliminate or reduce the racial disparity in discipline. Joshua sought to use the racial disparity in discipline to establish the LRSDs noncompliance with Revised Plan  62.5, and the Court correctly placed the burden of proof on Joshua to establish a causal connection between the current racial disparity in discipline and the LRSDs alleged noncompliance. (k) The Court correctly noted that not a single student testified that he or she had been discriminated against in the imposition of discipline. The LRSD fails to see how the Courts admonition not to present cumulative evidence prevented Joshua from calling any students to testify during the hearings on Revised Plan  2.5. (1) The Courts description of Dr. Watsons testimony is accurate given the context in which the statement was made. (m) The fact that African-American teachers suspended African-American students more than white teachers is not a finding of racial mistreatment by African- American teachers toward African-American students. (n) The Courts statement that students of all races tend to gravitate toward sports that they have grown up playing and that they enjoy does not condone racial disparities in activities. (o) The only inference to be drawn from testimony of Ray Gillespie is that the LRSD responded appropriately when confronted with allegations that white coaches mistreated African-American student athletes. (P) The Court did not accept a means test for participation in activities. The LRSD presented evidence of the steps it took to ensure that no student was denied participation in an activity due to a financial barrier, and Joshua came forward with no evidence that a single student was denied participation in an activity because of a financial barrier. (q) The Revised Plan did not require the LRSD to eliminate or reduce the racial disparity in the percentage of students taking AP courses. The LRSD has worked hard to increase the number of African-American students in AP courses, and it has done 7so. The LRSDs success cannot be diminished by Joshua characterizing the LRSDs efforts as minuscule. (r) The Court gave due weight to the testimony of Jason Mercer and Ramona Horton. (s) The Court did not accept a means test for participation in the University Studies Program at Hall High School. It is true that Dr. Lacey did not identify the race of the student for whom a private donation was sought so the student could participate in the University Studies Program. See Tr. July 24, 2002, p. 802. However, it was reasonable for the Court to infer that the student was African-American for two reasons. First, when counsel for Joshua began this series of questions, he limited the question to African- American students. See Tr. July 24, 2002, p. 801. Second, there was evidence that African-American students were more likely to be poor, and therefore, to be excluded by financial barriers to activities. See Tr. July 24, 2002, p. 602 and 624. (t) (u) The Court gave due weight to Ms. Watsons testimony. The Court correctly interpreted Revised Plan  2.7 as not requiring the LRSD to eliminate or reduce the racial disparity in achievement. (v) The Court may infer that counsel for Joshua read Revised Plan  2.7 before agreeing to it, and therefore, knew what it required. (w) The Court is correct that Joshua did not raise the issue of the LRSDs March 19, 2001, agreement with the State of Arkansas in its Opposition to the LRSDs Motion for an Immediate Declaration of Unitary Status filed May 30, 2002. WHEREFORE, the LRSD prays that Joshuas Motion for Reconsideration\nthat Joshuas Motion for New Trial or in the Alternative Motion for Relief from Judgment or Order be denied\nthat the LRSD be awarded its costs and attorneys fees expended herein\nand that the LRSD be awarded all other just and proper relief to which it may be entitled. 8Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) John C. Fendley, Jr. (#92182) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) 37^=iOH------- Chrislopher Heller F:\\HOME\\FENDLEY\\LRSD 200l\\unitary-rcsponse-mot-rcconsidCT wpd 9CERTIFICATE 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 October 7, 2002: 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 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 F:\\HOME\\FENDLEY\\LRSD 2001\\iinilary-response-mot-reconsidCTwpd 10 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO.4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ET AL RECEIVED DEFENDANTS MRS. LORENE JOSHUA, ET AL OCT -8 2002 INTERVENORS KATHERINE KNIGHT, ET AL OFFICE OF DESEGREGATION MONITORING INTERVENORS PLAINTIFFS RESPONSE TO JOSHUA INTERVENORS OCTOBER 1. 2002 LETTER For its response to the Joshua Intervenors (\"Joshua\") October I, 2002 letter. Plaintiff Little Rock School District (LRSD) states: 1. For more than decade, Joshua has reported to the Eighth Circuit Court of Appeals and to the District Court that it was engaged in the process of monitoring LRSDs compliance with LRSDs various desegregation obligations. At one oral argument, counsel for Joshua introduced a number of Joshua monitors to the panel of the Court of Appeals. 2. The 1998 Revised Desegregation and Education Plan formalized a process for resolving any desegregation compliance problems which were discovered during the course of Joshuas monitoring. The obvious purpose of that process, which is found beginning at  8.2 of the Revised Plan, was to allow the quick resolution of any compliance issues for the benefit of both the Joshua class members and the LRSD.3. There is nothing on page 172 of the Courts September 13,2002 Order which imposes upon the Joshua Intervenors any obligations which are not contained in the Revised Desegregation and Education Plan or inherent in the class representatives and class counsels obligations to the class members. 4. The Courts September 13, 2002 Order followed weeks of litigation about issues which Joshua did not raise with the LRSD during the term of the Revised Plan. By requiring that Joshua and LRSD follow the \"process for raising compliance issues\" set forth in  8.2, s^. of the Revised Plan, the Court is simply requiring the parties to abide by the terms of their own agreement. 5. The LRSD can find in the Courts Order no basis for Joshuas argument that the Court has somehow imposed \"a greater burden upon Joshua than it has imposed upon the Office of Desegregation Monitoring.\" The LRSD does not read the Courts Order as \"imposing\" any burden upon either Joshua or the ODM which did not exist for years prior to the Courts Order. 6. The Court should decline Joshuas request \"for the Court to spell out the obligations which it now imposes upon Joshua.\" Nothing is required of Joshua that Joshua should not have been doing all along. The Court has simply let the parties know that in addition to  2.7.1 of the Revised Plan, their agreement with respect to the resolution of compliance issues remains viable. The Courts Order continues a sensible and efficient system for resolving compliance issues and puts Joshua on notice that objections raised for the first time on April 15, 2004 which were not raised pursuant to the compliance process could be subject to an argument that those issues have been waived. 7. The Court should require that any future requests for relief submitted by Joshua should be placed in the form of a Motion and filed pursuant to the Federal Rules of Civil Procedure and the local rules of this Court.WHEREFORE, for the reasons set forth above, Joshuas letter/motion of October 1,2002 should be denied. Respectfully submitted. LITTLE ROCK SCHOOL DISTRICT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) John C. Fendley, Jr. (#92182) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501)376-2011 By:' Christopher HellerCERTIFICATE 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 October 7, 2002. Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 P. O. Box 17388 Little Rock, AR 72222 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Nations Bank Bldg. 200 West Capitol Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 iristopher HelleiR CEIVED iCT 1 2 201)2 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS URT KAN OCT 1 1 2002 \u0026gt;NS, \\S OFFICE OF LITTLE ROCK DIVISION DESEI iREGATION MONITORING JAMES W, By:.- - - - - - - - - ER LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4\n82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER On September 24,2002, Joshua Intervenors (Joshua) filed: (a) a Substituted Motion for Reconsideration (docket no. 3678),' which asks me to revisit many aspects of the September 13, 2002 Memorandum Opinion (docket no. 3675) (Memorandum Opinion) declaring the Little Rock School District (LRSD) to be unitary with regard to all aspects of its operations under the Revised Plan (CX 871), except for  2.7.1\nand (b) a Motion for New Trial or in the Alternative Motion for Relief from Judgment or Order (docket no. 3677). On October 7,2002, LRSD filed a Response to Joshua Intervenors Substituted Motion for Reconsideration and Motion for New 'On September 23,2002, Joshua filed their first Motion for Reconsideration (docket no. 3676), which contained numerous errors. The next day, September 24, 2002, Joshua filed a second Motion for Reconsideration, which corrected most of those errors. I will consider this second motion as a Substituted Motion for Reconsideration, although it was not so designated. As a matter of fact, a motion for reconsideration is not recognized in the Federal Rules of Civil Procedure. They are, however, commonly filed and ruled upon in this jurisdiction-and I will hew to this custom. AO 72A (Rev.8/82) Trial (docket no. 3682).^ After an initial review of Joshuas Substituted Motion for Reconsideration and Motion for New Trial, 1 considered summarily denying both motions on the ground that each of the arguments in support of reconsideration or a new trial is without any apparent merit. I believe that my 17 4-page Memorandum Opinion fully and accurately sets forth the relevant history of this case and that my detailed Findings of Fact and Conclusions of Law are amply supported by the record and controlling legal authority. In short, I have given this case my best shot, and, if counsel for Joshua believe I have erred, they should appeal my decision to the Court of Appeals for the Eighth Circuit. Thus, on the merits, Joshuas arguments raise nothing that warrants comment beyond my stating 1 find they are without any factual support or legal foundation. However, to the extent that a number of Joshuas arguments tend to torque the Memorandum Opinion out of shape, and are supported only by speculation and personal innuendo, 1 think it best to set the record straight. First, Joshua suggests that I improperly faulted Joshua for failing to present evidence ^Under Rule 7.2(b) of the Local Rules, LRSDs Response to Joshuas Substituted Motion for Reconsideration was due eleven days from September 24,2002, and its Response to Joshuas Motion for a New Trial was due eleven days from September 23, 2002. Because Joshuas Substituted Motion for Reconsideration and Motion for New Trial were served on counsel for LRSD pursuant to Fed. R. Civ. P. 5(b)(2)(B) (mail) and (D) (electronic means), an additional three days must be added to LRSDs eleven days. See Fed. R. Civ. P. 6(e). Thus, LRSD had fourteen days to respond to those motions, making its Response to Joshuas Motion for New Trial due on or before October 7 and its Response to Joshuas Substituted Motion for Reconsideration due on or before October 8. As indicated previously, LRSD filed its Response to both those Motions on October 7. In a letter dated October 9,2002, Joshuas counsel asked me to strike LRSDs Response to those two motions because it was not filed within eleven days. Because Joshuas counsel overlooked Fed. R. Civ. P. 5(b) and 6(e), they miscalculated the deadline for the filing of LRSDs Response to be October 4. Therefore, their request to strike that Response is denied. -2- AO 72A (Rev.8/82) on the March 19, 2001 Agreement between LRSD and the Arkansas Department of Education (CX 548). Substituted Motion for Reconsideration at 2. To the contrary, the Findings of Fact explicitly state that: The March 19, 2001 Agreement between the ADE and LRSD is unrelated to the question of whether LRSD has substantially complied with its obligations under the Revised Plan. It is important, too, that Joshua did not raise that issue as part of its challenge to LRSDs request for an immediate declaration of unitary status. Memorandum Opinion at 149, ^117 (emphasis in original). Thus, although Joshua introduced CX 548 into evidence,^ 1 expressly did not consider it in deciding the unrelated question of whether LRSD had substantially complied with its obligations under the Revised Plan. Nowhere in my Memorandum Opinion do I fault Joshua for failing to produce evidence regarding the March 19, 2001 Agreement between LRSD and ADE--a subject that clearly was not before me in the hearings on unitary status. Second, Joshua contends that I should not have addressed the involvement of the ODM with respect to issues which were litigated before Judge Wright and Judge Wilson ... [because] the competence of the ODM, the quality of the ODM reports, [and] the budget of the ODM ... 114 were not before the Court in evidentiary form. Substituted Motion for Reconsideration at 2, 6-7, and 10. The ODM, an employee of the district court, has monitored LRSDs compliance 3 It strikes me as a little strange that Joshua introduced the March 19,2001 Agreement into evidence during the hearing on unitary status and now argues, in their Substituted Motion for Reconsideration, that the document is irrelevant to the question of whether LRSD substantially complied with its obligations under the Revised Plan. I agree that the document is irrelevant to the issue of substantial compliance, but this begs the question of why Joshua chose to introduce the document into evidence in the first place. 1 remain puzzled. 4' ODM. For the record, my Memorandum Opinion does not consider the competence of the -3- AO 72A (Rev.8/82)with its obligations under the 1990 Settlement Agreement, the 1992 Desegregation Plan, and the Revised Plan. Because the ODM works for the court, all of its budgets, as well as all of the reports it has prepared over the years, have been filed and are part of the record in this case. Historically, all of the parties and the court have used ODM reports, to the extent they were relevant, during the many hearings that have taken place since 1991. After being assigned this case in January of 2002,1 carefully reviewed the entire record. In doing so, I examined the ODMs annual budgets from 1990 to date. I was troubled by the large increases in the ODMs budget over that period of time. I was also troubled by the large sums of money that I discovered had been paid to the attorneys for both Joshua and the three school districts.^ While attorneys are unquestionably necessary in school desegregation cases, it is the school children who ultimately are disadvantaged by unnecessary or exorbitantly high litigation costs. Thus, I believe that it was entirely appropriate for me to express my views on the ODMs rapidly escalating budgets,^ which are part of the record in this case, and the total amount of money that has been paid to all of the attorneys in this case during the last ten to fifteen years. As footnote 58 makes clear, my concern is with the enormous amount of money that has been paid to the entire professional groupthe ODM, the attorneys for LRSD, PCSSD, NLRSD, and Joshua. As I thought my admonition made clear on page 44 of the Memorandum Opinion, I believe the issue of the money paid to the professional group is important because I understand the meaning of being careful with a dollar, and I expect the professional group to keep that ^In most long-running school desegregation cases that have been decided in the last ten years, courts have expressed dismay over the high cost of school litigation. I now know why. ^See Memorandum Opinion at 26-27. -4- AO 72A (Rev.8/82) important point fixed in their minds from here on out. Why Joshuas eounsel seriously contend that I should not have addressed a subject of such obvious importance is beyond me. In the same vein, Joshuas counsel argue that I should not have commented on the quality of the ODMs June 14, 2000 Report of Disciplinary Sanctions in LRSD (docket no. 3366). Joshuas counsel used that Report extensively in his examination of various LRSD employees who testified during the hearings on unitary status. Joshuas decision to use that Report, one of the Court's own documents, in his examination of witnesses on the issue of student discipline. required me to read and carefully analyze that document. In doing so, I discovered patent deficiencies which rendered the Report of little use to the court or the parties in trying to determine the cause for African-American students being over-represented in disciplinary proceedings. Thus, in my discussion of the history of this litigation (Memorandum Opinion at 47-50), I was obliged to point out the flaws in the ODMs Report of Disciplinary Sanctions. I note that Joshua does not deny those flaws-they simply object to my noting them. In my Findings of Fact on the issue of student discipline, I again commented on the ODMs Report of Disciplinary Sanctions, which was prepared for the express purpose of being used by the court in monitoring and evaluating LRSDs compliance with the Revised Plan. In light of that fact, I believe 1 would have been remiss if I had not closely scrutinized the ODMs Report in deciding whether LRSD had substantially complied with those sections of the Revised Plan dealing with student discipline. Otherwise, what is the role of the Judge? Finally, and perhaps most importantly on this point, none of my Findings of Fact on the issue of whether LRSD substantially complied with its obligations regarding student discipline were based on anything contained in the ODMs Report of Disciplinary Sanctions. Rather, my -5- AO72A (Rev.8/82) findings simply pointed out that, because the Report failed to develop a proper statistical model for evaluating the data on student discipline, its conclusions were based on pure speculationmaking the Report of no use to the court or the parties in evaluating the cause for African- American students in LRSD receiving a disproportionate number of suspensions. See Memorandum Opinion at 105-07, 24-26. Third, Joshuas counsel take general exception to my discussion of the attorneys fees that have been paid in this case during the last twenty years and particular exception to my allegedly erroneous finding that the Joshua counsel, including the Legal Defense Fund counsel, were paid more than $3,750,000 for their work between 1987 and the present time. Substituted Motion for Reconsideration at 3. The amount that Joshuas counsel have been paid, to date, in attorneys fees is a matter of public record. As pointed out in footnote 58 of my Memorandum Opinion, these attorneys fees are as follows: $3,150,000 paid to Joshuas counsel under the 1990 Settlement Agreement\n $700,000 paid by LRSD to Joshuas counsel for monitoring work performed after December 12, 1990, and before July 1, 1998 (see Exhibit 7 to docket no. 3581)\nand $124,861 paid by LRSD to Joshuas counsel for monitoring work performed under the Revised Plan between July 1, 1998, and January 2001 (see Exhibit 8 to docket no. 3581). Thus, based entirely on the evidence in the record, without any need for me to speculate or make assumptions, Joshuas counsel have been paid, to date, $3,974,861 in attorneys fees-this is more than $3,750,000. In footnote 58 of my Memorandum Opinion, I hazard what I admit to be a guess that. since 1990, the attorneys fees that LRSD, PCSSD, and NLRSD have paid to their own attorneys fRSDv. PCSSD, 921 F.2d 1371, 1390 (8'\" Cir. 1990). -6- AO 72A (Rev.8/82)totals at least $4,000,000. Joshuas counsel clearly lack standing to complain about my guess regarding the aggregate amount of attorneys fees paid to counsel for the three school districtsan estimate that LRSD has not challenged. In light of these undisputed facts, I seriously question how Joshuas counsel can make the statement that counsel Walker does not accept the courts conclusion that he has directly benefitted from the perpetuation of this case. Substituted Motion for Reconsideration at 9. With all due respect to Mr. Walker, I am having a hard time escaping the conclusion that he has been directly benefitted by receiving millions of dollars in attorneys fees in this case. Fourth, Joshuas counsel, without citing any supporting facts, accuse me of a predisposition which could only have come from previous attitudes regarding the role of lawyers in this long-standing case\n^ i 'negative attitudes toward lawyers who are involved with and associated with this case\n and a bias or hostility toward Joshuas counsel.' nlO Although this should go without saying, I want to remind Joshuas counsel that, while I ruled against them on five of the six arguments they advanced, this does not mean that I harbor any bias against or hostility toward them.'' For the record, I have no predispositions, negative attitudes, or bias or hostility toward Joshuas counsel. I did indeed express dismay over the attorneys fees that have been paid to all of the ^Motion for Reconsideration at 2. Motion for Reconsideration at 3. \"Motion for Reconsideration at 7. llu- The Judge must not like me is a refrain usually sung by lawyers who have just been called to the barwhen a lawsuit doesnt turn out exactly as they had wanted. Experienced lawyers generally resist the temptation to raise this claim. -7- AO 72A (Rev.8/82)attorneys in this caseI believe that was a subject that called for comment during my discussion of the long history of this case. Likewise, the concerns I expressed about LRSDs decision to pay Joshuas counsel $700,000 for performing monitoring work for which Judge Wright ruled Joshuas counsel had already been paid (docket no. 2821) and the $48,333.33 per year that LRSD agreed to pay Joshuas counsel for performing monitoring work under the Revised Plan are directly supported by detailed citations to the record'^not speculation or conjectureand also deserved to be mentioned in my review of the history of this case. As I stated in the Memorandum Opinion, counsel for both LRSD and Joshua should have done a better job of documenting the reasons for the payment of these attorneys fees and the precise role of Joshuas counsel in receiving monthly payments from LRSD to monitor its compliance with the Revised Plan. However, in reaching that conclusion, I was guided entirely by the plain facts contained in the record and not by any preconceived ideas or a bias or hostility toward Joshuas counsel. Fifth, Joshua argues that: (a) because I discuss the fact that the ODMs staff and budget have more than doubled since its creation, I am implicitly criticizing Judge Wrights actions and the Court of Appeals for requiring the creation of the office in the first place\n'^ (b) I may be signaling that [I] want to end the role of the ODM as that role was established and created by the Eighth Circuit\n''* and (c) 1 may be trying to infer that Joshua take over the role of ODM with respect to monitoring at a rate of approximately $49,000 per year.' ,\u0026gt;15 No one could fairly read the ^^See Memorandum Opinion at 33-35 and 38-44. '^Motion for Reconsideration at 6. 'Motion for Reconsideration at 7. '^Motion for Reconsideration at 7. -8- AO72A (Rev.8/82)Memorandum Opinion as stating anything within shouting distance of these three farfetched notions. As 1 repeatedly noted in my Memorandum Opinion, Judge Wright did an outstanding job of presiding over this case for eleven long years, during which time she faithfully and skillfully decided well over a thousand motions. Nowhere do I implicitly or explicitly direct any criticism toward her.'^ Likewise, my Memorandum Opinion makes it clear that I believe it was a good idea for the Eighth Circuit to create the ODM so that the district court and the Eighth Circuit could ensure that each of the three school districts complied with their many desegregation obligations. Obviously, it is important for the ODM to continue its monitoring work until each of the three school districts is declared to be unitary and released from further supervision by the court. At this point, my only concern is that the ODM operate as frugally and efficiently as possible in going forward with its monitoring of the now much less onerous single remaining compliance issue for LRSD and the desegregation obligations that remain in effect for NLRSD and PCSSD. Finally, Joshuas counsel are absolutely correct that, in my Memorandum Opinion, there surely cannot be an inference that Joshua was [to] take over the role of ODM with respect to monitoring at a rate of approximately $49,000 per year.... There is no such inference or implication. Sixth, Joshua argues that they should be allowed to present additional evidence of LRSDs alleged noncompliance with other sections of the Revised Plan. Substituted Motion for Reconsideration at 10-11. In support of this argument, Joshua alleges that the court previously '^I do not understand how counsel can possibly discern (or divine) any such criticism in the Memorandum. -9- AO72A (Rev.8/82) instructed Joshua not to present any of that evidence [on LRSDs alleged failure to substantially comply with its obligations regarding faculty and staff, student assignment, special education and related programs, parental involvement, and school construction and closing]. This is not true. It is an after-the-fact assertion. On May 9,2002,1 entered an Order (docket no. 3598) explaining in detail how 1 intended to proceed in conducting up to five days of hearings on the remaining issues Joshua had raised in their challenge to LRSDs request for unitary status. Four pages of that Order were devoted to discussing what transpired during the December 11,2001 hearing before Judge Wright, which was held to discuss the remaining grounds for Joshuas challenge to LRSDs substantial compliance with the Revised Plan. Id. at 9-12. The May 9 Order pointed out that, during the December 11 hearing, Joshuas counsel attempted to raise numerous new grounds for challenging LRSDs alleged noncompliance after they had rested their case on what they viewed as their three strongest groundslack of good faith, failure to comply with obligations related to African- American achievement, and student discipline. Judge Wright ruled that Joshua could present evidence on three remaining grounds for noncompliance: advanced placement courses\nguidance counseling\nand extracurricular activities. In addition, she ruled Joshua could present additional evidence of LRSDs alleged lack of good faith, but only to the extent that evidence was related to advanced placement courses, guidance counseling, and extracurricular activities. Judge Wright also made it clear that, after she had heard the evidence on these three remaining areas of alleged noncompliance, she would decide the question of unitary status. Joshuas counsel responded: Thats fine, Your Honor.\" (Docket no. 3597 at 36-37.) Consistent with Judge Wrights ruling during the December 11,2001 hearing, the May 9 -10- AO 72A (Rev.8/82)Order provided that I planned to conduct up to five days of additional hearings on unitary status, during which Joshua would be allowed to present evidence of LRSDs alleged noncompliance with its obligations related to advanced placement courses, guidance counseling, and extracurricular activities. In addition, I allowed Joshua to present noncumulative evidence related to: (a) LRSDs lack of good faith, but only to the extent that it was related to advanced placement courses, guidance counseling, and extracurricular activities\nand (b) how LRSDs alleged failure to comply with its obligations regarding advanced placement, guidance counseling, and extracurricular activities adversely affected the academic achievement of Afiican-American students (docket no. 3598 at 13-14). I hardly see how the May 9 Order could have been any clearer in setting forth the precise ground rules regarding Joshuas three remaining challenges to LRSDs substantial compliance with the Revised Plan. Joshuas counsel raised no objection to the May 9 Order, and, after completing three additional days of evidentiary hearings on July 22-24,2002, Joshuas counsel rested their case challenging whether LRSD should be declared unitary. Under these circumstances, there is no basis for Joshuas counsel to argue that the court instructed them not to present evidence of LRSDs alleged noncompliance with numerous other provisions of the Revised Plan. Joshuas counsel agreed, flat footedly, to the ground rules for conducting the hearings on unitary status, including the six specific areas of the Revised Plan under which they challenged LRSDs substantial compliance. It is far too late for Joshua to argue that they should be allowed to engage in piecemeal litigation by raising additional grounds for attacking LRSDs substantial compliance with the Revised Plan. Again-one last time-the grounds delineated by Judge Wright and me, and agreed to by all counsel, were fully litigated. -11- AO72A (Rev.8/82)I do not know how to put it any more plainly than that. IT IS THEREFORE ORDERED that Joshuas Substituted Motion for Reconsideration be and it is hereby DENIED. IT IS FURTHER ORDERED that Joshuas Motion for a New Trial or in the Alternative Motion for Relief from Judgment or Order be and it is hereby DENIED. DATED this day / J of October, 2002. ITED STATES DISTRICT JUDGE UNITED JU THIS DOCUMENT ENTERED ON docket SHEET IN COMPLIANCE 79(a) FRcV ON 10/Il jo -12- AO72A (Rev.8/82)llECElVEr OCT 1 2 2002 OFRCFGF IltSEGREGATON MOKiTCRiJ\u0026lt;G IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION EAST^fSilslfeB^l OCT 1 1 2002 JAMES W, Me By\n_______/  RR LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER In a letter dated and delivered to me on October 1,2002, counsel for Joshua requested that I modify or clarify: (a) various aspects of the compliance remedy contained in the September 13, 2002 Memorandum Opinion (the Memorandum Opinion) declaring LRSD to be partially unitary\nand (b) the role of Joshua and the ODM in performing future monitoring work in this case. Later that day, I entered an Order (docket no. 3680), stating that I intended to treat the letter as a motion of some kind. In a letter dated October 9, 2002, counsel for Joshua wrote me a supplement to their October 1, 2002 letter. Attached to this Order is a copy of the October 9 letter. On October 7,2002, LRSD filed its Response to Joshuas October 1,2002 letter (docket no. 3681). Because I see no reason to await LRSDs Response to the matters raised in Joshuas 'A copy of the October 1 letter is attached to my Order. AO72A (Rev.8/82) 3 6 8 5 ssOctober 9 letter, I will proceed to address the merits of the relief requested by Joshuas counsel in both of those letters. As a threshold matter, I want to clarity how I view these two letters. On September 24, 2002, Joshua filed a Substituted Motion for Reconsideration (docket no. 3678) requesting that 1 clarify or modify many aspects of the Memorandum Opinion. Because both of Joshuas letters are seeking reconsideration of still other aspects of the Memorandum Opinion, I will treat those letters as a Supplement to their Substituted Motion for Reconsideration and address in this Order only those arguments raised in that Supplement. In the future, I think it will be best if all counsel file motionsnot lettersraising any issues that they believe require my attention. I should not be copied on general correspondence amongst counsel. First, Joshuas counsel request that I clarify the monitoring obligations the Memorandum Opinion imposed on them with regard to LRSDs compliance with  2.7.1 of the Revised Plan. I shall do so. In 1990, Joshuas counsel made the commitment to participate in a monitoring system to ensure that LRSD, NLRSD, and PCSSD complied with their desegregation obligations under the 1990 Settlement Agreement. See Memorandum Opinion at 34. Later, in approving that Settlement Agreement, the Eighth Circuit recognized that counsel for Joshua were the best defenders and guardians of the interests of their own clients. LRSD v. PCSSD, 921 F.2d 1371, 1386 (8\" Cir. 1990). Between 1990 and 1998, Joshuas counsel participated in monitoring ^In a companion Order that I am entering contemporaneously with this Order, I have addressed and rejected the arguments raised by Joshua in their Substituted Motion for Reconsideration. -2- AO72A (Rev.8/82)LRSDs compliance with the 1990 Settlement Agreement and the 1992 Desegregation Plan.^ After Joshua and LRSD implemented the Revised Plan in 1998, Joshuas counsel entered into an agreement with LRSD to monitor its compliance with the Revised Plan, a task for which LRSD agreed to pay Joshuas counsel $48,333.33 per year.'* Thus, for the last twelve years, Joshuas counsel have been involved with monitoring LRSDs compliance with its desegregation obligations. In Section VILA., B., and C. of the Memorandum Opinion, I outlined the Compliance Remedy LRSD must implement in order to comply with its remaining obligations under  2.7.1 of the Revised Plan. Because I believe that Joshuas counsel have an ethical obligation and professional duty to monitor LRSDs compliance with its obligations under  2.7.1,1 provided a monitoring role for them in Section VII.D of the Memorandum Opinion. I intended for Joshuas counsel to continue to perform their monitoring role according to the same procedure they and LRSD have followed for many years in this case. One could read the October 1,2002 letter as suggesting that Joshuas counsel only intend to continue to monitor LRSDs compliance with  2.7.1 of the Revised Plan if they are ordered to do so by me. I do not believe I can force Joshuas counsel to perform monitoring duties-something that I may have mistakenly assumed they wanted to continue to do. I will leave it up to Joshuas counsel to decide if they have an ethical duty and professional obligation to ^Judge Wright ruled Joshuas counsel were not entitled to receive attorneys fees for any monitoring work performed after the Eighth Circuits approval of the 1990 Settlement Agreement (docket no. 2821). While that ruling was on appeal to the Eighth Circuit, LRSD voluntarily agreed to pay Joshuas counsel $700,000 for performing that monitoring work. See Memorandum Opinion at 33-35 and 38-44. '^See Memorandum Opinion at 42. -3- AO72A (Rev.8/82)continue monitoring LRSDs compliance with its sole remaining obligation under the Revised Plan. 1 hope Joshuas counsel resolve that question in favor of continuing their long-standing commitment to monitoring LRSDs compliance with its desegregation obligations. However, since they complain about my expressly directing them to continue monitoring LRSDs compliance with  2.7.1 of the Revised Plansomething I never expected to hearI believe I must now modify Section Vll.D. of the Memorandum Opinion to read as follows: Joshua way monitor LRSDs compliance with  2.7.1 and, //they choose to do so, they should bring to the attention of LRSD, on a timely basis, all problems that are detected in its compliance with its obligations under  2.7.1, as those obligations are spelled out in this Compliance Remedy. Thereafter, Joshua and LRSD must use the process for raising compliance issues set forth in  8.2, et seq., of the Revised Plan to attempt to resolve those compliance issues. If those efforts are unsuccessful, Joshua shall present the issues to me for resolution, as required by  8.2.5. Any such presentation must be timely. Regardless of whether Joshuas counsel continue to monitor LRSDs compliance with  2.7.1, the ODM staff most certainly will continue their close monitoring of LRSDs compliance with that section of the Revised Plan. 1 have every confidence that the staff of the ODM will carefully monitor LRSDs implementation of the Compliance Remedy I have ordered under  2.7.1 of the Revised Plan. If Joshuas counsel decide to continue with their monitoring role, which is independent from the monitoring work performed by the ODM, the preceding paragraphs of this Order make it clear that I expect them to follow the same monitoring practices they have followed for years in this case. I expect counsel for Joshua and LRSD to cooperate and work together to ensure that things go smoothly with regard to monitoring LRSDs implementation of its obligations under  2.7.1. However, if actual disputes arise regarding monitoring, 1 will be available to resolve them. -4- AO72A (Rev.8/82)Second, Joshuas counsel makes an unsupportable and speculative statement that certain unspecified comments in the Memorandum Opinion indicated that [I] do not foresee or require a continued responsibility for monitoring of the intensity which the Court of Appeals for the Eighth Circuit required. This assertion simply is not true. I will expect and require the ODM staff to work hard every day to ensure that all three school districts fully comply with all of their remaining desegregation obligations. Of course, for LRSD, these obligations are now far less onerous than they have been in the past. Likewise, NLRSD has already been declared unitary with regard to several of its original desegregation obligations. In other words, while I will expect and require the ODM staff to diligently and fully discharge their obligation to monitor the three school districts. the reality is they now have far fewer obligations. Finally, in Joshuas counsels October 9,2002 letter, they request that I conduct a hearing to clarify the role of the ODM. I find there is no need for any requested clarification of the role of the ODMmuch less for a hearing on that subject. I feature myself capable of directing the ODM staff in performing their ongoing duties as monitors. If I waiver in this belief, I may, at that time, call on counsel for suggestions. Of course, if Joshuas counsel determines that the ODM staff is not adequately discharging its monitoring duties, I would expect them to immediately file an appropriate motion. In closing, let me repeat the comment I made in my companion Order addressing the merits of the arguments made by Joshua in their Substituted Motion for Reconsideration: I have given this case my best shot, and, if counsel for Joshua or LRSD believe that I have erred, they should appeal my decision to the Court of Appeals for the Eighth Circuit. No more paper should -5- AO 72A (Rev.8/82) be wasted in asking me to reconsider aspects of my September 13 Memorandum Opinion or to clarify roles or responsibilities associated with the Compliance Remedy. Thats my rulin. If any party perceives error, that party should get its best hold and go to the Eighth Circuit. IT IS THEREFORE ORDERED that Joshuas Supplement to their Substituted Motion for Reconsideration be and it is hereby DENIED. IT IS FURTHER ORDERED that Section VI.D. of the Memorandum Opinion is modified to read as set forth, supra, at 4. DATED this day of October, 2002. UNITED STATES DISTRICT JUl/gE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITH RULE 58 AND/OR 79^) FRCP ON 10 I II [CZ- by -6- AO72A (Rev.8/82)\u0026amp; RECEIVED FILES L C3irvi OOl OCT 2 9 2002 OFFICE OF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION OCT 2 5 2Q02 JAMESW. W By----------- CLERK  EP CLEF^ LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. LET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS MOTION FOR HEARING REGARDING RELEVANCE OF 28 U.S.C. 455 TO THE PRESENT PROCEEDINGS The Joshua Intervenors respectfully move the Court to set a hearing for the purpose of determining whether 28 U.S.C. 455 has any relevance to the present proceedings. The Joshua Intervenors respectfully submit that 28 U.S.C. 455 states: (a) Any justice, judge, or magistrate [magistrate judge] of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questions. (b) He shall also disqualify himself in the following circumstances: (1) Where he has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding\n(2) Where in private practice he served as lawyer in the matter in controversy, or a lawyer with whom he previously practiced law served during such association as a lawyer concerning the matter, or the judg eor such lawyer has been a material witness concerning it\n(3) Where he has served in governmental employment and in such capacity participated as counsel, adviser or material witness concerning the proceeding or -1-expressed an opinion concerning the merits of the particular case in controversy\n(d) For the purpose of this section the following words or phrases shallhave the meaning indicated: (1) proceeding includes pretrial, trial, appellate review, or other stages of litigation\nIn reference to 28 U.S.C. 455(b)(2), the Court is required to disqualify itself \"where in private practice he served as a lawyer in the matter in controversy . . Undersigned counsel are informed that the Honorable District Court, while in private practice, appeared in 833 F.2dll3 (8\"' Cir. 1987) in re: Little Rock School District vs. Pulaski County Special School District. No. 1.. Nos. 87-2150 and 87-2363, before the United States Court of Appeals for the Eighth Circuit. The cited Opinion addressed the issue of whether Judge Henry Woods should be disqualified. The disqualification issues had been raised by several of the parties including, notably, the Board of Education of the Little Rock School District. See attached Opinion, Exhibit A. The Court of Appeals determined that errors of procedure took place but we do not agree that it is reasonable to infer partiality or bias on the part the able and experienced district judge. The Court of Appeals apparently upheld the arguments of his honor which were made while His Honor was in private practice. The Court of Appeals did not explain its reasons in that Opinion but did so in 839 F.2d 1296, 1299. The disqualification issues, which were presented by His Honor while in private practice, were addressed in a lengthy Opinion on pages 1301, 1302 and 1303. The Court of Appeals, in that same Opinion, also addressed many of the issues which are raised or could have been raised in the present proceedings including compensatory programs in the LRSD, 839 F.2d 1306, magnet schools, 839 F.2d 1309, and teacher assignments in LRSD, 839 F.2d 1296. -2-The Court , in writing its Opinion dated September 13, 2002. included virtually all the citations from the Court of Appeals (see Exhibit B) hereto but did not refer to, mention or address these two important Opinions in which the Court, participated as a trial attorney in private practice. Plaintiffs counsel have sought to obtain the briefs which were filed with respect to Nos. 87-2150 and 87-2363 by His Honor, while in private practice, and any other briefs or activity which address that subject and have been unable to do so in a timely fashion. Their own records are incomplete regarding those filings. Request has been made of the Clerk of the Court of Appeals, however, to retrieve such briefs of all the parties regarding the two cited cases and are informed by the Clerk of that Court that he will retrieve the file. See Exhibit C. The Joshua Intervenors request that the Court convene an evidentiary hearing for the purpose of exploring the role the Court had, if any, while in private practice with respect to the subject case. In this respect, counsel having just learned this information, also notes that the Court has employed as a law clerk of the Courts staff one of the original lawyers who filed the instant case, Ms. Janet Pulliam. Counsel also note that at least one of Joshua counsel is a friend of Ms. Pulliam. Ms. Pulliam and her associates, however, are listed as counsel of record in at least these appellate citations\n775 F.2d 404, 407\nand959 F.2d 716. She was in association with Phil Kaplan and other counsel \\.yy833 F.2d 112 where Mr. Kaplans name appears before the Honorable William R. Wilson, Jr. and she was in association with Mr. Kaplan in 839 F.2d 1296. This is confirmed by the fee application of counsel for the LRSD which went to the Court of Appeals in 1992. See Exhibit D. The Joshua Intervenors believe that 28 US.C. 455 issues are raised which should be developed at a hearing. Counsel are not moving for the Court to recuse at this time\nhowever they would like to have an opportunity to review the proceedings that are set forth above and any other -J- writings to which the Court was privy, while in private practice, between himself and his client, Judge Woods. In that way, the Coun and the parties would be in a better position to address the applicability of 28 U.S.C. 455. FURTHERMORE, the Joshua Intervenors respectfully further pray that at such hearing the Court 1) inform counsel whether the present assignment of this case to this Court considered His Honors earlier role in the case while in private practice, in the light of 28 U.S.C. 455(b)(2)\n2) the basis for the Courts conclusion that it did not have a duty to recuse pursuant to 28 U.S.C. 455 (b)(2)\nand 3) request that the Court, if possible, make available to counsel copies of all briefs which His Honor has filed in this case while in private practice. Respectfully submitted. A i / I !(\u0026gt;/ -7^ i- Robert Pressman, Mass Bar No. 405^00 22 Locust Avenue Lexington, MA 02421 (781) 862-1955 John W, Walker, AR Bar No. 64046 JOHN W. WALKER. P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501)374-4187 (Fax) \\ Rickey HicksAT^^BarNo. 89235 Attorney at Law Evergreen Place 1100 North University, Suite 240 Little Rock, Arkansas 72207 (501) 663-9900 -4-CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing h^been sent-i prepaid to the following counsel of record, on this/S^day of ^'and U.S. Mail, postage 2002\nMr. Christopher Heller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock. Arkansas 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Richard Roachell ROACHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock. Arkansas 72222-7388 // / Jkn W. Walker -5- In re LI'ITLE HOCK SCHOOL DISTHKT, Petitioner. LITl'LE HOCK SCHOOL DISTRICT, Appellant, PULASKI COUNTY SPECIAI. SCHOOL DISTRICT NO. 1, Appellee. Nos. 87-2160, 87-23G3. United States Court of Appeals, Eighth Circuit. Submitted Nov. 3, 1987. Decided Nov. 6, 1987. Supplemental Opinion Filed Feb. 9. 1988. Litigation was brought involving election for school board jwsitions. The United States District Court for the Eastern Dis- trict of Arkansas, Henry Woods, J., directed elections for three school board positions and appeal was filed and petition for writ of mandate was filed asking for disqualification of district court judge. The Court of Appeals, Arnold, Circuit Judge, held that: (I) fact that lawyer with whom trial judge once practiced appeared at one time in another case consolidated with pending case did not require district court judges disqualification, and (2) errors of procedure in proceeding did not give rise to reasonable inference of partiality or bias so as to require disqualification of district court judge. Ordered accordingly. 1. Judges =46 Fact that lawyer with whom district court judge once practiced appeared at one time for amicus curiae in case consolidated with and later severed from pending case did not warrant disqualification of district court judge\nconsolidated case was closed case, or at most, dormant, when it was consolidated and such fleeting and tenuous connection did not require recusal. 28 U.S. C.A,  455(a). (b)(2). 1. The Hon. Henry WoikIs, United States District 833 FEUBKAL REPORTER, 2(1 SERIES 113 2. Judges *^=49(1) Procedural errors which occurred in litigation involving school board election did not give rise to reasonable inference of partiality or bias so as to require disqualification of district court judge. 28 U.S.C.A.  456(a). (b)(2). P.A. Hollingsworth, Little Rock, Ark., for appellant. William R. Wilson, Jr., Little Rock, Ark., for Judge Woods in mandamus. Phil Kaplan. Little Rock, Ark., for Little Hock School Dist. Sam Perroni, Little Rock, Ark., for Rayburn. Phillip Lyon, Chicago, III., for North Little Rock. Before HEANEY, ARNOLD, and WOLLMAN, Circuit Judges. ARNOLD, Circuit Judge. The two proceedings captioned above, together with a number of appeals raising related issues, were argued before us on November 3, 1987, in Little Rock, Arkansas. Two of the many important issues presented deserve immediate answers: (1) Shall the school-board election now scheduled for December 8, 1987, in the Little Rock School District (LRSD), be allowed to take place? (2) Who shall preside over the District Court? No. 87-2363 is an appeal by LRSD from the District Courts * order of October 1, 1987, directing that elections for three school-board positions be held on December 8, 1987. This order is affirmed. We find no error of law, abuse of discretion, or clearly erroneous finding of fact in the District Courts order. It is our understanding that LRSD is free now to pursue actively the search for a new superintendent, and that it will be free to hire someone right after the election. No. 87-2150 is a petition for writ of mandamus filed by LRSD, asking us to Judge for the Eastern District of Arkansas. APPLICATION OF WOOD Clle as 633 r.2d 113 (SlliCIr. 1987) declare that Judge Woods should have disqualified himself. In the alternative, it is suggested that we simply direct that anotli- er judge be assigned to this case. In addition to the petition for mandamus, various appeals also include suggestions for the disqualification of the trial judge. We are not satisfied that such drastic relief is appropriate. [1] Two main grounds for recusal are urged. First, a lawyer with whom Judge Woods once practiced appeared at one time for an amicxcs curiae in a case called Clark V. Board of Educ. of tke Little Rock School Dist., No. LR-C-64-16B. The Ds- trict Court first consolidated Clark witli the instant case, then later severed it and returned it to the docket of another judge. Disqualification is sought under 28 U.S.C,  456(b)(2), which requires disqualification where in private practice ... a lawyer with whom [the judge] previously practiced law served during such association as a lawyer concerning the matter. We dis- agree with this argument. Clark was a closed case, or at most dormant, when it was consolidated with this one, and in any event it has now been severed. We do not think that such a fleeting and tenuous connection between the present case and the judges partner's activities while in practice years ago, was intended by Congress to require recusal. [2] In addition, the parties seeking disqualification assert that because of certain procedural improprieties the judges impartiality might reasonably be questioned. 28 U.S.C.  455(a). We agree that errors of procedure took place, but we du not agree that it is reasonable to infer partiality or bias on the part of the able and experienced District Judge. He has performed with diligence in circumstances that We decline to re- are anytJiing but easy. move him from the case. Another opinion will be filed in due course further explaining our reasons for the conclusions expressed today with re- spect to the election and disqualification matters, and addressing as well the other questions raised in these cases. The judgment in No. 87-2363 is affirmed The petition for writ of mandamus in No. 87-2160 is denied. We direct that our man dates in these two cases issue forthwith It is so ordered. w fo Bkoh1\u0026gt;HW$WH^ In re Application of I.niry A. WOOD to Appear Before the Grand Jury (Mise. 85-L-02). |J4 Appeal of UNITED STATES of America. No. 8C-1719. United Slates Court of Appeals, Eighth Circuit. Submitted March 10, 1987. Decided Nov. 12, 1987. Former conspiracy defendant, who wt acquitted, brought application to make inc vidual presentation to grand jury concer ing allegations of perjury by FBI agent. United States Attorney presented alleg tions to grand jury, which declined to tai action. Applicant then filed petition alle ing matter bad not been fairly present* and again requesting permission to appe before grand jury. The United States D trict Court, District of Nebraska. Warn K. Urbom, J., issued order to United Stal Attorney of District to make re-preseiv lion of matter, or applicants petition wot be granted. The United States appeah The Court of Appeals, Heaney, Circ Judge, held that: (1) District Courts orc was proper exercise of supervisory pow and (2) order did not violate separation powers. Affirmed. Fagg, Circuit Judge, dissented w opinion.921 F.2d 1371 (1990) 949F.2d253 (1991) 56 F.3d 904 (1995) 148 F.3d 956 (1998) 243 F.2d 361 (1957) .369 F.2d661 (1966) 426F.2d 1035 (1970) 449F.2d493 (1971) 465 F.2d 1044 (1972) 705 F.2d 265 (1983) 778 F.2d 404 (1985) 971 F.2d 160 (1992) 131 F.3d 1255 (1997) 83 F.3d 1013 (1996) 112 F.3d 953 (1997) 'I,ii d 1 John W. WAlker, RA. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (5011 374-3758 FAX (501) 374-4187 JOHN W. WALKER SHAWN CHILDS Via Facsimile - 314-244-2780 OF COUNSEL ROBERT McHENRY. PA-DONNA J. McHENRY 3210 Henderson Road Little Rock. Ask.ans.as 72210 Phone: (501) 372-3425  Fax (501) 372-3428 EM.AIL: mchen17d@swbeU.net October 22, 2002 Nir. Michael Gans United States Court of Appeals for the Eighth Circuit Thomas F. Eagleton Court House Room 24.329 111 South 10 Street St. Louis, MO 63102 Re: Case No. 84-1543 Little Rock School District v. Joshua\nCase No. 84-1620 Little Rock School District\nCase Nos. 87-2150 and 87-2363 - Little Rock School District v. Pulaski County Special School Dear Mr. Gans: Would you kindly search your files and advise whether you have in your archives the briefs of the Appellants and the Appellees regarding the above captioned cases. I am particularly interested in whether there were briefs filed on behalf of the District Court in the above captioned cases. Thank you for your attention to this matter. Sincerely, /John W. Walker TWW:js ccki (L 959 PWEK^UJWPORTER, 2d SERIES LITTLE ROCK SCHOOL DISTRICT, Appellant, 6 F- LnTLB ROCK SCHOOL DIS-V. v. PUl.ASKI CVY. SCHOOL l\u0026gt;. Cllca9.59 r?.{l 716 (flIhClv. 1992) Hudsum Miltoll .Incksnn\nborene Josh- ua\nLcslie Joshua\nWayne Joshua\nSLacy Josliun\nKntlvevinc JUiight\n717 Sara MatthcHs: Bcclry McKinney\nnev- rick Miles\nJanice Miles\nJohn M. I Anne Mitchell\nBob Moore\nPat Gee\nPal Rayburn\nMary J. Gage\nNorth IJtIh Rock Classroom Teachers Associalion\nSora Malthev/s\nBecky McKinney: DerPulaski Association Teachers\nLittle Rock of Ciassioom Teachers Association\nClassroom Alexa Arm f' 3:\n- sV rick Miles\nJanice Miles\nJohn M. Miles\nNAACP\nJoyce Person\nBrian Taylor\nHilton Taylor\nPaishsi Taylor\nMiles\nNAACP\n.Foyce Person\nBrian Taylor\nHilton Taylor: Parsha Taylor\nRobert Willinghaiu\nham, Intervenors, Tonya Willing- Robert IVillingliaiu\nham. Intervenors, Tonya Willing- FUI..A8IU COUN'IY Sl'ECMl. SCHOOL strong\nKarlos Armstrong\nEtl Ballin,, ton\nKhayyam Do.vis\nJanice Deni\nJohn Harrison\nAlvin Hudson\nTali) hlSTUlCl* ff 1\nNorth LitUe Kock School District\nLeon Bornes\nSheryl Dituu\nMac Faulkner\nKtchnrd A. (lld- Hudson\nMilton Jackson\nLoieneJosh- dings\nman\nMarianne (Josser\nShirley bowcry: Doii Ilind- Boh Lyon\nua\nLeslie Wayne Joshua\nJoshua\nStacy Joshua: Katherine Knijlif\nSara Matthews\nBecky McKinney\nDer- rick Miles\nJanice Miles\nJohn M. Miles\nNAACP\nJoyce Person\nBrian Taylor\nHilton Taylor\nParsha Taylw: Robert Willingham\nTonya Willing, ham, Intervenors, PULASKI COUNTY SPECIAL SCHOOL DISTRICT #1\nNorth Little Rod School District\nLeon Barnes\nSheryl Dunn\nMac Faulkner\nRichard A. Gid- dings\nMarianne Gosser\nDon Hind- man\nShirley Lowery\nBob Lyon: George A. McCrary\nBob Moore\nSteve Morley\nBuddy Raines\nDavid Sain: Bob SteniJer\nDale Ward\nJohn AVard\nhidy Wear\nGrainger Williams, Dcfen- \u0026lt;lants, I?' George A. McCini j\nBoh Moore\nSteve Morley\nBuddy Kaines\nDavid Sain\nPULASKI COUNTY SPECIAL SCHOOL DISTRICT #1\nNorth Little Rock School District\nLeon Barnes\nSheryl Dunn\nMac Faulkner\nRichard A. Giddings\nMarianne Gosser\nDon Hind- iiinn\nShirley i^ouery\nBob Lyon\nGeorge A. McCrary\nBob Moore\nSteve Morley: Buddy Raines\nDavid Sahi\nDob Slender\nDale Ward\nJohn Ward\nJudy Wear\nGrainger Williams, Dcfen- dsiils, Bob Slender\nDale Ward\nJohn Ward\nJudy Wear\nGrainger Williams, Delen- dnnte, Philip E. Kaptnu\nJanet Fiilliaiu\nJohn Bilhciiuer\nP.A. Iloiliugsworth. Appelicc.s. Nos. Dl-IG.30, iind 91-7,402. United States Court of Appeals, Eighth Circuit. Submitted J.an. 7, 1992. Decided March 23, .1992. Philip E. Kaplan\n.Fanet Pulliam\nJohn Bilheimer\nP.A. Hollingsworth, Appellee.s. LOTLE RfJCK SCHOOL DISTRICT. Appellee, Anne Mitchell\nBob Moore: Pat G-e\nPjl Rayburn\nMary J. Gage\nMorth Lillli Roch Classroom Teachers Associalion: Pulaski Teachers\nAssociation of Little Rock Teachers Association\nr Classroom Classroom Alexa Arm- strong\nKarlos Armstrong\nEd Bullington\nKhayyam Davis\nJanice Beni: John Harrison\nAlvin Hudson\nTalia \u0026gt; I  !? Philip E. Kaplan\nJanet FuUiaiuj John Bilheiinev\nP.A. Holliug.swortli, Appellants. LITTLE ROCK StHIOOL DISTRICT. Appeliniit, Anne Mitchell\nBob Moore\nPat Gee\nPat Rayburn\nMary J. Gage\nNorth Little Rock Classroom Teachers Association\nIaw firm which represented school district in school desegregation case applied for attorney fees for services rendevod. The United States District Court for the. Eastern District of Arkansas, Susan Webber WiiRht, .1., foiijxl that disUict was a prevailijig party, that the parties had agreed that district would prosecute fee petitions at firm's pievailirig rates, that district would pay difference ijetwoeii their billed rates and proceetls of any attorneys fees award, and that the jiavties had modified their agreement U) provide that group and firm would split evenly any award made by theamrt. Difjlrlct appealed. The Court of Appeals held thak (1) amount of Pulnskt Teachers\nAssociation Little of Rock . Teachers Association\nClassi'ooiu Classroom Alexa Arm- strong\nKarlos Armstrong\nEtl Biilling- too\nKhayyam Davis\nJanice Dent\nJohn Harrison\nAlvin Hudson\nTalia Hudson\nMilton Jackson\nLorene Josh- ua\nWayne Leslie Joshua\nJoshua\nStacy Jofdnia\nKatherine Knight\naward was neilher clearly erroneous abuse of discrcUou\n(2) findiuK that nor con- h-acl existed between district\nainl firm and conlenU of the coutrncl\nwas suppoi l-ed by the evidence\nand (3) district was not es- topped to defend siRainst contention that superintendent had agreed to firm's proposal for 50/50 split in award of attorneys' fees. J Affirmed. izKlicbii CDRECEIVED OCT 3 1 2002 OFFICE OF DESEGREGATION MONITORING UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT vs. 4:82CV00866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, et al. MRS. LORENE JOSHUA, et al. KATHERINE KNIGHT, et al. 1. u.s: districtdourt EASTERN district ARKANSAS OCT 2 9 2002 JAMES VZ Plainluf Defendants Intervenors Intervenors ORDER DENYING MOTION FOR HEARING REGARDING RELEVANCE OF 28 U.S.C. 455 TO THE PRESENT PROCEEDINGS On July 22 - July 24,2002, an evidentiary hearing was held in this case on the issues raised by Little Rock School Districts motion for unitary status. 2. On September 13, 2002, a memorandum opinion was entered which ruled upon the issue of unitary status. 3. Last Friday, October 25, 2002, Joshua Intervenors filed a Motion for Hearing Regarding Relevance of 28 U.S.C. 455 to the Present Proceedings, raising two issues: a. Whether I should disqualify because approximately fifteen years ago I represented The Honorable Henry Woods, the presiding judge in this case at that time. This representation was in connection with a mandamus petition by the LRSD and Joshua Intervenors (the latter represented by Mr. Walker, among others)\n6 9 5b. Ms. Janet Pulliam, former counsel of record for a party in this case, joined my staff on September 26, 2002, as a law clerk (she came aboard nearly two weeks after the September 13 Memorandum Opinion). 4. I will deal with the issue involving Ms. Pulliam first. From the outset, Ms. Pulliam has been kept completely separate from this case, and will be in the future. Attached as Exhibits A and B to this order are interoffice memos dealing with this issue. I believe they resolve this question. SERVING AS A LAWYER IN THE MATTER IN CONTROVERSY 5. I turn now to my representation of Judge Woods in the 1987 mandamus proceeding. LRSD and Joshua Intervenors filed a petition for a writ of mandamus, asking that the Eighth Circuit disqualify Judge Woods. LRSD v. PCSSD, 839F.2dl296, 1301 (S' Cir. 1988). I entered the case, at that time, for the limited purpose of representing Judge Woods before the Eighth Circuit in connection with the request that he be disqualified. Crucially important is the fact that the mandamus issues had nothing to do with the merits of the underlying case. The mandamus was argued orally before the Eighth Circuit (sitting in Little Rock) on November 3,1987, and, two days later, the Court handed down its decision, denying the request for mandamus. The November 5 opinion, LRSD v. PCSSD, 833 F.2d 112,113 (8* Cir. 1987), was very brief. and included this language: Another opinion will be filed in due course further explaining our reasons for the conclusions expressed today with respect to the election and disqualification matters, and addressing as well the other questions raised in these cases. I was shown as counsel of record for Judge Woods in mandamus in the November 5 decision. Thereafter, I had no further involvement. 26. The Eighth Circuit handed down a supplemental opinion on February 9,1988, LRSD V. PCSSD, 839 F.2d 1296 (8* Cir. 1988). In this opinion, the Court explained, in more detail, why the petition for mandamus had been denied in the November 5 opinion. I am not shown as counsel of record in the February 9 opinion. 7. Actually, the answer to Intervenors question appears in LRSD v. PCSSD, 833 F.2d 112. The court stated: [A] lawyer with whom Judge Woods once practiced appeared at one time for an amicus curiae in a case called Clarkv. BoardofEduc. ofthe Little Rock School Dist., No. LR-C-64-155. The District Court first consolidated Clark with the instant case, then later severed it and returned it to the docket of another judge. Disqualification is sought under 28 U.S.C.  455 (b)(2), which requires disqualification where in private practice...a lawyer with whom [the judge] previously practiced law served during such association as a lawyer concerning the matter. We disagree with this argument. Clark was a closed case , or at most dormant, when it was consolidated with this one, and in any event it has now been severed. We do not think that such a fleeting and tenuous connection between the present case and the judges partners activities while in practice years ago, was intended by Congress to require recusal. Id. at 113. Likewise, my appearance fifteen years ago was brief (transitory). I represented none of the parties, and, as stated above, the narrow recusal issue that I addressed on behalf of Judge Woods had nothing to do with the merits of the underlying case. 8. In United States v. DeTemple, 162 F.3d 279 (4* Cir. 1998), the Court held that the recusal of a district judge was not required when the judge, as a lawyer, represented a creditor of the defendant (in a bankruptcy fraud case) because the creditors debt played no part in the defense or prosecution of the case. In other words, the key here is the phrase the matter in controversy. In United States v. Cleveland, 1997 WL 222533, *11 (E.D. La. May 5, 1997), the Court stated: In this Courts view, a former representation should trigger the matter in controversy requirement if the issues with which it dealt are put in issue in the 3subsequent case in the sense that they need to be resolved by the judge who is presiding over the subsequent case. If the judge need not resolve an issue that either she or her former partners were involved in, then there is no appearance of impartiality and the purpose of Section 455(b)(2) is satisfied. In reaching this conclusion, the district judge in Louisiana cited LRSD v. PCSSD, 839 F.2d 1296. WAIVER \u0026amp; ESTOPPEL 9. On top of the fact that my appearance in the case was brief and did not involve, in any way, any of the issues pending before me, a motion to disqualify me under section 455 would not be timely. On January 3,1984, the Joshua Intervenors, represented by Mr. John W. Walker and Mr. Wiley A. Branton, Jr., filed a Petition to Intervene (docket no. 452). On April 23, 1984, Judge Woods entered an Order (docket no. 470) denying Joshuas Petition to Intervene. On May 23,1984, the Eighth Circuit entered an Order (docket no. 565) directing Judge Woods to grant Joshua permission to intervene as parties in this case. Thus, Mr. Walker was counsel of record for Joshua before, during, and after the 1987 mandamus proceeding in which I appeared as counsel for Judge Woods. As the Ninth Circuit pointed out in E. \u0026amp; J. Gallo Winery v. Gallo Cattle Co., 967 F.2d 1280, 1295 (9* Cir. 1992): It is true that under section 455 a judge may have an obligation to recuse himself or herself without a motion from one of the parties\nit is self-enforcing on the part of the judge. However, it does not necessarily follow that a party having information that raises a possible ground for disqualification can wait until after an unfavorable judgment before bringing the information to the courts attention. It is well established in this circuit that a recusal motion must be made in a timely fashion. The absence of such a requirement would result in... a heightened risk that litigants would use recusal motions for strategic purposes.\" While there is no per se rule that recusal motions must be made at a fixed point in order to be timely,... such motions should be filed with reasonable promptness after the ground for such a motion is ascertained. (Emphasis added.) (Citations omitted.) 410. On January 3, 2002, this case was assigned to me by random selection (docket no. 3570). At that time, Mr. Walker knew full well that, thirteen years earlier, I had represented Judge Woods in the mandamus proceeding that Mr. Walker, himself, helped initiate in an attempt to have Judge Woods removed from this case. See LRSD v. PCSSD, 839 F.2d at 1301. Yet, it was only after my September 13,2002 Memorandum Opinion ruling against Joshua on 5 of the 6 asserted grounds for denying unitary status that Joshuas lawyers chose to file the motion for a section 455 hearing. If there ever was a case of waiver and estoppel, this is it. I hasten to point out again. however, that even if Joshua had not elected to take a wait and see approach to deciding whether to file their section 455 motion, there would be no reason for me to recuse since I have never served as lawyer in the matter in controversy.\" 11. In Joshuas section 455 motion, there appears this curious language: The Court, in writing its Opinion dated September 13, 2002, included virtually all the citations from the Court of Appeals. . .hereto but did not refer to, mention or address these two important Opinions in which the Court, participated as a trial attorney in private practice. Motion at 3. One reading the above quoted language with a jaundiced eye might take it to suggest that I attempted to hide my 1987 representation of Judge Woods in the mandamus proceeding. I described the language as curious since, as noted, Mr. Walker was counsel of record for Joshua at the time and one of the moving parties who filed the petition for writ of mandamus. See LRSD v. PCSSD, 839 F.2d at 1301. Thus, it is clear beyond peradventure that Mr. Walker knew of my being involved in this case on behalf of Judge Woods. For Joshuas benefit --1 will explain my reason for not citing these cases - a reason much less sinister than Joshua may be suggesting: they had no bearing on the unitary status issues that were decided in my September 13, 2002 Memorandum Opinion. 512. CONCLUSION Since this Order fully sets forth my involvement in, and my knowledge of, the matters raised in Joshuas section 455 motion, there is no reason for a hearing, i.e., there is nothing material I could add to the above. And, in my opinion, I have fully answered the concerns of Joshua. 13. If and when Joshuas counsel obtain copies of the briefs I filed in connection with the mandamus issue,' I will be willing to look at the issue again if, and only if, these briefs reveal that my participation in the case was significantly different from my clear recollection. At that time. however, Joshuas counsel would be required to convince me that raising the question at this late date, after losing, was not for strategic purposes. 14. Joshuas pleading raises the question of the relevance of 28 U.S.C. 455 to the present proceedings. Answer: none. SUGGESTION 15. It is obvious that Joshuas counsel feel aggrieved by my September 13, 2002 Memorandum Opinion. I again commend the Eighth Circuit Court of Appeals to them. That Court has had a world of experience in hearing disappointed suitors. In fact, this is its forte. IT IS SO ORDERED this day of October, 2002. UN: STATES DISTRICT JUDG THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITJ AND/OR 79(a) P ON 'My file has long since been destroyed. 6 BILL V L Wl 'ILSON JUDGE TO: DATE: RE: 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 MEMORANDUM All Hands at 423 U. S. Courthouse September 30, 2002 LRSD case Janet Pullium was, at one time, one of the attorneys for the Little Rock School District. So, she will not be involved in this case in any way whatsoever, directly or indirectly. EXHIBIT AKay Holt 09/25/2002 11:13AM To: Mary Johnson/ARED/08/USCOURTS@USCOURTS, Christa Newburg/ARED/08/USCOURTS@USCOURTS, Valerie Glover/ARED/08/USCOURTS@USCOURTS, Christina Conrad/ARED/08/USCOURTS@USCOURTS cc: Subject: LRSD case Per Judge. When Janet comes on board weve got to put a Chinese wall between her and the LRSD case. She was involved in it at some point. EXHIBIT B I IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS\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_326","title":"Compliance court filings","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","Education--Evaluation","School administrators","School districts--Arkansas--Pulaski County"],"dcterms_title":["Compliance court filings"],"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/326"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nFILED U.S. DISTRICT COURT EASTERN DISTRICT ARKANSAS IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION ' APR 19 2m JAM CC' lACK, CLERK DEP CLERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEiVED DEFENDANTS MRS. LORENE JOSHUA, ET AL. 1 200^ INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER Please file a list of your expected witnesses and exhibits by noon, day after tomorrow, April 21, 2004. For each witness you expect to call, please set forth the amount of time you expect to spend on direct examination. If you want a conference call regarding the presentation of evidence at the hearing next week please call Ms. Mary Johnson at 501-604-5144 forthwith. IT IS SO ORDERED this / day of April, 2004. CT Wm. R. Wilson, Jr. JUDGE 8 5 8 RECEIVED UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION APR 2 1 2004 OFFICE OF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. I, et al. DEFENDANTS SUPPLEMENT TO RESPONSE TO COURT ORDER BY SEPARATE 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 Response to the courts Order dated April 19, 2004, states: ADE does not plan to call any witnesses or offer any exhibits at the hearings currently scheduled before the court on April 27-28, 2004. Respectfully Submitted, MIKE BEEBE Attorney General By\nMARK A. HAGEMEIHR, #94127 Assistant Attorney Genewl 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 April 2004, addressed to:Stephen W. Jones Jack, Lyon \u0026amp; Jones 3400 TCBY Tower 425 W. Capitol Little Rock, AR 72201 Christopher Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 W. Capitol Little Rock, AR 72201-3493 M. Samuel Jones, III Wright, Lindsey \u0026amp; Jennings LLP 200 W. Capitol, Suite 2300 Little Rock, AR 72201-3699 John W. Walker John Walker, P.A. 1723 Broadway Little Rock, AR 72201 Arm Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3* Little Rock, AR 72201 2u vni 1 WMLKLPl NO.004 P.2 I I I 2 IN THE UNITED STATES DISTRICT  eastern DISTRICT OF ARKANSAS----- WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:S2CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. l.ETAL. DEFENDANT MRS. LORENE JOSHUA ETaL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS THE JOSHUA INTERVENORS WITNESS LTST The-Joshua Intervenors may call the following persons as witnesses during the hearin! 6 scheduled for April 26 and 27, 2004: 1. Gene Jones, Office of Desegregation Monitoring -1 hour 2. Walt Haney, Ed. D,, Expert -1 1/4 hours 3. Richard Hunter, Ed. D., Expert - 45 minutes 4. Margie Powell, Office of Desegregation Monitoring -1 hour 5. Dennis Glasgow, Little Rock School District - 20 minutes 6. Ann Marshall, Office of Desegregation Monitoring - 20 minutes 7. Willie Morris, Arkansas Department of Education - 20 minutes 8. Morris Holmes, Interim Superintendent, Little Rock School District - 1/4 hour 9. J unions Babbs, Associate Superintendent, Little Rock School District -15 minutes 10. Ethel Dunbar, Principal al Franklin Elementary School, LRSD -10 minutesII 1 pinu.rst.r-. NO.U04 P.3 11. David Smith, Principal at Southwest Middle School. LRSD -10 minutes 12. Cassandra Norman, Principal at McClellan High School, LRSD 13. Karl Brown, Assistant Superintendent PCSSD - 5 minutes -10 minutes 14. Bobby Acklin, Assistant Superintendent, NLRSD - 5 minutes Joshua reserves the right to call witnesses listed by the Little Rock School District. Respectfully submitted, 22 Locust Avenue Lexington, MA 02421 781-862-1955 Mass Bar 405900 W.*' Walker ^'Rickey Hicks John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 Elaine R, Jones .... President \u0026amp; Director-Counsel Norman Chachkin Theodore Shaw NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street New York, NY 212-965-2200 10013-2897 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing has been served on all counsel of record on this 21^ by placing a copy of s prepaid. day of April, 2004 apie in the United .States mail postage I / /' nited .States IV J tJU-4 \u0026gt;/C7-COO/^ I I iv. IN THE UNITED STATES DISTRICT^ Eastern district of Arkansas WESTERN division little rock school district PLAibmp? V, Case no. 4\n82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ETAL. defendant MRS. LORENE JOSHUA DT AL. Katherine knight, et al. INTERVENORS INTERVENORS THE JOSHUA INTERVENORS EXHTRTT LTST The Joshua Intervenors may use the following exhibits during the hearing scheduled for April 26 and 27, 2004\n1) LRSD Policy IL (Evaluation of Instructional Programs), CX 575 2) LRSD Regulation IL-Rl (^Program Evaluation Agenda) 3) Text of Plan, Sections 2.7 and 2.7.1 4) Review of Year Two Evaluations, Steven M. Ross, Ph.D. CProvided to Iniervenors by Counsel for e LRSD, October 25,2002) Superintendent James to LRSD Board of Education fPrcnaredbv Assoicate Superintendent for Instruction Bonnie A. Lesley)\nVri - 2) Approval of the Charter School Program Evaluation, October 24, 2002 , b) Approval of rhe SEDLs Program Evaluation for the CoEaborative Project, November 21, 2002 Action Team Vo \" of Program Evaluation for Southwest Middle Schools Partnership with Souwest Education Development Lab (SEDL), November 21, 2002 'I-iU. H.5 VtH d) Campus Leadership Team Program Evaluation, February 13,2003 e) HIPPY Program Evaluation, February 13, 2002 ' I Vol. C- f) Onward to ExceUence Program Evaluation, February 13, 2003 g) Campus Leadership Teem Progrem Eveleetidn, Febmeiy 13, 2003 i \"d\" ) Vijt A'!: h) Vital Link program Evaluation, February 13, 2003 v/ i) Middle School Transition Program Evaluation, February: j) Lyceum Scholars Program Evaluation, February 27, 2003 n, 2003 k) Extended Year Education CEYE) Program Evaluation, February 27, 2003 V\n)l. 1) Elementary Summer School Program Evaluatioi ii, February 27, 2003 6) (^delines for Completing Eights Program Evaluations Ph.D. (Filed by LRSD March 14, 2003) in LRSD, Steven M. Ross, S T) from Chris Heller to Ann Marshall and John W. Walker, October 27, 2003 8) Letter from Chris Heller to John W. Walker, January 12, 2004 9) LRSD Literacy Program Evaluation  I District from 1998 to 2003 c \u0026lt;1   * ^Srams in the We Rct School 11) The LRSDs Implementation of the Courts Compliance Remedy, March 30, 2004 / \u0026gt; 1'9' 1 i2) Resume, Walter M. Haney, Ed.D, (Professor, Lynch School of Education. Research Associate. Center for the Study of Testing, Evaluation - tion. Senior College) and Educational Policy, Boston  2 13) Grade to Grade Progression Data for LRSD and Arkansas, By Race nOh of Educational .Administration and Head of the Educational Organization and Leadership Organization ini^uanon and Head and Leadership Department. Joshua reserves rhe right to utilize the exhibits as listed by the defendants. Respectfully submitted.JOHNW. WALKER, P.A. Attorney at Lav/ 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-375S Fax (501) 574-4187 ------------transmission cover .SRPKT Date: To: Fax: Re: Sender: rcZ7SHOULD RLCEIVE [ COVER SHEET. IF YOU DO (including cover sheet)] PAGE(S). INCLUDING THIS \"\u0026lt;(1(11) 374.S75S\u0026gt;\" only for the use of the individual Or entity named above. If die reader of this message is not the intended .. , -------------------------- ut uiib inesss recipient, or the employee or agent responsible to deliver it to the intended recipient v that any dissemination, distribution received this communication in or :, you are hereby notified copying of this communication is strictly prohibited. If you have IO error, please immediate notify us by telephone, and return the original message TT C Dz\\z-ta1 _T'l____1___  o US at the above address via the U.S. Postal Service, Thank you.ONiUOilNOW N0liV33HD3S3a 30331330 ^ooz c 2 ydv aaAiHoau tv, IN THE UNITED STATES DISTRICTCl EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION 6ep LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ETAL. DEFENDANT MRS. LORENE lOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS THE JOSHUA INTERVENORS EXHIBIT LIST The Joshua Intervenors may use the following exhibits during the hearing scheduled for April 26 and 27, 2004: 1) LRSD Policy IL (Evaluation of Instructional Programs), CX 575 2) LRSD Regulation IL-Rl (Program Evaluation Agenda) 3) Text of Plan, Sections 2.7 and 2.7.1 4) Review of Year Two Evaluations, Steven M. Ross, Ph.D. (Provided to Intervenors by Counsel for the LRSD, October 25, 2002) 5) Memoranda from Superintendent James to LRSD Board of Education (Prepared by Assoicate Superintendent for Instruction Bonnie A. Lesley): a) Approval of the Charter School Program Evaluation, October 24, 2002 b) Approval of the SEDLs Program Evaluation for the Collaborative Action Team Project, November 21, 2002 c) Approval of Program Evaluation for Southwest Middle Schools Partnership with Southwest Education Development Lab (SEDL), November 21, 2002d) Campus Leadership Team Program Evaluation, February 13, 2003 e) HIPPY Program Evaluation, February 13, 2002 f) Onward to Excellence Program Evaluation, February 13, 2003 g) Campus Leadership Team Program Evaluation, February 13, 2003 h) Vital Link program Evaluation, February 13, 2003 i) Middle School Transition Program Evaluation, February 27,2003 j) Lyceum Scholars Program Evaluation, February 27, 2003 k) Extended Year Education (EYE) Program Evaluation, February 27, 2003 1) Elementary Summer School Program Evaluation, February 27, 2003 6) Guidelines for Completing Eights Program Evaluations in LRSD, Steven M. Ross, PhD, (Filed by LRSD March 14, 2003) 7) Letter from Clrris Heller to Aim Marshall and Jolm W. Walker, October 27, 2003 8) Letter from Chris Heller to John W. Walker, January 12, 2004 9) LRSD Literacy Program Evaluation 10) An Evaluation of Mathematics and Science Programs in the Little Rock School District from 1998 to 2003 11) The LRSDs Implementation of the Courts Compliance Remedy, March 30, 2004 12) Resume, Walter M. Haney, Ed.D. (Professor, Lynch School of Education, Senior Research Associate, Center for the Study of Testing, Evaluation and Educational Policy, Boston College) 13) Grade to Grade Progression Data for LRSD and Arkansas, By Race 14) Vita, Richard C. Hunter, Ed. D. (Professor of Educational Administration and Head if the Educational Organization and Leadership Organization and Leadership Department. Joshua reserves the right to utilize the exhibits as listed by the defendants. Respectfully submitted.li Robert Pressman i ' Walker Hicks Walker, .''^.hh W V 22 Locust Avenue /-Rickey ] Lexington, MA 02421 781-862-1955 Mass Bar 405900 {/ John W. P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 Elaine R. Jones President \u0026amp; Director-Counsel Norman Chachkin Theodore Shaw NAACP Legal Defense and Educational Fund, 99 Hudson Street Inc. New York, NY 212-965-2200 10013-2897 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing has been served on all counsel of record on this 21*^ day of April, 2004 by placing a copy of same in the United States mail postage prepaid. a W-b-A RECEIVED ARKANSAS APR 2 G 2004 OFFICE OF DESEGREGATION MONITORING 2 1200j clerk IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION EPCLE^ LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV866WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1. ETAL. DEFENDANT MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS THE JOSHUA INTERVENORS WITNESS LIST The Joshua Intervenors may call the following persons as witnesses during th kaon to rr scheduled for April 26 and 27, 2004: 1. Gene Jones, Office of Desegregation Monitoring - 1 hour 2. Walt Haney, Ed. D., Expert - 1 1/4 hours 3. Richard Hunter, Ed. D., Expert - 45 minutes 4. Margie Powell, Office of Desegregation Monitoring - 1 hour 5. Dennis Glasgow, Little Rock School District - 20 minutes 6. Ann Marshall, Office of Desegregation Monitoring - 20 minutes 7. Willie Morris, Arkansas Department of Education - 20 minutes 8. Morris Holmes, Interim Superintendent, Little Rock School District - 1/4 hour 9. Junious Babbs, Associate Superintendent, Little Rock School District - 15 minutes 10. Ethel Dunbar, Principal at Franklin Elementary School, LRSD - 10 minutes11. David Smith, Principal at Southwest Middle School, LRSD - 10 minutes 12. Cassandra Norman, Principal at McClellan High School, LRSD - 10 minutes 13. Karl Brown, Assistant Superintendent, PCSSD - 5 minutes 14. Bobby Acklin, Assistant Superintendent, NLRSD - 5 minutes Joshua reserves the right to call witnesses listed by the Little Rock School District. Respectfully submitted, P /I L F Robert Pressman\nsman Walker 22 Locust Avenue Lexington, MA 02421 781-862-1955 Mass Bar 405900 A'Rickey Hicks John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 Ark. 64046 Elaine R. Jones President \u0026amp; Director-Counsel Norman Chachkin Theodore Shaw NAACP Legal Defense and Educational Fund, Inc. 99 Hudson Street New York, NY 212-965-2200 10013-2897 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing has been served on all counsel of record on this 21 St day of April, 2004 by placing a copy of sapae prepaid. ' \\ 1 in the United States mail postage I / V mled IN THE UNITED STATES DISTRICT^j\n! . . X X , * ---------------- ---------- CT COURT EASTERN DISTRICT OF ARKANSAS Arkansas WESTERN DIVISION APR 2 1 2004 LITTLE ROCK SCHOOL DISTRICT JAMES W. MCCORMACK, CLERK -ELAINTIFF OtPCLfcRK V, LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL RECEIVED DEFENDANTS MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL APR 2, 2004 OFFICE OF DESEGREGATION MONITORING INTERVENORS INTERVENORS LITTLE ROCK SCHOOL DISTRICT WITNESS LIST AND EXHIBIT LIST The Little Rock School District expects to call the following witnesses and present the following exhibits at the hearing scheduled to being on April 26, 2004, except Dr. Lesley, whose testimony will be presented by deposition. WITNESS LIST 1. Dr. Steven M. Ross, Director, Center for Research in Education Policy, University of Memphis - expected direct examination time - 1 hour\n2. Dr. Bonnie Lesley, former LRSD Associate Superintendent for Curriculum and Instruction - expected direct examination time - 1 hour\n3. Dennis Glasgow, Interim Associate Superintendent for Curriculum and Instruction - expected direct examination time - 1 hour\n4. Dr. Ed Williams, LRSD Research Specialist - expected direct examination time - 30 minutes\n5. Krista Underwood, Director of Early Childhood and Elementary Literacy - expected direct examination time - 30 minutes\nPage 1 of 46. Suzi Davis, Director of Secondary English - expected direct examination time - 30 minutes\n7. Vanessa Cleaver, Director of National Science Foundation Grant - expected direct examination time - 30 minutes. EXHIBIT LIST 1. Program Evaluations and Accompanying Memoranda submitted to the LRSD Board of Directors for approval on October 24, 2002, November 21, 2002, December 19, 2002, February 13, 2003 and February 27, 2003 (These were attached to our Notice of Filing on March 14, 2003 in Volumes I - IV)\n2. September 26, 2002 Program Evaluation Agenda, 2002-03\n3. October 4, 2002 letter from Clay Fendley transmitting Compliance Plan to counsel and Ms. Marshall\n4. October 10, 2002 memo to Dr. Ken James from Ann Marshall re LRSDs Compliance Plan 5. October 10, 2002 Memo to LRSD Board from Dr. Bonnie Lesley\n6. October 11, 2002 letter from Clay Fendley to Counsel and Ann Marshall regarding Compliance Remedy\n7. October 17,2002 Request for Qualifications of Revised Desegregation and Education Plan Program Evaluation Consultant\n8. October 25, 2002 letter from Clay Pendley to Counsel and Ann Marshall\n9. November 4, 2002 letter to John Walker and Ann Marshall from Bonnie Lesley\n10. Guidelines for Completing Eight Program Evaluations in LRSD prepared by Dr. Ross\n11. December 3, 2002 letter to Ann Marshall from Bonnie Lesley\n12. December 3, 2002 letter to John Walker from Bonnie Lesley\n13. January 27, 2003 Memo to Dr. Ken James from Dr. Bonnie Lesley regarding contracted Services - Dr.Ross\n14. February 13, 2003 Memo to LRSD Board from Dr. Lesley regarding Information on Completion of Eight Program Evaluations for Submission to Federal Court Page 2 of 41 15. April 8, 2003 letter from John Walker to Clay Fendley\n16. Response to ODM and Joshua Objections, by Dr. Steven M. Ross\n17. Changes in Science Curriculum, by Dennis Glasgow\nRespectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Friday, Eldredge \u0026amp; Clark Christopher Heller (#81083) 2000 Regions Center 400 West Capitol Little Rock, AR 72201-3493 (501) 376-20JJ_______ BXC Christopher Heller Page 3 of 4 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 April 21,2004\nMr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Judge J. Thomas Ray U. S. District Courthouse 600 West Capitol Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Nations Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Mark Burnette Attorney at Law 1010 W. 3^\"^ Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Mark A. Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Christopher He^ Page 4 of 4RECEIVED MAY 1 r 2004 EASTERN RN DISTRICT ARK lUHT KANSAS OFFICE OF IN THE UNITED STATES DlSTRICTfpOURT EASTERN DISTRICT OF ARKANSAS I MAY 1 2 2004 ESEGREGATION MONITORING LITTLE ROCK DIVISION jameS W. McCORMACK, CLERK By:. DEP CLERK LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. RECEIVED DEFENDANTS MRS. LORENE JOSHUA, ET AL. MAY 1' 2004 INTERVENORS KATHERINE KNIGHT, ET AL. OFFICE OF DESEGREGATION MONITORING INTERVENORS { . ORDER In preparing for the June 14 and 15 evidentiary hearing on LRSDs Compliance Report, it is apparent that a number of matters need to be brought to the attention of counsel for LRSD and Joshua: (1) (2) The LRSD Board, in approving the October 10, 2002 Compliance Plan, also adopted IL-Rl, which sets forth the written procedures for evaluating the  2.7 programs. While the October 10, 2002 Compliance Plan is attached as Exhibit A to LRSDs March 14, 2003 Notice Of Filing Program Evaluations Required By Paragraph C Of The Courts Compliance Remedy (docket entry #3745), IL- Rl \" is not attached to that document or otherwise included in the record. Counsel for LRSD must immediately provide me with a copy of IL-Rl. Exhibit A to LRSDs Compliance Report is an October 25, 2002 letter from Mr. John Fendley, one of LRSDs attorneys, to all parties, responding to certain written concerns raised by Joshuas counsel, Mr. John Walker, regarding AO 72A (Rev.8/82) 8 6 4LRSDs proposed Compliance Plan. In order for the Court to place Mr. Pendleys October 25,2002 letter in context, I need the following additional documents: (a) Mr. Walkers October 10 and 24, 2002 letters to Mr. Fendley raising his concerns about the Compliance Plan\nand (b) a copy of the document that Mr. Fendley repeatedly quotes Mr. Walker referring to in his October 10 and October 24,2002 letters as ''''your document''^ Counsel for LRSD must immediately provide me with copies of the foregoing documents. (3) In my September 13, 2002 Memorandum Opinion, I thought I made it clear that I am a big fan of plain English and have no desire to learn the acronym-filled lexicon of the professional educator. Therefore, I am now directing counsel to comply with the following rules in all oral and written communications with the Court in this case: (a) Do not use any educational acronyms unless they are first defined. The pleadings that I have reviewed to date in preparing for the June 14 and 15 hearing are littered with references to SAIPs,' DRAs, DIBELs, ELLA, CRT, SMART, THRIVE, ACTAAP, SREB, CREP, and SFA. Counsel for LRSD must immediately prepare a glossary which defines all acronyms used in all exhibits attached to LRSDs Compliance Report. A copy of this glossary is to be provided forthwith. 'I speculate that your document is probably LRSDs Compliance Plan, which I already have. If my speculation is correct, LRSDs counsel should so advise me and need not provide the Court with a copy of that document. -2- AO72A (Rev.8/82)(b) During the hearing on June 14 and 15, please instruct your witnesses to testify using plain English - not professional educatorese. Based upon the parties previous written submissions and testimony taken in earlier hearings, I fear this may pose a significant challenge for some of the witnesses (and me). If so, I encourage these witnesses to begin now to practice speaking in plain English, so that they will be ready to testify by the June 14 and 15 hearing. (4) On or before June 7,2004, counsel for Joshua and LRSD must submit proposed Findings of Fact and Conclusions of Law on the issue of whether LRSD has substantially complied with its obligations under Section VII of the Courts September 13, 2002 Memorandum Opinion and  2.7.1 of the Revised Plan. (5) On April 22, 2004, we had a telephone conference during which LRSDs Compliance Hearing was rescheduled from April 26 and 27,2004, to June 14 and 15, 2004. During that telephone conference, I stated that I would make every effort to render my decision on LRSDs Compliance Report by June 30, 2004. Based upon my current work load, I now believe the earliest I will be able to enter my decision is thirty to sixty days after the conclusion of the evidentiary hearing in this matter. IT IS SO ORDERED., DATED this J day of May, 2004. AO72A (Rev.e/82) Thi-j uuouivicLi-. I .!\u0026lt; 11_,\\L-i. Oil  JCKST SHEET h- COMEuSmNC,' y_BY Oft c- FRC -3- UNITED STATES DISTRICT T c received IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION MAY 1 4 2004 OFRCEOF desegregation monitoring LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. NO.4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS PLAINTIFFS NOTICE OF FILING DOCUMENTS IN RESPONSE TO THE COURTS ORDER FILED MAY 12. 2004 Plaintiff Little Rock School District (LRSD) for its Notice of Filing states: 1. Attached are the following documents requested by the Court in its Order filed May 12,2004: A. Little Rock School District Proposed Compliance Plan Revised Plan  2.7.1 (Appendix 1 of which is EL-Rl\")\nB. Letter from John W. Walker to Chris Heller dated October 10, 2002\nand, C. Letter from John W. Walker to Chris Heller dated October 23, 2002 (received by fax on October 24, 2002). 2. As to Mr. Walkers references to your document, the Court is correct that Mr. Walker is referring to the Proposed Compliance Plan attached hereto as Exhibit A. Page 1 of 33. As to the educational acronyms, Counsel has requested that the authors of the comprehensive evaluations immediately prepare a glossary of acronyms used in their respective evaluations. These will be consolidated into a single glossary for all exhibits and provided to the Court as soon as possible. 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 Christopher Heller Page 2 of 3CERTIFICATE 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 May 13, 2004: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 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 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 Page 3 of 3 Christopher HellerLittle Rock School District Compliance Committee Proposed Compliance Plan Revised Plan  2.7.1 1^ EXHIBITThe District Courts Compliance Remedy On September 13, 2002, the District Court issued its Memorandum Opinion (hereinafter Opinion) finding that the Little Rock School District (LRSD) had substantially complied with all areas of the Revised Desegregation and Education Plan (Revised Plan), with the exception Revised Plan  2.7.1. Section 2.7.1 provided: LRSD shall assess the academic programs implemented pursuant to Section 2.7' after each year in order to determine the effectiveness of the academic programs in improving Afiican-American achievement. If this assessment reveals that a program has not and likely will not improve Afiican-American achievement, LRSD shall take appropriate action in the form of either modifying how the program is implemented or replacing the program. The District Courts Opinion set forth a detailed Compliance Remedy to be implemented by the LRSD. The Opinion first stated: Because LRSD failed to substantially comply with the crucially important obligations contained in 2.7.1, it must remain under court supervision with regard to that section of the Revised Plan until it: (a) demonstrates that a program assessment procedure is in place that can accurately measure the effectiveness of each program implemented imder 2.7 in improving the academic achievement of Afiican-American students\nand (b) prepares the program evaluations identified on page 148 of the Final Compliance Report and uses those evaluations as part of the program assessment procedure contemplated by  2.7.1 of the Revised Plan. The Opinion then outlined the details of the Compliance Remedy as follows: A. For the entire 2002-03 school year and the first semester of the 2003-04 school year, through December 31, 2003, LRSD must continue to assess each of the programs implemented under  2.7 to improve the academic achievement of African-American students. LRSD now has over three years of testing data and other information available to use in gauging the effectiveness of those programs. I expect LRSD to use all of that available data and information in assessing the effectiveness of those prograrhs and in deciding whether any of those programs should be modified or eliminated. 'Revised Plan  2.7 provided, LRSD shall implement programs, policies and/or procedures designed to improve and remediate the academic achievement of Afiican-American students, including but not limited to Section 5 of this Revised Plan. 1B. C. F. LRSD must maintain written records regarding its assessment of each of those programs. These written records must reflect the following information: (a) the written criteria used to assess each program during the 2002-03 school year and the first semester of the 2003-04 school year\n(b) the results of the annual assessments of each program, including whether the assessments resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the assessment of each program, as well as at least a grade level description of any teachers who were involved in the assessment process (e.g., all fourth grade math teachers\nall eighth grade English teachers, etc.). LRSD must use Dr. Nunnerly^ or another expert from outside LRSD with equivalent qualifications and expertise to prepare program evaluations on each of the programs identified on page 148 of the Final Compliance Report. I will accept all program evaluations that have already been completed by Dr. Nunnerly or someone with similar qualifications and approved by the Board. All program evaluations that have not yet been completed on the remaining programs identified on page 148 of the Final Compliance Report must be prepared and approved by the Board as soon as practicable, but, in no event, later than March 15, 2003. In addition, as these program evaluations are prepared, LRSD shall use them, as part of the program assessment process, to determine the effectiveness of those programs in improving African-American achievement and whether, based on the evaluations, any changes or modifications should be made in those programs. In addition, LRSD must use those program evaluations, to the extent they may be relevant, in assessing the effectiveness of other related programs. * * * On or before March 15, 2004, LRSD must file a Compliance Report which documents its compliance with its obligations under  2.7.1. Any party, including Joshua, who wishes to challenge LRSDs substantial compliance with  2.7.1, as specified above, may file objections with the court on or before April 15, 2004. Thereafter, I will decide whether the LRSD has substantially complied with  2.7.1, as specified in the Compliance Remedy, and should be released from all ftxrther supervision and monitoring. ^The Court is clearly referring to Dr. John Nunnery. 2Proposed Compliance Plan As the Compliance Committee understands the District Courts Opinion, the Compliance Remedy requires the LRSD to: 1. 2. 3. 4. 5. Continue to administer student assessments through the first semester of 2003-04\nDevelop written procedures for evaluating the programs implemented pursuant to Revised Plan  2.7 to determine their effectiveness in improving the academic achievement of African- American students\nMaintain written records of (a) the criteria used to evaluate each program\n(b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process\nPrepare a comprehensive program evaluation of each academic program implemented pursuant to Revised Plan  2.7 to determine its effectiveness in improving the academic achievement of Afiican-American students and to decide whether to modify or replace the program\nand Submit for Board approval the program evaluations identified on page 148 of the LRSDs Final Compliance Report that have been completed, and complete, with the assistance of an outside expert, the remaining evaluations identified on page 148 of the LRSDs Final Compliance Report. What follows is an explanation of how the Compliance Committee derived these five requirements from the District Courts Opinion, and what the Compliance Committee proposes to do to comply with each requirement. Assessment and Evaluation When first read, the District Courts Compliance Remedy seemed simple and straightforward, but as the Compliance Committee attempted to develop this Proposed Compliance Plan, numerous questions arose. The most fundamental question related to the District Courts use of the term assessment in Paragraphs A and B of the Compliance Remedy. The ambiguity of this term was the subject of testimony at the hearing. The District Court included in its Opinion Dr. Lesleys testimony on the difference between assessment and evaluation, see Opinion, p. 152, but it is unclear whether the Court accepted this testimony. 3It is clear that the District Court understood the distinction between testing data, which are derived from student assessments, and program evaluations, which are used to determine the effectiveness of programs. See Opinion, p. 152 (LRSD acknowledged in the Interim Compliance Report that it was required: (a) to use both the testing data and the program evaluations to determine the effectiveness of the key academic programs implemented pursuant to  2.7 ... (emphasis in original)). Even so, the District Court appears to have used the term assessment in some instances to refer to only student assessments and in other instances to refer to both student assessments and evaluations. This required the Compliance Committee to determine the District Courts intended meaning. In making this determination, the Compliance Committee considered the context in which the term was used, the District Courts findings of fact as set forth in the Opinion, what would be in the best interest of African- American students, and hopefully, common sense. An explanation of each requirement of the Compliance Remedy is provided below. To avoid any ambiguity, Compliance Committee hereinafter uses the term assessment to refer to student assessments and the term evaluation to refer to the program evaluations, whether formal or informal. 1. Continue to administer student assessments through the first semester of 2003-04. This requirement derives from Paragraph A of the Compliance Remedy. Given Paragraph As reference to testing data, it seems clear that Paragraph A concerns, in part, student assessments. The Compliance Committee proposes to comply with this part of Paragraph A by implementing the 2002-03 Board-approved assessment plan. The 2002-03 Board-approved assessment plan incorporates four changes that have been made since the LRSDs Final Compliance Report. First, the Board eliminated the fall administrations of the Achievement Level Tests (ALTs) in 2001-02. The administration recommended this for three reasons: (1) the loss of instructional time resulting from testing and test preparation\n(2) fall results did not provide significantly different information from the previous springs results\nand (3) the cost of administering and scoring the tests. Second, the fall administration of the Observation Surveys and Developmental Reading Assessment will only be used by the teacher for diagnostic purposes. The scores will not be reported to or maintained by the LRSD. This change saves considerable time in test administration and allows more time for instruction. It was approved by the Board on September 26,2002. Third, the LRSD will no longer administer the ALTs. The administration recommended the complete elimination of the ALTs for the following reasons: (1) the lack of alignment with the content and format of the State Benchmarks\n(2) the loss of instructional time resulting from 4testing and test administration\n(3) the new federal accountability requirements in the No Child Left Behind Act require annual testing by the State in grades 3-8, making the LRSDs administration of the ALTs redundant\nand (4) the costs of administering and scoring the tests. The Board approved this change on September 26, 2002. Finally, the Arkansas Department of Education (ADE) has moved the administration of the SAT9 from the fall to the spring, effective 2002-03. The 2002-03 Board-approved assessment plan calls for the administration of the following student assessments in English language arts and mathematics: Kindergarten Grade 1 Grade 2 Grade 4 Grade 5 Grade 6 Grade 7 Grade 8 Grades 7-10 Grades 9-11 Grade 10 Grade 11 Observation Surveys (5) Developmental Reading Assessment Observation Surveys (5) Development Reading Assessment Observation Surveys (3) Development Reading Assessment Norm-referenced test to be identified for gifted/talented screening Benchmark Literacy examination Benchmark Mathematics examination SAT9 Total Battery Benchmark Literacy examination Benchmark Mathematics examination SAT9 Total Battery Benchmark Literacy examination Benchmark Mathematics examination End-of Course Algebra I examination End-of Course Geometry examination SAT9 Total Battery End-of-Level Literacy examination All of these assessments are administered in the spring. Consequently, the final student assessment before March 15, 2004, will be administered in the spring of 2003. 2. Develop written procedures for evaluating the programs implemented pursuant to  2.7 to determine their effectiveness in improving the academic achievement of African-American students. This requirement derives from the opening paragraph of the Compliance Remedy. To comply with this requirement, two proposed regulations have been drafted, IL-Rl for formal evaluations and IL-R2 for informal evaluations, attached as Appendixes 1 and 2, respectively. 5Proposed regulation IL-Rl combines generally accepted principles of program evaluation with practices that have been in place in the LRSD for the past two years. See, e.g., Robby Champion, Map Out Evaluation Goals, Journal for Staff Development, Fall 2002, attached as Appendix 3. This regulation will be submitted to the Board, Office of Desegregation Monitoring (ODM) and the Joshua Intervenors (Joshua) for review and comment before being finalized. Proposed regulation IL-R2 specifically addresses the next requirement and is discussed therewith. 3. Maintain written records of (a) the criteria used to evaluate each program\n0)) the results of the annual student assessments, including whether an informal program evaluation resulted in program modiflcations or the elimination of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process. This requirement derives from Paragraph B of the Compliance Remedy. Paragraph B apparently came about as a result of the District Courts concern about the LRSD making program modifications based on informal evaluations of student assessment data. See Opinion, p. 155 (I have grave reservations about anyone this side of Solomon being wise enough to use two or three semesters worth of erratic composite test scores to make reliable decisions about which remediation programs for LRSDs African-American students were actually working.). Proposed regulations IL-R2 was drafted to specifically address this requirement. It prohibits substantial program modifications from being made without a written record as required by Paragraph B. This regulation will also be submitted to ODM and Joshua for review and comment before being finalized. Proposed regulation IL-Rl also complies with this requirement. It mandates that the criteria used to formally evaluate a program be identified as the research questions to be answered, the first of which will be, Has this curriculum/instruction program been effective in improving and remediating the academic achievement of African-American students?. See Appendix 1, IL-Rl, p. 5. Recommended program modifications and the members of the evaluation team are routinely included in formal evaluations. As to the results of annual student assessments, the LRSD will continue to maintain a computer database with the results of armual students assessments administered pursuant to the Board-approved assessment plan. 64. Prepare a comprehensive program evaluation of each academic program implemented pursuant to  2.7 to determine its effectiveness in improving the academic achievement of African-American students and to decide whether to modify or replace the program. This requirement derives from Paragraph A of the Compliance Remedy. To comply with this requirement, the Compliance Committee proposes to prepare the following new, comprehensive evaluations: (a) Primary Reading/Language Arts, (b) Middle and High School Literacy and (c) K-12 Mathematics and Science. Each evaluation will be prepared in accordance with proposed Regulation IL-Rl and will incorporate all available student assessment data relevant to the program being evaluated. Based on Paragraph F of the Compliance Remedy, the LRSD understands these evaluations must be submitted to the Court on or before March 15, 2004. new, Some may argue that Paragraph A and Paragraph C together require the LRSD to prepare comprehensive evaluations of all the programs identified on page 148 of the LRSDs Final Compliance Report. The Compliance Committee considered and rejected this argument for three reasons. First, Paragraph As description of the programs to be evaluated differs from that of Paragraph C. Paragraph A states that the LRSD must continue to assess each of the programs implemented under  2.7 ... The Compliance Committee understands this to mean that the LRSD should continue to prepare evaluations of some of the key programs, as identified in the Interim Compliance Report. See Opinion, p. 151 (In addition to the Assessment Plan,  2.7.1 of the Interim Compliance Report noted that the LRSD was preparing 'evaluations of some of the key programs designed to improve Afiican-American achievement in order to provide a more in-depth look at the effectiveness of those programs. (emphasis in original)). In contrast to Paragraph A, Paragraph C requires the LRSD to prepare evaluations of each of the programs identified on page 148 of the Final Compliance Report. The Compliance Committee understands this to mean that the LRSD should complete all of the evaluations identified on page 148 of the Final Compliance Report and submit those to the Court. See Opinion, p. 156 ([A]s of March 15, 2001, the date the Final Compliance Report was filed with the Court\n(1) PRE had prepared only draft evaluations of some of the programs in question\n(2) none of those evaluations had been approved by the Board .... (emphasis in original)). The District Courts statement in Paragraph C that it will accept evaluations already completed and approved by the Board further indicates that Paragraph C does not require new, comprehensive evaluations. Second, recognizing this distinction between Paragraph A and Paragraph C resolves a potential conflict between Paragraph C and Paragraph F. Paragraph C provides, All program evaluations that have not yet been completed on the remaining programs identified on page 148 7of the Final Compliance Report must be prepared and approved by the Board as soon as practicable, but, in no event, later than March 15, 2003. However, Paragraph F does not require the LRSD to file a compliance report on its compliance with Revised Plan  2.7.1 until March 15,2004. The Compliance Committee concludes that March 15, 2004, is the deadline for submitting the new, comprehensive evaluations of the programs implemented pursuant to  2.7. See Paragraph A of Compliance Remedy. This is consistent with Paragraph As requirement that the LRSD include assessment data through December 31, 2003. Obviously, such data could not be included in an evaluation filed on or before March 15, 2003. Finally, it makes the most sense for the LRSD to expend the greatest time and resources preparing evaluations of the programs designed to improve African-American achievement. While the requirement for new, comprehensive evaluations derives from Paragraph A, some may argue that Paragraph Cs requirement that the LRSD use an outside expert to prepare evaluations of each of the programs identified on page 148 of the Final Compliance Report applies to the new, comprehensive evaluations. The Compliance Committee hopes the District Court and the parties agree that the team approach to program evaluation set forth in proposed regulation IL-Rl renders this argument moot. Proposed Regulation IL-Rl states that the program evaluation team must include [a]n external consultant with expertise in program evaluation, the program area being evaluated, statistical analysis, and/or technical writing ... . Appendix 1, p. 4. The exact role of the external consultant may vary, depending upon the expertise required for the production of the program evaluation. Id. The Compliance Committee believes that the LRSDs practice over the last two years of using the team approach to program evaluation has produced credible evaluations. Moreover, participation of the LRSD staff on the evaluation team provides them an excellent learning experience that they do not typically receive when an evaluation is prepared entirely by an outside expert. The evaluations prepared over the last two years using the team approach are as follows\n1. 2. Dr. Steve Ross was the external consultant in the production of the Early Literacy program evaluation for 1999-2000 and 2000-01. He was asked to read a nearfinal draft and to provide feedback, which he did. His suggestions were then incorporated into the final report before it was published and disseminated. Other team members included Bonnie Lesley (associate superintendent), Patricia Price (program director), Pat Busbea (program specialist), Ed Williams (statistician), and Ken Savage (computer programmer). Dr. Julio Lopez-Ferraro is the National Science Foundation (NSF) program officer who over-sees the LRSDs implementation of the grant-funded 8Comprehensive Partnership for Mathematics and Science Achievement (CPMSA). NSF trained a team of LRSD staff to produce the mandated annual program evaluations for this initiative and then assembled an external team of practitioners and researchers who came to the LRSD each year to validate our findings and provide written feedback. The LRSD team members who participated in writing of the annual progress reports included Vanessa Cleaver (project director), Dennis Glasgow (director of mathematics and science), Bonnie Lesley (associate superintendent and co-project investigator), Virginia Johnson (CPMSA program evaluator), Ed Williams (statistician), and Ken Savage (computer programmer). 3. 4. Mr. Mark Vasquez, an attorney and former employee of the Office for Civil Rights in Dallas, has been retained by the LRSD for the past three years to provide guidance in the design and production of the English as a Second Language (ESL) program evaluation. Other team members have been Bonnie Lesley (associate superintendent), Karen Broadnax (program supervisor), Ed Williams (statistician), Ken Savage (computer programmer), and Eddie McCoy (program evaluator). Dr. Larry McNeal, a professor at the University of Arkansas at Little Rock in education administration and a private consultant in program evaluation, was retained by the LRSD to lead the team that produced the program evaluation for the Charter School. Other members of that team included Linda Watson (assistant superintendent), Krista Young (program director), and Ed Williams (statistician). Dr. McNeal wrote this report. The team approach, supported by an external expert, ensures that all areas of expertise (program, implementation, technical and evaluative) are included. No one person would have all the knowledge and skills that a team would have. As these examples show, the external expert does not always perform the same role in every project. Rather, the role changes, depending on the expertise that is required for a credible report. 5. Submit for Board approval the program evaluations identified on page 148 of the LRSDs Final Compliance Report that have been completed, and complete, with the assistance of an outside expert, the remaining program evaluations identified on page 148 of the LRSDs Final Compliance Report. The following program evaluations identified on page 148 of the Final Compliance Report have been completed\n1. Early Literacy. A comprehensive report for 1999-2000 and 2000-01 was prepared, completed, and presented to the Board in fall 2001. An update to this report for 2001-02 was presented to the Board in June 2002, with an emphasis on 9the improved achievement of African-American students and closing the achievement gap. 2. 3. 4. 6. 7. 8. 9. 10. Mathematics and Science. Three years (1998-99, 1999-2000, and 2000-01) of program evaluations as required by the NSF were prepared, presented to the Board, and submitted to NSF, and NSF has responded to each evaluation. Extended Year Schools. The LRSD staff prepared, completed, and presented to the Board in the spring of 2002 an evaluation of the Extended Year Schools. Elementary Summer School. The LRSD staff prepared, completed, and provided to the School Services Division an evaluation of elementary summer school programs for 2000-01. 5 HIPPY. The HIPPY program was evaluated by the LRSD staff in July 1999. The report was prepared, completed, and submitted to the program director and the Cabinet. Charter School. This program evaluation was prepared, completed, and presented to the Board in June 2001. ESL. The Office for Civil Rights has required the LRSD to prepare a program evaluation in this area for each of the past three years: 1999-2000, 2000-01, and 2001-02. The first two of these reports have been prepared, completed, submitted to the Board, and submitted to OCR. (A third program evaluation will be completed in October when state scores arrive and will be ready by the March 15, 2003 deadline). Lyceum Scholars Program. Two separate evaluations of this alternative education school program were prepared by the LRSD staff. South-west Middle School's SEDL Program. Southwest Middle School was the recipient of a two-year technical assistance grant from the Southwest Educational Development Lab (SEDL) to build professional community. SEDL prepared a comprehensive program evaluation that included Southwest among other grant recipients outside the LRSD. The LRSD staff provided SEDL data for this evaluation. Onward to Excellence (Watson Elementary). A grant from ADE funded a partnership between Watson Elementary and the Northwest Educational Development Lab to implement a school improvement initiative. The LRSD staff provided data to Watsons principal for preparation of program evaluations. The principal submitted two annual program evaluations to ADE. 1011. 12. Collaborative Action Team (\"CAT\"). This one-year partnership with SEDL provided in 2000-01 for establishing and training a Collaborative Action Team of parent and community volunteers supported by LRSD staff to improve parent involvement. SEDL wrote a 249-page evaluation of their three-year grant-funded program, of which LRSD was included only the last year. The LRSD staff provided SEDL data for this evaluation. Vital Link. The LRSD staff prepared a program evaluation, and it was provided to the project director. A question arises as to which of these evaluations are acceptable to the Court without additional work. The first sentence of Paragraph C of the Compliance Remedy provides, LRSD must use Dr. Nunnerly (sic) or another expert from outside LRSD with equivalent qualifications and expertise to prepare program evaluations of each of the programs identified on page 148 of the Final Compliance Report. The second sentence of Paragraph C states that the District Court will accept all program evaluations that have already been completed by Dr. Nunnerly (sic) or someone with similar qualifications. It is unclear whether an expert from outside the LRSD must have prepared the completed evaluations for them to be accepted by the District Court, or whether it is sufficient that they were prepared by someone within LRSD with similar qualifications. The District Courts findings of fact suggest that the District Court will accept only program evaluations already completed by an outside expert. The District Court noted that Dr. Lesley testified that, by the end of November 2000, it was her opinion that no one in PRE had the expertise to prepare program evaluations. Opinion, p. 153. Thus, the District Court likely concluded that the only acceptable program evaluations would be those prepared by persons outside the LRSD. Applying this standard, the Compliance Committee believes that the following evaluations are acceptable to the Court, following Board approval, without additional work: Early Literacy, Mathematics and Science, Charter School, ESL, Southwest Middle Schools SEDL Program and CAT. The remaining program evaluations identified on the bottom of page 148 of the Final Compliance Report must be completed by an outside expert. They are: Extended Year Schools, Middle School Implementation, Elementary Summer School, HIPPY, Campus Leadership Teams (CLTs), Lyceum Scholars Program, Onward to Excellence and Vital Link. The Compliance Committees proposal for completing each of these evaluations will be discussed below. In deciding how to go about completing these evaluations, the Compliance Committee focused on what makes sense to do at this time considering the goal of improving Afiican-American achievement and the limitations inherent in asking an expert to complete an evaluation. 11Extended Year Schools. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Middle School Implementation. A draft of this evaluation was presented to the Board in July and August 2000, but it was never completed. The Compliance Committee proposes retaining an outside expert to rewrite the report and, if possible, prepare an evaluation based on the existing data. Elementary Summer School. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. HIPPY. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. CLTs. The LRSD staff conducted a survey of CLTs during 2000-01. A summary of the survey findings was presented during a CLT training session, but no formal report was ever prepared. The Compliance Committee proposes retaining an outside expert to review the survey data and, if possible, prepare an evaluation based on the existing survey data. Lyceum Scholars Program. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Onward to Excellence. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Vital Link. This evaluation was completed by LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. 12Action Plan Timeline The Compliance Committee proposes implementation of this Compliance Plan in accordance with the following timeline. 1. Provide copies of this proposed Compliance Plan to ODM and Joshua for their reactions. 2. Incorporate, as possible, suggested revisions from ODM and Joshua. 3. Place Compliance Plan on the agenda for Board review and approval. 4. Place 2002-03 Program Evaluation Agenda on the Boards agenda for review and approval. 5. Place on Board agenda for approval two previously presented program evaluations (early literacy, and charter school). 6. Place on Board agenda for approval the evaluations of Southwest Middle Schools SEDL program and the Collaborative Action Team (also conducted by SEDL). 7. Place on Board agenda for approval the previously presented ESL program evaluations for 1999-2000 and 2000-01, plus the new evaluation for 2001-02. Week of September 30, 2002 Week of October 7, 2002 October 10, 2002 October 24, 2002 October 24, 2002 November 2002 November 2002 13 Clay Fendley Ken James Attorneys Ken James Compliance Team Ken James Attorneys Ken James Bonnie Lesley Bonnie Lesley Linda Watson Bonnie Lesley Bonnie Lesley Karen Broadnax8. Place on Board agenda for approval the three previously presented program evaluations for the NSF-funded CPMSA program, plus the new Year 4 report for 2001-2002. 9. Issue Request for Proposals (RFPs) from available external experts to review and complete the eight remaining program evaluations listed on page 148._____________________ 10. Form a screening team to determine recommendations to the Superintendent for designating external experts to review and complete the eight remaining program evaluations listed on page 148._____________________ 11. Select and negotiate consulting contracts with designated external experts. 12. Assign appropriate staff to each external expert to provide needed information, data, access to program staff, etc. 13. Monitor the work to ensure timely completion. 14. As each paper is completed and ready for circulation, send copies to ODM and Joshua for their review and comments. December 2002 Mid-October 2002 Late October 2002 Mid-November 2002 Mid-November 2002 Mid-November 2002February 2003 December 2002February 2003 14 Bonnie Lesley Vanessa Cleaver Dennis Glasgow Bonnie Lesley Darral Paradis Ken James Compliance Team Bonnie Lesley Ken James Bonnie Lesley Bonnie Lesley Bonnie Lesley15. As each paper is completed, place on the Boards agenda the item to be reviewed and approved. 16. Write Interim Compliance Report relating to programs on page 148 to be completed. 17. Establish staff teams for each of the three programs on the Boards Program Evaluation Agenda to be completed for 2002-2003 (Elementary Literacy, Secondary Literacy, and K- 12 Mathematics/ Science). 18. Publish RFPs to identify external experts to serve on each of the two staff teams for the Boards Program Evaluation Agenda (K-12 mathematics/science external experts are provided by NSF). 19. Establish consulting contracts with the two external experts required for the Elementary Literacy and Secondary Literacy program evaluations. 20. Train each program evaluation team, including the external expert, on the requirements of the approved Compliance Plan and IL-R. December 2002February 2003 March 15, 2003 March 1, 2003 March 1,2003 Late March 2003 May 2003 15 Ken James Bonnie Lesley Attorneys Compliance Committee Bonnie Lesley Bonnie Lesley Darral Paradis Bonnie Lesley Bonnie Lesley21. Monitor the completion of the work on all three program evaluations required in the Boards Program Evaluation Agenda. 22. Send copies of the completed Elementary Literacy program evaluation to ODM and Joshua for information. 23. Complete the evaluation of the Elementary Literacy program and place on the Boards agenda for approval. 24. Send copies of the Secondary Literacy program evaluation to ODM and Joshua for information. 25. Complete the evaluation of the Secondary Literacy program and place on the Boards agenda for approval. 26. Send copies of the completed CPMSA program evaluation to ODM and Joshua for information. 27. Complete the five-year evaluation of the CPMSA project (science and mathematics) and place on the Boards agenda for approval. 28. Write Section 2.7.1 Final Compliance Report for federal court and file with Court. MayOctober 2003 With October 2003 Board agenda packet October board meeting, 2003 With November 2003 Board agenda packets November board meeting, 2003 With December 2003 Board agenda packet December board meeting, 2003 March 15, 2004 16 Bonnie Lesley Ken James Bonnie Lesley Bonnie Lesley Pat Price Ken James Bonnie Lesley Bonnie Lesley Pat Price Ken Janies Bonnie Lesley Bonnie Lesley Vanessa Cleaver Dennis Glasgow Ken James Attorneys Compliance TeamAppendix 1 Proposed IL-RlLITTLE ROCK SCHOOL DISTRICT NEPN CODE: IL-R1 PROGRAM EVALUATION AGENDA Purpose The purpose of these regulations is to provide guidance to the staff involved in the evaluation of programs required in the Boards Program Evaluation Agenda. They do not necessarily apply to grant-funded programs if the funding source requires other procedures and provides funding for a required evaluation. Criteria for Program Evaluations Policy IL specifies that the evaluations of programs approved in its Board- approved Program Evaluation Agenda shall be conducted according to the standards developed by the Joint Committee on Standards for Educational Evaluation. (See Joint Committee on Standards for Educational Evaluation, James R. Sanders, Chair (1994). The Program Evaluation Standards, Edition: How to Assess Evaluations of Educational Programs. Thousand Oaks, CA: Sage Publications.) They are as follows: Utility Standards The utility standards are intended to ensure that an evaluation will serve the information needs of intended users. These standards are as follows\nStakeholder identification. People involved in or affected by the evaluation should be identified so that their needs can be addressed. Evaluator credibility. The people conducting the evaluation should be both trustworthy and competent to perform the evaluation so that the evaluation findings achieve maximum credibility and acceptance. Information scope and sequence. Information collected should be broadly selected to address pertinent questions about the program and should be responsive to the needs and interests of clients and other specified stakeholders. Values identification. The perspectives, procedures, and rationale used to interpret the findings should be described carefully so that the bases for value judgements are clear. Report clarity. Evaluation reports should describe clearly the program being evaluated, including its context and the purposes, procedures, and findings of the evaluation, so that essential information is provided and understood easily. 1Report timeliness and dissemination. Significant interim findings and evaluation reports should be disseminated to intended users so that they can be used in a timely fashion. Evaluation impact. Evaluations should be planned, conducted, and reported in ways that encourage follow-through by stakeholders, so that the likelihood that the evaluation will be used is increased. Feasibility Standards Feasibility standards are intended to ensure that an evaluation will be realistic, prudent, diplomatic, and frugal. Practical procedures. Evaluation procedures should be practical so that the disruption is kept to a minimum while needed information is obtained. Political viability. The evaluation should be planned and conducted with anticipation of the different positions of various interest groups so that their cooperation may be obtained, and so that possible attempts by any of these groups to curtail evaluation operations or to vias or misapply the results can be averted or counteracted. Cost-effectiveness. The evaluation should be efficient and produce information of sufficient value so that the resources expended can be justified. Propriety Standards The propriety standards are intended to ensure that an evaluation will be conducted legally, ethically, and with due regard for the welfare of those involved in the evaluation, as well as those affected by its results. Service orientation. Evaluations should be designed to assist organizations to address and effectively serve the needs of the full range of targeted participants. Formal agreements. Obligations of the formal parties to an evaluation (what is to be done, how, by whom, and when) should be agreed to in writing so that these parties are obligated to adhere to all conditions of the agreement or to formally renegotiate it. Rights of human subjects. Evaluations should respect human dignity and worth in their interactions with other people associated with an evaluation so that participants are not threatened or harmed. Complete and fair assessments. The evaluation should be complete and fair in its examination and recording of strengths and weaknesses of the program being evaluated so that strengths can be built upon and problem areas addressed. Disclosure of findings. The formal parties to an evaluation should ensure that the full set of evaluation findings, along with pertinent limitations, are made accessible to the people affected by the 2evaluation, as well as any others with expressed legal rights to receive the results. Conflict of interest. Conflict of interest should be dealt with openly and honestly so that it does not compromise the evaluation processes and results. Fiscal responsibility. The evaluators allocation and expenditure of resources should reflect sound accountability procedures and be prudent and ethically responsible so that expenditures are accounted for and appropriate. Accuracy Standards Accuracy standards are intended to ensure that an evaluation will reveal and convey technically adequate information about the features that determine the worth of merit of the program being evaluated. Program documentation. The program being evaluated should be described and documented clearly and accurately so that it programs is identified clearly. Context analysis. The context in which the program exists should be examined in enough detail so that its likely influences on the program can be identified. Described purposes and procedures. The purposes and procedure of the evaluation should be monitored and described in enough detail so that they can be identified and assessed. Defensible information sources. The sources of information used in a program evaluation should be described in enough detail so that the adequacy of the information can be assessed. Valid information. The information-gathering procedures should be chosen or developed and then implemented in a manner that will ensure that the interpretation arrived at is valid for the intended use. Reliable information. The information-gathering procedures should be chosen or developed and then implemented in a manner that will ensure that the information obtained is sufficiently reliable for the intended use. Systematic information. The information collected, processed, and reported in an evaluation should be review systematically so that the evaluation questions are answered effectively. Analysis of quantitative information. Quantitative information in an evaluation should be analyzed appropriately and systematically so that the evaluation questions are answered effectively. Analysis of qualitative information. Qualitative information in an evaluation should be analyzed appropriately and systematically so that the evaluation questions are answered effectively. Justified conclusions. The conclusions reached in an evaluation should be justified explicitly so that stakeholders can assess them. 3Impartial reporting. Reporting procedures should guard against distortion caused by personal feelings and biases of any party so the evaluation reports reflect the evaluation findings fairly. Metaevaiuation. The evaluation itself should be evaluated formatively and summartively against these and other pertinent standards so that its conduct is appropriately guided, and on completion, stakeholders can closely examine its strengths and weaknesses. Program Evaluation Procedures The following procedures are established for the evaluation of programs approved by the Board of Education in its annual Program Evaluation Agenda: 1. 2. 3. 4. 5. The Division of Instruction shall recommend to the Superintendent annually, before the budget for the coming year is proposed, the curriculum/instruction programs for comprehensive program evaluation. The recommendation shall include a proposed budget, a description of other required resources, and an action plan for the completion of the reports. Criteria for the proposed agenda are as follows: A. Can the results of the evaluation influence decisions about the program? B. Can the evaluation be done in time to be useful? C. Is the program significant enough to merit evaluation? (See Joseph S. Wholey, Harry P. Hatry, and Kathryn Newcomer (1994). Handbook of Practical Program Evaluation. San Francisco, CA: Jossey- Bass Publishers. 5-7.) The Superintendent shall recommend to the Board of Education for approval the proposed Program Evaluation Agenda^with anticipated costs and an action plan for completion. For each curriculum/instruction program to be evaluated as per the Program Evaluation Agena, the Associate Superintendent for Instruction shall establish a staff team with a designated leader to assume responsibility for thp production of the report according to the timelines established in the action plan approved by the Board of Education. Each team shall include, at a minimum, one or more specialists in the curriculum/instruction program to be evaluated, a statistician, a programmer to assist in data retrieval and disaggregation, and a technical writer. If additional expertise is required, then other staff may be added as necessary. An external consultant with expertise in program evaluation, the program area being evaluated, statistical analysis, and/or technical writing shall be retained 4as a member of the team. The role of the external consultant may vary, depending upon the expertise required for the production of the program evaluation. 6. The team leader shall establish a calendar of regularly scheduled meetings for the production of the program evaluation. The first meetings will be devoted to the following tasks: A. B. C. D. E. F. G. Provide any necessary training on program evaluation that may be required for novice members of the team, including a review of the Boards policy IL and all of the required criteria and procedures in these regulations, IL-R. Assess the expertise of each team member and make recommendations to the Associate Superintendent for Instruction related to any additional assistance that may be required. Write a clear description of the curriculum/instruction program that is to be evaluated, with information about the schedule of its implementation. Agree on any necessary research questions that need to be established in addition to the question, Has this curriculum/instruction program been effective in improving and remediating the academic achievement of African-American students? (See Policy IL, 2.7.1 of the Revised Desegregation and Education Plan, and Judge Wilsons Compliance Remedy.) Generate a list of the data required to answer each research question, and assign responsibility for its collection and production. All available and relevant student performance data must be included. (See Judge Wilsons Compliance Remedy.) Decide who will be the chief writer of the program evaluation. Plan ways to provide regular progress reports (e.g., dissemination of meeting minutes, written progress reports, oral reports to the Superintendents Cabinet and/or Compliance Team) to stakeholders, including the Associate Superintendent for Instruction, the Superintendent of Schools, the Office of Desegregation Monitoring (until Unitary Status is achieved), and the Joshua Intervenors (until Unitary Status is achieved). (See Joellen Killion (2002). Assessing Impact: Evaluating Staff Development. Oxford, OH. National Staff Development Council (NSDC)\nRobby Champion (Fall 2002). Map Out Evaluation Goals. Journal of Staff Development. 78-79\n5Thomas R. Guskey (2000). Evaluating Professional Development. Thousand Oaks. CA: Convin Press\nBlaine R. Worthen, James R. Sanders, and Jody L. Fitzpatrick (1997). Participant-Oriented Evaluated Approaches. Program Evaluation: Alternative Approaches and Practical Guidelines\n153-169\nBeverly A. Parsons (2002). Evaluative Inquiry: Using Evaluation to Promote Student Success. Thousand Oaks, CA: Corwin Press\nand Joseph S. Wholey, Harry P. Hatry, and Kathryn E. Newcomer (1994). Handbook of Practical Program Evaluation. San Francisco, CA: Jossey-Bass Publishers.) 7. 8. 9. Subsequent meetings of the program evaluation team are required for the following tasks: to monitor the completion of assignments\nto collaborate in the interpretation and analysis of data\nto pose any necessary new questions to be answered\nto review drafts and provide feedback to the writer\nto formulate recommendations, as required, for program improvement, especially to decide if a recommendation is required to modify or abandon the program if the findings reveal that the program is not being successful for the improvement of African- American achievement\nto assist in final proofreading\nand to write a brief executive summary, highlighting the program evaluation findings and recommendations. A near-final copy of the program evaluation must be submitted to the Associate Superintendent for Instruction at least one month before the deadline for placing the report on the Boards agenda for review and approval. This time is required for final approval by staff, for final editing to ensure accuracy, and for submission to the Superintendent. When the program evaluation is approved for submission to the Board of Education for review and approval, copies of the Executive Summary and complete report must be made for them, for members of the Cabinet, for ODM (until Unitary Status is achieved), and for the Joshua Intervenors (until Unitary Status is achieved). 10. The program evaluation team shall plan its presentation to the Board of Education on the findings and recommendations. 611 .The Associate Superintendent for Instruction shall prepare the cover memorandum to the Board of Education, including all the required background information (see Judge Wilsons Compliance Remedy): A. If program modifications are suggested, the steps that the staff members have taken or will take to implement those modifications. If abandonment of the program is recommended, the steps that will be taken to replace the program with another with more potential for the improvement and remediation of African-American students. (See Section 2.7.1 of the Revised Desegregation and Education Plan and Judge Wilsons Compliance Remedy.) B. Names of the administrators who were involved in the program evaluation. C. Name and qualifications of the external expert who served on the evaluation team. D. Grade-level descriptions of the teachers who were involved in the assessment process (e.g., all fourth-grade math teachers, all eighth grade English teachers, etc.). 10. When the program evaluation is approved by the Board of Education, the team must arrange to have the Executive Summary and the full report copied and design a plan for communicating the program evaluation findings and recommendations to other stakeholders. This plan must then be submitted to the Associate Superintendent for approval. 11. Each program evaluation team shall meet with the Associate Superintendent for Instruction after the completion of its work to evaluate the processes and product and to make recommendations for future program evaluations. (See u Joellen Killion (2002). Evaluate the Evaluation. Assessing Impact: Evaluating Staff Development. Oxford, OH: National Staff Development Council. 46, 123-124.) 7Appendix 2 Proposed IL-R2LITTLE ROCK SCHOOL DISTRICT NEPN CODE: IL-R2 INFORMAL PROGRAM EVALUATION Introduction The purpose of this regulation is to ensure that a written record exists explaining a decision to significantly modify an academic program. It is not the intent of this regulation to require a formal program evaluation before every significant program modification. Definitions Academic Program means one of the core curriculum programs of English/Language Arts, Mathematics, Science or Social Studies. Significantly modify means a material change in the content or delivery of an academic program implemented throughout the entire District. Written Record A written record must be prepared and maintained explaining a decision to significantly modify an academic program. The written record required by this regulation must include the following information: (a) the written criteria used to evaluate the program\n(b) a summary of the student assessment data or other data on which the decision was based\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process (e.g., all fourth grade math teachers\nall eighth grade English teachers, etc.). 1Appendix 3 Robby Champion, Map Out Evaluation Goals, Journal for Staff Development, Fall 2002'l a k i n g ROBBY CHAMPION Map out evaluation goals A master plan can guide you down the rocky path of evaluation when you launch a major professional development evaluation, regardless of the projects scope, you may quickly find yourself on a with twists and unexpected turns. slippery, often rocky road. Before venturing too far and becoming disillusioned about program evaluation, create a master plan. While it requires an upfront investment of time and may delay starting, it quickly becomes an invaluable road map that helps you avoid delays and detours along the way. Developing an evaluation master plan is most useful when you are launching a major, summative program evaluation. A summative evaluation is done at major junctures in a programs life cycle and emphasizes documenting impact. Information from summative evaluations is used to make important decisions about the initiative, such as whether to continue, alter, expand, downsize, or eliminate it. A formative evaluation, on the other hand, means monitoring and collecting data, often informally and spontaneously, throughout program implementation. Formative evaluation helps show implementers where to make adjustments so a program can eventually achieve significant results. A thoughtfully prepared master plan for a major evaluation effort would:  Focus the evaluation effort and help implementers avoid being sidetracked by leadership changes and new opinions\n Create a realistic timeline and work plan that  Robby Champion is president of Champion Training \u0026amp; Consulting. You can contact her at Champion Ranch at Trumbell Canyon, Mora, NM 87732, (505) 387-2016, fax (505) 387-5581, e-mail\nRobbychampion@aol.com. 78 provides needed momentum for the work\n Be a key informational document to provide an overview and answer specific questions throughout the process\n Help recruit people to assist with the project on the myriad evaluation tasks\n Give the message that the evaluation will be open and not secretive. Whether your evaluation must be completed within a few months or wiU extend for several years, think through four phases of work before starting. PHASE I: ORGANIZE THE PROCESS 1. Form a steering committee, including any needed outside expertise. 2. Learn more about program evaluation together. 3. Write a clear description of each program to be evaluated. 4. Agree on the primary purpose of the evaluation. .5. Plan how you will keep everyone informed along the way. Steering committees, charged specifically . with program evaluation, are important to focus attention and maintain the energy and momentum needed for the evaluation. They also help build a spirit of collaboration and open inquiry. And they keep the evaluation on track when other priorities ntight push the effort aside. Provide steering committee members with the tools to succeed. Members need not be evalu- National Staff Development Council JSD Fall 2002 t a k I J, g m e a 5 JI re ! i i i I I ! i ation experts, but they do need information, support, and guidance to make informed decisions. They need background material to leam about program evaluation and examples of good evaluation studies. Finally, they need access to experts on professional development, measurement, and the content areas of the training programs. Before launching any evaluation effort, have a written description of each program to be evaluated. You would be amazed at the number of people who do not have a clear idea of what you mean by the New TeacherJhduction Program or the Early Literacy Initiative since so many different initiatives are being undertaken simultaneously around the school or district PHASE II: DESIGN THE EVALUATION 1. Generate questions to guide the evaluation. 2. Generate potential data sources/ instruments to address the questions. 3. Using a matrix to provide a birds-eye view, agree on the most important questions and the best data sources. 4. Decide if collecting data from a sample group is warranted to make the evaluation manageable. 5. Determine the evaluation approach that makes sense\nquantitative vs. qualitative/naturalistic. 6. Gather or create the instruments for data collection. 7. Determine a realistic schedule for collecting data. 8. Create a system for collecting, analyzing, and interpreting data. Decisions made in Phase n are critical. They determine the technical quality of your evaluation. In the questions you select, you determine what to examine and what to ignore. When you finish with the design phase, your program evaluation win be shaped to use a quantitative or a , qualitative model  or a mixmre of the two. In the design phase, you make other major decisions, such as whether to use a sample group. You also decide whether to do an in-depth case study, whether to ON THE WEB. See an example of a matrix to help guide evaluations at: www.nsdc.org/library/jsd/ chainpion234.html. survey the whole population, whether to use examples of smdent work instead of official documents such as student grades or standardized test scores, or whether to judge adult learners understanding of the training content with performance tasks during training or by exit tests, classroom observations, or smdent feedback. If the programs to be evaluated already have stated indicators of longterm impact, generating appropriate evaluation questions is much simpler than when programs have only vague, lofty goals. The steering committee may drift into the realm of program planning as you encounter hurdles like fuzzy program outcomes. To avoid making misinformed evaluation design decisions, involve program leaders in your discussions. Developing or gathering instruments and then collecting the data are the most expensive steps in any evaluation. Think strategically about which data to collect, from whom to collect it or where to find it, and the best time to collect it. Your organization may already be collecting data for another purpose that now can be used for program evaluation. Some public records, such as smdent attendance, may be valuable if, for example, 20% increase in smdent attendance at aU grade levels is one of your programs indicators of impact. PHASE 111: PREPARE TO REPORT 1. Determine which audiences will want to know the results. 2. Consider several forums and formats to disseminate the results. 3. Plan reports, presentations, photo displays, graphs, charts, etc. Remember that your job is to make the evaluation results useful to your organization, so consider a range of ways to provide information to various groups. Consider briefs in the school or district newsletter, a handout updating staff about the schedule for data collection, five- minute progress updates in faculty meetings, bulleted statements on your web site, a digital picture album of the programs results in classrooms with photos of students, and hallway displays of student work. If your final report is a formal document complete with examples of your data collection instruments, consider writing an executive summary of five pages or less to help,readers get the essential information. PHASE IV: CREATE THE WORK PLAN 1. List all tasks to be completed for the whole evaluation., 2. Create a realistic timeline. 3. Assign work. 4. Distribute the master plan. You will have to be creative to accomphsh all the evaluation tasks. In education, we rarely have the luxury of contracting outsiders for the entire project Enlist steering committee members, partners, graduate students from the local university, and other talented critical friends to get the work done. One caution: For formal or summa- tive evaluations to be credible, avoid using insiders such as the program designers or implementers (coaches, mentors, trainers, or facilitators) to perform critical evaluation tasks that call for objectivity and distance. And be sure to get ongoing, high-quality techmeal expertise for the critical technical analysis. A CATALYST FOR REFLECTION Completing a major program evaluation usually serves as the catalyst for serious reflection on the current designs, poheies, and practices of your professional development programs  their goals, content, processes, and contexts. In fact, revelations are often so powerful that they bring about the realization that major changes are needed if significant results are really expected from professional development. People frequently conclude that designing the evaluation should be the first step in the program planning process, rather than an afterthought during implementation. E JSD Fall 2002 National Staff Development Council 79I 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 - 376-2147 October 10, 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: mchenryd^wbeU.net Mr, Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, AR 72201 Re: Little Rock School District v. PCSSD, et al. Case No. 4:82CV00866 Dear Chris: Plan. This refers to your letter of October 4, 2002, providing LRSDs proposed Compliance The courts remedy and the general subject matter are too complex for us to provide all comments and objections we may ultimately have before todays Board meeting. We do note the following: 1. More consideration is needed of the programs to be identified as implementation pursuant to Section 2.7 ..., which are to be subjected to a comprehensive program evaluation. .. Your document at page 7 identifies three areas. We note the absence of specific reference and detail regarding interventions / scaffolding ~ areas of vital importance given the achievement patterns of Afiican American students. We note also that the LRSD compliance report cited many more programs as designed to fulfill Section 2.7. 2. In a discussion prior to his testimony in the hearing Judge Wilson, we understood Dr. Ross to indicate that the existing evaluation of the Pre-K - 2 literary program was not adequate. The notation at page 4 of your document of the changed use of the Observation Survey and the DRA relates to part of the concerns he expressed. This undermines the LRSD argument (page 11) that the existing evaluation, upon Board approval, will satisfy a part of the courts remedy. 3. The LRSD discussion about satisfying the courts order regarding the evaluations mentioned at page 148 of the compliance report does not seem to take account of the material provided, which describes an adequate evaluation. 4. We question the period for implementation of a remedy which the court has identified and, therefore, the LRSD schedule. Once again, these comments should not be taken to be the full range of concerns, which Joshua may ultimately have about the courts remedy and the Compliance Plan. Nor do we intend to waive our concerns about the court setting forth a remedy, without first hearing from the parties and the ODM with regard to the courts views on an appropriate remedy. irtcerely, ohn W. Walker JWW:js cc: Ms. Ann Marshall All Counsel of RecordOCT.24.2002 8:06fiM JOHN W WALKER P A NO.963 P.2 JOHN W. WALKER SHAWN CHILDS John W. Volker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (601) 374-3758 FAX (501) 374-4187 October 23, 2002 or COUNSEL ROBERT McHENRY, PjL EONNAJ.McKE.NEY 8210 HbNDEKSON SQaD Litoe Rock, Arkansas 72210 Phone\n(501) 372-3425  Pax (501) 372-3428 Email: mchemyd^awbollnet Mr. Christopher Heller FRIDAY, ELDREDGE \u0026amp; CLARK 400 W, Capitol, Suite 2200 Little Rock, Arkansas 72201 Re\nLRSD V, PCSSD 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 performanof: 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 : EXHIBIT 10/24/2002 THU 09:03 [TX/RX NO 8580] 002' OCT. 24.2002 8:07AM JOHN W WALKER P A NO.963 P.3 Page Two October 23, 2002 requires the staff to undertake 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 Afiican 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. . Walker Sincere^, JWW:Ip All Counsel Ms. Ann Marshall Judge Thomas Ray 10/24/2002 THU 09:03 [TX/RX NO 8580] @003 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 RECEIVED PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. LET AL MAY 2 c 2004 DEFENDANTS MRS. LORENE JOSHUA, ET AL OFFICE OF DESEGREGATION MONITORING INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS PLAINTIFFS NOTICE OF FILING DOCUMENTS IN RESPONSE TO THE COURTS ORDER FILED MAY 12. 2004 Plaintiff Little Rock School District (LRSD) for its Notice of Filing states: 1. In response to the Courts Order filed May 12, 2004, attached is a Glossary of Acronyms and Educational Terms. 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\n^CL14---------- BYk Christopher Hell Page 1 of 2CERTIFICATE 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 May 24, 2004: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Mark T. Burnette Attorney at Law 1010 W. 3^ Little Rock, AR 72201 Mr. Robert Pressman 22 Locust Avenue Lexington, MA 02173 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 Nations Bank Bldg. 200 West Capitol Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Judge J. Thomas Ray U. S. District Courthouse 600 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Mark A. Hagemeier Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 istopher Heller Page 2 of 2 IGLOSSARY OF ACRONYMS AND EDUCATIONAL TERMS Below are identifications and/or definitions of acronyms and other educational terms that appear in exhibits. While most of the acronyms and terms are generically defined and equally applicable to most school districts in Arkansas, many are defined specifically in relation to the Little Rock School District. ACSIP (Arkansas Comprehensive School Reform Improvement Plan)  Plan required by State which specifically sets steps for school improvement AFRAMER (African-American) ALP (Alternative Language Program) - Another name for ESL ALT (Achievement Level Tests) - Tests the LRSD developed, with the assistance of a commercial testing firm, for the purpose of measuring student achievement growth within a school year. The test items were selected from a menu in the test firm's item bank, so all the questions had been used numerous times in schools across the country. Students in grades 3-11 took these tests in the fall and spring of each year. The LRSD discontinued the ALTs in September 2002, ANCOVA (Analysis of Covariance) ANOVA (Analysis of variance) - Statistical test with one outcome AP (Advanced Placement) - High-level courses with curriculum developed by College Board which allows students to test for earned college-level credit while in high school. AR (Accelerated Reader) - A program based on the premise that students become more motivated to read if they are tested on the content of the books they have read and are rewarded for correct answers. Students read books at predetermined levels of difficulty, individually take a test on a computer, and receive some form of reward when they score well. AYP (Adequate Yearly Progress) - Amount of improvement in proficiency required each year to reach total proficiency under NCLB (2013). Benchmark Examination - One of the criterion-referenced examinations implemented by the Arkansas Department of Education (ADE) for all Arkansas public schools in the 4th, 6th, Sth, and 11th grades and in selected high school courses. The tests are based on the state's curriculum as outlined in the curriculum frameworks. Test results are categorized as Below Basic, Basic, Proficient, and Advanced. BL (Balanced Literacy) - An approach to literacy instruction that focuses on providing instruction that addresses students individual strengths and needs through whole group and flexible grouping to enhance student development in all of the language arts areasreading, writing, spelling, listening, and speaking.CAP (Concepts about Print)  One of the assessments included in the Observation Survey Assessment which assesses childrens knowledge of book concepts. CAT (Collaborative Action Team)  A process designed to increase stakeholders involvement in schools. CBL (Calculator-based Laboratories)  Probes used to collect data for classrooms. CLT (Campus Leadership Teams)  A term used to refer to school-based leadership committees CMP (Connected Mathematics Project) - Mathematics curriculum resource used in Grades 6- 8 in Little Rock School District CREP (Center for Research in Educational Policy) - This is an organization based at the University of Memphis that conducts program evaluations for educational organizations. Dr. Steve Ross and Dr. John Nunnery are two researchers for CREP. CRT (Criterion Referenced Tests) - Tests that LRSD curriculum specialists, teachers, and other staff developed using the state's curriculum frameworks and the district's curriculum to guide item development. CSR (Comprehensive School Reform) - A whole school reform model DI (Direct Instruction) - A reading program that uses very explicit instructional language and follows a highly prescriptive program of instruction that is implemented according to a predetermined scope and sequence of skills DIBELS (Dynamic Indicators of Basic Early Literacy Skills) - This is a system utilizing a variety of assessments to monitor a childs progress in developing specific literacy skills which have predictive value for future reading achievement. The assessments include, but are not limited to, letter identification, phoneme segmentation, and oral reading fluency. DRA (Developmental Reading Assessment) - The second of two assessments given to LRSD students in grades K-2. This assessment consists of stories that increase in difficulty as the child's reading ability increases. Students are evaluated on a variety of reading skills, including comprehension. DSA (Developmental Spelling Assessment) - An assessment to monitor student progress along a spelling developmental continuum ELLA (Early Literacy Learning in Arkansas)  A statewide three-year staff development process designed to assist teachers in grades K-2 in implementing instructional techniques that support emergent learners. ELLA helps enhance teachers' understanding of how students learn to read and encourages them to use a balanced literacy approach in the classroom. EOC (End-of-course exam) - State-developed criterion-referenced tests implemented in Arkansas schools as part of the Arkansas Comprehensive Testing, Assessment, and Accountability Program (AT AAP). Currently, end-of-course exams are administered only in Algebra I and geometry. EXPLORE - An American College Testing (ACT) program designed to help Sth and 9th graders examine a broad range of options for their future. EXPLORE helps prepare students for their high school course work as well as their post-high school choices. ESL (English as a Second Language) - Refers to students for whom English is not their native language EYE (Extended Year Education) - Applies to schools with atypical school calendars without a long summer break. EEPE (Fluent English Proficient Exited) - students who are released from ESL program due to proficiency in English GT (Gifted and Talented) HBE (Home-based Educators) - employees of the Home Instruction for Parents of Preschool Youngsters (HIPPY) Program HIPPY (Home Instruction for Parents of Preschool Youngsters) - A parent-involvement readiness program for young children The program, which has been operating in the United States since 1984, offers home-based early childhood education for three-year-old children, working with their parent(s) as their first teacher. The HIPPY program provides parents with carefully developed materials, curriculum, and books designed to strengthen their children's early literacy skills and their social, emotional, and physical development. HLM (Hierarchical Linear Model) HSCP (Home, School, and Community Partnership) - A precursor to the Collaborative Action Team (CAT) HSTW (High Schools That Work) - A school-wide reform model for high schools that is based on the key practices of successful high schools IRC (Instructional Resource Center) - Offices of curriculum staff for LRSD. ITBS (Iowa Test of Basic Skills) - Norm-referenced assessment currently used by LRSD replacing Stanford Achievement TestJR TEAMS (Joint Recruiting and Teaching for Effecting Aspiring Minorities in Science) - A two week multidisciplinary pre-college science and engineering program offered through a partnership with the University of Arkansas at Little Rock aimed at increasing the number of minority students pursuing degrees in science and engineerinj LEP (Limited English Proficient) - Identifies students not proficient in English LPAC (Language Proficiency Assessment Committee) LPTQ - Literacy Program Teacher Questionnaire MANOVA (Multiple Analysis of Variance) - Statistical tests with multiple outcomes MSS - (Middle School Survey) - A survey completed by teachers and students on the implementation of the middle school model. NALMS (Not Assessed Language Minority Students) NCE (Normal Curve Equivalent) - A type of standard score, NCE scores are normalized standard scores on an equal interval scale from 1 to 99, with a mean of 50. The NCE was developed by RMC Research Corporation in 1976 to measure the effectiveness of the Title I Program across the United States. An NCE gain of 0 means that the Title I Program produced only an average gain or the expected gain if there was no Title I Program. (Students must answer more items correctly on the posttest than on the pretest in order to maintain the same NCE.) All NCE gains greater than 0 are considered positive. NCLB (No Child Left Behind) - Federal legislature requiring vast assessment and increased standards for American public schools NCTM (National Council of Teachers of Mathematics)  An organization of math teachers and specialists that has provided the standards for K-12 mathematics NPR (National Percentile Rank) - National percentile ranks indicate the relative standing of a student in comparison with other students in the same grade in the norm (reference) groups (in this case, the nation) who took the test at a comparable time. Percentile ranks range from a low of 1 to a high of 99, with 50 denoting average performance for the grade. The percentile rank corresponding to a given score indicates the percentage of students in the same grade in the norm group obtaining scores equal to or less than that score. For example, a student earning a percentile rank of 62 achieved a score that was equal to or better than the scores earned by 62% of the students in the national sample. NSES (National Science Education Standards) - The standards established for K-12 science educationNSF (National Science Foundation) - A government entity created in 1950 to promote excellence in science and to fund research. The LRSD received funds from NSF through a multiyear grant to improve mathematics and science instruction and achievement, naming the program Comprehensive Partnerships for Mathematics and Science Achievement (CPMSA). Grant funding ended August 31,2003.' NWEA (Northwest Evaluation Association) - A company that developed the Achievement Level Tests OTE (Onward to Excellence)  A whole school restructuring model PD (Professional Development) - Term used to describe the training provided to teachers to enhance their instructional or classroom management skills. PHLOTE (Primary Home Language other than English) PLAN - An American College Testing (ACT) guidance resource for 10th graders. PLAN helps students measure their current academic development, explore career or training options, and make plans for the remaining years of high school and post-graduation years. As a pre-ACT test, PLAN is a good predictor of success on the ACT. Typically, PLAN is administered in the fall of the sophomore year. PRE (Planning, Research, and Evaluation) - A department of the Little Rock School District Pre-AP (Pre-Advanced Placement) - Courses designed for middle school and high school to prepare students for success in Advanced Placement level courses. Pre-K-3 (Pre-kindergarten through 3^^ Grade) RIT (Rausch Unit) - a type of scaled score. RR (Reading Recovery) - An intensive early-intervention literacy program developed in New Zealand and used in this country for many years. The program is based on helping children with poor reading readiness skills develop the skills common to proficient readers. SAIP (Student Academic Improvement Plan) - A personalized plan required by State for lower-achieving students on ACTAAP Benchmark tests Includes both areas of deficiencies and plans for remediation. SAT 9 (Stanford Achievement Test, 9tb Edition) - A general education test used widely across the United States. It compares a student's performance on the test to a representative national norm group of students. For many years, the publisher of SAT-9 has had a contract with the ADE to provide tests to all students in the state's public schools in grades five, seven, and ten. The results are widely reported for every school district in the state, and each district receives data in varying formats to allow analysis of student performance by school, class, gender, race, or wealth.(Beginning in the 2003-04 school year, the state will require a similar nationally-normed test, the Iowa Tests, rather than the SAT.) SEDL (Southwest Educational Development Laboratory) - A private, not-for-profit education research and development corporation based in Austin, Texas. SEDL works with educators, parents, community members, and policymakers in the southwestern states to develop and implement effective strategies to address pressing educational problems. SEM (Science, Engineering, and Mathematics) SFA (Success for All) - A school-based achievement-oriented program for disadvantaged students in pre-K through grade five. The program is designed to prevent or intervene in the development of learning problems in the early years by effectively organizing instructional and family support resources within the regular classroom. Specifically, the goal of Success for All is to ensure that virtually every student in a high-poverty school will finish the 3rd grade with grade-level reading skills. SLET (Secondary Literacy Evaluation Team) SMART (Summer Mathematics Advanced Readiness Training) - This is a two-week halfday summer program for rising 8* and 9* grade students who will be enrolled in Algebra I during the upcoming school year. SMART provides opportunity for students to gain the knowledge, skills, and confidence needed to succeed in Algebra I. SpEd - Special Education SREB (Southern Regional Educational Board) - A private, not-for-profit education research and development corporation based in Atlanta, GA SREB works with schools, educators and policymakers in the southern states to develop and implement effective strategies to address pressing educational problems. One school-wide reform model, developed and sustained by SREB, is High School That Work (HSTW). SS (Scaled Score) - A type of standard score. Scaled score is calculated based on the difficulty of the questions and the number of correct responses. Scaled scores are useful for comparing student performance over time and across grades. All norm referenced scores are derived from the Scaled Score. Standard Score - Standard scores are a universally understood score system. Standard scores are used to place raw scores in context. For example, a raw score on a test doesnt mean much because it isn't compared to anyone or not compared to any scale. Standard scores offer two advantages to the student over conventional II. raw scores. It  standard scores take into account the relative difficulties of various exams and assignments  standard scores make it possible to measure improvementTAP (Teacher Advancement Program) - A strategy to attract, retain, motivate, and develop talented people to the teaching profession by rewarding good teachers with higher salaries. THRIVE - (Project THRIVE, a follow-up component to SMART) - This is a Saturday academy for students who are enrolled in Algebra I. Students participate in ten (10) Saturday sessions during the school year. Two primary goals of Project THRIVE are 1) to strengthen mathematical skills required to be successful in Algebra I, and 2) to prepare students for the State End-of-Course examination in Algebra I. URM (Underrepresented Minority Populations) - Includes American Indian/Alaskan Native, Black or African-American, and Hispanic or Latino. VOC - (Writing vocabulary) - One of the assessments included in the Observation Survey Assessment which WRAT (Wide Range Achievement Test) Z-scores - A test score that is converted to a common scale wherein scores from sets of data with different units can be compared.IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION 7Z//V LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. RECZiVED DEFENDANTS KATHERINE KNIGHT, ET AL. Jl/N - 9 200^ INTERVENORS OFFICE OF INTERVENORS 07 The Joshua Intervenors' Proposed Findings of Fact and Conclusions of Law Concerning the LRSD's Implementation of the Section 2.7.1 Compliance Remedy On September 13, 2002, this court held that the LRSD had failed to substantially comply with Section 2.7.1 of the agreed upon desegregation and education plan. [Mem. Opin. at 150-60] Accordingly, the court set forth a Compliance Remedy. II [Id. at n 170-72] This court's September 2002 opinion identified the purpose of Section 2.7.1, the importance of substantial compliance with its terms. and the capacity which the LRSD must demonstrate as one element of its burden to justify the termination of the court's supervision. This court wrote: . . . . I find that the purpose of Sec. 2.7.1 was to make sure that the programs under Sec. 2.7 actually worked to improve the academic achievement of Af rican-american students. further find that LRSD's 2.7.1 was crucial to its commitment substantial compliance with Sec. to improve the academic I 1achievement of African-American students\nfor, without performing a rigorous annual assessment of each of the many dozens of programs implemented under Sec. 2.7, it would be impossible to determine which programs were working and should be continued and which programs were not working and should be discontinued, modified, emphasis in original] replaced with new programs [at 150\nsupervision and monitoring conclude that the court should continue of LRSD's compliance with this crucially important section of the Revised Plan in order to ensure that LRSD has in place an effective assessment program that will allow it to identify and improve those programs that are most effective in remediating the academic achievement of African American students, [at 168] I These elements of the court's opinion help to frame the issues presented by the Joshua Intervenor's opposition to the LRSD effort to be released from court supervision, heard by the court on June 14-15, 2004. Based upon the record, the court enters the following findings of fact and conclusions of law. 1 I. Findings of Fact A. The Lack of Capacity of the LRSD to Perform the Requisite Assessments and Evaluations (1.) Based upon the facts set forth in paragraphs 2 through 26, the court finds that the LRSD has failed to TI [demonstrate] that a program assessment procedure is in place that can accurately measure the effectiveness of each program implemented under Section 2.7 in improving the academic achievement of African-American students\n. J! [\"Compliance Remedy, TI Mem. Opin. at 170\nsee also id. at 168] [Haney, Hunter, Jones, Marshall testimony] 1 LRSD and Joshua Intervenors' exhibits are cited LRX at and JX at names. --, respectively. Witnesses are cited by their last 2The Lack of Adequate Staff (2.) In its ruling of September 13, 2002, this court cited the recognition of the school board and upper echelon administrators that the LRSD had been without the capacity to prepare what the court termed in-depth and analytic program evaluations.  [Mem. Opin. at 15 6\nsee id. at 153 (Dr. Lesley)\nat 156-57 (school board)\nat 157 (Superintendent Carnine)]\nat 159 (Dr. Lesley). (3.) The LRSD Compliance Plan was heavily dependent on actions by former Associate Superintendent Bonnie Lesley. n [LRX 3 (\"Action Plan Timeline at 15-16)] Doctor Lesley left the district for employment out-of-state on March 14, 2003. [JX 11 at 5] The slow pace of filling her position played substantial part in continuing the lack of adequate staffing for the assessment \\ evaluation task. [Id. (ODM notes filling of position on an interim basis on June 26, 2003)] [Jones and Marshall testimony] (4.) Overall, the evidence establishes that subsequent to the court's entry of the Compliance Remedy, the LRSD has continued to have an inadequately staffed evaluation\\assessment capacity. [JX 11 at 2 (third paragraph), 5, 6, 16 (second paragraph) (ODM report. March 30, 2004)\nJones and Marshall testimony] The ODM report states in part: ri In the summer of 2001, the associate superintendent who led PRE had resigned and that position had remained empty. As a result, the top positions in both PRE and the instructional division were vacant at the critical time for preparing program evaluations. omitted] IT [JX 11 at 16] PRE II [footnote Planning, Research and Evaluation. refers to the Department of a 2 2 3The Failure to Identify the Programs Subject to the Compliance Remedy____________________________ (5.) In the opinion of September 13, 2002, this court found that the LRSD had identified many dozens of programs [as] implemented under Section 2.7 [of the agreed upon Plan] . . n [Mem. Opin. at 150] The court's Compliance Remedy provides in part as follows: A. For the entire 2002-03 school year and the first semester of the 2003-04 school year, through December 31, 2003, LRSD must continue to assess each of the programs implemented under Section 2.7 to improve the academic achievement of African- TXmerican students. . . [Mem. Opin. at 170\nemphasis added] Nevertheless, despite inquiries from ODM, the LRSD never identified, with clarity, the programs which it deems to be subject to this mandate. [JX 11 at 23 (ODM report, March 30, 2004)\nJones testimony] Standards for Conducting Evaluations (6.) In the light of the court's opinion [Mem. Opin. at 151- 52\n153\n156-58], the LRSD properly concluded [LRX 3 at 7 (LRSD Compliance Plan)] that it must each year complete some comprehensive evaluations of key parts of the curriculum fl designed to improve and remediate the academic achievement of African- 7\\merican students . If [Plan Section 2.7] (7.) In 2000, Dr. Ross met with the LRSD Compliance Committee. A part of the discussion is described in the ODM report, March 30, 2004, as follows: . . [Dr. Ross] also described the program evaluation process, which included classroom observation plan developed at the University of Memphis. The observations were to ensure that programs were being consistently implemented in the classrooms throughout the district a 4[JX 11 at 3\nJones testimony] (8.) Dr. Ross prepared for the LRSD a document, dated December n 3, 2002, regarding the completion of of the 14 page 148 8 evaluations (that is evaluations listed on page 148 of the March 2002 interim compliance report). It IS titled Guidelines for Completing Eight Program Evaluations in Little Rock School District. I! [JX 6] The document articulates. among others. the following premise [JX 6 at 1]\n(9.) Program evaluations that focus predominately on student achievement outcomes while sufficient lacking implementation data have reduced value due to inability to determine the nature of the 'treatment.' The study will also fail to inform policymakers about the practicality of the program, how it was used and reacted to by stakeholders, or whether and\\or how it needs to be improved to impact at-risk learners. On October 10, 2002, the LRSD school board adopted Regulation IL-Rl titled \"Program Evaluation Agenda. The Regulation sets forth standards and procedures for the content of program evaluations in the LRSD. [JX 2] (a) LRSD Regulation IL-Rl [JX 2 at 3] identifies the need for the evaluation process to satisfy \"accuracy standards. including one concerning tl program documentation. 11 n H Program Documentation. The program being evaluated should be described and documented clearly and accurately so that it is identified clearly........ (b) LRSD Regulation IL-Rl also contains the following The LRSD concluded that 6 of the 14 IT page 148 evaluations \"without additional work could be approved by the school board . [LRX 3 at 5] Dr. Ross' Guidelines addressed the completion of the other 8 \"page 148 evaluations.\" [JX 6 at 12] evaluations. TT 3 5provision: \"Program Evaluation Procedures [JX 2 at 4-5] 6.C. Write a clear description of the curriculum\\instruction program that is to be evaluated, schedule of its implementation. with information about the (c) Regulation IL-Rl provides in part (JX 2 at 5) that the first meetings [of the evaluation team] will be devoted to the following tasks . . D. Agree on any necessary research questions that need to be established in addition to the question, this curriculum\\instruction program been ineffective in improving and remediating the academic achievement of African-American students?' (See Policy IL, 2.7.1 of the Revised Desegregation and Education Plan, and Judge Wilson's Compliance Remedy.) Thus, LRSD policy recognized that the court's Compliance remedy required a focus on individual programs (\". . . program (10.) LRSD Policy IL (\"Evaluation of Instructional Programs\") [JX 1] provides that all program evaluations will follow standards established by the National Joint Committee on Standards for Education Evaluation. TI Policy IL-Rl further identifies these n ' Has . this . standards as The Program Evaluation Standards, 2nd Edition: How to Assess Evaluations of Educational Programs (Thousand Oaks, CA: Sage Publications). [JX 2 at 1] These standards include the following content in the section on \"accuracy standards TI [at 125, 127-28]: STANDARD The program being evaluated should be described and documented clearly and accurately. so that the program is clearly defined. Overview It IS necessary for the evaluator to gain solid understanding of the program being evaluated, including both the way it was intended to be and the way it actually was a 6implemented, and to convey this description to others. Failure to gain such understanding will lead to an evaluation that, when completed, is likely to be of questionable use. A valid characterization of a program as it actually was implemented will describe its unique features and component parts in order to facilitate comparisons of the program with similar programs. A good description of the program will also facilitate attempts to associate components of the program with its effects. * GUIDELINES A. Ask the client and the other stakeholders to describe orally, and, if possible, in writing  the intended and the actual program with reference to such characteristics as personnel, cost, procedures. location, facilities, setting, activities, objectives, nature of participation, and potential side effects .... C. Engage independent observers to'describe the program if time and budget permit. D. Set aside time at the beginning of the evaluation to observe the program and the staff and participants who are involved .... The Literacy Evaluation (filed by LRSD on March 12, 2004) (11.) The LRSD offers as one comprehensive evaluation the \"Little Rock School District Literacy Program Evaluation.\" The LRSD provided or approved a list of research questions for this study not includincf the question quoted in para. 9(c), identified by the LRSD as a necessary element of any evaluation to be a part of the effort to satisfy the court's Compliance Remedy. 4 Where the focus was to be the impact of individual programs on African American achievement and the possible need for program changes. this omission led to an evaluation with an insufficient focus on 4 See Literacy Evaluation at 1\nat 4 (indicating that question most relevant to the Compliance Remedy was given lesser emphasis). 7particular programs and their impact on the intervenor class. (12.) The Literacy Evaluation contains insufficient description of the program(s) being evaluated to satisfy LRSD or professional standards. See Literacy Evaluation at 10-11\nparagraphs 9-10, supra\nHaney, Hunter, Jones testimony. This IS particularly the case at the middle school and high school levels. [Literacy Evaluation at 11] Interviews of middle and high school teachers revealed a lack of knowledge of any literacy plan at those levels. [Literacy Evaluation at 7, 13, 43] (13.) The Literacy Evaluation does not provide senior administrators or the school board information on particular programs adequate to determine whether any particular program should be eliminated, modified, or better implemented. [Hunter and Jones testimony] There are evaluation models allowing a focus on individual programs. [Haney and Hunter testimony\nLRX 16 at 6] (14.) The Literacy Evaluation provides scant information on the extent of implementation of any particular program. As Sec. 2.7.1 refers to \"modifying how the program is implemented,\" this deficiency is highly significant. [Haney, Hunter testimony] (15.) The Literacy Evaluation is in the main an evaluation of student test scores. rather than an evaluation of the impact of particular education programs. [Literacy Evaluation at 44-47\nHaney and Hunter testimony] The Literacy Evaluation is marked by several technical problems (absence of data on use of teacher questionnaires\nlack of demographic information on teachers in focus groups\ninadequate data on student whose files were excluded 8from analyses). [Hunter testimony] (16.) There are at least two problems in the analyses of the trends in African American students' scores on successive version of Arkansas benchmark tests. [Literacy Evaluation at 44-45] There IS no discussion of \"equating successive versions (that IS , considering whether later versions are of comparable rigor). There is no consideration of whether the pattern reported at upper grades is attributable to the dropping out, disproportionately, of black students with weaker achievement levels. [Haney and Marshall testimony\nJX 13] (17.) To satisfy professional standards for evaluations. a report that addresses progress on standardized tests should include other data bearing on the presence or absence of academic progress. such as grade to grade progression data (that is, whether students are being promoted or retained) and drop out data. [Haney and Marshall testimony] (18.) The Literacy Evaluation is deficient when measured against the standards earlier articulated by Dr. Ross . See paragraphs 7-8. The text of the Literacy Evaluation shows that it n focus[es] predominately on student achievement outcomes while lacking sufficient implementation data . . n The description of programs is exceedingly terse and, at grade levels 10-12, almost non-existent. [Literacy Evaluation at 10-11] It reflects no observation of classrooms by outside observers to assess actual program implementation. The latter problem is a consequence of the schedule for the evaluation adopted by the LRSD, as well as the 9inadequacy of funding (not sufficient to pay for classroom observation). This study can not help to answer the question n whether and\\or how [the literacy program] needs to be improved to n impact at-risk learners. LRSD Regulation IL-Rl [JX 2] includes as one criterion for identifying evaluation topics the following question [at 4] :  Can the results of the evaluation influence decisions about the program? II See also LRX 16 at 6 (memorandum by Dr. Ross dated April, 2004 recognizing the parameters of the Literacy Evaluation). The Math-Science Evaluation (filed by LRSD on March 12, 2004) (19. ) The LRSD offers as one comprehensive evaluation \"An Evaluation of Mathematics and Science programs in the Little Rock School District from 1998 to 2003. The Math-Science Evaluation contains insufficient description of the program(s) being evaluated to satisfy LRSD or professional standards. See Math-Science Evaluation at 5-10\nparagraphs 9-10, supra\nHaney, Hunter, Jones testimony] (20.) The Math-Science Evaluation does not provide senior administrators or the school board information on particular programs adequate to determine whether any individual program should be eliminated, modified, or better implemented. [Hunter and Jones testimony] (21. ) The Math-Science Evaluation identifies methods for determining the extent of implementation of educational programs. but does not provide results for the math-science program. [Math- Science-Evaluation at 11] As Sec. 2.7.1 refers to \"modifying how 10the program is implemented, IT this deficiency is highly significant. [Haney, Hunter testimony] (22.) The Math-Science Evaluation is in the main an evaluation of student test s\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_289","title":"Compliance court orders","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":["2002-01/2002-07"],"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 districts--Arkansas--Pulaski County","Educational law and legislation","Education--Evaluation","School administrators"],"dcterms_title":["Compliance court orders"],"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/289"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nRECEIVED JUL - 8 2002 OFFICE OF IN THE UNITED STATES DISTRICT COURT ARKANSAS DESEGREGATION MONITORING EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION JUL 0 1 2002 JAMES 0y:^ LITTLE ROCK SCHOOL DISTRICT V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER Pending is Plaintiffs Motion for a Protective Order and for Emergency Hearing. For the time being. Plaintiffs request for a protective Order against Joshua, or anyone acting on their behalf, is GRANTED. The deadline for exchanging exhibits and witnesses was set on May 15,2002, for June 21, 2002. At the request of lawyers for LRSD and Joshua, the deadline was orally extended until 5:00 p.m. on Monday, June 24, 2002. It appears, from the documents attached to Plaintiffs Motion, that Joshuas FOI request was submitted on June 26, two days after the deadline for exchanging exhibits and the names of witnesses. Even assuming the FOI can be used in addition to the Federal Rules of Civil Procedure by a party to litigation, it appears quite certain that this request was not timely. It is my impression, from a quick review of the law, that the great weight of authority precludes a party from using the FOI as a supplement to the discovery rules of the Federal Rules AO 72A (Rev.8/82)of Civil Procedure\nbut, be that as it may, this particular request appears to be manifestly out of time. I note in passing that many, if not most, of the documents requested in the FOI request are not pertinent to the three remaining issues in this case. Accordingly, the LRSD is relieved of any duty to respond to the FOI request by Joshua. If Joshua wants a hearing on this issue, it should file a response to Plaintiffs Motion forthwith. and request a hearingif such a request is made, a hearing will be set as soon as practicable. IT IS SO ORDERED. DATED this J day of July, 2002. UNITED STATES DISTRICT JUDGE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITHERULE 58 AND/OR 79\u0026gt;) FRCP BY. -2- AO72A (Rev.8/82)AO 72A (Rev.8/82) oJIaOilNaW N01iV33H03S3a 30301330 zooz 8 - inr cisAiaoau EASTeflN district nsac 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. 1,ETAL. RECEIVED MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. JUL 0 2 2002 JAMES w Ml By:. PLAINTIFF DEFENDANTS IX JUL -8 2002 INTERVENORS OmCEOF DESEGREGATION MONITORING INTERVENORS ORDER On July 1, 2002, I entered an Order (docket no. 3611) granting LRSDs request for a protective order to the extent that LRSD was relieved of its duty to respond to Joshuas FOI requests, which appeared to be untimely under the May 15, 2002 Scheduling Order (docket no. 3600). However, I permitted Joshuas counsel the opportunity to file a written response to LRSDs Motion for Protective Order and for Emergency Hearing and to request a hearing if he deemed it necessary. This morning, I received Joshuas counsels July 1, 2002 letter, a copy of which is attached to this Order. In that letter, Joshuas counsel requests me to rescind my July 1 Order, allow him an opportunity to file a written response to LRSDs Motion, and then allow either party to request a hearing. This Order responds to the various points raised by Joshuas counsel in his July 1 letter. First, my July 1 Order admittedly was entered in haste because LRSDs motion papers declared an emergency and made it clear that July 1, 2002, was the deadline for it to produce 6 1 2documents pursuant to Joshuas FOI requests. Furthermore, in LRSDs Brief in Support of Motion for Protective Order and Emergency Hearing, its counsel pointed out that Ark. Code Arm.  25-19-104 provides a potential criminal penalty (of thirty days in jail) which could flow from the LRSDs failure to respond within three days [to Joshuas FOI requests]. This time of year, jails in Arkansas are particularly uncomfortable. Therefore, I hastened to enter my Order before 5:00 p.m. on July 1, lest I place someone in jeopardy of being hauled off in chains. I want to assure counsel for Joshua that, in entering that Order, I was not vexed with counsel-somewhat or otherwise. I appreciate counsel for Joshua clarifying that the FOI requests were filed in connection with his ongoing monitoring of LRSD under the 1998 Revised Desegregation and Education Plan (the Revised Plan). This important point apparently was not communicated to LRSD, which understandably construed the FOI requests as seeking documents that Joshua intended to use in connection with the upcoming evidentiary hearing which commences on July 22, 2002. In LRSD V. PCSSD, 921 F.2d 1371,1386 (8* Cir. 1990), Judge Arnold made it clear that, in approving the 1989 global settlement of this case, the Court placed a great deal of weight on the fact that the parties have all agreed to continued monitoring, which the Court found to be essential. Likewise, Exhibit B to the Revised Plan makes it clear that Joshuas counsel will continue his monitoring of the LRSDs implementation of its desegregation obligations. By clarifying that Joshua is seeking the documents described in its FOI requests in connection with Its continuing monitoring duties, and not for use in the July 22 hearing, I believe counsel should be able to work out a satisfactory schedule for the production of the requested documents. As an aside, I believe that counsel for both sides have more than enough to do in preparing for the -2- AO72A (Rev.8/82)upcoming five days of evidentiary hearings beginning on July 22, and should not to have to concern themselves with the collection and production of a large volume of documents related to Joshuas ongoing monitoring function. It appears to me the production of those documents can and should be delayed until after the completion of the evidentiary hearings that begin in less than three weeks. In conclusion, my July 1 Order will remain in effect until after the evidentiary hearing unless counsel for Joshua can convince me that there is a need for the production of the documents described in the FOI requests before the July 22 hearing. Counsel for Joshua is allowed until and including July 8, 2002, to file a response to LRSDs Motion for Protective Order and for Emergency Hearing. LRSD can submit a short reply by 5:00 p.m. on Thursday, July 11, 2002. Thereafter, if either party requests a hearing on that Motion, the Court will likely conduct one. IT IS SO ORDER^ DATED this day of July, 2002. UNITED STATES DISTRICT JUDGE THIS DOCUMENT ENTERED ON docket sheet in compliance 58 and/or 79(a CP -3- AO72A (Rev.8/82)JUL. 1.2002 5:55PM JOHN M WALKER P A NO.521 P.2/3 JOHN W. WALKER, P.A. .'Attorney At Law 1723 Broadway LriTLB Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WAT.KP.ft SHAWN CHILDS Via Facsimile - 604-5149 July 1, 2002 OF COUNSEL ROBERT McHENKY, DONNAJ.McHENRY 8210 HxndbebonRoad Lmu Eock, Abkansas 72210 PHONE\n(501) 372-3426  Fax (501) 372-3428 Email mehonrydSawbalLnat Honorable Judge William R, Wilson United States District Judge 600 West Capitol, Suite 423 Little Rock, AR 72201 Re: Case Ne. 4\n82CV0S66WRW/JTR LRSD V. PCSSD Dear Judge Wilson\nI received your order dated July 1, 2002 after 5:30 p.m. when I returned to the office from trial before the Honorable George Howard, Jr., USA v. Dennis Williams and Joe Bryant. I am a 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-ceunsel. I believe the Court would not be ygjtfid 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 fiom 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 A^eements 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 maimer 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 toJUL. 1.2002 5:55PM JOHN UI WALKER P A NO.521 P.3/3 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 of March 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. JWW\njs cc: All Counsel of Record Cleric of the Court Si irely, ihn W. Walker Deceived JUL -8 2002 OFFICE OF ESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS LITTLE ROCK DIVISION :^NSAS JUL - 5 2002 JAMES W, Mc( By.----------J .RMACK, IRK EAST^R^N LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. No. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS ORDER On July 3, 2002, LRSD filed a Motion in Limine and Supporting Memorandum Brief arguing that\n(1) because Joshuas witness list fails to comply with the Courts May 15, 2002 Order, Joshua should be required, on or before 5:30 p.m. on July 10,2002, to identify the date and time each of their witnesses will be called, to identify the issues on which each witness is expected to testify and to provide a detailed statement of the witnesses expected testimony on each issue\n(2) certain Joshua exhibits should be excluded because they have not been provided to LRSD as required by the Courts May 15 Order\n(3) Joshua should not be allowed to call Sadie Mitchell and Junious Babb, because, in earlier evidentiary hearings, Joshuas counsel has called and examined both of them on student achievement, guidance counseling, and advanced placement courses\n(4) various Joshua exhibits should be excluded because, on their face, they do not directly relate to the three remaining issues of advanced placement courses, guidance counseling, and extracurricular activities\n(5) any testimony from Jim Mosby and Jody Carter related to their recent removal as principals of Southwest Middle School and McClellan High AO 72A (Rev.8/82) 61 61 School should be excluded under Fed. R. Evid. 401,402, and 403\n(6) Joshuas failure to identify any witnesses or exhibits for use in their thirty minutes of true rebuttal prevents them from presenting any rebuttal testimony at 8:30 a.m. on July 22,2002\nand (7) Joshua Exhibits 767- 776 and 791 should be excluded under Fed. R. Evid. 801-804, 401-403, and 901. The schedule for LRSD and Joshua submitting their exhibits and witness lists to the Court on July 9 and the commencement of evidentiary hearings on July 22 necessitates an expedited response from Joshua to LRSDs Motion in Limine. Therefore, Joshua must file their response to LRSDs Motion in Limine no later than 2:00 p.m. on Monday, July 8, 2002, and serve other counsel by fax at or before that time. Thereafter, the Court will promptly decide the merits of LRSDs Motion in Limine. Since time is of the essence, this Order will be faxed to counsel of record as soon as it is entered. IT IS SO ORDERED. DATED this day of July, 2002. IITED STATES DISTRICT JUDG' UNITED DGE THIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE BY. WITH RULE 58 AND/OR79(a) FRCP OU 11 OTx -2- AO72A (Rev.8/82)RECEIVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION JUL \"8 2002 OFFICE OF DESEGREGATION MONITORING LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1,ETAL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS MEMORANDUM BRIEF IN SUPPORT OF PLAINTIFF'S MOTION IN LIMINE RELEVANCE GENERALLY The LRSD moves to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors pursuant to Fed. R. Evid. 401, 402 and 403. The ultimate issue before this Court is whether noncompliance with the Revised Plan casts doubt on the Board's intent to comply with the Constitution in the future absent court supervision. See Cody v. Hillard, 139 F.3d 1197, 1199 (8* Cir. 1998). Noncompliance that the Board knew nothing about has no bearing on this issue and is irrelevant. See Fed. R. Evid. 401. Section 1983 Liability Standard The issue before this Court is analogous to the issue of whether a governmental entity may be held liable under 42 U.S.C.  1983 for the unconstitutional conduct of its employees. Respondeat superior is not a permissible theory for holding a governmental entity liable for the unconstitutional acts of its employees. Monell v. Department of Social Services, 436 U.S. 658, 690, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978). Instead, a governmental entity is liable under 1983 when \"a policy, statement, ordinance, regulation or decision officially adopted and promulgated by that body's officers\" can be causally related to the allegedly unconstitutional conduct of itsemployees. Id. Liability may also be based on \"constitutional deprivations visited pursuant to governmental custom even though such a custom has not received formal approval through the body's official decision-making channels.\" Id. at 690- 91, 98 S.Ct. 2018. See Ryan v. Board of Police Commissioners of the City of St. Louis. 96 F.3d 1076, 1084 (8th Cir.1996). In Ware v. Jackson County. 150 F.3d 873 (8th Cir.1998), the Eighth Circuit explained that: Official policy involves 'a deliberate choice to follow a course of action * * * made from among various alternatives' by an official who [is determined by state law to have] the final authority to establish governmental policy.\" Jane Doe A. 901 F.2d at 645. Alternatively, \"custom or usage\" is demonstrated by: (1) The existence of a continuing, widespread, persistent pattern of unconstitutional misconduct by the governmental entity's employees\n(2) Deliberate indifference to or tacit authorization of such conduct by the governmental entity's policymaking officials after notice to the officials of that misconduct\nand (3) Th[e] plaintiff['s] injur[y] by acts pursuant to the governmental entity's custom, i.e., [proof] that the custom was the moving force behind the constitutional violation. Ware, 150 F.3d at 880 (citations omitted) (emphasis supplied). \"[I]naction or laxness can constitute government custom if it is permanent and well settled.\" Tilson v. Forrest City Police Dept.. 28 F.3d 802, 807 (8th Cir.1994) (citation omitted). \"Such a government custom of laxness or inaction must be the moving force behind the constitutional violation.\" Id. \"To establish a city's liability based on its failure to prevent misconduct by employees, the plaintiff must show that city officials had knowledge of prior incidents of police misconduct and deliberately failed to take remedial action. Fowler. 98 F.3d 1069, 1075 (Sth Cir.1996) (emphasis supplied). Andrews v. In the context of the present case, the Board is the \"final authority\" in making District policy. During the term of the Revised Plan, the Board adopted and/or re-adopted clear, unambiguous policies indicating its intent to comply with the Revised Plan, federal civil rights statutes and the Constitution. See CX 719. Thus, to cast doubt on the Board's intent to comply with the Constitution in the future, Joshua must establish a \"custom or practice\" of failing to remedy noncompliance with the Revised Plan. This requires that Joshua show \"that [the Board] had knowledge of prior incidents of [noncompliance] and deliberately failed to take remedial 2action.\" Andrews, 98 F.3d at 1075. Accordingly, incidents of noncompliance of which the Board did not have knowledge are irrelevant. See Fed. R. Evid. 401. Joshua may argue that the District failed to adequately train or supervise its employees who were violating the Revised Plan. It is true that a governmental body may also be held accountable under certain circumstances based on a failure to adequately train and supervise employees. City of Canton v. Harris, 489 U.S. 378, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989). In Andrews, the Eighth Circuit summarized these circumstances related to a city police force. The court stated: A city also may be liable for deficient policies regarding hiring and training police officers where (1) the city's hiring and training practices are inadequate\n(2) the city was deliberately indifferent to the rights of others in adopting them, such that the failure to train reflects a deliberate or conscious choice by a municipality\nand (3) an alleged deficiency in the city's hiring or training procedures actually caused the plaintiffs injury. It is necessary to show \"that in light of the duties assigned to specific officers or employees the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, the policymakers of the city can reasonably be said to have been deliberately indifferent to the need.\" In other words, the plaintiff must demonstrate that the city \"had notice that its procedures were inadequate and likely to result in a violation of constitutional rights. Andrews, 98 F.3d at 1076 (citations omitted) (emphasis supplied). In the context of the present case, Joshua must establish that the Board \"had notice that its procedures were inadequate and likely to result in a violation of [the Revised Plan.].\" Id. It is simple common sense that the Board cannot be on \"notice that its procedures were inadequate\" if the Board was unaware of the noncompliance resulting from the alleged procedural inadequacy. Therefore, Joshua must at a minimum show that the Board had knowledge of noncompliance with the Revised Plan in order to cast doubt on the Board's intent to comply with the Constitution in the future absent court supervision. The Revised Plan Requiring Joshua to show, at a minimum, that the Board had knowledge of noncompliance about which they complain is consistent with the Revised Plan. As a part of the 3Revised Plan, Joshua and the LRSD agreed to a process for raising and resolving compliance issues. Revised Plan  8 outlined a three step process for resolving compliance issues. First, the issue would be brought to the attention of the District. If the parties were unable to reach an agreement, the issue would be submitted to ODM for facilitation. Finally, the issue would be presented to the Court for resolution. During the term of the Revised Plan, all compliance issues raised by Joshua were resolved without the need for facilitation by ODM or resolution by the Court. See Final Report, p. 166. Consistent with Revised Plan  8, the Board expected Joshua to bring to its attention any substantial compliance issues. To facilitate Joshua's monitoring of the District's compliance, the Board agreed in advance to pay Joshua to monitor the LRSD's compliance with the Revised Plan, and Joshua billed the LRSD for monitoring the LRSD's Compliance. See Exhibits 7 and 8 to Plaintiffs Memorandum Brief in Support of Motion for an Immediate Declaration of Unitary Status. Therefore, Joshua cannot be heard to complain that requiring it to show that the Board had knowledge of noncompliance is inconsistent with the Revised Plan. Conclusion The parties knew there would be compliance issues, and for that reason, agreed to Revised Plan  8. Thus, real question before this Court is not whether there was noncompliance, but how the Board responded to noncompliance. The Board had no opportunity to respond to noncompliance of which it was unaware. Thus, noncompliance that was not brought to the Board's attention is irrelevant and should be excluded pursuant to Fed. R. Evid. 401, 402 and 403. 4t Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE \u0026amp; CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 / (501 S5011 Christopher Hell 81063) CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by mail on July 2, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 (via hand-delivery) Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026amp; Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Ms. Ann Marshall Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Christopher Hellei 5RECEIVED -/o 4^y JUL 1 0 2002 OmCEOF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT d^URT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION  By. He 08 2082 LITTLE ROCK SCHOOL DISTRICT ^OTF V. NO. 4:82CV00866 WRW/JTR PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. LET AL DEFENDANTS MRS. LORENE JOSHUA, ET AL INTERVENORS KATHERINE KNIGHT, ET AL INTERVENORS JOSHUA INTERVENORS RESPONSE TO THE LRSD I. Joshua Intervenors Witness List The Joshua Intervenors maintain that their witness list generally parallels the list submitted by the LRSD, by identifying the topics of witness testimony. For example, the LRSD can maintain that the summary of the testimony of Dr. Leslie (for 6 hours) provide [s] a detailed statement of the witnesses expected testimony on each issue only on a tongue in cheek basis. The Joshua Intervenors face two problems in preparing a witness list, which the LRSD does not face. The LRSD has ready access to all of its witnesses, who are its employees. In contrast, none of Intervenors witnesses are employees.' Moreover, at least 11 of Intervenors witnesses are subject to the direction of the LRSD. These are witnesses number 1-3, 5, 7, 14-15, 18-19, 23, and 26 on the Intervenors list. Nevertheless, the Joshua Intervenors will submit a supplemental witness list by 5:00 p.m. on Doctors Roberts and Ross are experts designated by Intervenors. -1-July 10, 2002. 2. Asserted Failure to Provide Exhibits The LRSD complains about the failure to provide exhibits identified by the numbers 793, 794, 799, 800 and 801. Each exhibit is an LRSD document(s). Some are voluminous. By this objection, the LRSD is simply seeking to frustrate the Joshua Intervenors effort to present the position of the class in a reasonable manner. Exhibit 801, LRSD Quarterly Status Reports, was the subject of testimony during the earlier hearings. These reports contain information regarding enrollment in advanced courses, as well as the extent to which students succeed. 3. Testimony by Sadie Mitchell and Junious Babbs These associate superintendents served on the LRSD compliance committee during the implementation of the revised plan and have had responsibility for the areas of guidance counseling and extracurricular activities. LRSD plans to offer lengthy testimony by Ms. Mitchell (two hours). The Joshua Intervenors, in contrast, propose to question each administrator for approximately 10 minutes. In this light, it is appropriate to allow Joshua Intervenors to proceed with the testimony. with the LRSD having the right to object to a question as repetitive. 4. Various Exhibits Assertedly Not Relevant to Issues to be Heard The exhibits deal with the following issues: advance placement: 754, 801-802 guidance and counseling: 780, 786-789 extracurricular activities: 746 (lumped statistics), 771, 773, 775 rebuttal: 743, 747, 749, 750, 755, 757, 758, 759, 760, 762, 763, 764, 779, 785 will not be offered: 752, 756, 761, 777, 778, 779, 782, 783, 784 -2-5. Testimony from Jim Mosby and Jody Carter The Joshua Intervenors do not plan to question Messrs. Mosby and Carter regarding their recent removal as principals. 55 6. Rebuttal The Joshua Intervenors will present rebuttal testimony by ODM Monitors Ann Marshall and Gene Jones. They will address the LRSDs testimony at the earlier hearing, which asserted compliance with Section 2.7.1 of the revised plan. 7. Joshua Exhibits 767-776. 791 These letters written by Ms. Springer are offered to show notice to the district of various problems. Counsel for Joshua Intervenors intends to explore at the hearing what if any investigation and other responsive actions were undertaken by the LRSD, after receipt of the letters. The LRSD pledged to implement programs, policies and procedures to insure non-discriminatory access to extracurricular activities. Its administrators responses to the letters is therefore relevant. The Joshua Intervenors should have the opportunity to seek the authentication of pages 2 and 3 of Exhibit 791, dealing with guidance, by the testimony of Junious Babbs and Sadie Mitchell. 8. Relevance Generally The LRSDs efforts to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors . . . [Motion in Limine at 3] and to rely on Section 1983 entity liability standards [Memorandum Brief in Support of Plaintiff s Motion in Limine] is flawed. These gambits ignore the law of the case, and, more particularly, multiple promises, throughout the plan, to implement various activities without regard to whether or not non-compliance was called to the attention of the Board. See, e.g.. Revised -J-Plan Sections 2.5, 2.7, 2.7.1, 2.12.1, 6, and 11. As emphasized in Joshua Intervenors response of May 30, 2002, the Court of Appeals has held and reiterated that the terms of settlement agreements in this case provide the standards for measuring the performance of the school districts, here the LRSD. [Memorandum at 47] The Revised Plan does not identify Section 1983 entity liability principles as the standard for evaluating compliance with its terms. Rather, it calls, inter alia, for adoption of various programs, policies, and procedures, their implementation, and monitoring to identify problems and provide a basis for remedial actions. School Board members are not LRSD employees, their commitment is for less than full-time. Manifestly, the plan envisions implementation activities by administrators and other elements of the work force, without qualification in terms of notice to the school board. Joshua Intervenors proof will be consistent with this framework. There will likely be questioning on the adoption of programs, policies, and procedures (largely the domain of the school board). There will be questioning of implementation, or the lack thereof (largely the domain of fulltime employees). The effort to exclude evidence, wholesale, is without merit. Respectfully submitted. / Robert Pressman, Mass Bar No. 405900 22 Locust Avenue Lexington, MA 02421 (781) 862-1955 4, // Lu John Walker, AR Bar No64046 JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 (501) 374-3758 (501) 374-4187 (Fax) -4-CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has-been serit\\by fax and U.S. Mail, postage prepaid to the following counsel of record, on this T\" day of ,2002: Mr. Clay Fendley FRIDAY, ELDREDGE \u0026amp; CLARK 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 Mr. Dennis !en Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, Arkansas 72201 Ms. Ann Brown Marshall ODM One Union National Plaza 124 West Capitol, Suite 1895 Mr. Sam Jones WRIGHT, LINDSEY \u0026amp; JENNINGS 2200 Worthen Bank Building 200 West Capitol Little Rock, Arkansas 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201-3472 Mr. Richard Roachell ROACHELL LAW FIRM 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 1 Jo^ W. Walker -5-RECEIVED IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION JUL ~8 2002 OmCEOF DESEGREGATION MONITORING 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 PLAINTIFF'S MOTION IN LIMINE Plaintiff Little Rock School District (\"LRSD\") for its Motion in Limine states: 1. May 15 Order: Joshua's Witness List. On May 15, 2002, the Court ordered the parties on or before June 21, 2002 to \"identify the name of each of their witnesses, the date and time each witness will be called, and the anticipated time it will take for direct examination of each witness. A detailed statement must be included of each witnesses anticipated testimony on each issue the witness will address.\" Order filed May 15, 2002, p. 2 (emphasis in original). Joshua's witness list is attached hereto as Exhibit 1. As can be seen, Joshua failed to comply with the Court's order in every respect. Upon information and belief, Joshua has not even contacted many of the individuals identified to discuss their appearing at the hearing and testifying, and Joshua has no intention of calling all of the witnesses identified. The LRSD moves in limine that Joshua be ordered on or before 5:00 p.m. on July 10, 2002 to identify the date and time on which each witness will be called, to identify the issue(s) on which each witness is expected to testify and to provide a detailed statement of the witnesses' expected testimony on each issue. The LRSD further requests that Joshua be precluded from calling any witness for which it fails to provide this information on or before 5:00 p.m. on July 10, 2002. Finally, the LRSD asks that Joshua be instructed to only identify witnesses that it has interviewed and confirmed their availability for the hearing.2. May 15 Order: Joshua's Exhibits. On May 15, 2002, the Court also ordered the parties to exchange pre-marked exhibits on or before June 21, 2002. The Court further stated that \"[a]ny exhibit not pre-marked and exchanged on or before June 21, 2002 will not be received into evidence during the July 22 hearing, absent highly imusual circumstances. A copy of Joshua's Exhibit list and the exhibits provided to the LRSD are attached hereto as Exhibit 2. Joshua failed to provide the LRSD with copies of Exhibits 793, 794, 799, 800 and 801 stating (t [rjequest is hereby made for those exhibits ..This request by Joshua is untimely. See Order filed July 1, 2002, p. 1. To the extent Joshua may be in possession of these documents, the LRSD moves in limine to exclude Joshua Exhibits 793, 794, 799, 800 and 801. 3. May 15 Order: Exhibit 803. The LRSD also moves to exclude any additional documents which Joshua may intend to introduce as Exhibit 803. Joshua identified as Exhibit 803, \"The exhibits filed by the Little Rock School District for this hearing.\" This fails to comply with the Court's May 15, 2002 order, as the LRSD understood it. 4. May 9 Order: Good Faith. The Court stated in its order of May 9, 2002 that Joshua would be permitted to present additional evidence on the issue of the LRSD's good faith tr but only to the extent that: (a) it relates directly to the issues of advanced placement courses. guidance counseling, extracurricular activities and student achievement\nand (b) it does not duplicate testimony already presented by Joshua on the issue of good faith.\" Order filed May 9, 2002, p. 14 (emphasis in original). Consistent with the Court's Order, the LRSD moves in limine as follows: a. Sadie Mitchell. Joshua called Mitchell to testify on August 1 and 2, 2001. S^ Tr. August 1, 2001, pp. 564-570 and August 2, 2001, pp. 848-896. Joshua specifically questioned Mitchell about student achievement (see. e,., Tr. August 1, 2001, p. 575) and advance placement courses (see, e^, Tr. August 1, 2001, p. 600), Additional testimony from Mitchell on these issues would be duplicative. Accordingly, the LRSD moves to prohibit Joshua from questioning Mitchell about student achievement and advanced placement courses. 2b. Junious Babbs. Joshua called Babbs to testify on July 5 and 6, 2001. See Tr. July 5, 2001 (all) and July 6, 2001, pp. 283-340. Joshua specifically questioned Babbs about advanced placement courses (s^, e^g., Tr. July 5, 2001, p. 219), guidance counseling (see, e^, Tr. July 5, 2001, p. 228), extracurricular activities (see, e.g.. Tr. July 5, 2001, p. 218) and student achievement (see, e^, Tr. July 5, 2001, p. 231). Accordingly, the LRSD moves to prohibit Joshua calling Babbs as a witness. c. Exhibits. The LRSD moves to exclude the following exhibits not directly related to the issues of advanced placement courses, guidance counseling, extracurricular activities and student achievement\n743, 746, 747, 749, 750, 752, 754, 755, 756, 757, 758, 759, 760, 761, 762, 763,764,771, 773,775, 777, 778, 779, 780, 782, 783, 784, 785, 786, 787, 788,789 801 and 802. 5. Relevance Generally. The LRSD moves to exclude all evidence and testimony of noncompliance with the Revised Plan that was not brought to the attention of the entire LRSD Board of Directors pursuant to Fed. R. Evid. 401, 402 and 403. The LRSDs memorandum brief in support of this Motion is hereby incorporated by reference. The LRSD also incorporates by reference its Memorandum Brief in Support of Motion for an Immediate Declaration of Unitary Status and its Reply Brief in Support of Motion for an Immediate Declaration of Unitary Status. 6. Jim Mosby and Jodie Carter. The LRSD also moves to exclude evidence and testimony related to the removal of Jim Mosby and Jodie Carter as the principals of Southwest Middle School and McClellan High School, respectively, pursuant to Fed. R. Evid. 401,402 and 403. Both men are represented by counsel for Joshua, and filed Complaints against the LRSD on July 7, 2002 related to their removal which are now pending before this Court. The July 22 hearing on whether the LRSD should be declared unitary is not the appropriate forum to decide the merit of their Complaints, and this Court has a long-standing practice of not hearing individual claims as a part of this case. See, e.g.. Docket No. 1874, Order filed June 30, 1993. 37. Rebuttal Evidence. This Court's order of May 15, 2002 granted Joshua 30 minutes to present rebuttal evidence pertaining to the three issues tried virtually to conclusion during previous hearings before Judge Wright. Joshua failed to identify any witnesses or exhibits for this purpose. Moreover, none of the witnesses or exhibits would reasonably be construed as \"true\" rebuttal, as defined by Judge Wright. Judge Wright defined rebuttal evidence as evidence necessary to respond to evidence presented by the other side which could not have been anticipated. Tr. Nov. 20, 2001, 399. The LRSD submitted no evidence which could not have been anticipated by Joshua because it had all been previously outlined in the LRSD's Interim Report and/or Final Report. Therefore, the LRSD moves in limine that Joshua be prohibited from presenting any rebuttal evidence on July 22, 2002, at 8:30 a.m. 8. Letters from Joy Springer. Joy Springer is counsel for Joshua's paralegal, and she has not been identified as a witness. However, Joshua has identified as Exhibits 767- 776 a series of letters from her to District personnel related to individual student/parent complaints. The LRSD moves to exclude these letters for several reasons. First, the letters are hearsay reporting hearsay, and they fail to fall within any exception to the hearsay rule. See Fed. R. Evid. 801, 802 803 and 804. Second, the letters are irrelevant in that there is no evidence that these complaints were brought to the attention of the Board. See Fed. R. Evid. 401 and 402 and paragraph 5, supra. Third, any relevance is outweighed by the danger of unfair prejudice where no evidence will be presented that would allow this Court to assess the merit of the complaints made in the letters. See Fed. R. Evid. 403. 9. Joshua Exhibit 791. Joshua Exhibit 791 appears to be notes from a meeting with Ms. Jo Evelyn Elston, the LRSD's Director of Pupil Services. The LRSD assumes that the notes were prepared by Springer or another Joshua monitor. However, neither Springer nor any other Joshua monitor has been identified as a witness in this case. The LRSD moves to exclude Joshua Exhibit 791 for the same reasons set forth in paragraph 8 above. Joshua Exhibit 791 should also be excluded for an additional reason: the document, standing alone, cannot be 4authenticated, and Joshua has not identified any witness who will be able to authenticate the document. See Fed. R. Evid. 901. WHEREFORE, the LRSD prays that its Motion in Limine be granted\nthat it be awarded the relief sought herein\nand that it be awarded all other just and proper relief to which it may be entitled. Respectfully Submitted, LITTLE ROCK SCHOOL DISTRICT Christopher Heller (#81083) John C. Fendley, Jr. (#92182) FRIDAY, ELDREDGE \u0026amp; CLARK Regions Center, Suite 2000 400 West Capitol Little Rock, AR 72201-3493 (501) 376^Crn BY: 'hristopher Heller (#( '83) CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by U.S. mail on July 3, 2002: Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 (VIA FAX and MAIL) Mr. Sam Jones Mr. Richard Roachell Roachell Law Firm 11800 Pleasant Ridge Road, Suite 146 Post Office Box 17388 Little Rock, Arkansas 72222-7388 Little Rock, AR 72201 Wright, Lindsey \u0026amp; Jennings 2200 NationsBank Bldg. 200 West Capitol Little Rock, AR 72201 Ms. Ann Brown Desegregation Monitor 1 Union National Plaza 124 W. Capitol, Suite 1895 Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026amp; JONES, P.A. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Dennis R. Hansen Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Christopher Heller F:\\HOME\\FENDLEY\\LRSD 2001\\dra-mot.limine-7.(l9-02 wpd 5 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4:82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANT MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE W KNIGHT, ET AL. INTERVENORS JOSHUA INTERVENORS WITNESS LIST REGARDING JULY 22-26. 2002 HEARINGS The Joshua Intervenors plan to call the following persons during the July 22-26, 2002 hearings: 1. Ms. Sadie Mitchell - Associate Superintendent for School Services Will disQuss guidance counseling and her oversight or lack of it within the schools. She will be called on July 23, 2002, and her testimony will be expected to take approximately ten minutes. 2. Mr. Junious Babbs - Associate Superintendent for Administrative Services Will address extracurricular activities and his oversight of those activities as Associate Superintendent for Administrative Services. His testimony will be approximately ten minutes and will occur on July 23, 2002. 3. Dr. Marian Lacey - Asst. Superintendent of Secondary Schools EXHIBIT 1 Will discuss her oversight of the secondary schools with respect to guidance counseling i S I 1advanced placement courses, and extracurricular activities. Her direct testimony will take approximately fifteen minutes. 4. Mr. Jodie Carter - Principal McClellan High School Will discuss special problems with advanced placement courses, guidance counseling, extracurricular activities and the Districts good faith. His testimony will take approximately two hours and will be presented on July 22, 2002. He will also discuss the support and involvement of school board members or the lack of. 5. Ms. Dorothy McDonald - Teacher Will discuss the Districts counseling program and problems which affect Afiican American students which have not been effectively addressed by the District. Her testimony will take approximately fifteen minutes. 6. Dr. Michael Faucette - Teacher Central High School Will discuss in detail the problems with the administration of advanced placement courses, the racial effect of the placements, the manner in which the placements are made, how the placements tend to favor one group of children over another, the problems with scheduling and how those scheduling decisions interact with other decisions of placement and counseling, participation in extracurricular activities, the favor given to white students at Central High School\nthe disparate effect of advanced placement courses with respect to teaching, awards, and other opportunities, and he will discuss the Districts good faith compliance. He testimony will presented on July 22\"* and is expected to take approximately four hours on direct examination. 1. Ms. Pat Watson - Counselor at Hall High School 2Will address the Districts counseling program and how they are implemented. Her testimony will take approximately 15 minutes. 8. Mr. Kenneth Moore, Assistant Principal at Hall High School Will discuss extracurricular activities and good faith compliance. His testimony will take approximately ten minutes and will be presented July 23, 2002. 9. Ms. Pam Mercer - Parent of Former Student of Central High School Will discuss her efforts as a parent with respect to securing fair and equitable treatment for her children, Crystal and Justin, while they were at Central and how she was rebuffed along the way. She will also discuss the atmosphere at Central High School as it relates to privilege being extended to white children from middle class families. It will also cover counseling and extracurricular activities. Ms. Mercers testimony will take approximately twenty minutes on direct examination. 10. Mr. Justin Mercer - Former Student at Central High School Will address the problems he experienced of a racial nature while at Central High School and his efforts to obtain assistance and help from teachers, counselors and administrators. His testimony will take approximately ten minutes. 11. Crystal Mercer - Former Student at Central High School Will address the Districts counseling services from a African American students perspective. Her testimony will take approximately ten minutes. 12. Ms. Paulette Blevins - Former teacher at Central High School Will discuss how the grading system was manipulated so as to change grades and otherwise provide favor to white children at Central High School. Her testimony will take 3approximately fifteen minutes on direct examination. 13. Mr. Jimmy Mosby - Principal of Southwest Middle School Will discuss the efforts of the District to comply with the Plan with respect to good faith, guidance counseling and extracurricular activities while at Southwest Middle School and Hall High School. His testimony will take approximately twenty minutes on direct examination. 14. Ms. Sharon Brooks - Principal of Stephens Elementary School Will testify regarding good faith compliance and how she avoids it. The specific matter she will address will be unreported punishment without the involvement of a guidance counselor regarding the taking away of educational privileges for black boys for a period of two months while she was principal of Rightsell Elementary School. Her ' testimony will take ten minutes. 15. Ms. Susie Davis - LRSD Coordinator of English Will discuss the efforts of the Instruction Department to communicate Instruction Department standards to principals and teachers with respect English and Reading and other subjects which she supervises in her capacity as special assistant to Dr. Bonnie Lesley. Although this is not her title, she was regarded as the agent for Dr. Lesley within the schools. She will also discuss the extent of her and Dr. Lesleys association with respect to principals and counselors. Her testimony will take approximately ten minutes. 16. Ray Gillespie - Former Athletic Director Will discuss his role with respect to extracurricular activities and monitoring activities to ensure the absence of racial discrimination. His testimony will take approximately fifteen 4minutes. 17. Cassandra Norman - Principal at J. A. Fair High School Will discuss the Districts good faith compliance and her schools disparate treatment of black and white students. She will also discuss the support and involvement of school board members or the lack of. 18. Judith Pickering - Teacher - J.A. Fair High Schools Will discuss the racial atmosphere, advanced placement courses and extracurricular activities at J. A. Fair. Her testimony should take approximately fifteen minutes. 19. Foster Allen - Teacher at Central High Will discuss advance placement practices at Central High School and his relationship to those practices. His testimony will take five minutes. 20. Romona Horton and Bennie Horton - Parents of Former Central High Student Will discuss problems with AP placement of their child at Central High School. Their testimony will take five minutes a piece. 21. Alisha Allmon - Teacher Will discuss advanced placement practices at Central High School and his relationship to those practices. Her testimony will take five minutes. 22. Chris Payne- Former Student at J. A. High School Will discuss his efforts to participate in Quiz Bowl at J. A. Fair. His testimony will take ten minutes. 23. Ms. Sue Strickland, Dr. Katherine Mitchell, Dr. Michael Daugherty, Mr. Tony Rose Mr. Larry Berkley, Ms. Judy Magness and Mr. H. Baker Kurrus 5Will each give testimony regarding good faith compliance and their involvement in and knowledge of the development and implementation of guidance and counseling programs, advanced placement courses, regular courses, class sizes of regular courses, pupil teacher ratios between regular, advanced placement, honors and gifted and talented courses. Their testimony together is expected to take one hour on direct examination. 24. Jeanette Carter and Dr. Vertie Carter Will discuss problems which they experience with respect to the AP teachers and administrators and counselors regarding placement, retention and fair treatment in the AP program. Their testimony will take fifteen minutes. 25. Ms. Ethel Dunbar - Principal Franklin Elementary School Will discuss elementary good faith compliance, gifted and talented courses, guidance counseling and the assistance received with respect to these issues from the Division of Instruction. Her testimony will take approximately thirty minutes. 25. Mazie Phillips - Counselor at Fair High School Will address the Districts counseling program and how they are implemented. Her testimony will take approximately 15 minutes. 26. Leon Adams - Director of Federal programs Will discuss efforts to use Title I funds to promote the educational interests of all children rather than the children who were the intended beneficiaries of those funds\nthe correlation between counseling services, advanced placement courses and good faith compliance. His testimony will take approximately twenty minutes. 627. D.J. Thames and Avis Thames - Student and Parent - Fair High School Will discuss the Districts good faith compliance with respect to extracurricular activities. This testimony will take approximately ten minutes on direct examination. 28. Ann Marshall, Gene Jones, and Margie Powell - ODM Monitors Will discuss good faith compliance. Their testimony will take approximately thirty minutes. 29. Ray Simon Will discuss the Districts decision and the reason for it to retreat from the remediation requirement for loan forgiveness. His testimony will address the roles of Drs. Ross and Gamine with respect to discontinuing emphasis upon remediation of Black students relative achievement levels. It will take approximately twenty minutes. The exhibit which he will address is an agreement between the State of Arkansas and the Little Rock School District the description of about which I am not certain. 30. Dr. Terrence Roberts Will address the issue of good faith compliance, guidance counseling and relationship between regular and advanced courses. His testimony will take approximately twenty minutes and will be presented on July 23, 2002. 31. Dr. Stephen Ross Will testify about the Districts good faith compliance and advanced placement and honors courses. He will address the need for criteria for placement as will Dr. Roberts (see above). His testimony will take approximately thirty minutes. 7Respectfully submitted, John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72206 501-374-3758 501-374-4187 (fax) John W. Walker - Bar No. 64046 I CERTIFICATE OF SERVICE I hereby state that a copy of the foregoing witness list has been hand delivered to Counsel for the Little Rock School District on this 24* day of June, 2002. 8 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. CASE NO. 4\n82CV00866 WRW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE W. KNIGHT, ET AL. INTERVENORS JOSHUA INTERVENORS EXHIBIT LIST REGARDING JULY 22-26. 2002 HEARINGS The Joshua Intervenors plan to use the following documents during the July 22-26, 2002 hearings: 743. E-mail dated July 2, 2001 from Virginia Johnson to Bonnie Lesley (page 182) 744. E-mail dated October 19, 2000 from Gary Smith to Bonnie Lesley (page 290) 745. E-mail dated June 29, 2001 from Sueellen Mann to Gail Hester and subsequent dated July 2, 2001 (page 167) 746. E-mail dated January 18, 2001 from Junious Babbs to Kathy Lease (page 12) 747. E-mail dated July 2, 2001 from Mona Briggs to Bonnie Lesley (page 191) 748. E-mail dated November 16, 2000 from Les Camine to Bonnie Lesley 749. E-mail dated November 21, 2000 from Ken Savage to Kathy Lease (page 38) 750. E-mail dated March 7, 2001 from Kathy Lease to T Rose and subsequent dated March 7, 2001 at 12:44 p.m. (page 7) 751. E-mail dated July 15, 2001 from Bonnie Lesley to Lionel Ward and subsequent 1 1 exhibit I I A.dated July 16, 2001 (page 88) 752. E-mail dated July 14, 2001, July 15, 2001 and July 16, 2001 from Bonnie Lesley to Ken James (page 96) 753. E-mail dated July 15, 2001 from Bonnie Lesley to Chris Heller (page 102) 754. E-mail dated April 18, 2001 from Bonnie Lesley to Kathy Lease and subsequent response (pages 708 and 709) 755. E-mails dated October 25, 2000 from Bonnie to Irma Truett and Kathy Lease re: Benchmark scores (pages 16 and 17) 756. E-mail dated June 28, 2001 8:00 p.m. from Mona Briggs to Bonnie Lesley (page 192 757. E-mail dated June 28, 2001 9:08 am. from Bonnie Lesley to members of her staff (Page 192 and 193) 758. E-mails dated September 29, 2000 between Bonnie Lesley and Kathy Lease re: Priorities 2000-01 (Page 51) 759. E-mail dated October 3, 2000 between Les Camine. Bonnie Lesley and Kathy Lease Re\nALT Check-in (Page 50) 760. E-mail dated June 20, 2001 from Bonnie Lesley to Beverly Griffin re: semester test Exemption (Page 351) 761. E-mail dated June 25, 2001 from Bonnie Lesley to Clay Fendley (page 297) 762. F-mails dated June 29, 2001 between Sadie Mitchell, Deanna Eggeston and Bonnie Lesley (pages 218-219) 763. E-mails dated February 12 and 13, 2001 Lesley, Ruffins, Lease and Camine (page 19) 764. Email dated February 13, 2001 from Kathy Lease to Les Camine (Pages 17 and 18) 765. Memo dated November 17, 2000 from Dr. Faucette to Mrs. Hargis re: exclusion of Regular English students fro Jennie Calder lecture 766. Email dated September 27, 2000 from Sadie Mitchell to Junious Babbs (Page 1) 27 767. Letter dated December 16, 1998 to Les Gamine from Joy Springer 768. Letter dated February 18, 1999 to Sadie Mitchell from Joy Springer 769. Letter dated March 17, 1999 to Rudolph Howard from Joy Springer 770. Letter dated October 14, 1999 to James Washington from Joy Springer 771. Letter dated February 28, 2000 to James Washington from Joy Springer 772. Letter dated February 28, 2000 to James Washington from Joy Springer re: Scouts 773. Letter dated August 28, 2000 to Ray Gillespie from Joy Springer 774. Letter dated September 12, 2000 to Les Gamine from Joy Springer 775. Letter dated October 10, 2000 to Les Gamine from Joy Springer 776. Letter dated September 13, 2000 to James Washington from Joy Springer 777. E-mail dated June 6, 2000 to Les Gamine from Don Stewart (Pages 100-0 1) 778. E-mail dated April 19, 2001 from Deanna Eggeston to Don Stewart (Page 37) 779. E-mail dated April 25, 2001 from Kathy Lease to Mark Millhollen 780. E-mail dated May 25, 2001 from Bonnie Lesley to Debbie Berry (Page 358) 781. E-mail dated June 7, 2000 from Glay Fendley to Bonnie Lesley 782. E-mail dated June 7, 2000 from Bonnie Lesley to Mary Paal (Page 136) 783. E-mail dated April 17-18, 2001 to Don Stewart from Bonnie Lesley 784. E-mail dated July 12, 2001 to Bonnie Lesley from Don Stewart (240) 785. E-mail dated February 28, 2001 to Bonnie Lesley from Don Stewart 786. Memo dated February 24, 1999 to Gayle Bradford from James Washington 787. Memo dated March 11, 1999 to Les Gamine from James Washington 788. Letter dated April 12, 1999 to Gayle Bradford from James Washington 3789. Letter dated March 22, 1999 to Gayle Bradford from James Washington 790. Letter dated April 26, 1999 to John Walker from Les Gamine 791. Memo dated May 3, 1999 regarding visit to Pupil Services \u0026amp; Administration buildings 792. Email dated 9/30/300 from Marian Lacey to Sadie Mitchell w/attachments 793. High School Master Schedule Audit, Little Rock School District 2001-2002 794. School Yearbooks for Central, Hall, McClellan, Fair, Hall and Parkview for school years 1998-99 through 2001-2002 795. Letter dated February 28, 2002 from Dr. Michael Faucette to Jane Welch regarding enrollment in Creative Writing course 796. Little Rock Central - Requests for Course - Creative Writing 797. Essay by Justin Mercer entitled: Black at Central: My 45 Years of Struggle 798. Memo dated August 4, 1999 from Bonnie Lesley to Ann Marshall 799. Academic awards reports for the period 1998 through 2002. 800. Rank Lists for Hall, Parkview, Central, McClellan and Fair for graduating senior classed for the period 1998 through 2002 801. LRSD Quarterly Status Reports - School Services - 1999 through 2002 802. Deposition of School Board Members - a. Sue Strickland b. Tony Rose c. Judy Magness d. Larry Berkley e. Katherine Mitchell 803. The exhibits filed by the Little Rock School District for this hearing Joshua notes that some of the foregoing exhibits are in the exclusive possession of the Plaintiff. Request is hereby made for those exhibits which include numbers 793, 794, 799, 800. 801. 4By: Respectfully submitted, JohnW. Walker,?. A. 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing exhibit list and exhibits have been hand carried to counsel for the Little Rock School District and the Office of Desegregation Monitoring on this day of June, 2002. 5 LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 2:24 PM 'heller^fec.nef Latest Fax 743' 1 had Anita fax over to you the latest-a bunch of stuff on our literacy plan. 1. He already has a copy of the PreK-3 Literacy Plan. Other information is in the Interim and Final Compliance Reports. 2. He also has the test results for SAT9, Grade 4 Benchmark, and DRA-so those are the results. 3. I don't know what he means by monitoring reports. 4. The assessment program is outlined in several pages in the Compliance Report. 5. I can copy those policies and regs for him. Want me to go ahead and send? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 1:44 PM JOHNSON, VIRGINIA RE: Needed Information-Important! Do you have dates for those three times? From: Sent: To: Subject: iriginal Message JOHNSON, VIRGINIA Monday, July 02, 2001 1:15 PM LESLEY, BONNIE RE: Needed Information-Important! Three times I sat in on sessions with Steve Ross along with other PRE staff. At no time did we review any NSF documents. The sessions focused on document review of the ESL and Pre-K Literacy reports. I have never \"consulted\" with him. I have never consulted with Dr. Roberts either. Original Message----- From: Sent: To: LESLEY, BONNIE Monday, July 02, 2001 12:07 PM ADAMS, LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRIGGS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE\nCLEAVER, VANESSA\nCLIFFORD, ELIZABETH\nCRAWFORD, PAMELA: DAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE: DONALDSON, MABLE: FINNEY. ANTONETTE\nFLETCHER. DANNY\nFREEMAN. ANN\nGILLIAM. ANITA\nGLASGOW, DENNIS\nHARDING, CASSANDRA: HUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\nKIILSGAARD, SHARON\nKILLINGSWORTH, PATRICIA\nKOVACH, RENEE\nLAJUANA RAINEY: LOYA, STELLA,: MARION BALDWIN: MARTIN, PAULETTE: McCOY, EDDIE\nMcNEAL, MARIE\nMILAM, JUDY\nNEAL, LUCY\nPAAL, MARY M.\nPAUL, ANNITA\nPERRITT, YORIKO U.\nPRICE, PATRICIA: RYNDERS, PAULA: SMITH, GARY\nSMITH, PAULA\nTEETER, JUDY\nWALLS, COLLEEN\nWARD, LIONEL\nWILLIAMS, BARBARA\nWILLIAMS, ED\nWILSON, LEVANNA\nWOODS, MARION Subject: Needed Information-Important! 182snimitci@lrsdadm.lrsd.kl2.ar.us Original Message----- From: Sent To: Cc: Subject: CARNINE, LESLIE V. Thursday, October 19, 2000 1:59 PM MITCHELL, SADIE NEAL, LUCY\nLESLEY, BONNIE\nLEASE, KATHY R.\nSMITH, GARY RE: Will we have the software available by 2nd Semester? What system(s) are being looked at? Original Message From: Sent To: Subject: MITCHELL, SADIE Thursday, October 19. 2000 10:33 AM CARNINE, LESLIE V. FW: Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us Original Message From: Sent To: Cc: Subject 7^^ SMITH, GARY Thursday, October 19, 2000 10\n25 AM LESLEY. BONNIE WARD. LIONEL\nGADBERRY. BRADY L.\nNEAL. LUCY\nMITCHELL. SADIE\nCAWTHON. FRANCES H.\nLACEY. MARIAN G.\nADAMS. LEON\nAUSTIN. LINDA\nBRADFORD. GAYLE: BRIGGS. MONA\nBROADNAX. KAREN\nCLEAVER. VANESSA: COLFORD. SUSAN\nDAVIS. SUZI\nDONALDSON. MABLE\nEddie McCov\nELSTON, JO\nFULLERTON, JAMES\nGLASGOW, DENNIS: HAWKS, EVERETT\nKEOWN, ADA\nMARION BALDWIN\nNORMAN, CASSANDRA R.\nPRICE, PATRICIA\nTATUM, KATHY: WYATT-ROSS, JANICE Dr. Lesley, The consensus recommendation of the SAIP committee is for a SAIP be created for students at all grade levels who are not proficient based state mandated benchmark tests and/or District mandated Achievement Level Tests (ALT) - Our specific recommendations to implement this are\nobtain/create the software necessary to identify students not proficient on state benchmarks/district assessment that will also generate/print the adopted SAIP form with student information and test scores printed on the SAIP form  obtain/create the software that will generate/print specific strategies (along with and printed checklists for those who wish not to use computer) developed by a committee made up of teachers and curriculum specialists as a resource available for teachers to use (especially secondary teachers) - this can be attached to the SAIP form as needed develop an \"instructional\" sheet for the SAIP form that will explain in more detail the information to documented and procedures to follow  provide training on the use of SAIP form directly to teachers (the exact training may have to be determined at a future date based on the development of software noted above) - delivery of training would need to be coordinated with staff development for most effective and comprehensive presentation to all teachers to ail of you in Cyber Land - is there anything else I forgot? - thanks Gary 290LESLEY, BONNIE From: Sent: To: Cc: Subject: BABBS, JUNIOUS Monday, July 02, 2001 8:08 AM ELSTON, JO NEWBURN, LINDA\nLESLEY, BONNIE RE\nCounseling Program Kit 745- Message Flag: Due By\nFlag Status\nFollow up Monday, July 09, 2001 5:00 PM Flagged It is positive to see that things are moving forward on this \"01 - 02 priority. Prior to coming to closure, I ask that your look to set up a time to fill me in on the \"buy in\" of players called upon (committee members) to develop districtwide literature to be distributed. The connection to Curriculum and Instruction is a biggee that should be run through Dr. Lesley. I will look to give you a call a bit later regarding B/W high school scholarship information and the 3 - 4 year comparisons. To date, this information has not been provided. Junious C. Babbs, Jr jcDabbs@stuasn.lrsd.kl2.ar,us Little Rock Schoo! District -----Original Message From: Sent: To: Cc: Subject: VANN, SUELLEN Friday, June 29, 2001 11:08 AM HESTER, GAIL ELSTON, JO\nBABBS, JUNIOUS Counseling Program Kit Jo Evelyn Elston is in my office, and we're working on a counseling program kit with insert sheets. Mr. Babbs will pay for this out of his budget. I'm going to talk with Kristy Black about the design of the kit and sheets, but I figured we'd better give you the info for the quote since it looks like a pretty good-sized job. The kit will be one-pocket on right side with a business card slot\nthe kit will print front and back with one pocket. There won't be a separate \"wing\" like the recruitment kit had. Quantity: 25,000 Jo Evelyn likes the paper we used for the recruitment kit and insert sheets, so we could just go with those. The insert sheets: 1. JOBBS sheet - print front only\nquantity 30,000 2. Early college planning sheet - print front only\nquantity 20,000 3. PCEP sheet - print front only\nquantity 20,000 4. What Does Counselor Do? sheet - print front only\nquantity 30,000 5. Counseling program sheet - print front and back\nquantity 30,000 6. Couseling fact sheet - print front only\nquantity 30,000 The kit and insert sheets would print 4-color. Have I forgotten anything? No bleeds. THANKS! (Mr. Babbs, you might want to set up a lemonade stand on Sherman to pay for this!!!!!) Suelle.n S. Vann,- APR Director of Communications Little Rock School District (501)324-2020 167LESLEY, BONNIE 7^6 From: Sent\nTo: Subject: LEASE, KATHY R. Thursday, January 18, 2001 6:06 PM BABBS, JUNIOUS RE\nSection 2 Thanks for the input! We have been with the program evaluation consultant all cay, so I just finished editing the report to send to Bonnie. I will incorporate your changes and suggestions, and send it to her again. Do you want the Power Point as an Appendix or the outline for it incorporated into the body of the report? I'm so sorry I am just getting around to my email, but I'll take the heat for sending another correction. Not enough hours in the day!! Kathy PS--Thanks for the encouragement! Original Message From: Sent: To: Cc: Subject: BABBS, JUNIOUS Thursday, January 18, 2001 10:53 AM LEASE, KATHY R. GADBERRY, BRADY L. FW/: Section 2 Good information. Working with timelines and specific report information submissions for this division, I have not been able to dissect in great detail but my original thinking touches upon 2 - 3 items that may warrant some review. You will note that Brady is also being forwarded who can provide his thinking as well. Future compliance sessions will toss this about for further revision. 1. Inclusion of the power point presentation. 2. When touching upon Dr. Ross - It may be advantageous to refer to \"looks to build or acknowledges\" specific district efforts as opposed to \"praising\". 3. It would be appropriate to list current data that is available. Be reminded that when writing materials for our report submission, we will include \"districtwide\" numbers We may not be thprp yet but this will help to serve as an indicator of established basSTihe Fnformation from which we will jump off of. Keep your chin up. . ---------------------------  Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message----- From: Sent: To: Cc: Subject: LEASE, KATHY R. Wednesday, January 17, 2001 6:14 PM LESLEY, BONNIE BABBS. JUNIOUS\nDILLINGHAM, YVETTE\nHUFFMAN, MAC\nJOHNSON, VIRGINIA\nMcCOY, EDDIE\nSUMMERVILLE, ROSALYN P.\nTRUETT, IRMA\nWILLIAMS, ED Section 2  File\nDeseg Report (2.7.1).doc  Bonnie, Here is the first draft of Section 2.7.1. Please let me know what additions or revisions you want made. Thanks, Kathy PS-PRE folks-Look to see what I left out, what typos 1 have, and what needs to be edited. Thanks 12747 Chris, I am in LR this week-end and you can reach me at 868-4289, I can come to your office to help, or I can work from my office. Call if you need me. Are we having fun yet? Dr, Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 8:16 AM BRIGGS, MONA R, RE\nThank you, my friend, I \"vegged\" all week-end, seriously \"vegged,\" I know this will be a HARD week. Yes, I hear Kathy is on his witness list. It'll be interesting. -----Original Message----- From: Sent: To\nSubject: BRIGGS, MONA R. Monday, July 02, 2001 6:53 AM LESLEY, BONNIE RE: I have been thinking a lot about you. You can't let this bring on a stroke or something. You don't need this kind of pressure all by your self!! It is not worth it-no job is worth it. And you can't take on the woes of a district that has been screwing up for a decade or more. I hope Kathy does get called to testify. She needs to have to answer to John Walker and if it bodes ill for the district so be it! She and Camine just waltzes out of here and leaves everyone else holding the rope. You make time for sleep and food!! Mona R, Briggs Middle Level Specialist Little Rock School District 501-324-2412 \" Seek First to Understand\nthen to be understood\" (Covey) Original Message From: Sent: To: LESLEY. BONNIE Friday, June 29, 2001 7:55 AM BRICSS, MONA R, 191STEWART, DONALD M. From: Sent: To: Cc: Subject: CARNINE, LESLIE V. Thursday, November 16, 2000 12:23 PM LESLEY, BONNIE BABBS, JUNIOUS\nMitchell, Sadie\nGADBERRY, BRADY L.\nSTEWART, DONALD M. Upper Division Classes and African Americans 74^ Were you able to pull together the numbers-last year and this year's enrollment? John Walker also has called and is questioning his non involvement in the policy development(IKF). I told him I thought the evidence was so strong for Black kids and that I would send him the information. When was the first time he would have received the policy for comment? He is raising much the same issue-impact on black kids as Katherine...IKF\\ \\ Cc: Subject LESLEY. BONNIE: CARNINE. LESLIE V. RE: Chart Revisions Ken, _ Thanks so much for this explanation of what happened, i he important thing about making a mistake is finding a way not to make it again. I think you have done this, and we will all profit from it. I know you feel really badly about this, but the most important thing is to correct the process. We all make mistakes. We are committed to quality in PRE and that includes continuous improvement and continuous learning. This experience has provided us with both. What a bonus!! Thanks for helping with the corrections. I will take care of getting them to the appropriate Cabinet people and getting them redistributed to the Board. -----Original Message----- From: Sent: To: Subject: Dr Lease, SAVAGE. KEN Tuesday. November 21, 2000 10:31 AM LEASE. KATHY R. Chart Revisions I have reviewed the charts that I created from the benchmark data. When I created the charts originally I had encountered a problem similar to the one described by Dr. Lesley, but I specifically remember correcting the error prior to sending the charts to you. Needless to say, I was more than a little alanned that the charts you received contained errors because the charts I have appear to coincide with the data I have. I went on further to investigate by looking at the email I sent you. And there, big as day, the error had reappeared. So the charts I had sent you were incorrect because they were never updated in the manner that I expected. Here is what I believe happened based on what I remember and what I learned this morning:  I created the charts in an Excel document that contained the data.  1 copied the charts only out into another document, creating what is called a linked object.  I printed and reviewed the charts and this is when I found the error.  I corrected the error and reopened the \"linked charts. They appear to have accepted the corrections.  I emailed the file with the linked charts to you rather than the file containing the charts and data. Heres where the problem arose and information that I have just become aware of this morning.  First, when using linked objects, each time you open the file you are given a choice to update the information. Unfortunately, 1 only sent you the charts and not the data that drives them. So regardless, you could not have updated the charts.  Second, and more importantly, even though a chart has been updated previously, it will always revert back to the original chart that was corrected no matter how many times the data has been updated.  Third, if the file with the original data is already open, when the linked item is opened it automatically updates without intervention. I believe that the second option above is what occurred. The charts were created, an error was encountered and corrected, the link was updated but the chart reverted back to its original when the file was closed. What 1 propose to do to prevent this kind of fiasco in the future is: 1. Only send charts embedded in files which contain the data--no linking. 2. Only create the linked charts after ALL data has been proofed and corrected. The erroneous data was only last year's data for black students in the comparison between this year and last'year for both Math and Literacy. I am printing and will send ten revised copies of the charts. Ken. 38 LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Wednesday, March 07, 2001 12:44 PM BABBS, JUNIOUS- RE: Research Committee Meeting 7JO Bonnie said that the evaluations weren't part of the court submission. Is that still correct? If so, then it looks like we should slow down a bit and do it rignt. are you in agreement? - '  KL -----------------------------  -------------- Original Message From: Sent: To: Subject: BASES, JUNIOUS Wednesday, March 07, 2001 12:36 PM LEASE, KATHY R. RE\nResearch Committee Meeting Orioinai thinking was to get another date scheduled prior to the March 15th court submission but with information you have noted, consideration of a later date is necessary. I don't see major conflict. Junious C Babbs, Jr )Cbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District -Original Message----- From\nSent: To: Subject: Importance: High LEASE, KATHY R. Wednesday. March 07, 2001 12:27 PM 'trrose@ualr.edu'\nBABBS, JUNIOUS Research Committee Meeting We have had another committee member who will not be able to come to the meeting on the 13th. We now have agenda meeting at 5:00, and Steve can only be with us by phone. What do you all think about postponing the meeting until after spring break? That would give John plenty of time to make revisions, and we can schedule a meeting when Steve can be w'ith us. I hope to have the template/program evaluation guidelines completed by then as well. Let me know what you think! Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 7LESLEY, BONNIE From: Sent: To: Subject\nLESLEY, BONNIE Monday, July 16, 2001 z\n24 PM MITCHELL, SADIE RE\nDocuments yes, thanks. I need asap. -----Original Message----- From: Sent: To: Cc: Subject: MITCHELL, SADIE Monday, July 16, 2001 5:51 PM LESLEY, BONNIE WASHINGTON, CHARLOTTE Documents We got the list of documents on file done but I forgot to remind Charlotte to send it to you. She is gone for the day and it is on her computer. You will have it first thing in the morning. Sadie Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 16, 2001 7:24 PM WARD, LIONEL RE\nSAIP He requested info from me. I told him I had given him all I had but that you are the administrator on this issue. I was following up to see if he had contacted you. -----Original Message----- From: Sent To: Subject: WARD, LIONEL Monday, July 16, 2001 4:29 PM LESLEY, BONNIE RE: SAIP Are you trying to tell me something? I have not received any such request from Mr. Walker. If he talks with me, I will talk to you about a proper response first. One basic problem with implementation is in the thought some might harbor which explains why their efforts started late in the game. I am sure some folks faced more struggles than others. Clearly, schools must satisfy the requirements v/ith wise, careful and timely deliberations this year. Original Message From: Sent: To: LESLEY, BONNIE Sunday, July 15, 2001 3:49 PM WARD, LIONEL Subject: SAIP Lionel, has Mr. Walker requested anything from you about the implementation of SAIPs? If so, what did you send to him? Thanks. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 88501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE. Monday, July 16, 2001 8\n16 AM JAMES, KENNETH RE: Work in Progress Absolutely! Original Message From: Sent To\nSubject: JAMES, KENNETH Monday, July 16, 2001 7:54 AM LESLEY, BONNIE RE\nWork in Progress Bonnie: I agree. The work and time that you have invested in this will indeed pay off. as the testimony unfolds. It will be interesting to see how the judge handles all of this information and to observe her thought process. Ken Original Message From: Sent: To: LESLEY, BONNIE Sunday, July IS, 2001 9:42 PM JAMES, KENNETH Subject: RE\nWork in Progress When I left today, I left a lot still un-done, but I left feeling more and more certain that we have strong evidence that we did the plan. This is going to be helpful to me in remembering all the effortseven if Chris decides not to use some of it as evidence. I think it will particularly be strong when we combine what Sadie has with ours in this Division. -----Original Message----- From\nSent\nTo: LESLEY, BONNIE JAMES, KENNETH Sunday, July 15, 2001 9:34 PM Subject: RE: Work in Progress Bonnie\nI have reviewed both documents and they are excellent at showing what has been accomplished in the areas of evaluation and assessment Great job! We will touch base tomorrow. Ken Original Message----- From: Sent: To: Subject: LESLEY, BONNIE Saturday, July 14, 2001 6:24 PM 'helle.r@fec.net\nJAMES, KENNETH\nMITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback.  File: 1 Program cvaluation.doc   File: 1 Assessment Grid.doc  96Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject\nLESLEY, BONNIE Sunday, July 15, 2001 3:41 PM 'heller@fec.net' JAMES, KENNETH SAIPs Mr. Walker requested on June 20 the follow: \"Please advise whether you have information regarding the District's implementation of STudent Academic Improvement Plan (SAIP) as required by the State. If so, please share with this this office.\" 1 replied: \"You will find that information in the March 2001 Compliance Report in Section 2.7. I do not have any information beyond what you will rind there since the implementation is done at the school level. Leonel Ward is in charge of implementation.\" When I searched everything for the documents I needed from you, I found several memos in Learning Links that I had forgotten about-about the philosophy in implementing SAIP, sample SAIPs done by Price, Glasgow, and Davis, the memo establishing the committee to develop the program, the memo to the board, etc. Should I forward those to Mr, Walker as well?. Dr, Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From\nSent\nTo: Subject: LESLEY, BONNIE Saturday, July 14, 2001 6:24 PM 'heller@fec.net'\nJAMES, KENNETH\nMITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback. s 1 Program Evaluation.Qoc 1 Assessment Grid.doc Dr. Bonnie A. Lesley, Associate Supe.hntendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 102LESLEY, BONNIE From: Sent: To: Cc: Subject: Don Crary [dcrary@newfuturesforyouth.org] Wednesday, April 18, 2001 1:33 PM LESLEY, BONNIE mopierce@newfuturesforyouth.org Re: Computer with Access Great. We can pay for it. I'm sure it will be cheaper if it is purchased through the district contract. The district can invoice us and we will reimburse them for the cost. Don -----Original Message From: LESLEY, BONNIE \u0026lt;BALESLE@IRC.LRSD.K12.AR.US\u0026gt; \u0026gt; To: 'dcrary@newfuturesforyouth.org' \u0026lt;dcrary@newfuturesforyouth.org Cc: BRIGGS, MONA R. \u0026lt;MRBRIGG@ANNEX.LRSD.K12.AR.US\u0026gt;\nPAAL, MARY M. \u0026lt;MrVIPAAL@ANNEX.LRSD.K12.AR.US\u0026gt; Date: 04/18/2001 12:50 PM Subject: Computer with Access \u0026gt;l talked with Mona about your need for a dedicated computer somewhere in the \u0026gt;district so that your evaluator can come work on direct access to the data \u0026gt;base. She is arranging for an additional computer drop in the office that \u0026gt;Mary Paal will have at Garland. Can you all purchase the computer out of \u0026gt;your budget? \u0026gt; \u0026gt;Dr. Bonnie A. Lesley, Associate Superintendent for Instruction \u0026gt;Little Rock School District \u0026gt;3001 S. Pulaski \u0026gt;Little Rock, Arkansas 72206 \u0026gt;501/324-2131 \u0026gt;501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject: LEASE, KATHY R. Wednesday, April 18, 2001 12:32 PM LESLEY, BONNIE MITCHELL, SADIE\nCAWTHON, FRANCES H.\nLACEY, MARIAN G. RE: ALT Results Bonnie, did you meet with yesterday? Do I need to contact them? I explained to all of them when we What group of principals ot tnem wnen did the testing calendar that we could get results back to everyone before school was out, if they followed the schedule. If there are some that we need to follow up with, please let me know who they are. We are returning ALT results as quickly as schools get them in. The whole purpose of setting up the schedule like it is centers around being able to get the results back to everyone before school is out. District results can't be calculated until all schools are in. That is why it is imperative that everyone stay on schedule. Both teachers and parents will get their results unless someone doesn't follow the schedule. Second grade results have all been returned to the schools, along with two copies of the parent report. High school preliminary results have been returned to Parkview and Fair. McClellan's results are here and are being scored. Central and Hall have not turned in their answer sheets yet. All make-ups were to have been completed by this past Monday. Retests for high schools are due back on Friday. The first page of the parent report can be printed, but we can't print the longitudinal report for parents unless all high schools are in. 70875^ Our elementary schools did a great job during 2nd grade testing\nso if they keep that up, we will sail right through their scoring and printino. They have all of their results. We're still missina two of the middle schools' Algebra I / geometry results as of this morning. We are having a scoring problem with the high school science tests, but NWEA is working on it. The subject specific math and science tests require no retests, so that shouldn't hold things up. . . . Also, we have provided data on request any school who wants to know last fall's ALT scores for their rising grade students. If you have any other questions, please let me know. Kathy Original Message From: Sent: To: Subject: LESLEY, BONNIE Wednesday, April 18, 2001 10:37 AM LEASE, KATHY R. ALT Results I met with a group of principals yesterday who suggested to me that if they can't receive their ALT results before school is out that there is no use in sending them at all. Kids and parents need them quickly, and the school needs them quickly in order to plan for next school year. What our your chances of being able to do that? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: Paulette Mabry [pmabry(gnewfuturesforyouth.org] Wednesday, April 18, 2001 10:59 AM Bonnie Lesley\nBrady Gadberry\nJunious Babbs\nLinda Austin\nMarian G. Lacey\nSadie Mitchell Words to encourage us Rosedoc Thought you might enjoy this today as a way to jumpstart the afternoon when things seem impossible. Paulette LESLEY, BONNIE From: Sent: To: Subject: BRIGGS. MONA R. Wednesday, April 18, 2001 10:10 AM LESLEY, BONNIE Cost of Tools for Learning (Fred Jones)\nParent Component Importance: High The discounted costs of books is: 500 books @ $18.00 (regularly priced at 29.95) 300-499 @ $18.50 200-299 @ $18.95 100-199 @ $19.95 Shipping for 500 is S546.75\nit may be slightly less for fewer numbers but not significantly. RE\nParent involvement with training 709GADBERRY, BRADY L. 735 From: Sent: To: Subject: LEASE, KATHY R. Tuesday, November 28, 2000 4:31 PM BABBS, JUNIOUS: FRANCES CAWTHON\nGadberry, Brady L\nHurley, Richard: LESLEY, BONNIE: Leslie Camine: LINDA WATSON: MARIAN LACEY: Milhollen, Mark: Sadie Mitchell: STEWART, DONALD M.: Vann, Suellen Steve Ross-Program Evaluation.ppt Steve Ross-Program Evaluation__ KL FYI--Here is a copy of Steve's presentation to the Board. GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Thursday, November 16, 2000 8:32 AM GADBERRY, BRADY L. RE\nPRE List Requested I shared with Babbs that I thought we could provide some assistance in PRE to make the surveying process a little easier We've got the equipment and the software! I just talked with Gene Jones to confirm his schedule, and he said that he was invited to the compliance meeting tomorrow morning. I told him, \"Great! See you then!\" KL Original Message From: Sent: To: Cc: Subject: GADBERRY, BRADY L. Thursday, November 16, 2000 8:17 AM BABBS, JUNIOUS LEASE, KATHY R. RE: PRE List Requested We were told early in the year by Dr. Camine that all surveys would be done through PRE. -----Original Message----- From: BABBS, JUNIOUS Sent: Tuesday, November 14, 2000 7:15 PM To: GADBERRY, BRADY L. Cc: LEASE, KATHY R. Subject: FW\nPRE List Requested To my knowledge Vic and I both allowed department \"Quality of Service Surveys\" that went to appropriate building staff to be returned and worked through our own division shops. What is your thinking to continue with this format or consideration through PRE ? Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message From: Sent: To: Cc: Subject: LEASE, KATHY R. Friday, November 10, 2000 12:18 AM Clay Fendley\"\nLESLEY, BONNIE\nBABBS, JUNIOUS\nMITCHELL, SADIE\nGADBERRY, BRADY L.\nSTEWART, DONALD M. CARNINE, LESLIE V. List Requested Dear Folks, Attached is the list of programs or strategies that have either received some evaluation services or have requested evaluation services. If you need additional information, please let me know. 15 Thanks, Kathy File\nAdditional Programs and Strategies Requesting Evaluation.doc GADBERRY, BRADY L. From\nSent: To: Subject: LEASE, KATHY R. Friday, October 27, 2000 2:52 PM MITCHELL, SADIE\nLESLEY, BONNIE\nBABBS, JUNIOUS\nGADBERRY, BRADY L\nSTEWART, DONALD M. Memo to Gene Jones 0 logo memo.doc know ASAP. KL Here is what I am having Irma send on Monday. If you see anything that needs to be changed, let her GADBERRY, BRADY L. From: Sent: To\nSubject\nLEASE, KATHY R. Wednesday, October 25, 2000 8:37 PM CARNINE, LESLIE V.\nMITCHELL, SADIE\nBABBS, JUNIOUS\nGADBERRY, BRADY L. FW\nBenchmark Scores Dear Folks. If Bonnie wants to continually harass me that is one thing, but I would appreciate it if she didn't pick on my assistant. Please read the exchanges below. She also left Irma a voice message that was very curt. Irma has been working like a dog in room 16 to finish up the answer documents for the CRTs, so she wasn't immediately available to read email or answer the telephone. No one came down here looking for her, so she didn't know that there was an urgent message. I emailed a reply message to Bonnie and sent you all a blind copy\nso I'm sure I'll be in trouble again. However, there has to be an end to this. We are working as hard as we can to produce these test reports, implement the assessment program, and produce program evaluations. I don't know how much more I can stand. She also continues to work behind my back through Eddie McCoy. This is ridiculous!! Who could be successful in such an environment? I'm sorry for ranting, but I am exhausted mentally, physically, and emotionally. Kathy Original Message From: Sent: To: Subject: TRUETT, IRMA Wednesday, October 25, 2000 8:21 PM LEASE, KATHY R. FW: Benchmark Scores Original Message From: Sent: To: Subject: LESLEY, BONNIE Wednesday, October 25, 2000 5:05 PM TRUETT, IRMA RE: Benchmark Scores I'm sorry, Irma, but I can't accept that response. -----Original Message From: Sent: To: Subject: TRUETT, IRMA Wednesday. October 25. 2000 2:08 PM LESLEY, BONNIE RE: Benchmark Scores Sorry, I'm just now getting your e-mail, but Ive been working in room 16. I don't have this information and from what I understand Dr. Lease has it with her to give to the principals this afternoon. Sorry! Original Message 16 From: Sent: To: LESLEY. BONNIE Wednesday. October 25. 2000 9:44 AM TRUETT. IRMA 7^3 Subject: Benchmark Scores I need copies of the state test results by school in my office asap. Board members and others are calling for information. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Wednesday, October 25, 2000 8:17 PM LESLEY, BONNIE Benchmark Scores ?rma forwarded your messages to her about the test scores. As I told you when we met with Suellen, I would have your curriculum copies ready by Friday. They are ready now. After learning that you were insistent on having the scores immediately I stayed late tonight and finished them up. Irma came back down here from home to help me. I am iust waiting on your initials on the memos. I will bring them to the Institute tomorrow. Irma can come pick them up and make copies I understood Dr. Carnine to say that the Board reports could be sent in the Friday report. I had them readv at the Board meeting but he didn't want them distributed until we had more time to confirm the data. Since you have asked for them I printed what we have at this time in draft copy. I will give the copies to you that are printed for the Board. If you think they need to be sent by special courier rather than in the Friday report, that will be your choice. I was only trying to follow the directions I was given. ..... , u If you needed the scores so guickly. why didn't you call me out of the meeting today? Irma didn t even know where we had secured the copies of the reports. It was very unfair of you to keep harassing her and making her feel badly because ~ 1 \u0026gt; ir.____ J f-i-iz-. tkrt oAi iHocu Mt ck'inn mo tnr it i nau becuieu iHti cuuic:\u0026gt; UI uic\nicpwiio. It w.  ,.r\n--------\\l -t c jt i she couldn't oroduce the reports instantly for you. If you need something, please do me the courtesy of asking me for it. I r ..  . . \u0026lt; ________L'.-C_____________:tU . . U /z\u0026gt;t I okzM ilrl Izif ma Ln/^VA/ understood that the Friday timeline was satisfactory with you. If it wasnt, you should have let me know. Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 17Subject: RE: This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Friday! Original Message From: Sent: To: Subject: BRIGGS, MONA R. Thursday, June 28, 2001 8:00 PM LESLEY, BONNIE RE: Bonnie, I hate all this, don't you? I guess you will have your day in court.\" Too bad Kathy didn't get in on it...I understand from Eddie that she took all her files with her. What a deal. Surelv, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 \"Seek First to Understand\nthen to be understood^ (Covey) -----Original Message------ From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN\nSLENN, RANDALL\nWATSON, LINDA\nELSTON, JO\nWIEDOWER, JULIE\nESSLESTON, DEANA\nADAMS, LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRIGGS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE'\nCLEAVER, VANESSA\n CLIFFORD, ELIZABETH\nCRAWFORD, PAMELA\nDAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE\nDONALDSON, MABLE\nFINNEY, ANTONETTE\nFLETCHER, DANNY\nFREEMAN, ANN\nGILLIAM, ANITA\nGLASGOW, DENNIS\nHARDING, CASSANDRA\nHUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\n. 192Subject: RE: 751 This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Friday! Original Message From\nSent: To: Subject: BRIGGS, MONA R. Thursday, June 28, 2001 8:00 PM LESLEY, BONNIE RE: Bonnie, I hate all this, don't you? I guess you will have your \"day in court.\" Too bad Kathy didn't get in on it...I understand from Eddie that she took all her files with her. What a deal. Surely, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 \"Seek First to Understand: then to be understood!' -----Original Message------ From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN\nCLENN, RANDALL\nWATSON, LINDA\nELSTON, JO\nWIEDOWER, JULIE\nECSLESTON, DEANA\nADAMS, LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRieOS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE'\nCLEAVER, VANESSA\n CLIFFORD, ELIZABETH\nCRAWFORD, PAMELA\nDAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE\nDONALDSON, MABLE\nFINNEY, ANTONETTE\nFLETCHER, DANNY\nFREEMAN, ANN\nGILLIAM, ANITA\nGLASGOW, DENNIS\nHARDING, CASSANDRA\nHUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\n192Cc: KIILSSAARD, SHARObJ\nKILLINSSWORTH, PATRICIA\nKOVACH, RENEE\nLA JUAN A RAINEY\nLOYA, STELLA\nMARION BALDWIN\nMARTEN, PAULETTE\nMcCOY, EDDIE\nMcNEAL, MARIE\nMILAM, JUDY\nNEAL, LUCY\nPAAL, MARY M.: PAUL, ANNITA\nPERRITT, YORIKO U.\nPRICE, PATRICIA\nRYNDERS, PAULA\nSMITH, CARY\nSMITH, PAULA\nTEETER, JUDY\nWALLS, COLLEEN\nWARD, LIONEL\nWILLIAMS, BARBARA\nWILLIAMS, ED\nWILSON, LEVANNA\nWOODS, MARION 'heller@fec.net' Subject: I just spoke with Chris Heller, our attorney. He asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Please make sure the staff not named in this e-mail also understand this directive. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To\nSubject\nLESLEY, BONNIE Friday, June 29, 2001 2:47 PM ADAMS, LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRIGGS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE'\nCLEAVER, VANESSA\nCLIFFORD, ELIZABETH\nCRAWFORD, PAMELA\nDAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE\nDONALDSON, MABLE\nFINNEY, ANTONETTE\nFLETCHER, DANNY\nFREEMAN, ANN\nGILLIAM, ANITA\nGLASGOW, DENNIS\nHARDING, CASSANDRA\nHUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\nKIILSG/V\\RD, SHARON\nKILLINGSWORTH, PATRICIA\nKOVACH, RENEE\nLAJUANA RAINEY\nLOYA, STELLA\nMARION BALDWIN\nMARTIN, PAULETTE\nMcCOY, EDDIE\nMcNEAL, MARIE\nMILAM, JUDY\nNEAL, LUCY\nPAAL, MARY M.\nPAUL, ANNITA\nPERRITT, YORIKO U.\nPRICE, PATRICIA\nRYNDERS, PAULA\nSMITH, GARY\nSMITH, PAULA\nTEETER, JUDY\nWALLS, COLLEEN\nWARD, LIONEL\nWILLIAMS, BARBARA\nWILLIAMS, ED\nWILSON, LEVANNA\nWOODS, MARION\nBABBS, JUNIOUS\nFRANCES CAWTHON\nGADBERRY, BRADY L\nHURLEY, RICHARD\nJAMES, KENNETH\nLINDA WATSON\nMARIAN LACEY\nMILHOLLEN, MARK\nSadie Mitchell\nSTEWART, DONALD M.\nVANN, SUELLEN\nWATSON, LINDA\nANDERSON, BARBARA\nASHLEY, VIRGINIA\nBRANCH, SAMUEL\nBROOKS, SHARON\nCARSON, CHERYL\nCARTER, LILLIE\nCOURTNEY, THERESA\nCOX, ELEANOR\nDARIAN SMITH\nDEBORAH MITCHELL\nETHEL DUNBAR\nFaith Donovan\nFIELDS, FREDERICK\nGOLSTON, MARY\nHALL, DONNA\nHARKEY, JANE\nHOBBS, FELICIA L\nJONES, BEVERLY\nKEOWN, ADA\nLillie Scull\nMANGAN, ANN\nMANNO, ROBERTA\nMARY BARKSDALE\nMENKING, MARY\nMORGAN, SCOTT\nNANCY ACRE\nOLIVER, MICHAEL\nPHILLIPS, TABITHA\nSHARON BROOKS\nSMITH, MARY\nTAYLOR, LESLIE\nTUCKER, JANIS A.\nWILSON, JANICE M.\nWORM, JERRY\nZEIGLER, GWEN S.\nBERRY, DEBORAH\nBLAYLOCK, ANN\nFULLERTON, JAMES\nHUDSON, ELOUISE\nLarry Buck\nMOSBY, JIMMY\nPATTERSON, DAVID\nROUSSEAU, NANCY\nSAIN, LLOYD DRA Results by Middle School Feeder Pattern 193 the ALTS, and so they were down there yesterday and again today just kind of picking it up, but they do not necessarily know' what they are supposed to be doing. They need direction, and I don't feel that I should provide it. How do you want to handle this? LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Monday, October 02, 2000 6:48 PM CARNINE, LESLIE V. FW: Priorities 2000-2001 Dr. C., I'm sorry. I guess I don't quite know what to do with the plan I sent to Bonnie. I guess I missed the mark. I thought we were to develop what we were doing in our department to meet the areas you outlined in your critical priorities processes. Do you want me to send the parts to the people Bonnie mentioned below? Or are you going to put it all together using what you want out of what we sent? Let me know what you want me to do. KL Original Message----- From: Sent\nTo\nSubject: LESLEY, BONNIE Friday, September 29, 2000 3:04 PM LEASE, KATHY R. RE: Priorities 2000-2001 You need to send the technology stuff to Lucy Neal. You need to send the Campus Leadership stuff to Sadie Mitchell. I suggest that you forward the other two pieces directly to Dr. Carnine. They are much more detailed than the other items in the Division of Instruction Work Plan and therefore don't \"fit\" with what we have, /^si^ I know nothing about the_Quality Initiative Plan, so that makes no sense, to. me. Perhaps he can just include your items separately. .......... ~ -----Original Message From\nSent: To: Subject: LEASE, KATHY R. Friday, September 29, 2000 2:50 PM LESLEY, BONNIE Priorities 2000-2001 Importance: High I had massive computer failures today. It took Ed, Ken, Virginia, and Irma to help me get it all back. Here are the priorities from PRE. Call me, if you want me to go over them with you. Thanks, Kathy  File: Priority II Technology 2000-2001.doc   File: Priority lll-2000.doc  Assessmentdoc   File: Priority IV lnstruction-evaluation.doc  File: Priority IV instruction- Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 51sounds like the our data is available. LESLEY, BONNIE From\nSent\nTo\nSubject\nLEASE, KATHY R. Tuesday, October 03, 2000 6:09 PM CARNINE. LESLIE V. CTA issues 75^1 Did Clementine come in today to discuss assessment issues with you? I invited her in last spring to talk with me, but she never came. If she has some specific issues that you think we need to address in the questionnaire, let me know. I started drafting some ideas about questions, but I think 1 need some input from you. It looks like from one of the emails you sent that folks have been communicating with you about their concerns. They may have shared some things we haven't thought about. Let me know if you have any time tomorrow afternoon to visit with me (phone or in person) about the survey. Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To\nSubject: LEASE, KATHY R. Tuesday, October 03, 2000 5:45 PM CARNINE, LESLIE V. RE: ALT Check-In, Etc. This is pure fabrication. This is not the situation here in PRE. We have a fox in the hen house. 1 thought this kind of thing was supposed to be over. The digs have continued. The ALT process has to have someone who shepherds it. I said originally that I would need Gayle at least six weeks to two months. I fully understand the strain that Sadie is under because she has come to depend on Gayle as well. If Gayle cannot fulfill her commitment with ALT, then I think she would let me know. She had to go over to the administration building to get some work done to be ready for the Bi-Racial committee report that she is scheduled to give tonight. Roz told her that she could take care of anyone who checked in things today. I guess the real question is that if my staff thinks they are having a problem \"handling\" the ALT today, why didn't they contact me? We had Ed here scanning and scoring, and Irma received no calls that she couldn't handle. I'm afraid 1 am left with no other conclusion but that this is continued harassment by the person that I thought had agreed to quit harassing. Can you help me with any other explanation? KL Original Message----- From\nSent To: Cc: Subject: CARNINE. LESLIE V. Tuesday, October 03, 2000 11:10 AM LEASE, KATHY R. Mitchell, Sadie FW: ALT Check-In, Etc. I know you know how assumptions can get you in trouble. Obviously, there appears to be a communication problem and I would hope you and Sadie could work it out. Original Message From: Sent\nTo: Subject: LESLEY, BONNIE Tuesday, October 03, 2000 10:55 AM CARNINE, LESLIE V. ALT Check-In, Etc. I have had three complaints already today-two from IRC staff and one from building-level. Gayle has returned to downtown, and Kathy is sitting in the school improvement meetings. Neither of them organized the staff for the return of 50LESLEY, BONNIE From\nSent: To: Subject\nLESLEY, BONNIE Wednesday, June 20, 2001 1:13 PM GRIFFIN, BEVERLY RE: Semester Test Exemption Thanks, Bev. -----Original Message----- From: Sent: To: Subject: GRIFFIN, BEVERLY Wednesday, June 20, 2001 1:15 PM LESLEY, BONNIE RE: Semester Test Exemption I gave a copy of the minutes from the February Board meeting to Mrs. Lacey earlier this week. I don't think I have a copy of the kids proposal, but I will check. I was under the impression that this action was for this year's seniors only. I might be wrong . . . but, it might be worth\nchecking with Board members to see if they intended for it to be a permanent change to the policy. I will fax you the minutes in just a minute. Original Message----- From: Sent: To: LESLEY, BONNIE Wednesday, June 20, 2001 12:51 PM GRIFFIN, BEVERLY Subject: Semester Test Exemption Bev, there is wide disagreement about what people remember as the motion the board made regarding the exemption of seniors from their spring semester tests. I don't remember the month they did thatprobably February or March? Will you send to me the text of the motion, as well as the text of the language used by the , kids in their proposal. I don't have that and will need it to update those regulations/poiicies. i Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock,.Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Wednesday, June 20, 2001 1:12 PM TRUETT, IRMA Compliance The compliance report lists several \"program evaluations\" that PRE reported that they had completed, but which I have never seen. Please provide me with three copies each of the following reports. They have been requested by Mr. Walker. Extended Year Schools Summer School HIPPY Program Charter School Campus Leadership Teams English as a Second Language Lyceum Scholars Program at Philander Smith College Southwest Middle School's SEDL Program Onward to Excellence (Watson Elementary) Collaborative Action Tearn (CAT) 3S1LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, June 25, 2001 12:37 PM 'Clay Fendley'\n'heller@fec.net' RE: Meeting schedule Yea! Thanks you! I can't tell you how important this is! I just talked with Ann Brown. She wanted all the test scores. I put her off until the end of the week. We need to talk about what to give her. -----Original Message From: Sent: To: Cc: Subject: Clay Fendley [SMTP:FENDLEY@fec.net] Monday, June 25, 2001 12:42 PM BALESLE@IRC.LRSD.K12.AR.US Chris Heller RE: Meeting schedule Leaving at 1:05 on the 6th is fine. We will tell Walker that if he wants to call you as a witness, he will need to call you on the 5th. Thanks. \u0026gt; \"LESLEY, BONNIE\" \u0026lt;BALESLE@IRC.LRSD.K12.AR.US\u0026gt; 06/25/01 11:49AM \u0026gt; I just called the airlines. I would need to catch a plane at 1:05 on the 6th to get to Amarillo in time for the rehearsal dinner for this big wedding. If I can't do that, then the latest I could leave to get there at all on Friday is at 5:35. Then I would come home on Sunday. What do you advise? \u0026gt;-----Original Message----- \u0026gt; From: Clay Fendley [SMTP:FENDLEY@fec.net] \u0026gt; Sent: Monday, June 25, 2001 9:41 AM \u0026gt; To: BALESLE@IRC.LRSD.K12.AR.US\nblgadbe@lrsdadm.lrsd.k12.ar.us\nDMSTEWA@lrsdadm.lrsd.k12.ar.us\nIvcarni@lrsdadm.lrsd.k12.ar.us\nSMMitch@lrsdadm.lrsd.k12.ar.us\nJCBABBS@STUASN.LRSD.K12.AR.US \u0026gt; Cc: Chris Heller\nKJAMES@lrsdadm.lrsd.k12.ar.us Subject: Meeting schedule \u0026gt; \u0026gt; \u0026gt; Here's the meeting schedule so far Mr. Gadberry - Wednesday at 2:00 at our office. Dr. Lesley - Thursday at 1:00 at our office. Ms. Mitchell - Friday at 9:00 at our office. \u0026gt; \u0026gt; We should get Joshua's objections today and have requested a witness list \u0026gt; by Wednesday. \u0026gt; We are leaving Monday (July 2) open until we get Joshua's witness list. \u0026gt; Everybody plan on meeting Tuesday (July 3) all day at our office. Let me \u0026gt; know if that presents a problem for you, and we can try to work around \u0026gt; your schedule. \u0026gt; \u0026gt; Remember, the most important thing in preparation for the hearing is for \u0026gt; you to know what's in the Revised Plan and the interim and final \u0026gt; compliance reports. \u0026gt; \u0026gt; We will provide copies of Joshua's objections as soon as they are \u0026gt; received. \u0026gt; Let me know if you have any questions. 297 76 Z selected to receive Merit Scholarship*' awards. The info in italics is from the National Merit web site. So, of the 1.2 million entrants, only 7,900 are named Finahsts for National Merit scholarships and corporate-sponsored scholarships. That amounts to 6/10 of 1 % of the entrants. Mr. Walker's statement on page 22 is: \"We note here that the district is yet to have a single Black national merit scholar in the nineteen years of this active litigation.\" THIS IS INCORRECT. Without reviewing 19 years of data (and we don't have all of the data for those years), as recently as 4 years ago Salonica Gray, an Afiican American female senior at Central, was a National Merit Finalist. Hope this helps! Suellen S. Vann, APR Director of Communications Little Rock School District (501) 324-2020 LESLEY, BONNIE From: Sent\nTo: Subject: LESLEY, BONNIE Thursday, June 28, 200T 11:36 AM MITCHELL, SADIE RE\nI am wondering how he is feeling as well. This is baptism by fire. -----Original Message From: Sent: To: Subject: MITCHELL, SADIE Thursday, June 28, 2001 9:29 AM LESLEY, BONNIE RE: I panicked when I got here and saw all of the stuff from John. I am worried about Dr. James. I hope he will be able to handle all of this. Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us Original Message----- From\nSent To: Subject\nLESLEY, BONNIE Thursday, June 28, 2001 9:09 AM MITCHELL, SADIE RE: He was kind of angry that we are even attempting to respond to this stuff. He asked me what he needed to do to make sure everyone understands that we are not to play Mr. Walker's game. How ya doing today? Original Message----- From: Sent: To: LESLEY, BONNIE MITCHELL. SADIE Thursday, June 28, 2001 9:18 AM Subject: RE\n:) Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 218762. Original Message From: Sent: To: Cc: Subject: LESLEY, BONNIE Thursday, June 28, 2001 9:04 AM MITCHELL, SADIE\nEGGLESTON, DEANA: GADBERRY, BRADY L\nSTEWART. DONALD M  BABBS JUNIOUS\nJAMES, KENNETH 'heller@fec.net' RE: I just spoke with Chris Heller, and he asked me to tell all of you that we are not going to make this information (copies of our invitations and documents sent to Mr.Walker or Ms. Springer) available to Mr. Walker. It is without exception stuff we have already sent to him. He also asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Original Message From: Sent: To: Cc: Subject: MITCHELL, SADIE Thursday, June 28, 2001 9:03 AM EGGLESTON, DEANA LESLEY, BONNIE\nGADBERRY, BRADY L.\nSTEWART, DONALD M.\nBABBS, JUNIOUS RE: Thank you Sadie Mitchell srnmitch@lrsdadm.lrsd.kl2.ar.us -----Original Message From: Sent: To: Cc: Subject: EGGLESTON.DEANA Thursday, June 28, 2001 8:38 AM MITCHELL, SADIE BABBS, JUNIOUS RE: Everyone sent the information when it was requested, however. I'm not sure if they have sent recent documents since his original request. I just spoke with Clay and he said to make the folders we have available to Joy on Monday as per her request, but for me to not to put the documents in any particular order (ie. date, subject, etc.) Deana Original Message From: Sent: To: Cc: Subject: MITCHELL, SADIE Thursday, June 28, 2001 8:41 AM LESLEY, BONNIE\nSTEWART, DONALD M.\nGADBERRY, BRADY L\nBABBS, JUNIOUS\nJAMES, KENNETH EGGLESTON, DEANA Mr. Walker sent a fax requesting \"all invitations to Ms. Springer or Mr. Walker to meetings of any kind, as well as copies of any documents you have sent to them over the past three years. Also any document of whether Mr. Walker or Ms. Springer actually attended the meetings to which you invited them.\" I think we already sent this information to Mr. Babbs and he compiled it. Is this correct? Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 219LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:54 PM CARNINE, LESLIE V. FW: Test Pack Importance: High Dr. Camine, What is the purpose of this? Am I missing something? Is Bonnie trying to eliminate her need to work with this department? We have some software that is licensed to this department. Eddie has been trying to get it loaded on her computer. My guess is that she needs it to work on her dissertation. She has not spoken to me about what her data needs are for her dissertation. Most doctoral candidates come in and visit with us about their data needs. We work with them, but they get data in an aggregate form, not individual students' information. I wish you would please tell me what role you want this department to play. I know the game that is being played. I am about to my wit's end with it. Kathy -----Original Message----- From: Sent To: Subject: JOHNSON, VIRGINIA Tuesday, February 13, 2001 12:43 PM LEASE, KATHY R. FW: Test Pack Original Message From: Sent To\nCc: Subject LESLEY, BONNIE Monday, February 12, 2001 5:31 PM RUFFINS, JOHN JOHNSON, VIRGINIA\nMcCOY, EDDIE\nCLEAVER, VANESSA RE: Test Pack Thanks so much, JOhn. -Original Message From\nSent To\nSubject RUFFINS, JOHN Monday, February 12, 2001 4:46 PM LESLEY, BONNIE RE: Test Pack I will come over and personally visit with Virginia and Eddie to access their data and program needs. From: Sent: To: Original Message- LESLEY, BONNIE Monday, February 12, 2001 2:40 PM RUFFINS, JOHN Subject: Test Pack John, 1 am moving Eddie McCoy and Virginia Johnson out of the rooms designated for PRE and into the room where Vanessa Cleaver is. Both of them will have some program evaluation responsibilities and need to be able to access the SAT9 data, as well as other student data. How do I get those programs loaded onto their machines? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 SOl/324-2131 S01/324-0S67 (fax) 19 \" LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 5:36 PM CARNINE, LESLIE V. RE: Another thought Here's one more thought, then I'm burying this frustration. I wouldn't have known about what she is doing at all if Virginia hadn't forwarded me a copy of the message. I'm trapped in junior high!!! Can't somebody save me??? Kathy Original Message From: Sent: To: Subject: CARNINE, LESLIE V. Tuesday, February 13, 2001 4:05 PM LEASE, KATHY R. RE\nAnother thought I can support but you do not want to hold the data... You want free access. Give her ail the access she wants or needs... and then give her more. -----Original Message From\nSent\nTo: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in ail my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 4:10 PM CARNINE, LESLIE V. RE: Another thought I totally agree with that. I want everyone to have access to the data at his or her fingertips. I just continue to be frustrated with the way she refuses to work with me. Kathy Original Message From: Sent: To: Subject: CARNINE, LESLIE V. Tuesday, February 13, 2001 4:05 PM LEASE, KATHY R. RE\nAnother thought I can support but you do not want to hold the data... You want free access. Give her all the access she wants or needs... and then give her more. -----Original Message From: Sent\nTo: Subject\nLEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought 177^^ is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject LEASE, KATHY R. Tuesday, February 13, 2001 12:59 PM CARNINE, LESLIE V. Positions After Don's comment in Cabinet about not hiring people, I visited with him about the positions that I currently have advertised. He suggested that I visit with you about whether or not I can hire the people I need to do the assessment program. I am currently down to three employees. I don't think we can do assessment for 20,000 kids with that number. I want to set up interviews this week, but I want your blessing! Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE. LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski UttleRock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 18From: Dr. Faucette To: Mrs. Hargis Date: 17 November 2000 76 S Subject: Exclusion of regular English students from Jennie Calder lecture I write to request a bit of information concerning the recent visit of Jennie Calder, a Robert Louis Stevenson scholar from Scotland, to Central as a part of the conference celebrating this great writer. It was my understanding, after our conversations last spring, that the event was in recognition of the universal appeal of a revered writer. Known and loved the world over, Stevenson is one of a select group whose works attract readers from widely varying backgrounds, uniting people of all classes and condition in the appreciation of a gifted artist. I was excited about the opportunity Central studentsincluding my own students would have to be^exposed to a world of exciting and enthusiastic research that would be especially significant for seniors, (Traditionally, the last year of high school English is dedicated to the exploration of the rich legacy of British literature.) I was disappointed beyond belief to learn that nonenot oneof my regular English students would be allowed to benefit from the singular experience of having the chance to see and hear the visiting scholar. Only AP and pre-AP students were allowed to attend the presentation. In fact, most teachers of regular English classes only learned of the event when students began to ask why they were not allowed to attend the assembly that students in other classes were discussing at lunch. Limiting the experience to students in AP and pre-AP English classes meant that very few black students were allowed to attend. I am shocked and outraged that yet another singular educational opportunity has been reserved for the children of privilege. Because many of the privileged AP English students took advantage of the event to slip out of the building and skip the assembly, and because you wanted to supplement their numbers, you solicited the attendance of students from AP science and history classes, still denying access to students from regular English classes. If you really wanted to impress Ms. Calder, having the Creative Writing Club presented would have done just that. The knowledge that, at 287 members, the Creative Writing Club is the most active club at Central would impress any true scholar or teacher. One can only wonder why you, Mr. Howard, and the third floor English department all miss the significance of the fact that the club that most fully represents the student diversity in our building is a club centered around an academic endeavor, the study and practice of literature. Yes, this is quite an example you set for our students. Central, Mr. Howard, the English department, and you all had a chance to shine as this scholar brought her enthusiasm to our large and diverse student body. Central, Mr. Howard, the English department, and you dropped the ball disastrously on this one. Rather than seizing the opportunity to be shining beacons by providing this opportunity for learning outside the traditional limitations of the classroom to all of our students, you have shown your true stripe. I thank you for the demonstration once again that, instead of a single unified English department. Central actually has two\nthe second floor containing primarily regular English classes, and the privileged third-floor home of AP English. I would now ask an additional bit of information. Please inform me in writing of your reasons for this latest instance of educational snobbery so that I might explain more accurately to my classes your dismissal of them as second-class students. I 1 I i ! I i j I i i i j iVia Facsimile - 324-2146 December 16, 1998 7^7 Dr. Leslie Gamine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Dr. Carnine: Would you please ask Mr. James Washington, the Districts ombudperson, to look into the complaint of Mr. \u0026amp; Mrs. Deodis Fleming regarding their concerns at Carver Magnet. You are probably not aware that this office has had several complaints from other parents regarding the unfair treatment of black students at Carver. You should have received a letter from the Flemings outlining their concerns along with a response from Ms. Barksdale. Copies of both are enclosed for your convenience. The Flemings believe that Ms. Barksdale is trying to excuse the reason for Ms. Ransoms exclusion of their son from participation by stating that he had behavior problems. In todays society, persons who discriminate usually attempt to establish legitimate reasons for their discriminatory actions. The reason given by Ms. Ransom, we believe, is pretextual. In other words, the reason that she has given is not legitimate. The Flemings were not previously advised that their son had behavior problems regarding his participation in Odyssey of the Mind. Moreover, they are not aware that their son has a behavior problem. Ms. Barksdales commitment to establish an OM Guideline booklet is a step, I believe, in the right direction. However, I do not believe that she should wait until next year. That process should start immediately. Opportunity for discrimination evolves when there are no written guidelines or rules for participation in a particular activity. The person overseeing or administering the activity usually has the discretion to make rules as they go along. These rules usually favor their own personal interests. Moreover, these rules or guidelines usually change daily to fit a particular interest or situation. I am not sure why the Flemings chose not assist in the coaching of Odysseys students as indicated by Ms. Barksdale\nhowever, many of our childrens parents are unable to participate in many of the schools activities because often they occur when they are obliged to work and other commitments to meet the overall needs of their families. 76 7 Page 2 - Letter to Dr. Carnine December 17, 1998 I have indicated to Mr. \u0026amp; iVIrs. Fleming that I would be happy to sit down with Mr. Washington, Ms. Mitchell, Ms. Barksdale, and any other persons that they believe can help brini ig this matter to an amicable resolution. In fact, Mr. Washington may assume the role as the parent advocate, if the Flemings agree. I would, however, like to receive a report of his findings and resolution. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors JCS/ Enclosures cc: Mr. \u0026amp; Mrs. Deodis Fleming Ms. Diane Barksdale Ms Sadie Mitchell Mr. James WashingtonVia Facsimile - 324-2146 February 18, 1999 Ms. Sadie Mitchell Associate Superintendent for Student Services Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Ms. Mitchell: This office has received several calls regarding the selection process for the new football coach at J. A. Fair High School. It is our information that the selection process has been changed to favor the selection of a particular coach for the position. In order to address the concerns that have been raised, would you please provide to me a copy of process being utilized by District officials for the selection of coaching positions including the selection criteria. If this information has changed from prior years, also please provide the process and criteria that was utilized in previous years. I have spoken with Mr. Gillespie regarding this matter and he has assured me that the only change in the process was that the selection committee did not meet on the school campus as it has done in previous years. I was, however, a bit concerned about the gender makeup of the selection committee for the Fair position. I voiced my concern to Mr. Gillespie that the committee was all males. I am available to discuss this matter with you and Mr. Gillespie at a mutually convenient time. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Mr. Ray GillespieVia Facsimile - 324-2308 March 17, 1999 Rudolph Howard  Principal, Central High School 1400 Park Street Little Rock, AR 72202 Dear Mr. Howard: I am writing on behalf of Rev. \u0026amp; Ms. Bennie Horton and their son, Tarick, to request a conference regarding his grades. As I review the revised desegregation plan, I can point to a number of areas including equal treatment, participation in honors and gifted classes, academic achievement, parental involvement etc. that are involved in these parents concern. By copy of this letter to the Districts Ombudsperson, Mr. James L. Washington, I am also putting him on notice of this concern and invite him to participate in the conference. I have spoken with Ms. Horton and she is available during her lunch hour to discuss this matter. Please let me hear from you. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Rev. \u0026amp; Mrs. Bennie Horton Mr. James L. WashingtonJohn W. Walker, P.A. Attorney At Law 1723 Broadway Dttle Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 . 377(. ./7 JOHN W. WALKER RALPH WASHINGTON N-LARK BURNETTE AUSTIN PORTER, JR. Via Facsimile - 324-2213 October 14, 1999 Mr. James Washington Little Rock School District Office of Ombudsman 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: I am writing to request that you look into the selection process for students participating on mock trial teams at Central High School. We request that you obtain some background information regarding past composition by grade, race and gender and the current composition by grade, race and gender. This office has received a complaint that these teams are generally one race and favor white students because their parents or other relatives are business professionals such as lawyers, judges, etc. Thank you for your attention to this matter. We further request a report of your findings with respect to this inquiry. By copy of this letter to Mr. Howard, Nir. Babbs and Dr. Camine, I am also advising them of these allegations. On Behalf of Joshua JCS/ cc: Mr. Ruduloph Howard Nir. Junious Babbs Dr. Leslie Camine y?/ Via Facsimile February\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_321","title":"Compliance court orders","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":["2002-01/2002-07"],"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 districts--Arkansas--Pulaski County","Educational law and legislation","Education--Evaluation","School administrators"],"dcterms_title":["Compliance court orders"],"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/321"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nreceived JAN 2 200t IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION Office of Desegregation Monitoring LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V CASE NO. 4:82CV00866 SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANT MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE W. KNIGHT, ET AL. INTERVENORS JOSHUA INTERVENORS PRELIMINARY EXHIBIT LIST REGARDING JANUARY 28, 2002 HEARINGS The Joshua Intervenors plan to use the following documents during the January 28, 2002 hearings: 1. E-mail dated July 2, 2001 from Virginia Johnson to Bonnie Lesley (page 182) 2. E-mail dated October 19, 2000 from Gary Smith to Bonnie Lesley ( page 290) J. E-mail dated June 29, 2001 from Sueellen Vann to Gail Hester and subsequent dated July 2, 2001 (page 167) 4. E-mail dated January 18, 2001 from Junious Babbs to Kathy Lease (page 12) 5. E-mail dated July 2, 2001 from Mona Briggs to Bonnie Lesley ( page 191) 6. E-mail dated November 16, 2000 from Les Carnine to Bonnie Lesley 7. E-mail dated November 21, 2000 from Ken Savage to Kathy Lease (page 38) 8. E-mail dated March 7, 2001 from Kathy Lease to T Rose and subsequent dated March 7, 2001 at 12:44 p.m. (page 7) 9. E-mail dated July 15, 2001 from Bonnie Lesley to Lionel Ward and subsequent dated1 July 16, 2001 (page 88) 10. E-mail dated July 14, 2001, July 15, 2001 and July 16, 2001 from Bonnie Lesley to Ken James (page 96) 11. E-mail dated July 15, 2001 from Bonnie Lesley to Chris Heller (page 102) 12. E-mail dated April 18, 2001 from Bonnie Lesley to Kathy Lease and subsequent response (pages 708 and 709) 13. E-mails dated October 25, 2001 from Bonnie to Irma Truett and Kathy Lease re: Benchmark scores (pages 16 and 17) 14. E-mail dated June 28, 2001 8:00 p.m. from Mona Briggs to Bonnie Lesley (page 192 15. E-mail dated June 28, 2001 9:08 a.m. from Bonnie Lesley to members of her staff (Page 192 and 193) 16. E-mails dated September 29, 2000 between Bonnie Lesley and Kathy Lease re: Priorities 2000-01 (Page 51) 17. E-mail dated October 3, 2000 between Les Carnine. Bonnie Lesley and Kathy Lease Re: ALT Check-in (Page 50) 18. E-mail dated June 20, 2001 from Bonnie Lesley to Beverly Griffin re: semester test Exemption (Page 351) 19. E-mail dated June 25, 2001 from Bonnie Lesley to Clay Pendley (page 297) 20. E-mails dated June 29, 2001 between Sadie Mitchell, Deanna Eggeston and Bonnie Lesley (page 219) 21. 22. 23. 24. 25. 26. E-mails dated February 12 and 13, 2001 Lesley, Ruffins, Lease and Carnine (page 19) Email dated February 13m 2001 from Kathy Lease to Les Carnine (Pages 17 and 18) Memo dated November 17, 2000 from Dr. Faucette to Mrs. Hargis re: exclusion of Regular English students fro Jennie Calder lecture Email dated September 27, 2000 from Sale Mitchell to Junious Babbs (Page 1) Letter dated December 16, 1998 to Les Carnine from Joy Springer Letter dated February 18, 1999 to Sadie Mitchell from Joy Springer27. Letter dated March 17, 1999 to Rudolph Howard from Joy Springer 28. Letter dated October 14, 1999 to James Washington from Joy Springer 29. Letter dated February 28, 2000 to James Washington from Joy Springer 30. Letter dated February 28, 2000 to James Washington from Joy Springer re: Scouts 31. Letter dated August 28, 2000 to Ray Gillespie from Joy Springer 32. Letter dated September 12, 2000 to Les Gamine from Joy Springer 33. Letter dated October 10, 2000 to Les Gamine from Joy Springer 34. Letter dated September 13, 2000 to James Washington from Joy Springer 35. E-mail dated June 6, 2000 to Les Gamine from Don Stewart (Pages 100-01) 36. E-mail dated April 19, 2001 from Deanna Eggeston to Don Stewart ( Page 37) 37. E-mail dated April 25, 2001 from Kathy Lease to Mark Millhollen 38. E-mail dated May 25, 2001 from Bonnie Lesley to Debbie Berry (Page 358) 39. E-mail dated June 7, 2000 from Glay Fendley to Bonnie Lesley 40. E-mail dated June 7, 2000 from Bonnie Lesley to Mary Paal (Page 136) 41. E-mail dated April 17-18, 2001 to Don Stewart from Bonnie Lesley 42. E-mail dated July 12, 2001 to Bonnie Lesley from Don Stewart (240) 43. E-mail dated February 28, 2001 to Bonnie Lesley from Don Stewart 44. Memo dated February 24, 1999 to Gayle Bradford from James Washington 45. Memo dated March 11, 1999 to Les Gamine from James Washington 46. Letter dated April 12, 1999 to Gayle Bradford from James Washington 47. Letter dated March 22, 1999 to Gayle Bradford from James Washington 48. Letter dated April 26, 1999 to John Walker from Les Gamine 49. Memo dated May 3, 1999 regarding visit to Pupil Services \u0026amp; Administrationbuildings Joshua reserves the right to utilize exhibits listed by Little Rock School District and further reserves the right to supplement this list after additional discovery. Respectfully submitted, John W. Walker, P. A. 1723 Broadway Little Rock, AR 72206 501-374-3758 501-374-4187 fax By: CERTIFICATE OF SERVICE 1 do hereby state that a copy of the foregoing exhibit list and exhibits have been hand carried to counsel for the Little Rock School District and the Office of Desegregation Monitorini on this 2\"' day of Janauiy, 2002. ig LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 2:24 PM 'heller@fec.net' Latest Fax I had Anita fax over to you the latest-a bunch of stuff on our literacy plan. 1. He already has a copy of the PreK-3 Literacy Plan. Other information is in the Interim and Final Compliance Reports. 2. He also has the test results for SAT9, Grade 4 Benchmark, and DRA-so those are the results. 3. I don't know what he means by monitoring reports. 4. The assessment program is outlined in several pages in the Compliance Report. 5. I can copy those policies and regs for him. Want me to go ahead and send? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 1:44 PM JOHNSON, VIRGINIA RE: Needed Information-Important! Do you have dates for those three times? -----Original Messagi From: Sent: To: Subject: JOHNSON, VIRGINIA Monday, July 02, 2001 1:15 PM LESLEY, BONNIE RE: Needed Information-Important! Three times I sat in on sessions with Steve Ross along with other PRE staff. At no time did we review any NSF documents. The sessions focused on document review of the ESL and Pre-K Literacy reports. I have never \"consulted\" with him. I have never consulted with Dr. Roberts either. Original Message From: Sent: To: LESLEY, BONNIE Monday, July 02, 2001 12:07 PM ADAMS LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRIGGS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE'\nCLEAVER, VANESSA\nCLIFFORD, ELIZABETH\nCRAWFORD, PAMELA: DAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE\nDONALDSON, MABLE\nFINNEY, ANTONETTE\nFLETCHER, DANNY\nFREEMAN, ANN\nGILLIAM, ANITA\nGLASGOW, DENNIS: HARDING, CASSANDRA\nHUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\nKIILSGAARD, SHARON\nKILLINGSWORTH, PATRICIA\nKOVACH, RENEE\nLAJUANA RAINEY\nLOYA, STELLA\nMARION BALDWIN\nMARTIN, PAULETTE\nMcCOY, EDDIE\nMcNEAL, MARIE\nMILAM, JUDY\nNEAL, LUCY\nPAAL, MARY M.\nPAUL, ANNITA\nPERRITT, YORIKO U.\nPRICE, PATRICIA\nRYNDERS, PAULA\nSMITH, GARY\nSMITH, PAULA: TEETER, JUDY\nWALLS, COLLEEN\nWARD, LIONEL: WILLIAMS, BARBARA: WILLIAMS, ED\nWILSON, LEVANNA\nWOODS, MARION Subject: Needed Information-Important! 182snimitch@lrsdadm.lrsd.kl2.ar.us Original Message----- From: Sent: To: Cc: Subject: CARNiNE, LESLIE V. Thursday, October 19, 2000 1:59 PM MITCHELL, SADIE NEAL, LUCY: LESLEY, BONNIE\nLEASE, KATHY R.\nSMITH, GARY RE: Will we have the software available by 2nd Semester? What system(s) are being looked at? Original Message From: Sent: To: Subject: MITCHELL, SADIE Thursday, October 19, 2000 10:33 AM CARNINE, LESLIE V. FW: Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us -----Original Message----- From: Sent: To: Cc: SMITH, GARY Thursday, October 19, 2000 10:25 AM LESLEY, BONNIE WARD, LIONEL\nGADBERRY, BRADY L\nNEAL, LUCY\nMITCHELL, SADIE\nCAWTHON, FRANCES H.\nLACEY, MARIAN G.\nADAMS, LEON\nAUSTIN, LINDA\nBRADFORD, GAYLE\nBRIGGS, MONA\nBROADNAX, KAREN\nCLEAVER, VANESSA\nCOLFORD, SUSAN\nDAVIS, SUZI\nDONALDSON, MABLE\nEddie McCoy\nELSTON, JO\nFULLERTON, JAMES\nGLASGOW, DENNIS\nHAWKS, EVERETT\nKEOWN, ADA\nMARION BALDWIN\nNORMAN, CASSANDRA R.\nPRICE, PATRICIA\nTATUM, KATHY: WYATT-ROSS, JANICE Subject: Dr. Lesley, The consensus recommendation of the SAIP committee is for a SAIP be created for students at all grade levels who are not proficient based state mandated benchmark tests and/or District mandated Achievement Level Tests (ALT) - Our specific recommendations to implement this are\nobtain/create the software necessary to identify students not proficient on state benchmarks/district assessment that will also generate/print the adopted SAIP form with student information and test scores printed on the SAIP form obtain/create the software that will generate/print specific strategies (along with and printed checklists forthose who wish not to use computer) developed by a committee made up of teachers and curriculum specialists as a resource available for teachers to use (especially secondary teachers) - this can be attached to the SAIP form as needed develop an \"instructional\" sheet for the SAIP form that will explain in more detail the information to documented and procedures to follow provide training on the use of SAIP form directly to teachers (the exact training may have to be determined at a future date based on the development of software noted above) - delivery of training would need to be coordinated with staff development for most effective and comprehensive presentation to all teachers to all of you in Cyber Land - is there anything else I forgot? - thanks Gary 290LESLEY, BONNIE From: Sent: To: Cc: Subject\nBABBS, JUNIOUS Monday, July 02, 2001 8:08 AM ELSTON, JO NEWBURN, LINDA\nLESLEY, BONNIE RE: Counseling Program Kit Message Flag: Due By: Flag Status\nFollow up Monday, July 09, 2001 5:00 PM Flagged It is positive to see that things are moving forward on this \"01 - 02 priority. Prior to coming to closure, I ask that your look to set up a time to fill me in on the \"buy in\" of players called upon (committee members) to develop districtwide literature to be distributed. The connection to Curriculum and Instruction is a biggee that should be run through Dr. Lesley. I will look to give you a call a bit later regarding B/W high school scholarship information and the 3 - 4 year comparisons. To date, this information has not been provided. Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message From: Sent: To: Cc: Subject: VANN, SUELLEN Friday, June 29, 2001 11:08 AM HESTER, GAIL ELSTON, JO\nBABBS, JUNIOUS Counseling Program Kit Jo Evelyn Elston is in my office, and we're working on a counseling program kit with insert sheets. Mr. Babbs will pay for this out of his budget. I'm going to talk with Kristy Black about the design of the kit and sheets, but 1 figured we'd better give you the info for the quote since it looks like a pretty good-sized job. The kit will be one-pocket on right side with a business card slot\nthe kit will print front and back with one pocket. There won't be a separate \"wing\" like the recruitment kit had. Quantity\n25,000 Jo Evelyn likes the paper we used for the recruitment kit and insert sheets, so we could just go with those. The insert sheets: 1. JOBBS sheet - print front only\nquantity 30,000 2. Early college planning sheet - print front only\nquantity 20,000 3. PCEP sheet - print front only\nquantity 20,000 4. What Does Counselor Do? sheet - print front only\nquantity 30,000 5. Counseling program sheet - print front and back\nquantity 30,000 6. Couseling fact sheet - print front only\nquantity 30,000 The kit and insert sheets would print 4-color. Have I forgotten anything? No bleeds. THANKS! (Mr. Babbs, you might want to set up a lemonade stand on Sherman to pay for this!!!!!) Suellen S. Vann, APR Director of Communications Little Rock School District (501) 324-2020 167LESLEY, BONNIE From\nSent: To: Subject\nLEASE, KATHY R. Thursday, January 18, 2001 6:06 PM BABBS, JUNIOUS RE: Section 2 Thanks for the input! We have been with the program evaluation consultant all day, so I just finished editing the report to send to Bonnie. I will incorporate your changes and suggestions, and send it to her again. Do you want the Power Point as an Appendix or the outline for it incorporated into the body of the report? I'm so sorry I am just getting around to my email, but I'll take the heat for sending another correction. Not enough hours in the day!! Kathy PS-Thanks for the encouragement! Original Message- From: Sent: To: Cc: Subject: BABBS, JUNIOUS Thursday, January 18, 2001 10:53 AM LEASE, KATHY R. GADBERRY, BRADY L. FW: Section 2 Good information. Working with timelines and specific report information submissions for this division, I have not been able to dissect in great detail but my original thinking touches upon 2 - 3 items that may warrant some review. You will note that Brady is also being forwarded who can provide his thinking as well. Future compliance sessions will toss this about for further revision. 1. Inclusion of the power point presentation. 2. When touching upon Dr. Ross - It may be advantageous to refer to \"looks to build or acknowledges\" specific district efforts as opposed to \"praising\". 3. It would be appropriate to list current data that is available. Be reminded that when writing materials for our report submission, we will include \"districtwide\" numbers. We may not be there vet but this will help to serve as an indicator of established basSline information from which we will jump off of. Keep your ohm up.' ---------------------~~  Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message----- From: Sent: To: Cc: Subject: LEASE, KATHY R. Wednesday, January 17, 2001 6:14 PM LESLEY, BONNIE BABBS. JUNIOUS\nDILLINGHAM, YVETTE\nHUFFMAN, MAC\nJOHNSON, VIRGINIA\nMcCOY, EDDIE\nSUMMERVILLE, ROSALYN P.\nTRUETT, IRMA\nWILLIAMS, ED Section 2  File: Deseg Report (2.7.1).doc  Bonnie, Here is the first draft of Section 2.7.1. Please let me know what additions or revisions you want made. Thanks, Kathy PS--PRE folks-Look to see what I left out, what typos I have, and what needs to be edited. Thanks 12Chris, I am in LR this week-end and you can reach me at 868-4289. I can come to your office to help, or I can work from my office. Call if you need me. Are we having fun yet? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 02, 2001 8:16 AM BRIGGS, MONA R. RE: Thank you, my friend. I \"vegged\" all week-end, seriously \"vegged.\" I know this will be a HARD week. Yes, I hear Kathy is on his witness list. It'll be interesting. -----Original Message----- From: Sent: To: Subject: BRIGGS, MONA R. Monday, July 02, 2001 6:53 AM LESLEY, BONNIE RE: I have been thinking a lot about you. You can't let this bring on a stroke or something. You don't need this kind of pressure all by your self!! It is not worth it-no job is worth it. And you can't take on the woes of a district that has been screwing up for a decade or more. I hope Kathy does get called to testify. She needs to have to answer to John Walker and if it bodes ill for the district so be it! She and Carnine just waltzes out of here and leaves everyone else holding the rope. You make time for sleep and food!! Mona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 \"Seek First to Understand\nthen to be understood.\" {CQvzy'} Original Message- From: Sent: To: LESLEY, BONNIE Friday, June 29, 2001 7:55 AM BRICSS, MONA R. 191STEWART, DONALD M. From\nSent: To: Cc: Subject: CARNINE, LESLIE V. Thursday, November 16, 2000 12:23 PM LESLEY, BONNIE BABBS, JUNIOUS\nMitchell, Sadie\nGADBERRY, BRADY L\nSTEWART, DONALD M. Upper Division Classes and African Americans Were you able to pull together the numbers--last year and this year's enrollment? John Walker also has called and Is questioning his non involvement in the policy development(IKF). I told him I thought the evidence was so strong for Black kids and that I would send him the information. When was the first time he would have received the policy for comment? He is raising much the same issue-impact on black kids as Katherine...IKFI \\ Cc: Subject: LESLEY, BONNIE\nCARNINE, LESLIE V. RE\nChart Revisions Ken, Thanks so much for this explanation of what happened. The important thing about making a mistake is finding a way not to make it again. I think you have done this, and we will all profit from it. I know you feel really badly about this, but the most important thing is to correct the process. We all make mistakes. We are committed to quality in PRE and that includes continuous improvement and continuous learning. This experience has provided us with both. What a bonus!! Thanks for helping with the corrections. I will take care of getting them to the appropriate Cabinet people and getting them redistributed to the Board. -----Original'Message----- From: Sent: To: Subject: Dr Lease, SAVAGE, KEN Tuesday, November 21, 2000 10:31 AM LEASE, KATHY R. Chart Revisions I have reviewed the charts that I created from the benchmark data. When I created the charts originally 1 had encountered a problem similar to the one described by Dr. Lesley, but I specifically remember correcting the error prior to sending the charts to you. Needless to say, I was more than a little alarmed that the charts you received contained errors because the charts I have appear to coincide with the data I have. I went on further to investigate by looking at the email I sent you. And there, big as day, the error had reappeared. So the charts I had sent you were incorrect because they were never updated in the manner that I expected. Here is what I believe happened based on what I remember and what 1 learned this morning:  I created the charts in an Excel document that contained the data.  I copied the charts only out into another document, creating what is called a linked object.  I printed and reviewed the charts and this is when I found the error.  I corrected the error and reopened the linked charts. They appear to have accepted the corrections.  I emailed the file with the linked charts to you rather than the file containing the charts and data. Heres where the problem arose and information that I have just become aware of this morning.  First, when using linked objects, each time you open the file you are given a choice to update the information. Unfortunately, 1 only sent you the charts and not the data that drives them. So regardless, you could not have updated the charts.  Second, and more importantly, even though a chart has been updated previously, it will always revert back to the original chart that was corrected no matter how many times the data has been updated.  Third, if the file with the original data is already open, when the linked item is opened it automatically updates without intervention. I believe that the second option above is what occurred. The charts were created, an error was encountered and corrected, the link was updated but the chart reverted back to its original when the file was closed. What I propose to do to prevent this kind of fiasco in the future is: 1. Only send charts embedded in files which contain the data-no linking. 2. Only create the linked charts after ALL data has been proofed and corrected. The erroneous data was only last year's data for black students in the comparison between this year and last year for both Math and Literacy. I am printing and will send ten revised copies of the charts. Ken. 38LESLEY, BONNIE From\nSent\nTo: Subject\nLEASE, KATHY R, Wednesday, March 07, 2001 12:44 PM BABBS, JUNIOUS RE: Research Committee Meeting Bonnie said that the evaluations weren't part of the court submission. Is that still correct? If so, then it looks like we should slow down a bit and do it rignt. Are you in agreement? ' --------------------- ~ KL ------------------------------------------------- . Original Message- From: Sent\nTo: Subject: BABBS, JUNIOUS Wednesday, March 07, 2001 12:36 PM LEASE, KATHY R. RE: Research Committee Meeting Original thinking was to get another date scheduled prior to the March 1 Sth court submission but with information you have noted, consideration of a later date is necessary. I don't see major conflict. Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message From: Sent: To: Subject: Importance: High LEASE, KATHY R. Wednesday, March 07, 2001 12:27 PM 'trrose@ualr.edu'\nBABBS, JUNIOUS Research Committee Meeting We have had another committee member who will not be able to come to the meeting on the 13th. We now have agenda meeting at 5:00, and Steve can only be with us by phone. What do you all think about postponing the meeting until after spring break? That would give John plenty of time to make revisions, and we can schedule a meeting when Steve can be with us. I hope to have the template/program evaluation guidelines completed by then as well. Let me know what you think! Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 7LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, July 16, 2001 7:24 PM MITCHELL, SADIE RE\nDocuments yes, thanks. I need asap. Original Message From: Sent: To: Cc: Subject: MITCHELL. SADIE Monday, July 16, 2001 5:51 PM LESLEY, BONNIE WASHINGTON. CHARLOTTE Documents We got the list of doouments on file done but I forgot to remind Charlotte to send it to you. She is gone for the day and it is on her computer. You will have it first thing in the morning. Sadie Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us LESLEY, BONNIE From\nSent: To\nSubject: LESLEY, BONNIE Monday, July 16, 2001 7:24 PM WARD, LIONEL RE\nSAIP He requested info from me. I told him I had given him all I had but that you are the administrator on this issue. I was following up to see if he had contacted you. Original Message From: Sent: To: Subject: WARD, LIONEL Monday, July 16, 2001 4:29 PM LESLEY, BONNIE RE: SAIP Are you trying to tell me something? I have not received any such request from Mr. Walker. If he talks with me, I will talk to you about a proper response first. One basic problem with implementation is in the thought some might harbor which explains why their efforts started late in the game. I am sure some folks faced more struggles than others. Clearly, schools must satisfy the requirements with wise, careful and timely deliberations this year. Original Message From: Sent: To: Subject\nSAIP LESLEY, BONNIE Sunday, July 15, 2001 3:49 PM WARD, LIONEL f I Lionel, has Mr. Walker requested anything from you about the implementation of SAlPs? if so, what did you send to him? Thanks. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 88501/324-0567 (fax) LESLEY, BONNIE From: Sent: To\nSubject\nLESLEY, BONNIE. Monday, July 16, 2001 8:16 AM JAMES, KENNETH RE\nWork in Progress Absolutely! -----Original Message From: Sent: To: Subject\nJAMES, KENNETH Monday, July 16, 2001 7:54 AM LESLEY, BONNIE RE: Work in Progress Bonnie: I agree. The work and time that you have invested in this will indeed pay off, as the testimony unfolds. It will be interesting to see how the judge handles all of this information and to observe her thought process. Ken -----Original Message- From: Sent: To: LESLEY, BONNIE Sunday, July 15, 2001 9:42 PM JAMES, KENNETH Subject: RE: Work in Progress When I left today, 1 left a lot still un-done, but I left feeling more and more certain that we have strong evidence that we did the plan. This is going to be helpful to me in remembering all the efforts-even if Chris decides not to use some of it as evidence. 1 think it will particularly be strong when we combine what Sadie has with ours in this Division. -----Original Message----- From: Sent: To: LESLEY, BONNIE JAMES, KENNETH Sunday, July 15, 2001 9:34 PM Subject: RE\nWork in Progress Bonnie: 1 have reviewed both documents and they are excellent at showing what has been accomplished in the areas of evaluation and assessment. Great job! We will touch base tomorrow. Ken Original Message- From: Sent: To: Subject: LESLEY, BONNIE Saturday, July 14, 2001 6:24 PM 'heller@fec.net\nJAMES, KENNETH\nMITCHELL, SADIE Work in Progress Ive worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback. File: 1 Program tvaluation.doc   File: 1 Assessment Grid.doc  96Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject: LESLEY, BONNIE Sunday, July 15, 2001 3:41 PM 'heller@fec.net' JAMES, KENNETH SAIPs Mr. Walker requested on June 20 the follow: \"Please advise whether you have information regarding the District's implementation of STudent Academic Improvement Plan (SAIP) as required by the State. If so, please share with this this office.\" I replied: \"You will find that information in the March 2001 Compliance Report in Section 2.7. I do not have any information beyond what you will find there since the implementation is done at the school level. Leonel Ward is in charge of implementation.\" When I searched everything for the documents I needed from you, I found several memos in Learning Links that I had forgotten aboutabout the philosophy in implementing SAIP, sample SAiPs done by Price, Glasgow, and Davis, the memo establishing the committee to develop the program, the memo to the board, etc. Should I forward those to Mr. Walker as well? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Saturday, July 14, 2001 6:24 PM 'heller@fec.net'\nJAMES, KENNETH\nMITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback. Q 1 Program Evaiuation.doc 1 Assessment Grid.doc Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 102LESLEY, BONNIE From: Sent: To: Cc: Subject: Don Crary [dcrary@newfuturesforyouth.org] Wednesday, April 18, 2001 1:33 PM LESLEY, BONNIE mopierce@newfuturesforyouth.org Re: Computer with Access Great. We can pay for it. I'm sure it will be cheaper if it is purchased through the'district contract. The district can invoice us and we will reimburse them for the cost. Don -----Original Message----- From: LESLEY, BONNIE \u0026lt;BALESLE@IRC.LRSD.K12.AR.US\u0026gt; To- 'dcrary@newfuturesforyouth.org' \u0026lt;dcrary@newfuturesforyouth.org\u0026gt; Cc: BRIGGS, MONA R. \u0026lt;MRBRIGG@ANNEX.LRSD.K12.AR.US\u0026gt;\nPAAL, MARY M. \u0026lt;MMPAAL@ANNEX.LRSD.K12.AR.US\u0026gt; Date: 04/18/2001 12:50 PM Subject: Computer with Access \u0026gt;1 talked with Mona about your need for a dedicated computer somewhere in the \u0026gt;district so that your evaluator can come work on direct access to the data \u0026gt;base. She is arranging for an additional computer drop in the office that \u0026gt;Mary Paal will have at Garland. Can you all purchase the computer out of \u0026gt;your budget? \u0026gt;Dr. Bonnie A. Lesley, Associate Superintendent for Instruction \u0026gt;Little Rock School District \u0026gt;3001 S. Pulaski \u0026gt;Little Rock, Arkansas 72206 \u0026gt;501/324-2131 \u0026gt;501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject: LEASE, KATHY R. Wednesday, April 18, 2001 12:32 PM LESLEY, BONNIE MITCHELL, SADIE\nCAWTHON, FRANCES H.\nLACEY, MARIAN G. RE\nALT Results Bonnie, did you meet with yesterday? Do I need to contact them? I explained to all of them when we What group of principals ot tnem wnen did the testing calendar that we could get results back to everyone before school was out, if they followed the schedule. If there are some that we need to follow up with, please let me know who they are. We are returning ALT results as quickly as schools get them in. The whole purpose of setting up the schedule like it is centers around being able to get the results back to everyone before school is out. District results can't be calculated until all schools are in. That is why it is imperative that everyone stay on schedule. Both teachers and parents will get their results unless someone doesn't follow the schedule. Second grade results have all been returned to the schools, along with two copies of the parent report. High school preliminary results have been returned to Parkview and Fair. McClellan's results are here and are being scored. Central and Hall have not turned in their answer sheets yet. All make-ups were to have been completed by this past Monday. Retests for high schools are due back on Friday. The first page of the parent report can be printed, but we can't print the longitudinal report for parents unless all high schools are in. 708Our elementary schools did a great job during 2nd grade testing\nso if they keep that up, we will sail right through their scoring and printing. They have all of their results. We're still missing two of the middle schools' Algebra I / geometry results as of this morning. We are having a scoring problem with the high school science tests, but NWEA is working on it. The subject specific math and science tests require no retests, so that shouldn't hold things up. Also, we have provided data on request any school who wants to know last fall's ALT scores for their rising grade students. If you have any other questions, please let me know. Kathy Original Message----- From: Sent: To: Subject: LESLEY, BONNIE Wednesday, April 18, 2001 10:37 AM LEASE, KATHY R. ALT Results I met with a group of principals yesterday who suggested to me that if they can't receive their ALT results before school is out that there is no use in sending them at all. Kids and parents need them quickly, and the school needs them quickly in order to plan for next school year. What our your chances of being able to do that? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: Paulette Mabry [pmabry@newfuturesforyouth.org] Wednesday, April 18, 2001 10:59 AM Bonnie Lesley\nBrady Gadberry\nJunious Babbs\nLinda Austin\nMarian G. Lacey\nSadie Mitchell Words to encourage us 0 Rose.doc Thought you might enjoy this today as a way to jumpstart the afternoon when things seem impossible. Paulette LESLEY, BONNIE From: Sent: To: Subject: BRIGGS, MONA R. Wednesday, April 18, 2001 10:10 AM LESLEY, BONNIE Cost of Tools for Learning (Fred Jones)\nParent Component Importance: High The discounted costs of books is\n500 books @ $18.00 (regularly priced at 29.95) 300-499 @ $18.50 200-299 @ $18.95 100-199 @ $19.95 Shipping for 500 is $546.75\nit may be slightly less for fewer numbers but not significantly. RE\nParent involvement with training 709From: Sent: To: LESLEY, BONNIE Wednesday, October 25, 2000 9:44 AM TRUETT, IRMA Subject: Benchmark Scores I need copies of the state test results by school in my office asap. Board members and others are calling for information. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Wednesday, October 25, 2000 8\n17 PM LESLEY, BONNIE Benchmark Scores Bonnie, Irma forwarded your messages to her about the test scores. As I told you when we met with Suellen, I would have your curriculum copies ready by Friday. They are ready now. After learning that you were insistent on having the scores immediately, I stayed late tonight and finished them up. Irma came back down here from home to help me. I am just waiting on your initials on the memos. I will bring them to the Institute tomorrow. Irma can come pick them up and make copies. I understood Dr. Carnine to say that the Board reports could be sent in the Friday report. I had them ready at the Board meeting, but he didn't want them distributed until we had more time to confirm the data. Since you have asked for them, I printed what we have at this time in draft copy. I will give the copies to you that are printed for the Board. If you think they need to be sent by special courier rather than in the Friday report, that will be your choice. I was only trying to follow the directions I was given. If you needed the scores so quickly, why didn't you call me out of the meeting today? Irma didn't even know where we had secured the copies of the reports. It was very unfair of you to keep harassing her and making her feel badly because she couldn't produce the reports instantly for you. If you need something, please do me the courtesy of asking me for it. I understood that the Friday timeline was satisfactory with you. If it wasn't, you should have let me know. Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 17Thanks, Kathy  File\nAdditional Programs and Strategies Requesting Evaiuation.doc  GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Friday, October 27, 2000 2:52 PM MITCHELL, SADIE\nLESLEY, BONNIE\nBABBS, JUNIOUS\nGADBERRY, BRADY L\nSTEWART, DONALD M. Memo to Gene Jones logo memo.doc know ASAP. KL Here is what I am having Irma send on Monday. If you see anything that needs to be changed, let her GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Wednesday, October 25, 2000 8:37 PM CARNINE, LESLIE V.\nMITCHELL, SADIE\nBABBS, JUNIOUS\nGADBERRY, BRADY L. FW: Benchmark Scores Dear Folks, If Bonnie wants to continually harass me that is one thing, but I would appreciate it if she didn't pick on my assistant. Please read the exchanges below. She also left Irma a voice message that was very curt. Irma has been working like a dog in room 16 to finish up the answer documents for the CRTs, so she wasn't immediately available to read email or answer the telephone. No one came down here looking for her, so she didn't know that there was an urgent message. I emailed a reply message to Bonnie and sent you all a blind copy\nso I'm sure I'll be in trouble again. However, there has to be an end to this. We are working as hard as we can to produce these test reports, implement the assessment program, and produce program evaluations. I don't know how much more I can stand. She also continues to work behind my back through Eddie McCoy. This is ridiculous!! Who could be successful in such an environment? I'm sorry for ranting, but I am exhausted mentally, physically, and emotionally. Kathy Original Message From: Sent: To: Subject: TRUETT, IRMA Wednesday, October 25, 2000 8:21 PM LEASE, KATHY R. FW: Benchmark Scores Original Message From: Sent: To: Subject: LESLEY, BONNIE Wednesday, October 25, 2000 5:05 PM TRUETT, IRMA RE: Benchmark Scores I'm sorry, Irma, but I can't accept that response. Original Message From: Sent: To: Subject: TRUETT, IRMA Wednesday, October 25, 2000 2:08 PM LESLEY, BONNIE RE: Benchmark Scores Sorry, I'm just now getting your e-mail, but I've been working in room 16. I don't have this information and from what I understand Dr. Lease has it with her to give to the principals this afternoon. Sorry! Original Message 16 GADBERRY, BRADY L. From: Sent: To\nSubject: LEASE, KATHY R. Tuesday, November 28, 2000 4:31 PM BABBS, JUNIOUS\nFRANCES CAWTHON\nGadberry, Brady L\nHurley, Richard\nLESLEY, BONNIE\nLeslie Carnine\nLINDA WATSON\nMARIAN LACEY\nMilhollen, Mark\nSadie Mitchell\nSTEWART, DONALD M.\nVann, Suellen Steve Ross-Program Evaluation.ppt Steve Ross-Program Evaluation.... KL FYl-Here is a copy of Steve's presentation to the Board. GADBERRY, BRADY L. From: Sent: To: Subject: LEASE, KATHY R. Thursday, November 16, 2000 8:32 AM GADBERRY, BRADY L. RE: PRE List Requested I shared with Babbs that I thought we could provide some assistance in PRE to make the surveying process a little easier. We've got the equipment and the software! I just talked with Gene Jones to confirm his schedule, and he said that he was invited to the compliance meeting tomorrow morning. I told him, \"Great! See you then!\" KL Original Message From: Sent: To: Cc: Subject: GADBERRY, BRADY L. Thursday, November 16, 2000 8:17 AM BABBS, JUNIOUS LEASE, KATHY R. RE: PRE List Requested We were told early in the year by Dr. Carnine that all surveys would be done through PRE. -----Original Message----- From: BABBS, JUNIOUS Sent\nTuesday, November 14, 2000 7:15 PM To\nGADBERRY, BRADY L. Cc\nLEASE, KATHY R. Subject\nFW: PRE List Requested To my knowledge Vic and I both allowed department \"Quality of Service Surveys\" that went to appropriate building staff to be returned and worked through our own division shops. What is your thinking to continue with this format or consideration through PRE ? Junious C. Babbs, Jr jcbabbs@stuasn.lrsd,kl2.ar.us Little Rock Schoo! District Original Message From: LEASE, KATHY R. Sent: To: Cc: Subject: Friday, November 10, 2000 12:18 AM 'Clay Fendley\nLESLEY, BONNIE\nBABBS, JUNIOUS\nMITCHELL, SADIE\nGADBERRY, BRADY L.\nSTEWART, DONALD M. CARNINE, LESLIE V. List Requested Dear Folks, Attached is the list of programs or strategies that have either received some evaluation services or have requested evaluation services. If you need additional information, please let me know. IS Subject: RE: This has been the week from hell. I hear that Walker may call Kathy to testify. Of course, that may not be good for the district. We'll see. I'm so tired I could fall on my face. Sooooooo glad it's Fridayl Original Message- From: Sent: To: Subject: BRIGGS, MONA R. Thursday, June 28, 2001 8:00 PM LESLEY, BONNIE RE: Bonnie, I hate all this, don't you? I guess you will have your \"day in court.\" Too bad Kathy didn't get in on it...I understand from Eddie that she took all her files with her. What a deal. Surely, the judge will see through this and let us get on with our lives. Walker just doesn't want to give up those big bucks he makes off of us. Hope you have some down time somewhere along the line. Mona R. Briggs Middle Level Specialist Little Rock School District 501-324-2412 \"Seek First to Understand\nthen to be understood!' (Covey) ----Original Message----- From: LESLEY, BONNIE Sent: Thursday, June 28, 2001 9:08 AM To: CHAPMAN, SUSAN\nGLENN, RANDALL\nWATSON, LINDA\nELSTON, JO\nWIEDOWER, JULIE\nEGGLESTON, DEANA\nADAMS, LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRIGGS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE'\nCLEAVER, VANESSA\n CLIFFORD, ELIZABETH\nCRAWFORD, PAMELA\nDAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE\nDONALDSON, MABLE\nFINNEY, ANTONETTE\nFLETCHER, DANNY\nFREEMAN, ANN\nGILLIAM, ANITA\nGLASGOW, DENNIS\nHARDING, CASSANDRA\nHUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\n192Cc-. KIILSGAARD, SHARON\nKILLINGSWORTH, PATRICIA\nKOVACH, RENEE\nLAJUANA RAINEY\nLOYA, STELLA\nMARION BALDWIN\nMARTIN, PAULETTE\nMcCOY, EDDIE\nMcNEAL, MARIE\nMILAM, JUDY\nNEAL, LUCY\nPAAL, MARY M.\nPAUL, ANNITA\nPERRITT, YORIKO U.\nPRICE, PATRICIA\nRYNDERS, PAULA\nSMITH, GARY\nSMITH, PAULA\nTEETER, JUDY\nWALLS, COLLEEN\nWARD, LIONEL\nWILLIAMS, BARBARA\nWILLIAMS, ED\nWILSON, LEVANNA\nWOODS, MARION 'heller@fec.ne+' Subject: I just spoke with Chris Heller, our attorney. He asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Please make sure the staff not named in this e-mail also understand this directive. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Friday, June 29, 2001 2:47 PM ADAMS, LEON\nARNOLD, LAURA BETH\nAUSTIN, LINDA\nBRANDON, BARBARA\nBRIGGS, MONA R.\nBROADNAX, KAREN\nBUSBEA, PAT\nCARR, MARCELLINE\nCARSON, RENE'\nCLEAVER, VANESSA\nCLIFFORD, ELIZABETH\nCRAWFORD, PAMELA\nDAVIS, SUZI\nDEBBIE MILAM\nDILLINGHAM, YVETTE\nDONALDSON, MABLE\nFINNEY, ANTONETTE\nFLETCHER, DANNY\nFREEMAN, ANN\nGILLIAM, ANITA\nGLASGOW, DENNIS\nHARDING, CASSANDRA\nHUFFMAN, KRIS\nJACKSON, MARION\nJOHNSON, VIRGINIA\nJONES, DOCIA\nJONES, STEPHANIE\nKIILSGAARD, SHARON\nKILLINGSWORTH, PATRICIA\nKOVACH, RENEE\nLAJUANA RAINEY\nLOYA, STELLA\nMARION BALDWIN\nMARTIN, PAULETTE\nMcCOY, EDDIE\nMcNEAL, MARIE\nMILAM, JUDY\nNEAL, LUCY\nPAAL, MARY M.\nPAUL, ANNITA\nPERRITT, YORIKO U.\nPRICE, PATRICIA\nRYNDERS, PAULA\nSMITH, GARY\nSMITH, PAULA\nTEETER, JUDY\nWALLS, COLLEEN\nWARD, LIONEL\nWILLIAMS, BARBARA\nWILLIAMS, ED\nWILSON, LEVANNA\nWOODS, MARION\nBABBS, JUNIOUS\nFRANCES CAWTHON\nGADBERRY, BRADY L.\nHURLEY, RICHARD\nJAMES, KENNETH\nLINDA WATSON\nMARIAN LACEY\nMILHOLLEN, MARK\nSadie Mitchell\nSTEWART, DONALD M.\nVANN, SUELLEN\nWATSON, LINDA\nANDERSON, BARBARA\nASHLEY, VIRGINIA\nBRANCH, SAMUEL\nBROOKS, SHARON\nCARSON, CHERYL\nCARTER, LILLIE\nCOURTNEY, THERESA\nCOX, ELEANOR\nDARIAN SMITH\nDEBORAH MITCHELL\nETHEL DUNBAR\nFaith Donovan\nFIELDS, FREDERICK\nGOLSTON, MARY\nHALL, DONNA\nHARKEY, JANE\nHOBBS, FELICIA L.\nJONES, BEVERLY\nKEOWN, ADA\nLillie Scull\nMANGAN, ANN\nMANNO, ROBERTA\nMARY BARKSDALE\nMENKING, MARY\nMORGAN, SCOTT\nNANCY ACRE\nOLIVER, MICHAEL\nPHILLIPS, TABITHA\nSHARON BROOKS\nSMITH, MARY\nTAYLOR, LESLIE\nTUCKER, JANIS A.\nWILSON, JANICE M.\nWORM, JERRY\nZEIGLER, GWEN S.\nBERRY, DEBORAH\nBLAYLOCK, ANN\nFULLERTON, JAMES\nHUDSON, ELOUISE\nLarry Buck\nMOSBY, JIMMY\nPATTERSON, DAVID\nROUSSEAU, NANCY\nSAIN, LLOYD DRA Results by Middle School Feeder Pattern 193sounds like the our data is available. LESLEY, BONNIE From: Sent: To: Subject: LEASE. KATHY R. Tuesday, October 03, 2000 6:09 PM CARNINE, LESLIE V. CTA issues Dr. C., Did Clementine come in today to discuss assessment issues with you? I invited her in last spring to talk with me, but she never came. If she has some specific issues that you think we need to address in the questionnaire, let me know. 1 started drafting some ideas about questions, but I think I need some input from you. It looks like from one of the emails you sent that folks have been communicating with you about their concerns. They may have shared some things we haven't thought about. Let me know if you have any time tomorrow afternoon to visit with me (phone or in person) about the survey. Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject: LEASE. KATHY R. Tuesday, October 03, 2000 5:45 PM CARNINE, LESLIE V. RE: ALT Check-In, Etc. This is pure fabrication. This is not the situation here in PRE. We have a fox in the hen house. I thought this kind of thing was supposed to be over. The digs have continued. The ALT process has to have someone who shepherds it. I said originally that I would need Gayle at least six weeks to two months. I fully understand the strain that Sadie is under because she has come to depend on Gayle as well. If Gayle cannot fulfill her commitment with ALT, then I think she would let me know. She had to go over to the administration building to get some work done to be ready for the Bi-Racial committee report that she is scheduled to give tonight. Roz told her that she could take care of anyone who checked in things today. I guess the real question is that if my staff thinks they are having a problem \"handling\" the ALT today, why didn't they contact me? We had Ed here scanning and scoring, and Irma received no calls that she couldn't handle. I'm afraid I am left with no other conclusion but that this is continued harassment by the person that I thought had agreed to quit harassing. Can you help me with any other explanation? KL Original Message From: Sent: To: Co: Subject: CARNINE, LESLIE V. Tuesday, October 03, 2000 11:10 AM LEASE, KATHY R. Mitchell, Sadie FW: ALT Check-In, Etc. I know you know how assumptions can get you in trouble. Obviously, there appears to be a communication problem and I would hope you and Sadie could work it out. Original Message From: Sent: To: Subject: LESLEY, BONNIE Tuesday, October 03, 2000 10:55 AM CARNINE, LESLIE V. ALT Check-In, Etc. I have had three complaints already today-two from IRC staff and one from building-level. Gayle has returned to downtown, and Kathy is sitting in the school improvement meetings. Neither of them organized the staff for the return of 50the ALTS, and so they were down there yesterday and again today just kind of picking it up, but they do not necessarily know what they are supposed to be doing. They need direction, and I don't feel that I should provide it. How do you want to handle this? LESLEY, BONNIE From: Sent: To: Subject: LEASE, KATHY R. Monday, October 02, 2000 6:48 PM CARNINE, LESLIE V. FW: Priorities 2000-2001 Dr. C., I'm sorry. I guess 1 don't quite know what to do with the plan I sent to Bonnie. I guess I missed the mark. I thought we were to develop what we were doing in our department to meet the areas you outlined in your critical priorities processes. Do you want me to send the parts to the people Bonnie mentioned below? Or are you going to put it all together using what you want out of what we sent? Let me know what you want me to do. KL Original Message From: Sent: To: Subject: LESLEY, BONNIE Friday, September 29, 2000 3:04 PM LEASE, KATHY R. RE: Priorities 2000-2001 You need to send the technology stuff to Lucy Neal. You need to send the Campus Leadership stuff to Sadie Mitchell. I suggest that you forward the other two pieces directly to Dr. Carnine. They are much more detailed than the other items in the Division of Instruction Work Plan and therefore don't \"fit\" with what we have. /Mso, 1 know nothing about the Qjjality Initiative Plan, so that makes no sense to, me, Perhaps he can just include your items s'eparately. ' -----Original Message From: Sent: To: Subject: LEASE, KATHY R. Friday, September 29, 2000 2:50 PM LESLEY, BONNIE Priorities 2000-2001 Importance: High I had massive computer failures today. It took Ed. Ken, Virginia, and Irma to help me get it all back. Here are the priorities from PRE. Call me, if you want me to go over them with you. Thanks. Kathy File: Priority 11 Technology 2000-2001.doc Assessmentdoc   File: Priority IV lnstruction-evaiuation.doc File: Priority lll-2000.doc  File: Priority IV Instruction- Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 51Original Message From: Sent: To: LESLEY, BONNIE Tuesday, June 26, 2001 12:08 PM MITCHELL, SADIE\nMOSBY, JIMMY\nOLIVER, MICHAEL\nRAINEY, L. KAYE Subject: Requests from Mr. Walker I have an foi from John Walker requesting copies of program evaluations on the following programs. PRE says they provided you data for them, but I need a copy of the report. SEDL program-Southwest Middle School-Jim Mosby Onward to ExcellenceWatson Elem.-Mike Watson Collaborative Action Team-Kaye Rainey Campus Leadership Teams-surveys done\nGayle Bradford did report? He wants these right away, please. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Tuesday, June 26, 2001 1:21 PM MITCHELL, SADIE RE: Update In Waco, Delaware, and KCK. We went to Austin the next year after they became unitary and we had to implement the plan that the court had approved-mainly a system of providing lots of resources to what they called \"priority\" schools-like the incentive schools here. The pre-hearing process was fairly peaceful in all. The hearing itself is always awful. John Walker was the plaintiff attorney in Waco. I probably told you that. But he came into town the day before the hearing, did depositions that evening, and beat the hell out of us for the next two days-mainly about how cheerleaders at Waco High had been selected. We had great test score improvement there, etc., and he didn't dwell on that. Delaware had a long process of trying to develop a plan in collaboration with the plaintiffs, and the leader of that group was pretty hostile. In KCK I was the person in charge of desegregation planning. I did the redistricting plan, the facilities study, the demographic projections, the assessment of need fora millage increase\nplus the planning and beginning implementation of the education plan. So when we went to court, 1 was almost the only witness for the district-hours and hours. The supt, some board members, and the interim supt. were briefly questioned. The plaintiff there was the US Dept, of Justice, so 1 had been working in collaboration for three years with an attorney from DC, plus two consultants whom she hired to help us develop our plans. It wasn't all peaches and cream, but fairly non violent. In both Waco and KCK, the judge ruled that we were unitary from the bench. We didn't even have to wait for a written opinion. What I don't understand here is that LR has done many more times as much as either Waco or KCK-or Delaware, and they all got almost instant unitary status. Going to federal court is scarey. They can ask you absolutely anything, and you have to answer. The rules for discovery are real different in federal court than in state, and I was really confused the first couple of times I had to be a witness. I try to be super prepared, to breathe deeply, and to remember that it's not an oral exam, that if I don't know, I can say that, and it will be all right. But it is awful at best, and we need to start getting steeled for that. Original Message- From: Sent: To: Subject: MITCHELL, SADIE Tuesday, June 26, 2001 1:23 PM LESLEY, BONNIE RE: Update Have you gone through this before and how did you deal wiith it? Sadie Mitchell 255LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Wednesday, June 20, 2001 1:13 PM GRIFFIN, BEVERLY RE: Semester Test Exemption Thanks, Bev. -----Original Message----- From: Sent: To: Subject: GRIFFIN, BEVERLY Wednesday, June 20, 2001 1:15 PM LESLEY, BONNIE RE\nSemester Test Exemption I gave a copy of the minutes from the February Board meeting to Mrs. Lacey earlier this week. I don't think I have a copy of the kids proposal, but I will check. I was under the impression that this action was for this year's seniors only. I might be wrong .. . but, it might be worth j checking with Board members to see if they intended for it to be a permanent change to the policy.  I will fax you the minutes in just a minute. Original Message----- From: Sent: To: LESLEY, BONNIE Wednesday, June 20, 2001 12:51 PM GRIFFIN, BEVERLY Subject: Semester Test Exemption Bev, there is wide disagreement about what people remember as the motion the board made regarding the exemption of seniors from their spring semester tests. I don't remember the month they did that--probabiy February or March? Will you send to me the text of the motion, as well as the text of the language used by the , kids in their proposal. I don't have that and will need it to update those reguiations/policies.\nDr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock,.Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Wednesday, June 20, 2001 1:12 PM TRUETT, IRMA Compliance The compliance report lists several \"program evaluations\" that PRE reported that they had completed, but which I have never seen. Please provide me with three copies each of the following reports. They have been requested by Mr. Walker. Extended Year Schools Summer School HIPPY Program Charter School Campus Leadership Teams English as a Second Language Lyceum Scholars Program at Philander Smith College Southwest Middle School's SEDL Program Onward to Excellence (Watson Elementary) Collaborative Action Team (CAT) 351LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Monday, June 25, 2001 12:37 PM 'Clay Fendley'\n'heller@fec.net' RE: Meeting schedule Yea! Thanks you! I can't tell you how important this is! i just talked.with Ann Brown. She wanted all the test scores. I put her off until the end of the week. We need to talk about what to give her. Original Message From\nSent: To: Cc: Subject: Clay Fendley [SMTP:FENDLEY@fec.net] Monday, June 25, 2001 12:42 PM BALESLE@IRC.LRSD.K12.AR.US Chris Heller RE: Meeting schedule Leaving at 1:05 on the 6th is fine. We will tell Walker that if he wants to call you as a witness, he will need to call you on the 5th. Thanks. \u0026gt; \"LESLEY, BONNIE\" \u0026lt;BALESLE@IRC.LRSD.K12.AR.US\u0026gt; 06/25/01 11:49AM \u0026gt; I just called the airlines. I would need to catch a plane at 1:05 on the 6th to get to Amarillo in time for the rehearsal dinner for this big wedding. If I can't do that, then the latest I could leave to get there at all on Friday is at 5:35. Then I would come home on Sunday. What do you advise? -----Original Message----- From: Clay Fendley [SMTP:FENDLEY@fec.net] Sent: Monday, June 25, 2001 9:41 AM \u0026gt;To: BALESLE@IRC.LRSD.K12.AR.US\nblgadbe@lrscladm.lrsd.k12.ar.us\nDMSTEWA@lrsdadm.lrsd.k12.ar.us\nIvcarni@lrsdadm.lrsd.k12.ar.us\nSMMitch@lrsdadm.lrsd.k12.ar.us\nJCBABBS@STUASN.LRSD.K12.AR.US \u0026gt; Cc: Chris Heller\nKJAMES@lrsdadm,lrsd.k12.ar.us \u0026gt; Subject\nMeeting schedule Here's the meeting schedule so far: \u0026gt; Mr. Gadberry - Wednesday at 2:00 at our office. \u0026gt; Dr. Lesley - Thursday at 1:00 at our office. \u0026gt; Ms. Mitchell - Friday at 9:00 at our office. \u0026gt; \u0026gt; We should get Joshua's objections today and have requested a witness list by Wednesday. \u0026gt; We are leaving Monday (July 2) open until we get Joshua's witness list. \u0026gt; Everybody plan on meeting Tuesday (July 3) all day at our office. Let me \u0026gt; know if that presents a problem for you, and we can try to work around \u0026gt; your schedule. Remember, the most important thing in preparation for the hearing is for \u0026gt; you to know what's in the Revised Plan and the interim and final compliance reports. \u0026gt; We will provide copies of Joshua's objections as soon as they are \u0026gt; received. \u0026gt; \u0026gt; Let me know if you have any questions. \u0026gt; 297-----Original Message From: Sent: To: Cc: Subject: LESLEY, BONNIE Thursday, June 28, 2001 9:04 AM MITCHELL, SADIE\nEGGLESTON, DEANA\nGADBERRY, BRADY L\nSTEWART DONALD M  BABBS JUNIOUS\nJAMES, KENNETH 'heller@fec.net' RE: I just spoke with Chris Heller, and he asked me to tell all of you that we are not going to make this information (copies of our invitations and documents sent to Mr.Walker or Ms. Springer) available to Mr. Walker. It is without exception stuff we have already sent to him. He also asked me to reiterate to everyone that he does not want any of the staff talking with Mr. Walker about anything-to refer all his calls, faxes, and visits to Mr. Heller. And he asks that we absolutely not send to Mr. Walker anything without clearing it with him first. Finally, he asks that we remind all our staff once more about this! He was adamant. Original Message----- From: Sent: To: Cc: Subject: MITCHELL, SADIE Thursday, June 28, 2001 9:03 AM EGGLESTON, DEANA LESLEY, BONNIE\nGADBERRY, BRADY L\nSTEWART, DONALD M.\nBABBS, JUNIOUS RE: Thank you Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us -----Original Message----- From: Sent: To: Cc: Subject: EGGLESTON,DEANA Thursday, June 28, 2001 8:38 AM MITCHELL, SADIE BABBS, JUNIOUS RE: Everyone sent the information when it was requested, however, I'm not sure if they have sent recent documents since his original request. I just spoke with Clay and he said to make the folders we have available to Joy on Monday as per her request, but for me to not to put the documents in any particular order (ie. date, subject, etc.) Deana -----Original Message----- From: Sent: To: Cc: Subject: MITCHELL, SADIE Thursday, June 28, 2001 8:41 AM LESLEY, BONNIE\nSTEWART, DONALD M.\nGADBERRY, BRADY L\nBABBS, JUNIOUS\nJAMES, KENNETH EGGLESTON, DEANA Mr. Walker sent a fax requesting \"all invitations to Ms. Springer or Mr. Walker to meetings of any kind, as well as copies of any documents you have sent to them over the past three years. Also any document of whether Mr. Walker or Ms. Springer actually attended the meetings to which you invited them.\" I think we already sent this information to Mr. Babbs and he compiled it. Is this correct? Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 219selected to receive Merit Scholarship'^ awards. The info in italics is from the National Merit web site. So, of the 1.2 million entrants, only 7,900 are named Finalists for National Merit scholarships and corporate-sponsored scholarships. That amounts to 6/10 of 1 % of the entrants. Mr. Walker's statement on page 22 is: \"We note here that the district is yet to have a single Black national merit scholar in the nineteen years of this active litigation.\" THIS IS INCORRECT. Without reviewing 19 years of data (and we don't have all of the data for those years), as recently as 4 years ago Salonica Gray, an African American female senior at Central, was a National Merit Finalist. Hope this helps! Suellen S. Vann, APR Director of Communications Little Rock School District (501) 324-2020 LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Thursday, June 28, 2001 11:36 AM MITCHELL, SADIE RE: I am wondering how he is feeling as well. This is baptism by fire. -----Original Message----- From: Sent: To: Subject: MITCHELL, SADIE Thursday, June 28, 2001 9:29 AM LESLEY, BONNIE RE: I panicked when I got here and saw all of the stuff from John. I am worried about Dr. James. I hope he will be able to handle all of this. Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us Original Message----- From: Sent: To: Subject: LESLEY, BONNIE Thursday, June 28, 2001 9:09 AM MITCHELL, SADIE RE: He was kind of angry that we are even attempting to respond to this stuff. He asked me what he needed to do to make sure everyone understands that we are not to play Mr. Walkers game. How ya doing today? -----Original Message----- From: Sent: To: LESLEY, BONNIE MITCHELL, SADIE Thursday, June 28, 2001 9:18 AM Subject: RE: Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.ar.us 218LESLEY, BONNIE From\nSent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:54 PM CARNINE, LESLIE V. FW: Test Pack Importance: High Dr. Carnine, What is the purpose of this? Am I missing something? Is Bonnie trying to eliminate her need to work with this department? We have some software that is licensed to this department. Eddie has been trying to get it loaded on her computer. My guess is that she needs it to work on her dissertation. She has not spoken to me about what her data needs are for her dissertation. Most doctoral candidates come in and visit with us about their data needs. We work with them, but they get data in an aggregate form, not individual students' information. I wish you would please tell me what role you want this department to play. I know the game that is being played. 1 am about to my wit's end with it. Kathy -----Original Message----- From: Sent: To: Subject\nJOHNSON, VIRGINIA Tuesday, February 13, 2001 12:43 PM LEASE, KATHY R. FW: Test Pack -----Original Message- From: Sent: To\nCc: Subject\nLESLEY, BONNIE Monday, February 12, 2001 5:31 PM RUFFINS, JOHN JOHNSON, VIRGINIA\nMcCOY, EDDIE\nCLEAVER, VANESSA RE: Test Pack Thanks so much, JOhn. Original Message- From: Sent: To: Subject: RUFFINS, JOHN Monday, February 12, 2001 4:46 PM LESLEY, BONNIE RE: Test Pack I will come over and personally visit with Virginia and Eddie to access their data and program needs. -Original Message- From: Sent: To: LESLEY, BONNIE Monday, February 12, 2001 2:40 PM RUFFINS, JOHN Subject\nTest Pack John, I am moving Eddie McCoy and Virginia Johnson out of the rooms designated for PRE and into the room where Vanessa Cleaver is. Both of them will have some program evaluation responsibilities and need to be able to access the SAT9 data, as well as other student data. How do I get those programs loaded onto thejr machines? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 19LESLEY, BONNIE From: Sent\nTo: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 5:36 PM CARNINE, LESLIE V. RE: Another thought Here's one more thought, then I'm burying this frustration. I wouldn't have known about what she is doing at all if Virginia hadn't forwarded me a copy of the message. I'm trapped in junior high!I! Can't somebody save me??? Kathy Original Message- From: Sent: To: Subject: CARNINE, LESLIE V. Tuesday, February 13, 2001 4:05 PM LEASE, KATHY R. RE: Another thought I can support but you do not want to hold the data... You want free access. Give her all the access she wants or needs... and then give her more. -----Original Message----- From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From\nSent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 4:10 PM CARNINE, LESLIE V. RE: Another thought I totally agree with that. I want everyone to have access to the data at his or her fingertips. I just continue to be frustrated with the way she refuses to work with me. Kathy Original Message- From: Sent: To: Subject: CARNINE, LESLIE V. Tuesday, February 13, 2001 4:05 PM LEASE, KATHY R. RE: Another thought I can support but you do not want to hold the data... You want free access. Give her all the access she wants or needs... and then give her more. -Original Message From: Sent: To: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought 17Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent\nTo: Subject: LEASE, KATHY R. Tuesday, February 13, 2001 12:59 PM CARNINE, LESLIE V. Positions After Don's comment in Cabinet about not hiring people, I visited with him about the positions that I currently have advertised. He suggested that I visit with you about whether or not I can hire the people I need to do the assessment program. I am currently down to three employees. I don't think we can do assessment for 20,000 kids with that number. I want to set up interviews this week, but I want your blessing! Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us LESLEY, BONNIE From: Sent: To: Subject\nLEASE, KATHY R. Tuesday, February 13, 2001 12:56 PM CARNINE, LESLIE V. Another thought Is it possible to require Bonnie to work through me to get the data she needs? She is doing everything possible to undermine the work of this department. I have never seen such viciousness in all my professional experience. Can you support us or are we on our own? Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd.kl2.ar.us 18From: Dr. Faucette To: Mrs. Hargis Date: 17 November 2000 Subject: Exclusion of regular English students from Jennie Calder lecture I write to request a bit of information concerning the recent visit of Jennie Calder, a Robert Louis Stevenson scholar from Scotland, to Central as a part of the conference celebrating this great writer. It was my understanding, after our conversations last spring, that the event was in recognition of the universal appeal of a revered writer. Known and loved the world over, Stevenson is one of a select group whose works attract readers from widely varying backgrounds, uniting people of all classes and condition in the appreciation of a gifted artist. I was excited about the opportunity Central studentsincluding my own students - would have to be-exposed to a world of exciting and enthusiastic research that would be especially significant for seniors. (Traditionally, the last year of high school English is dedicated to the exploration of the rich legacy of British literature.) I was disappointed beyond belief to learn that nonenot oneof my regular English students would be allowed to benefit from the singular experience of having the chance to see and hear the visiting scholar. Only AP and pre-AP students were allowed to attend the presentation. In fact, most teachers of regular English classes only learned of the event when students began to ask why they were not allowed to attend the assembly that students in other classes were discussing at lunch. Limiting the experience to students in AP and pre-AP English classes meant that very few black students were allowed to attend. I am shocked and outraged that yet another singular educational opportunity has been reserved for the children of privilege. Because many of the privileged AP English students took advantage of the event to slip out of the building and skip the assembly, and because you wanted to supplement their numbers, you solicited the attendance of students from AP science and history classes, still denying access to students from regular English classes. If you really wanted to impress Ms. Calder, having the Creative Writing Club presented would have done just that. The knowledge that, at 287 members, the Creative Writing Club is the most active club at Central would impress any true scholar or teacher. One can only wonder why you, Mr. Howard, and the third floor English department all miss the significance of the fact that the club that most fully represents the student diversity in our building is a club centered around an academic endeavor, the study and practice of literature. Yes, this is quite an example you set for our students. Central, Mr. Howard, the English department, and you all had a chance to .shine as this scholar brought her enthusiasm to our large and diverse student body. Central, Mr. Howard, the English department, and you dropped the ball disastrously on this one. Rather than seizing the opportunity to be shining beacons by providing this opportunity I for learning outside the traditional limitations of the classroom to all of our students, you have shown your true stripe. I thank you for the demonstration once again that, instead of a single unified English department, Central actually has two: the second floor containing primarily regular English classes, and the privileged third-floor home of AP English. I would now ask an additional bit of information. Please inform me in writing of your reasons for this latest instance of educational snobbery so that I might explain more accurately to my classes your dismissal of them as second-class students. i i I ! i I (GILLESPIE, RAY From\nSent: To: Subject: LACEY, MARIAN G. Saturday, September 30, 2000 10:46 PM MITCHELL, SADIE\nGILLESPIE, RAY RE\nFinal Report What do you think, Ray? I can see last year's: what about the other 2 years? mgl Original Message From: MITCHELL, SADIE Sent: To: Subject: Wednesday, September 27, 2000 6:28 PM GILLESPIE, RAY\nLACEY, MARIAN G. FW: Final Report '* T.?' r? ZT i. it V Z .Til Can this be done? OCT 2 ZOOO i ! I From\nSent: To\nCc: Subject\nBABBS, JUNIOUS Wednesday, September 27, 2000 5:32 PM GILLESPIE, RAY LACEY, MARIAN G.\nSMITH, LINDA K.\nMITCHELL, SADIE RE: Final Report We should be able to pull this data from past LRSD AAA report information submitted ? Junious C. Babbs, Jr jcbabbs(astuasn.lrsd.kl2.ar.us Little Rock Schoo! District Original Message- From: Sent\nTo: Cc\nMITCHELL, SADIE Wednesday, September 27, 2000 6:36 AM BABBS, JUNIOUS LACEY.'MARIAN G.\nSMITH. LINDA K.\nGILLESPIE, RAY Subject: FW\nFinal Report Marian and Linda will not have the data to pull a three year report together for the extracurricular activites. We have not compiled that data since we discontinued the School Profile. However, we will have it for this school year. Ray does not have any information on file either. Sorry From: Sent: To: Subject: Clay Fendley(SMTP:FENDLEY@fec.net] Tuesday, September 19, 2000 2:52 PM BALESLE@IRC.LRSD.K12.AR.US\nblgadbe@lrsdadm.lrsd.k12.ar.us: DMSTEWA@lrsdadm.lrsd.k12.ar.us\nIvcaml@lrsdadm.lrsd.k12.ar.us\nSMMItch@lrsdadm.lrsd.k12.ar.us\nJCBABBS@STUASN.LRSD.K12.AR.US Final Report  File: Des-final-report-outline.doc  Attached please find a draft outline for the final report to be filed 3/15/2001. Please think about additions/changes for the sections for which you are responsible, and we can discuss at our next meeting. I look forward to seeing you then. Clay Fendley Friday, Eldredge \u0026amp; Clark 400 W. Capitol, Suite 2000 Little Rock. AR 72201 E-mail: fendley@fec.net Direct Phone: 501-370-3323 Direct Fax: 501-244-5341 1Via Facsimile - 324-2146 December 16, 1998 Dr. Leslie Carnine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Dr. Carnine: Would you please ask Mr. James Washington, the Districts ombudperson, to look into the complaint of Mr. \u0026amp; Mrs. Deodis Fleming regarding their concerns at Carver Magnet. You are probably not aware that this office has had several complaints from other parents regarding the unfair treatment of black students at Carver. You should have received a letter from the Flemings outlining their concerns along with a response from Ms. Barksdale. Copies of both are enclosed for your convenience. The Flemings believe that Ms. Barksdale is trying to excuse the reason for Ms. Ransoms exclusion of their son from participation by stating that he had behavior problems. In todays society, persons who discriminate usually attempt to establish legitimate reasons for their discriminatory actions. The reason given by Ms. Ransom, we believe, is pretextual. In other words, the reason that she has given is not legitimate. The Flemings were not previously advised that their son had behavior problems regarding his participation in Odyssey of the Mind. Moreover, they are not aware that their son has a behavior problem. Ms. Barksdales commitment to establish an OM Guideline booklet is a step, I believe, in the right direction. However, I do not believe that she should wait until next year. That process should start immediately. Opportunity for discrimination evolves when there are no written guidelines or rules for participation in a particular activity. The person overseeing or administering the activity usually has the discretion to make rules as they go along. These rules usually favor their own personal interests. Moreover, these rules or guidelines usually change daily to fit a particular interest or situation. I am not sure why the Flemings chose not assist in the coaching of Odysseys students as indicated by Ms. Barksdale, however, many of our childrens parents are unable to participate in many of the schools activities because often they occur when they are obliged to work and other commitments to meet the overall needs of their familias Page 2 - Letter to Dr. Carnine December 17, 1998 I have indicated to Mr. \u0026amp; Mrs. Fleming that I would be happy to sit down with Mr. Washington, Ms. Mitchell, Ms. Barksdale, and any other persons that they believe can help brin\nQ '  -------------------------------3 VXXV-J l^\\,/AXVVV VCill Ulllig this matter to an amicable resolution. In fact, IVIr. Washington may assume the role as the parent advocate, if the Flemings agree. I would, however, like to receive a report of his findings and resolution. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors ICS/ Enclosures cc: Mr. \u0026amp; Mrs. Deodis Fleming Ms. Diane Barksdale Ms. Sadie Mitchell Mr. James WashingtonVia Facsimile - 324-2146 February 18, 1999 Ms. Sadie Mitchell Associate Superintendent for Student Services Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Ms. Mitchell: This office has received several calls regarding the selection process for the new football coach at J. A. Fair High School. It is our information that the selection process has been changed to favor the selection of a particular coach for the position. In order to address the concerns that have been raised, would you please provide to me a copy of process being utilized by District officials for the selection of coaching positions including the selection criteria. If this information has changed from prior years, also please provide the process and criteria that was utilized in previous years. I have spoken with Mr. Gillespie regarding this matter and he has assured me that the only change in the process was that the selection committee did not meet on the school campus as it has done in previous years. I was, however, a bit concerned about the gender makeup of the selection committee for the Fair position. I voiced my concern to Mr. Gillespie that the committee was all males. I am available to discuss this matter with you and Mr. Gillespie at a mutually convenient time. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Mr. Ray Gillespie Via Facsimile - 324-2308 March 17, 1999 Rudolph Howard Principal, Central High School 1400 Park Street Little Rock, AR 72202 Dear Mr. Howard: I am writing on behalf of Rev. \u0026amp; Ms. Bennie Horton and their son, Tarick, to request a conference regarding his grades. As I review the revised desegregation plan, I can point to a number of areas including equal treatment, participation in honors and gifted classes, academic achievement, parental involvement etc. that are involved in these parents concern. By copy of this letter to the Districts Ombudsperson, Mr. James L. Washington, I am also putting him on notice of this concern and invite him to participate in the conference. I have spoken with Ms. Horton and she is available during her lunch hour to discuss this matter. Please let me hear from you. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Rev. \u0026amp; Mrs. Bennie Horton Mr. James L. WashingtonJohn W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 M /? JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE AUSTIN PORTER, JR. Via Facsimile - 324-2213 October 14, 1999 Mr. James Washington Little Rock School District Office of Ombudsman 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: I am writing to request that you look into the selection process for students participating on mock trial teams at Central High School. We request that you obtain some background information regarding past composition by grade, race and gender and the current composition by grade, race and gender. This office has received a complaint that these teams are generally one race and favor white students because their parents or other relatives are business professionals such as lawyers, judges, etc. Thank you for your attention to this matter. We further request a report of your findings with respect to this inquiry. By copy of this letter to Mr. Howard, Mr. Babbs and Dr. Gamine, I am also advising them of these allegations. On Behalf of Joshua JCS/ cc: Mr. Ruduloph Howard Nir. Junious Babbs Dr. Leslie Gamine Via Facsimile February 28, 2000 Mr. James Washington Ombudsperson Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: I am writing to request that you investigate the complaints of discrimination and retaliatory treatment by Mr. \u0026amp; Mrs. Eddy Harris Sr. against his son, Eddy Jr. by members of the staff at Oak Grove High School in the Pulaski County Special School District. For several years, Eddy Jr. was a M to M student in the County. Eddy is currently a student in the Little Rock School District. I have previously requested that Mr. Billy Bowles, Assistant Superintendent for Desegregation, look into complaints of the Harrises. I am enclosing a copy of my request to Mr. Bowles. Mr. Bowles assured me that he would conduct a thorough investigation and, thereafter, provide a report of his findings. I am enclosing a copy of Mr. Bowles purported report of his findings. It is basically a one sentence conclusion. At least, I expected a report which enumerated all charges and a summary of his findings. I expected a more thorough report similar to the one that he and members of his staff conducted several years ago at Robinson High School where he noted findings, whether substantiated or unsubstantiated. The Harrises claim Eddy Harris Jr. was not allowed to participate on the football team for the last four or five games for racial and/or retaliatory reasons, that Eddy Jr. was not selected to participate on the basket ball team for racial and/or retaliatory reasons and that Eddy Jr. received retaliatory treatment from his classroom teachers, in particular, Ms. Morrison, his English teacher, who gave him gave him an F. The Harrises claim that Eddys English grade for the semester is based, in part, upon assignments that he should not have been charged for because they had officially withdrew him from Pulaski County School District. Enclosed is the documentation from the Harrises. Also enclosed are copies of letters directed to or copied to Mr. Bowles regarding the claims of the Harrises. I also have several tape recordings of conferences with staff members that I will be happy to share with you. Mr. Bowles was aware of these taped conferences, but he did not request a copy of either of them for his review. Mr. Bowles did not make single finding regarding his investigation nor did he address any of the points in this correspondence.In summary, the complaints of the Harrises are as follow: 1) failure of Eddy Jr. to participate in the remaining four or five games of the football season\n2) failure to Eddy Jr. to participate on the basketball team, and\nrade received by Eddy Jr. in English. 3) the failing g: The treatment referenced above, we believe is due to racial and/or retaliatory treatment by Pulaski County School District officials. Please let me know if additional information or clarification is needed regarding this matter. Again, 1 am copying Mr. Junious Babbs to alert him of this egregious situation and to request that he also utilize his offices to assist in the amicable resolution of this matter. I would also appreciate a report of your findings. Thank you for your attention to this request. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Mr. \u0026amp; Mrs. Eddy Harris Sr. Mr. Billy Bowles Mr. Junious Babbs Ms. Ann BrownFebruaiy 28, 2000 Mr, James Washington Ombudsperson Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: I am writing to request that you investigate the complaints of Mr. Reginald Abrams. I am taking the time to put this request in writing due to the egregious nature of the situation. Mr. Abrams son is a Boys Scout at Cloverdale Middle School. Mr. Abrams complained to me regarding the treatment his son and other black Scouts received while attending the Boys Scout Council Area Banquet on last Thursday evening, February 24, 2000 at Ricks Armory. I have asked Mr. Abrams to call you with the specific details of this experience. I must state, however, that based upon his communication to me, I do not believe that the Little Rock School Districts commitment to inclusiveness and desegregation was demonstrated at this banquet. Upon information and belief, it appears that the black scouts roles at this activity were both demeaning and nonexistent. I must also question the expectations of Mr. Lacour, the Scout Master, who tolerated this treatment and was reported to have said that he did not expect black parents to participate and thus be able to question the roles and participation of their children during particular scouting activities. Mr. Lacour needs to understand that the spirit of desegregation plan called for activities such as scouting and that scouting would be an opportunity for black students to have new experiences and be given opportunities to develop skills such as social and leadership skills, to new a few. May I suggest that you conduct an investigation into the scouting programs for the entire District and determine the roles of black students and whether similar situations have occurred. I believe that you should interview Mr. Lacour to determine the schools that he has been working with and the names of other scout masters in the area who work with Little Rock District students. I understand that Mr. Lacours number is 758-1838 or pager 688-4533. Mr. Abrams may be reached at 9700 Stardust Trail, Little Rock, AR 72209, telephone number 562-0348. Please let me hear from you regarding the result of your findings and your recommendations to ensure that similar situations do not occur in the future. Thank you for your attention to this request. I believe that it is important that Air. Junious Babbs receives a copy of this letter given his role to ensure compliance with desegregation. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Mr. Reginald Abrams Mr. Junious BabbsJohn W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Via Facsimile August 28, 2000 Mr. Ray Gillespie Athletic Director Little Rock School District 810 West Markham Little Rock, AR 72201 Re: Southwest Middle School Dear Mr. Gillespie: I am writing to request that you investigate the complaints of Mr. \u0026amp; Mrs. Michael Wesley regarding their son, Marquis, a student at Southwest Middle School. Mr. Wesley reports a very disturbing incident that occurred on Friday, August 24, 2000 at the school involving Coach Foote. In summary, Mr. Wesley reports that Coach Foote choked Marquis and has openly admitted doing so. The Wesleys are very upset about Coach Foote actions and request that he be dealt with. We are available to meet with you, if additional information is needed. 4ncerely, On Behalf of Joshua Intervenors JCS/ I  February 28, 2000 Mr. James Washington Ombudsperson Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Mr. Washington: I am writing to request that you investigate the complaints of Mr. Reginald Abrams. I am taking the time to put this request in writing due to the egregious nature of the situation. Mr. Abrams son is a Boys Scout at Cloverdale Middle School. Mr. Abrams complained to me regarding the treatment his son and other black Scouts received while attending the Boys Scout Council Area Banquet on last Thursday evening, February 24, 2000 at Ricks Armory. I have asked Mr. Abrams to call you with the specific details of this experience. I must state, however, that based upon his communication to me, I do not believe that the Little Rock School Districts commitment to inclusiveness and desegregation was demonstrated at this banquet. Upon information and belief, it appears that the black scouts roles at this activity were both demeaning and nonexistent. I must also question the expectations of Mr. Lacour, the Scout Master, who tolerated this treatment and was reported to have said that he did not expect black parents to participate and thus be able to question the roles and participation of their children during particular scouting activities. Mr. Lacour needs to understand that the spirit of desegregation plan called for activities such as scouting and that scouting would be an opportunity for black students to have new experiences and be given opportunities to develop skills such as social and leadership skills, to new a few. May I suggest that you conduct an investigation into the scouting programs for the entire District and determine the roles of black students and whether similar situations have occurred. I believe that you should interview Mr. Lacour to determine the schools that he has been working with and the names of other scout masters in the area who work with Little Rock District students. I understand that Mr. Lacours number is 758-1838 or pager 688-4533. Mr. Abrams may be reached at 9700 Stardust Trail, Little Rock, AR 72209, telephone number 562-0348. Please let me hear from you regarding the result of your findings and your recommendations to ensure that similar situations do not occur in the future. Thank you for your attention to this request. I believe that it is important that Air. Junious Babbs receives a copy of this letter given his role to ensure compliance with desegregation. Sincerely, Joy C. Springer Joshua Intervenors JCS/ cc: Mr. Reginald Abrams Mr. Junious BabbsJohn W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Via Facsimile September 12, 2000 Dr. Leslie Carnine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR 72201 Dear Dr. Carnine: I am writing on behalf of Marcus Winston, a 9\"' grade student at Parkview High School and similarly situated students in the Little Rock District. Would you please direct my attention to the section of the Districts student handbook which states that 9* grade students cannot participate in varsity team athletics. It is my understanding that the practice of the District in previous years has been to allow these students to participate on varsity teams. By copy of this letter to Mr. James Washington, I am also requesting that he investigate this matter. I recommend that he identify all 9* grade students at the senior high level to determine the number, race and gender of the students who are being adversely affected by unwritten directive. As I review the Districts desegregation plan, I note in Section 2.6 of that plan that the District shall implement programs, policies and/or procedures designed to promote participation and to ensure that there are no barriers to participation by qualified African Americans in extracurricular activities...  It appears that the Districts refusal to allow 9\" grade students to participate in athletics at the varsity level is contrary to plan commitments. This new practice is neither promoting nor ensuring participation. Prior to invoking the process regarding compliance issues, I ask that Mr. Washington provide to this office a report of his preliminary findings by September 20, 2000. Thank you for your attention to this matter.On Behalf of Joshua Intervenors JOS/ cc: Mr. James Washington, Ombudsman Mr. Junious Babbs, Associate Superintendent Mr. Ray Gillespie, Althletic Director Ms. Ann Brown John Walker, p.a. f Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Via Facsimile - 324-2146 October 10, 2000 Dr. Leslie V. Carnine Superintendent of Schools Little Rock School District 810 West Markham Little Rock, AR  72201 Re: Duties of Ombudsman Dear Dr. Carnine: Your letter of October 5, 2000, in response to my letter of October 3, 2000, was received by this office today. I look forward to receiving the other requested information. With respect to the second instance, may I call your attention to a letter dated July 25, 2000 addressed to you from a Parkview parent, Bill Winston? A copy is attached for your convenience. According to Mr. Winston, you did not respond to his inquiry. On September 12, 2000, I spoke briefly with Mr. Gillespie about Mr. Wintons concerns. Mr. Gillespie reported to Mr. Winston and me that there existed documentation which communicated to all parents the \u0026gt;ih Districts position regarding 9' grade participation on varsity teams for the 2000-2001 school year. This information was requested for the parent through the Ombudsman. To date, this information has not been received. This complaint was subsequently assigned to Dr. Marion Lacey for handling. Dr. Lacey, Mr. Gillespie and I met on September 29, 2000 regarding Mr. Winstons concerns. I was assured by Dr. Lacey that she would provide a written response along with the previously requested information by the Ombudsman and myself. By copy of this letter to Dr. Lacey, I hope that this will serve as a reminder that I would still like to have her letter and the requested information. By copy of this letter to Mr. Washington, I hope that this also refreshes his memory regarding the requested information that was not shared with him or a parent after inquiry and request for it. Surely, these records do not fall in the category of confidentiality. Moreover, the District has had approximately thirty (30) days to provide the information. Thank you again for your response and consideration given to this inquiry. LSin^rely, UH Q,. Springer / On Behalf of Joshua U JCS/ Enclosure cc: Mr. Junious Babbs Mr. James Washington Dr. Marion Lacey Mr. Ray Gillespie Ms. Ann Brown Mr. Gus TaylorSEP 1300 7:48 PR NfiTIONLJIDE 501 223 1743 TO 3374418? P.02/03 July 25,2000 Superiniendent Les Carnine 810 W. Markham Little Rock, AR 72202 Superiniendent Carnine, Please be advised that I am attempting to contact you by letter, having been unsuccessful so far in getting you to call me back. 1 have left several messages with your secretary requesting to speak to you concerning my oldest son, Demarcus Winston, a freshman scheduled to attend Little Rock Parkview Arts and Science Magnet High School this year. My last attempt to reach you was July 14, 2000 and 1 was told by your secretary that you were out of town and she would have you call me on Monday, July 24, 2000 upon your return. In any event, my concern involves the situation or status of 9th grade athletes being able to participate on the varsity level. J have spoken with the head football coach, Ernest Mcgee, and the head basketball coach, Al Flanagan, about this issue and they advised they were unclear on whether 9th graders could play with the varsity, but both were hoping they could. They encouraged me to voice my concerns to you hopefully before any decision is made. I personally feel that my son would be penalized and held back ui his development as an athlete if he were not allowed to play on the varsity level. The 9th graders who were good enough to play at the varsity level were allowed to do so last year and I have no idea and, as a concerned parent, have not been given an explanation of why my son would not be allowed to play this year. There is not an organized 9th grade league of competition there is in the Pulaski County school district. Since the new format now moves 9th as graders to Senior High (9-12), then he should be allowed to play. The coaches want him to play, his parents want him to play, but I am told that he may not be allowed to play. I would hope that you would consider that my son who is 6-6, 2001bs gets penalized if he is not allowed to play with the varsity and compete at the highest level of competition. I am again asking you to discuss this issue with me and listen to my concerns. Sincerely, Mr. Bill WinsxonJohn W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE SHAWN CHILDS Via Facsimile - 324-2260 September 13, 2000 Mr. James Washington Ombudsman Little Rock School District 810 West Markham Little Rock, AR 72201 Re: 9\"' grade Athletics Dear Mr. Washington\nFor your information, I am attaching a copy of a letter that was sent to Dr. Carnine by one of the concerned parents. It is my understanding that Dr. Carnine has not responded to the letter nor has he returned the parents numerous telephone calls. Also attached hereto is a list of other parents whose children stand to be adversely affected by the District unwritten rule regarding Q* grade athletics. Hopefully this information will assist you with your investigation. In speaking briefly with Mr. Gillespie on yesterday, he indicated that the District sent notices to parents regarding this matter. Would you also inquire about the notices that were sent to parents and share copies of same with this office. Finally, would you also check to see whether this issue was submitted to the Board for approval. I look forward to your preliminary report by September 20, 2000. Thank you for your cooperation. pnnger On Behalf of Joshua JCS/ SEP 1300 7:48 PR NfiTIONLJIDE 501 223 1743 TO 93744187 P . 02/03 July 25, 2000 Superintendent Les Carnine 810 W. Markham Little Rock, AR 72202 Superintendent Carnine, Please be advised that 1 am attempting to contact you by letter, having been unsuccessful so far in getting you to call me back. 1 have left several messages with your secretary requesting to speak to you concerning my oldest son, Demarcus Winston, a freshman scheduled to attend Little Rock Parkview Arts and Science Magnet High School this year. My last attempt to reach you was July 14, 2000 and 1 was told by your secretary that you were out of town and she would have you call me on Monday, July 24, 2000 upon your return. In any event, my concern involves the situation or status of 9th grade athletes being able to participate on the varsity level. I have spoken with the head football coach, Ernest Mcgee, and the head basketball coach, Al Flanagan, about this issue and they advised they were unclear on whether 9th graders could play with the varsity, but both were hoping they could. They encouraged me to voice my concerns to you hopefirlly before any decision is made. 1 personally feel that my son would be penalized and held back in his development as an athlete if he were not allowed to play on the varsity level. The 9th graders who were good enough to play at the varsity level were allowed to do so last year and I have no idea and, as a concerned parent, have not been given an explanation of why my son would not be allowed to play this year. There is not an organized 9th grade league of competition there is in the Pulaski County school district. Since the new format now moves 9th as graders to Senior High (9-12), then he should be allowed to play. The coaches want him to play, his parents want him to play, but 1 am told that he may not be allowed to play. I would hope that you would consider that my son who is 6-6, 2001bs gets penalized if he is not allowed to play with the varsity and compete at the highest level of competition. I am again asking you to discuss this issue with me and listen to my concerns. Sincerely, Mr. Bill WinstonSEP 1300 7:49 PR NATIONWIDE 501 223 1749 TO 93744197 P.03/03 Concerned Parents:  Bill and Tammy Winston (Demarcus Winston, Little Rock Parkview) Home Phone # (501)224-5138  Glenn and Karen Anderson (Jamaal Anderson, Little Rock Parkview) Home Phone # (501)224-2593  Lynn and Angie Smith (Nicholas Smith, Little Rock Parkview) Home Number Unknown  Brian and Tracey Salley (Trey Salley, Little Rock Parkview) Home Phone # (501 )565-0947  William and Jean Givens (CaTravia Givens, Little Rock Central) Home Phone # (501 )562-6882  Fred and Dorothy Bledsoe (Fred Bledsoe, Jr., Little Rock Central) Home Phone # (501)562-5661  Eric Mcghee (Tori Mcghee, Linle Rock Central) Home Number Unknown ** TOTAL PAGE.003 **Friday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY (1522-1994) WILLIAM H. SUTTON. P.A. ' ON M. EISEMAN. JR. P.A. BELL. P.A. J A. BUTTRY. P.A. ..^RICK S. URSERY. P.A. OSCAR E. DAVIS. JR. P.A. JA14ES C. CLARK. JR.. P.A. THOMAS P. LEGGETT. P.A. JOHN DEWEY WATSON. P.A. PAUL B, BENHAM IH. 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 m. P.A. DONALD H. BACON. P.A. WILLIAM THOMAS BAXTER. P.A. BARRYE. 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 m. P.A. MICHAEL S. MOORE. P.A. DIANE S. MACKEY, P.A. WALTER M. EBEL m, 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. JOSEPH P. MCKAY ALEXANDRA A. IFRAH JAY T. TAYLOR MARTIN A. KASTEN JONANN ELIZABETH CONIGUO, 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 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 fendley@fec.net July 18, 2001 Ms. Joy C. Springer John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 RE: FOIAs to LRSD Dear Ms. Springer: This letter shall serve as the District's response to you letter dated July 10, 2001, pertaining to your FOIA requests. We have reviewed the requests to determine if all documents requested have been provided. Our findings our as follows. FOIA request to Dr. Ken James dated June 25, 2001. requesting standardized test data from 1982 to present. Dr. Bonnie Lesley has responded and advised that this information is available for your review. When we spoke on July 16, it was my understanding that you were going to contact Dr. Lesley to schedule a time to review this data. Please let me know if there is any problem in that regard. FOIA request to Dr. Ken James dated July 2. 2001. regarding 18 different documents. (1) Minority graduate pool rate. The rate (8%) is in the District's Comphance Report. The District has been unable to locate the source document from which this was derived. (2) Manpower reports. These have been provided.Ms. Joy Springer July 18, 2001 Page 2 (3) Monitoring reports of staff. The District has no document entitled, \"Monitoring Reports of Staff.\" Based on our telephone conversation, we will provide you with a copy of Dr. Richard Hurley's notebooks used to monitor staff composition at schools. (4) Reports of the \"teachers of tomorrow\". For 2000-01, this report is part of the Recruitment Annual Report which is now CX 543. Per your request, we will request dom the District the Recruitment Annual Reports for 1989-99 and 1999-2000. (5) Staffing pattern reports. The District has no document entitled, \"Staffing Pattern Reports.\" Dr. Hurley's notebooks should provide the information you are seeking in this regard. (6) Strategic plan for the Dept, of Exceptional Children. This has been provided. (7) Strategic plan regarding student assignment. The District has no document entitled, \"Strategic Plan Regarding Student Assignment.\" In this regard, please review Section 3 of the Revised Plan and the Student Assignment Handbook previously provided. (8) Diploma award rate of handicap students by race and gender. The District has no document compiling this information. (9) Behavior modification plans bv school, race and gender including monitoring reports. FERPA prohibits the District from providing you with any individual student's behavior modification plan or documentation of monitoring related thereto. The District does not have any document compiling the total number of behavior modification plans or the race or gender of students for whom behavior modification plans have been prepared. Finally, the District does not have any document entitled, \"Monitoring Report of Behavior Modification Plans. H (10) Monitoring Reports and/or evaluations of placement criteria for Pre-AP and AP courses. The final Compliance Report provides the number of students in Pre-AP and AP courses II during the term of the Revised Plan. As we understand the phrase, there are no \"placement criteria' for Pre-AP or AP courses. (11) List of students who were encouraged to participate in honors, enriched and AP courses. The District has not compiled such a list. (12) Evaluations of the programs that assisted teachers and counselors in identifyingand encouraging students to participate in AP. enriched and honors classes. As noted above, the Compliance Report provides the numbers of students in Pre-AP and AP courses during the term of the Revised Plan. The District evaluated its efforts in this regard by looking at these numbers.Ms. Joy Springer July 18, 2001 Page 3 (13) programs. List of students by school, race and gender who participated in the CPEP and AEGIS The District has not compiled such a list. (14) Each school's plan to increase the number of minority students enrolling in AP courses. This was a District-wide initiative. If you would like to review the School Improvement Plan of each school to see if they included additional activities for increasing minority enrollment in AP courses, please let me know. (15) your review. Each school's guidance plans. Each school guidance plan can be made available for Please let me know if you would like to schedule a time to do so. (16) School profiles. The District no longer compile \"School Profiles. II (17) Evaluations of magnet programs listed in Section 3.3 of the Revised Plan. We are still attempting to determine what documents we may have responsive to this request. We will respond as soon as possible. (18) Budget allocations for former incentive schools. This has been provided. FOIA request to Dr. Don Stewart dated July 3, 200 T regarding enrollment and budget data for former incentive schools. We provided you this information by letter dated July 12, 2001. FOIA request to Junious Babbs dated July 2. 2001. regarding list of problems adversely affecting African-Americans. See attached response from Mr. Babbs. FOIA request to Junious Babbs dated July 2, 2001. regarding Compliance Plan and Compliance Handbook. See attached response from Mr. Babbs. FOIA request to Dr. Ken James dated July 3. 2001, regarding eight documents. Based on our telephone conversation of July 17, 2001, you have received Dr. Lesley's response to this request. You indicated that she did not respond to two requests, numbers six and seven. We will follow-up and respond to those request as soon as possible.Ms. Joy Springer July 18, 2001 Page 4 FOIA request to Junious Babbs dated July 3, 2001. regarding six documents. See attached response from Mr. Babbs. In our telephone conversation of July 17, you informed me that did not receive the Activities Advisory Board documents from Ms. Sadie Mitchell. Please give me a call to schedule a time to review these documents. FOIA request to Dr. Ken James dated July 3, 2001. regarding K-3 raw data. You now acknowledge that this has been proyided. FOIA request to Junious Babbs dated July 2. 2001. regarding Compliance Committee. In an effort to provide you the closest thing we have to \"minutes\" of the Compliance Committee, we will provide for your review copies of Mr. Babbs e-mail files. In addition to the above, you advised on July 16 that Dr. Lesley responded to an FOIA request regarding summer school that Ms. Mitchell would have that information. You requested that Ms. Mitchell be asked to respond to that request. We are meeting with Ms. Mitchell today and wiU discuss this with her. We appreciate your patience in working with us to gather the documents you have requested. We are doing are best to gather the documents you request in a timely maimer, but it takes time given the broad scope of many of your requests. Sincerely, John C. Fendley,STEWART, DONALD M. From: Sent: To: Subject: LESLEY, BONNIE Tuesday, June 06, 2000 10:49 AM STEWART, DONALD M. RE: Desegregation Payments to Pulaski Co. Districts Thanks so much for this information. I am understanding it for the first time. Original Message From: Sent: To: Cc: Subject: STEWART, DONALD M. Wednesday, May 24, 2000 4:17 PM CARNINE, LESLIE V. GADBERRY, BRADY L.\nANDERSON, VICTOR\nMILHOLLEN, MARK\nBABBS, JUNIOUS: MITCHELL, SADIE\nLESLEY, BONNIE Desegregation Payments to Pulaski Co. Districts Attached to this email is an Excel worksheet which calculates the total amount of funds received from the State by the three school districts in Pulaski County as a result of the Desegregation Settlement Agreement and various court orders. These calculations are based on the data from the 1999-2000 school year and do change slightly from year to year. In total payments the three districts in Pulaski County will receive approximately $39.5 M. in the 1999-2000 school year. This total is made up of funds for: Magnet School operation ($10.1), M-to-M transfer payments ($13 M), Magnet and M-to-M transportation ($5.9 M), Teacher Ret. \u0026amp; Health Ins. Reimburse. ($10.3 M), and Worker's Compensation Reimbursement ($.2 M). These payments are divided among the three Pulaski County Districts utilizing various methods and result in annual payments on behalf of district students to: LRSD ($19.86 M), NLRSD ($4.88 M), and PCSSD ($14.76 M). M-to-M Funding: Currently M-to-M transfer students are removed from the district enrollment prior to regular State Equalization Aid computations. If these students were not being funded through the separate M-to-M funding mechanism they would be eligible for regular State Aid and would create approximately $8.5 M per year. LRSD is currently sending a larger number (1100) of M-to-M students than it receives (422) and also, through the pooling agreement, must pay to the PCSSD ($.4 M) for the education of M-to-M students. Because of these provisions, doing away with the M-to-M provision would actually result in an increase in aid to the LRSD of appiroximately ($1.2 M), while NLRSD would lose ($1.3 M) and PCSSD would lose ($4.1 M). If all M-to-M transfers were returned to their home district, LRSD would be responsible for educating approximately 675 more students than it currently does. At the current rate of expense per student that would cost the district in excess of $4 M. Magnet Funding: Magnet funding is limited to students in the original stipulated magnet school, all located in LRSD. These students are included in the home districts enrollment count for equalization aid purposes. In addition to this funding source, the State is required to fund one half the cost of educating these students. This amount is calculated from MRC approved budget submissions and is paid directly to the LRSD on behalf of all students enrolled in those schools. The approved amount for the 1999-2000 school year is approximately ($10.1 M). The amount paid on behalf of each districts students is\n100LRSD ($6.3 M), LRSD ($1.29 M), and PCSSD ($2.47 M). Magnet \u0026amp; M-to-IVI Transportation: The three districts in Pulaski County are currently paid one hundred percent of the costs of providing transportation for all Magnet and M-to-M students, including some expenses for getting these students to after school activities and events. The estimated costs for 1999-2000 is: LRSD ($3.41 M), NLRSD ($.57 M), and PCSSD ($1.94 M). If this funding source were eliminated there would be no resulting increase in Transportation Aid to the districts from regular State sources. The basic assumption would likely be that all of these cost would also end. Teacher Retirement \u0026amp; Health Insurance: During 1999-2000 the school districts in Pulaski County are projected to receive approximately ($10.28 M) to offset teacher retirement and health insurance costs. This number is somewhat stable but is effected by a number of factors and could change significantly from year to year. Under the present payment calculation any increase in the required contribution rate, (currently $114. per employee, per month and set by the State Board of Education) would result in a corresponding increase in funding to the Pulaski County Districts. The funding breakout by district is currently: LRSD ($6.17 M), NLRSD ($1.02 M), and PCSSD ($3.08 M). The cessation of these payments would result in a negative bottom line of the amounts received. No offsetting funds would exist and no method for significantly decreasing cost is available. Workers Compensation: During 1999-2000 the school districts in Pulaski County will receive ($.19 M) to offset costs for providing Workers Compensation coverage to district employees. These payment amounts by district are currently\nLRSD ($.06 M), NLRSD ($.04 M), and PCSSD ($.09 M). Summary: If all special funding for desegregation programs and services were discontinued the ($39.5 M) estimated aid to the three Pulaski County School Districts from desegregation related funding sources would be offset by M-to-M students again being counted for regular State Equalization Aid. When that calculation is made the total aid loss would be approximately ($31 M) and by district would be: LRSD ($15.13M ), NLRSD ($4.21 M), and . PCSSD ($11.66 M). The actual total aid loss to the LRSD budget would be increased by the amount paid directly to the District on behalf of students from the other districts attending Stipulated Magnet Schools. The additional amount would be approximately $3.76 M but there would also be a decrease in the districts costs since the magnet students attending LRSD schools would by necessity either be reassigned to their home district or some other funding mechanism would need to be put in place. The total aid package is obviously a significant amount of funds and the abrupt loss of these funding sources would necessitate drastic changes in the way all the districts operate. A transition of several years may be necessary in order for the districts to work through the various changes that would be required. 101STEWART, DONALD M. From: Sent: To: Subject: BABBS, JUNIOUS Thursday, April 19, 2001 9:19 AM STEWART, DONALD M. FW: LRSD Biracial Committee Request Thanks for agreeing to give him a call. You will find his number listed in an earlier mailing attached. Will stay in touch. Junious C. Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District Original Message From: Sent: To: Subject: EGGLESTON, DEANA Wednesday, April 18, 2001 1:51 PM BABBS, JUNIOUS FW: LRSD Biracial Committee Request FYI Original Message----- From: Sent: To: Subject: STEWART, DONALD M. Wednesday, April 18, 2001 2:01 PM EGGLESTON, DEANA RE: LRSD Biracial Committee Request The reason we do not have an estimated completion date on Romine is that we have just started the preliminary design work on that project and until we know exactly what we are going to do we cant guess when it will be complete. I dont know who needs to talk to this person but if Junious want it to be me, let me know. -----Original Message----- From: EGGLESTON, DEANA Sent: Wednesday, April 18, 2001 10:06 AM To: STEWART, DONALD M.\nGADBERRY, BRADY L. Cc: BABBS, JUNIOUS Subject: LRSD Biracial Committee Request We held the April meeting of the LRSD Biracial Committee last night. Delaney Fleming (Joshua's representative) was questioning why the Romine project had no start! est. completion date on the handout that Don provided. FYI - Delaney has questioned the district's committment to Romine and the \"poor conditions\" of the Romine bldg, many times. Mr. Babbs said that he would check into the projected start dates and have one of you telephone Mr. Fleming. His # is 224-0630. Mr. Fleming's address is 9505 Cerelle, Little Rock, AR 72205 (in Romine's zone). Babbs is out today, however, he wanted me to pass this info along to you. Deana Deana M. Eggleston Student Registration Office (501) 324-2408 dmeggle@stuasn.lrsd.l\u0026lt;12.ar.us 37STEWART, DONALD M. From: Sent: To: Cc: Subject:  T LEASE, KATHY R. Wednesday, April 25, 2001 2:32 PM MILHOLLEN, MARK STEWART, DONALD M. Leave Accountability Report :^5 A\"*- .c \u0026gt;n- Importance: High Mark, I just received the June to March Leave Accountability Report. The names of all those people that we discussed earlier are still on the report. One of my concerns is that they do not have access to their leave information because it was all sent to my department. Another concern is that, again, it looks like there are more people in PRE that there really are. Interestingly enough, Regina Moore got changed to PRE since she is now Karen Broadnax' secretary. The following list of folks do not work in PRE\nMona Briggs, Karen Broadnax, Virginia Johnson, Shirley Lewis Eddie McCoy, Regina Moore, Rosalyn Summerville. The people who do work for me are the following: Eula Yvette Dillingham, Irma Truett, Charlotte Marks, Malinda Allen, Paulette Denson, and Ed Williams. Thanks for your help in straightening this out. It concerns me that the PRE staff list has not been accurate the whole time I've been here. I'm afraid that it presents a distorted picture of staffing for this department. If there is anything that you need me to do, please let me know. Thanks, Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease(a!irc.lrsd.k12.ar.usSent\nTo: WELCH, JANE Cc\nLESLEY, BONNIE Tuesday, May 22, 2001 1:01 PM Subject: RE: Plato Communication grade I did not know that Central was offering a PLATO Communications course. I am going to research my email from last year. Seemingly there was a question about it then either at Central or Hall. Original Message From\nSent: To: Cc: Subject: WELCH, JANE Tuesday, May 22, 2001 12:15 PM LESLEY, BONNIE GREEN, CAROL Plato Communication grade I have been given a grade in the Plato Lab for Larts-/communication. We do not have a number assigned for communication. How do I key this grade without an identifying number? Jane Welch, Registrar-Central High school LESLEY, BONNIE From: Sent: To: Cc\nSubject: LESLEY, BONNIE Friday, May 25, 2001 4:14 PM BERRY, DEBORAH\nBLAYLOCK, ANN\nFULLERTON, JAMES\nHUDSON, ELOUISE\nLarry Buck\nMARIAN LACEY\nMOSBY, JIMMY\nPATTERSON, DAVID\nROUSSEAU, NANCY\nSAIN, LLOYD DAVIS, SUZI\nAUSTIN, LINDA Middle School Evaluation I understand that you all got \"assigned\" the middle school program evaluation yesterday. Probably most of the stuff you need is in the Compliance Report or the Interim Report. I am attaching both for your information. They are long, so you may want to look at what you need before you print them. I am not at all sure that you need to spend much time on that assignment. Let me check with the superintendent before you do a lot. I know you have many other things on your plate right now. Q 1A Final Compliance Report-001... Compliance Report, Feb. 2OOO.d... Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 358 STEWART, DONALD M. From: Sent: To: Subject: LESLEY, BONNIE Wednesday, June 07, 2000 11:31 AM CARNINE, LESLIE V.\nANDERSON, VICTOR\nBABBS, JUNIOUS\nMITCHELL, SADIE\nSTEWART, DONALD M.\nGADBERRY, BRADY L. FW\nAP  fyi Original Message From: Sent: To: Subject: Clay Fendley [SMTP:FENDLEY@fec.net1 Wednesday. June 07. 2000 11:13 AM BALESLE@IRC.LRSD.KI 2.AR.US AP I have received and reviewed you memo on AP enrollment. It looks great! As you know, there will be concern that we are simply lowering the standards so more kids can get into the courses. To counter this perception, it would be nice to show an increased number and/or percentage of students passing the AP exam. For this reason, I would support either requiring them to take the exam or offering some incentive for doing so. I think it's as important as a motivator for the teachers as the students because it provides an objective measure of their performance. With that said, I think Walker would object to withholding weighted grade points from students who do not take the exam. That makes the exam a de facto requirement. I would also be concerned in that this provides no incentive to actually pass the exam. Now that we have the kids in the pipeline, I think you may want to consider another run at requiring the exam. I think the weighted grade points should be the reward for passing the exam. Good work and good luck! Clay Fendley Friday, Eldredge \u0026amp; Clark 400 W. Capitol, Suite 2000 Little Rock, AR 72201 E-mail: fendlev@fec.net Direct Phone: 501-370-3323 Direct Fax: 501-244-5341LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Thursday, June 07, 2001 2:17 PM 'groussea@pcssd1.k12.ar.us' Middle Schools Hello, Gloria. I was so pleased to see that the judge is going to allow you all to move forward with your middle school plan. Congratulations! Remember that we'll be willing to share our stuff with you if you need us. Again, my best wishes to you. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: Sent: To: Subject: LESLEY, BONNIE Thursday, June 07, 2001 2\n04 PM PAAL, MARY M. Hello I am soooo joyful that you are back among us. We missed you so very much. I forgot to give you an undate on the 010 controversy. We are NOT going to provide transportation to that program-and I am in full agreement with that decision. However, I did suggest to the Cabinet that we review the contracts with those churches, renegotiate the lease costs for space, look for space close to (with easy walking distance of each of the middle schools), and try to find resources to have a CIC near EACH middle school. Junious said he'd talk to Jo Evelyn about that, but probably either you and/or Mona needs to follow up with him to make sure that we have a serious conversation about making the ClC's more accessible. Also, we did NOT change the minimum suspension to 5 days, as Jo E. requested. It remains at 3. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) 136STEWART, DONALD M. From: Sent: To: Subject: LESLEY, BONNIE Wednesday, April 18, 2001 12:54 PM STEWART, DONALD M. RE: There is NO justification that is legit for keeping Lionel in that position. We need to limit that office strictly to the compliance/grant management activities--not programming in any shape or form. Original Message From: Sent: To: Cc: Subject: STEWART, DONALD M. Wednesday, April 18, 2001 10:54 AM MITCHELL, SADIE LESLEY, BONNIE\nGADBERRY, BRADY L.\nBABBS, JUNIOUS\nMILHOLLEN, MARK RE: If that is your ultimate intention, I would say yes. We need all the cards on the table as soon as possible so that better decisions can be made about who goes where and when. I know that Leon is going to make a pitch to keep the position that Lionel is currently holding. Original Message- From: Sent: To: Cc: Subject: MITCHELL, SADIE Tuesday, April 17, 2001 6:03 PM STEWART, DONALD M. MILHOLLEN, MARK\nGADBERRY, BRADY L. Should I go ahead and request an additional Assistant Superintendent and or Middle School Director at this time? Sadie Mitchell smmitch@lrsdadm.lrsd.k12.ar.usSTEWART, DONALD M. From: Sent: To: Subject: JAMES, KENNETH Thursday, July 12, 2001 2:00 PM STEWART, DONALD M. RE: Title I \u0026amp; Title VI Budgets Don: Thanks for the info and your follow-up on this. As you know, this is the only way that we can get the system where it needs to be. Ken Original Message- From: Sent: To: Cc: Subject: STEWART, DONALD M. Thursday, July 12, 2001 1:31 PM LESLEY, BONNIE MITCHELL, SADIE\nMILHOLLEN, MARK\nJAMES, KENNETH Title I \u0026amp; Title VI Budgets I met with Mr. Adams this morning regarding preparation and submission of both the Title I and Title VI budgets, including the Class size reduction funds. We also discussed the compliance visits and reports for both of these programs. We have a compliance report from ina i iti? \\/i vi.\nit and ^4r Ariamg rinpsnt pypprt that wn will have tn pay back any funds. There were some pr^lems and I ask Mr. Adams to work with Bonnie and other involved staff to resolve those issues. There an le orohlem.q on the Title I compliance report hut 'a\u0026gt;o ha''e-*^?t yet th? final rppnrt Mr Adams is workiiigwith ADE to try and resolve as many of those issues as possible before they finalize the report. Mark is working on getting all of the 2000-2001 expenditure information together which must be done before the final budget can be assembled. I also requested that Mr. Adams share current Title I budget information with Bonnie, both plan and financial information. He assured me that he would do this ASAP. There are still five or so schools who have not completed this information but those can be shared when they are available. I also requested that Mr. Adams talk with Sadie on the issue of how we are to report School Improvement Plan and Title I budget information to the ADE. He agreed to do that also. I know all of this is just adding to everyones already hectic schedule but if we can learn to work as a team on all of this it really will work better for all of us. Please let me know if I can do anything to help any of you. 240STEWART, DONALD M. From: Sent: To: Subject: STEWART, DONALD M. Wednesday, February 28, 2001 5:05 PM LESLEY, BONNIE mou-2-28-01 .doc Bonnie, Dr. Carnine just e mailed me his comments on his discussion with Ray Simon yesterday. His goal is for you and I to sit down with ADE folks tomorrow or Friday and try to iron out an agreement on the loan payback. I have called Ray and he is trying to set the time after he talks to Charity tomorrow. I will let you know the minute he calls me. We are also talking about some other means of ending this ordeal. Maybe just an agreement that we will pay back part of the loan and they will forgive the rest. He started with half and I said NO, actually hell no. Chris agrees. I also ran into Judy Magness and bounced that idea off of her, she also agrees. Ray indicated that he would not shut the door to something less but would not make a commitment. I suspect he needs advice from above and I recognize that with the POLS and other school people across the State he cant agree to just forgive it all. We will see if that can go anywhere but in the meantime we need to try and work out an acceptable agreement if that approach falls through. I know Dr. C requested that we all return the copy of the Draft agreement so if you didnt keep a copy and need one I have it in my email files. Let me know. Im going home now so will talk with you tomorrow.  mou-2-28-01_.doc STEWART, DONALD M. From: Sent: To: Subject: STEWART, DONALD M. Thursday, November 30, 2000 11\n46 AM LESLEY, BONNIE RE: Millage Bonnie you didnt ask and I didnt answer but of course there was another 13 to 15 million for technology in the bond issue part of the millage increase. Original Message From: LESLEY, BONNIE Sent: To: Wednesday, November 29, 2000 5:12 PM STEWART, DONALD M. Subject: Millage We need to tell NSF the following: How m\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_339","title":"Compliance plan","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":null,"dc_date":["2002/2004"],"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 integration"],"dcterms_title":["Compliance plan"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/339"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["documents (object genre)"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"\n \n\n\n\n\n\n\n\n  \n\n\n   \n\n   \n\n\n   \n\n\n   \n\n\n\n\n   \n\n\n\n\n   \n\n\n\n\n\n\n\n\n   \n\n   \n\n \n\n\n   \n\n   \n\n  \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n \n\n\n   \n\n  \n\n  \n\nMr. John W. Walker October 4, 2002 Page 2 We respectfully request that any obj ections you may have to the compliance plan be provided in wnting to Ken James before the October 10,2002, Board meeting, so we will have an opportunity to resolve any disagreements before the Board meeting. Thank you for your time and attention to this matter. Please do not hesitate to call if you have any questions. Sincerely, ohn C. Fendley, Jr. / John JCF/bgb enclosure(s) cc: Dr. Ken James (w/enclosures) F:\\H0ME\\BBrowD\\Feodley\\LK5]\u0026gt;desegkouiMel b.wpd1 Friday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY (1922-1994) WILLIAM H. SUTTON. P.A. BYRON M. BISEMAN. 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. JAMBS 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. 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 III, P.A. MICHAELS. 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. 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 F. JONES, P.A. DAVID D. WILSON. P.A. JEFFREY H. MOORE. P.A. DAVID M. GRAF, P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayflrm.cofn 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 479-685-2011 FAX 478-695-2147 CARLA GUNNELS SPAINHOUR, P.A. JOHN C. FENDLEY, JR., P.A. JONANN ELIZABETH CONIGLIO. P.A. 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 6. 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 LINDSEY MITCHAM SLOAN KHAYYAM M. EDDINGS JOHN F. PEISERICH AMANDA CAPPS ROSE BRANDON J. HARRISON RECEIVED OCT - 4 2002 office OF desegregation monitoring 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2696 FAX 870-762-2918 October 4,2002 OF COUNSEL B.S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON. JR. H.T. LARZELERE. P.A. JOHNC. ECHOLS. P.A. A.D. MCALUSTBR JOHN C. FENDLEY, JR. LITTLE ROCK TEL 501-370-3323 PAX 501-244-5341 fndlyOfc.nt ( By Hand Delivery ) Mr. John W. Walker Mr. Sam Jones Mr. Steve Jones John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 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 Mr. Richard Roachell Roachell Law Firm ( By Hand Delivery ) Ms. Ann Marshall 11800 Pleasant Ridge Road, #146 Desegregation Monitor 1 Union National Plaza Ms. Sammye Taylor Office of the Attorney General 323 Center Street P.O. Box 17388 Little Rock, Arkansas 72222 124 W. Capitol, Suite 1895 Little Rock, Arkansas 72201 200 Tower Building Little Rock, Arkansas 72201 RE: Compliance Remedy Dear Counsel \u0026amp; Ms. Marshall: Enclosed please find the Little Rock School Districts proposed Compliance Plan for implementing the courts Compliance Remedy set forth in the District Courts September 13,2002, Memorandum Opinion. Included in the Compliance Plan is a timeline for implementation. It contemplates submitting the Compliance Plan to the Board for approval at the October 10, 2002, agenda meeting. All parties are invited to attend the meeting and will be provided an opportunity to address the board. F:\\HOME\\BBrown\\FcDdley\\LRSD\\deseg\\couQsel LwpdLittle Rock School District Compliance Committee I Proposed Compliance Plan Revised Plan  2.7.1 RECEIVED OCT - 4 2002 OFFICE OF DESEGREGATION MONITORINGThe District Courts Compliance Remedy On September 13,2002, the District Court issued its Memorandum Opinion (hereinafter Opinion) finding that the Little Rock School District (LRSD) had substantially complied with all areas of the Revised Desegregation and Education Plan (Revised Plan), with the exception Revised Plan  2.7.1, Section 2.7.1 provided: LRSD shall assess the academic programs implemented pursuant to Section 2.7' after each year in order to determine the effectiveness of the academic programs in improving African-American achievement. If this assessment reveals that program has not and likely will not improve Afiican-American achievement, LRSD shall take appropriate action in the form of either modifying how the program is implemented or replacing the program a The District Courts Opinion set forth a detailed Compliance Remedy to be implemented by the LRSD. The Opinion first stated: Because LRSD failed to substantially comply with the crucially important obligations contained in 2.7.1, it must remain under court supervision with regard to that section of the Revised Plan until it\n(a) demonstrates that a program assessment procedure is in place that can accurately measure the effectiveness of each program implemented under 2.7 in improving the academic achievement of Afincan-American students\nand (b) prepares the program evaluations identified on page 148 of the Final Compliance Report and uses those evaluations as part of the program assessment procedure contemplated by  2.7.1 of the Revised Plan. The Opinion then outlined the details of the Compliance Remedy as follows\nA. For the entire 2002-03 school year and the first semester of the 2003-04 school year, through December 31,2003, LRSD must continue to assess each of the programs implemented under  2.7 to improve the academic achievement of African-American students. LRSD now has over three years of testing data and other information available to use in gauging the effectiveness of those programs. I expect LRSD to use all of that available data and information in assessing the effectiveness of those programs and in deciding whether any of those programs should be modified or eliminated. 'Revised Plan  2.7 provided, LRSD shall implement programs, policies and/or procedures designed to improve and remediate the academic achievement of Afiican-American students, including but not limited to Section 5 of this Revised Plan. 1B. C. F. LRSD must maintain written records regarding its assessment of each of those programs. These written records must reflect the following information: (a) the written criteria used to assess each program during the 2002-03 school year and the first semester of the 2003-04 school year\n(b) the results of the annual assessments of each program, including whether the assessments resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved -with the assessment of each program, as well as at least a grade level description of any teachers who were involved in the assessment process {e.g., all fourth grade math teachers\nall eighth grade English teachers, etc.). LRSD must use Dr. Nunnerl/ or another expert from outside LRSD with equivalent qualifications and expertise to prepare program evaluations on each of the programs identified on page 148 of the Final Compliance Report. I will accept all program evaluations that have already been completed by Dr. Nunnerly or someone with similar qualifications and approved by the Board. All program evaluations that have not yet been completed on the remaining programs identified on page 148 of the Final Compliance Report must be prepared and approved by the Board as soon as practicable, but, in no event, later than March 15, 2003. In addition, as these program evaluations are prepared, LRSD shall use them, as part of the program assessment process, to determine the effectiveness of those programs in improving African-American achievement and whether, based on the evaluations, any changes or modifications should be made in those programs. In addition, LRSD must use those program evaluations, to the extent they may be relevant, in assessing the effectiveness of other related programs.  * * On or before March 15,2004, LRSD must file a Compliance Report which documents its compliance with its obligations under  2.7.1. Any party, including Joshua, who wishes to challenge LRSDs substantial compliance with  2.7.1, as specified above, may file objections with the court on or before April 15,2004. Thereafter, I will decide whether the LRSD has substantially comphed with  2.7.1, as specified in the Compliance Remedy, and should be released from all further supervision and monitoring. ^The Court is clearly referring to Dr. John Nunnery. 2Proposed Compliance Plan As the Compliance Committee understands the District Courts Opinion, the Compliance Remedy requires the LRSD to: 1. 2. 3. 4. 5. Continue to administer student assessments through the first semester of2003-04\nDevelop written procedures for evaluating the programs implemented pursuant to Revised Plan  2.7 to determine their effectiveness in improving the academic achievement of Afiican-American students\nMaintain written records of (a) the criteria used to evaluate each program\n(b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elirmnation of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved m the evaluation process\nPrepare a comprehensive program evaluation of each academic program implemented pursuant to Revised Plan  2.7 to determine its effectiveness in improving the academic achievement of African-American students and to decide whether to modify or replace the program\nand Submit for Board approval the program evaluations identified on page 148 of the LRSDs Final Compliance Report that have been completed, and complete, with the assistance of an outside expert, the remaining evaluations identified on page 148 of the LRSDs Final Compliance Report. What follows is an explanation of how the Compliance Committee derived these five requirements from the District Courts Opinion, and what the Compliance Committee proposes to do to comply with each requirement. Assessment and Evaluation When first read, the District Courts Compliance Remedy seemed simple and straightforward, but as the Compliance Committee attempted to develop this Proposed Compliance Plan, numerous questions arose. The most fundamental question related to the District Courts use of the term assessment in Paragraphs A and B of the Compliance Remedy. The ambiguity of this term was the subject of testimony at the hearing. The District Court included in its Opinion Dr. Lesleys testimony on the difference between assessment and evaluation, see Opinion, p. 152, but it is unclear whether the Court accepted this testimony. 3It is clear that the District Court understood the distinction between testing data, which are derived from student assessments, and program evaluations, which are used to determine the effectiveness of programs. See Opinion, p, 152 (LRSD acknowledged in the Interim Comphance Report that it was required: (a) to use both the testing data and the program evaluations to detemune the effectiveness of the key academic programs implemented pursuant to  2,7 ,,, (emphasis in original)). Even so, the District Court appears to have used the term assessment in some instances to refer to only student assessments and in other instances to refer to both student assessments and evaluations. This required the Compliance Committee to determine the District Courts intended meaning. In making this determination, the Compliance Committee considered the context in which the term was used, the District Courts findings of fact as set forth in the Opinion, what would be in the best interest of African-American students, and hopefully, common sense. An explanation of each requirement of the Compliance Remedy is provided below. To avoid any ambiguity, Compliance Committee hereinafter uses the term assessment to refer to student assessments and the term evaluation to refer to the program evaluations, whether formal or informal. 1. Continue to administer student assessments through the first semester of 2003-04. This requirement derives from Paragraph A of the Compliance Remedy, Given Paragraph As reference to testing data, it seems clear that Paragraph A concerns, in part, student assessments. The Compliance Committee proposes to comply with this part of Paragraph A by implementing the 2002-03 Board-approved assessment plan. The 2002-03 Board-approved assessment plan incorporates four changes that have been made since the LRSDs Final Compliance Report, First, the Board eliminated the fall administrations of the Achievement Level Tests (ALTs) in 2001-02, The administration recommended this for three reasons: (1) the loss of instructional tune resulting from testing and test preparation\n(2) fall results did not provide sigmficantly different information from the previous springs results\nand (3) the cost of administering and scoring the tests. Second, the fall admimstration of the Observation Surveys and Developmental Reading Assessment will only be used by the teacher for diagnostic purposes. The scores will not be reported to or maintained by the LRSD, This change saves considerable time in test administration and allows more time for instruction. It was approved by the Board on September 26,2002, Third, the LRSD will no longer administer the ALTs. The administration recommended the complete elimination of the ALTs for the following reasons: (1) the lack of alignment with the content and format of the State Benchmarks\n(2) the loss of instructional time resulting from 4testing and test admimstration\n(3) the new federal accountability requirements in the No Child Left Behind Act require annual testing by the State in grades 3-8, making the LRSDs administration of the ALTs redundant\nand (4) the costs of administering and scoring the tests. The Board approved this change on September 26,2002. Finally, the Arkansas Department of Education (ADE) has moved the administration of the SAT9 from the fall to the spring, effective 2002-03. The 2002-03 Board-approved assessment plan calls for the administration of the following student assessments in English language arts and mathematics: Kindergarten Grade 1 Grade 2 Grade 4 Grade 5 Grade 6 Grade 7 Grade 8 Grades 7-10 Grades 9-11 Grade 10 Grade 11 Observation Surveys (5) Developmental Reading Assessment Observation Surveys (5) Development Reading Assessment Observation Surveys (3) Development Reading Assessment Norm-referenced test to be identified for gifted/talented screening Benchmark Literacy examination Benchmark Mathematics examination SAT9 Total Batteiy Benchmark Literacy examination Benchmark Mathematics examination SAT9 Total Battery Benchmark Literacy examination Benchmark Mathematics examination End-of Course Algebra I examination End-of Course Geometry examination SAT9 Total Battery End-of-Level Literacy examination All of these assessments are admimstered in the spring. Consequently, the final student assessment before March 15, 2004, will be administered in the spring of 2003. 2. Develop written procedures for evaluating the programs implemented pursuant to  2.7 to determine their effectiveness in improving the academic achievement of African-American students. This requirement derives from the opening paragraph of the Compliance Remedy. To comply with this requirement, two proposed regulations have been drafted, IL-Rl for formal evaluations and IL-R2 for informal evaluations, attached as Appendixes 1 and 2, respectively. 5as Proposed regulation IL-Rl combines generally accepted principles of program evaluation with practices that have been in place in the LRSD for the past two years. See, e.g,, Robby Champion, Map Out Evaluation Goals, Journal for Staff Development, Fall 2002, attached _ Appendix 3. This regulation will be subimtted to the Board, Office of Desegregation Monitoring ( ODM) and the Joshua Intervenors (Joshua) for review and comment before being finalized Proposed regulation IL-R2 specifically addresses the next requirement and is discussed therewith. 3. Maintain written records of (a) the criteria used to evaluate each program\n(b) the results of the annual student assessments, including whether an informal program evaluation resulted in program modifications or the elimination of any programs\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process. This requirement derives from Paragraph B of the Compliance Remedy. Paragraph B apparently came about as a result of the District Courts concern about the LRSD making program modifications based on informal evaluations of student assessment data. See Opinion, p. 155 ( I have grave reservations about anyone this side of Solomon being wise enough to use two or three semesters worth of erratic composite test scores to make reliable decisions about which remediation programs for LRSDs African-American students were actually working.). Proposed regulations IL-R2 was drafted to specifically address this requirement. It prohibits substantial program modifications from being made without a written record as required by Paragraph B. This regulation will also be submitted to ODM and Joshua for review and comment before being finalized. Proposed regulation IL-Rl also complies with this requirement. It mandates that the criteria used to formally evaluate a program be identified as the research questions to be answered, the first of which will be, Has this cuiriculum/instruction program been effective in improving and remediating the academic achievement of African-American students?. S^ Appendix 1, IL-Rl, p. 5. Recommended program modifications and the members of the evaluation team are routinely included in formal evaluations. As to the results of annual student assessments, the LRSD will continue to maintain a computer database with the results of annual students assessments administered pursuant to the Board-approved assessment plan. 64. Prepare a comprehensive program evaluation of each academic program implemented pursuant to  2.7 to determine its effectiveness in improving the academic achievement of African-American students and to decide whether to modify replace the program. or This requirement derives from Paragraph A of the Compliance Remedy. To comply with this requirement, the Compliance Committee proposes to prepare the following new, comprehensive evaluations: (a) Primary ReadingLanguage Arts, (b) Middle and High School Literacy and (c) K-12 Mathematics and Science. Each evaluation will be prepared in accordance with proposed Regulation IL-Rl and will incorporate all available student assessment data relevant to the program being evaluated. Based on Paragraph F of the Compliance Remedy, the LRSD understands these evaluations must be submitted to the Court on or before March 15 2004. Some may argue that Paragraph A and Paragraph C together require the LRSD to prepare new, comprehensive evaluations of all the programs identified on page 148 of the LRSDs Final Compliance Report. The Compliance Committee considered and rejected this argument for three reasons. First, Paragraph As description of the programs to be evaluated differs from that of Paragraph C. Paragraph A states that the LRSD must continue to assess each of the programs implemented under  2.7 . .. The Compliance Committee understands this to mean that the LRSD should continue to prepare evaluations of some of the key programs, as identified in the Interim Compliance Report. See Opinion, p. 151 (In addition to the Assessment Plan,  2.7.1 of the Interim Compliance Report noted that the LRSD was preparing ^\"evaluations\" of some of the key programs designed to improve Afifrcan-American achievement in order to provide a more in-depth look at the effectiveness of those programs. (emphasis in original)) In contrast to Paragraph A, Paragraph C requires the LRSD to prepare evaluations of each of the programs identified on page 148 of the Final Compliance Report. The Compliance Committee understands this to mean that the LRSD should complete all of the evaluations identified on page 148 of the Final Compliance Report and submit those to the Court. See Opinion, p. 156 ( [A]s of March 15,2001, the date the Final Compliance Report was filed with the Court: (1) PRE had prepared only draft evaluations of some of the programs in question\n(2) none of those evaluations had been approved by the Board .... (emphasis in original)). The District Courts statement in Paragraph C that it will accept evaluations already completed and approved by the Board further indicates that Paragraph C does not require new, comprehensive evaluations. Second, recognizing this distinction between Paragraph A and Paragraph C resolves a potential conflict between Paragraph C and Paragraph F. Paragraph C provides, All program evaluations that have not yet been completed on the remaining programs identified on page 148 7of the Final Compliance Report must be prepared and approved by the Board as soon as practicable, but, in no event, later than March 15,2003. However, Paragraph F does not require the LRSD to file a compliance report on its compliance with Revised Plan  2.7.1 until March 15,2004. The Compliance Committee concludes that March 15,2004, is the deadline for submitting the new, comprehensive evaluations of the programs implemented pursuant to  2.7. S^ Paragraph A of Comphance Remedy. This is consistent with Paragraph As requirement that the LRSD include assessment data through December 31,2003. Obviously, such data could not be included in an evaluation filed on or before March 15,2003. Finally, it makes the most sense for the LRSD to expend the greatest tune and resources preparing evaluations of the programs designed to improve Afiican-American achievement. While the requirement for new, comprehensive evaluations derives from Paragraph A, some may argue that Paragraph Cs requirement that the LRSD use an outside expert to prepare evaluations of each of the programs identified on page 148 of the Final Compliance Report applies to the new, comprehensive evaluations. The Compliance Committee hopes the District Court and the parties agree that the team approach to program evaluation set forth in proposed regulation IL-Rl renders this argument moot. Proposed Regulation IL-Rl states that the program evaluation team must include [a]n external consultant with expertise in program evaluation, the program area being evaluated, statistical analysis, and/or technical writing .. . . Appendix 1, p. 4. The exact role of the  external consultant may vary, depending upon the expertise required for the production of the program evaluation. Id. The Compliance Committee believes that the LRSDs practice over the last two years of using the team approach to program evaluation has produced credible evaluations. Moreover, participation of the LRSD staff on the evaluation team provides them an excellent learning experience that they do not typically receive when an evaluation is prepared entirely by an outside expert. The evaluations prepared over the last two years using the team approach are as follows: 1. 2. Dr. Steve Ross was the external consultant in the production of the Early Literacy program evaluation for 1999-2000 and 2000-01. He was asked to read a nearfinal draft and to provide feedback, which he did. His suggestions were then incorporated into the final report before it was published and disseminated. Other team members included Bonme Lesley (associate superintendent), Patricia Price (program director), Pat Busbea (program specialist), Ed Williams (statistician), and Ken Savage (computer programmer). Dr. Julio Lopez-Ferraro is the National Science Foundation (NSF) program officer who over-sees the LRSDs implementation of the grant-funded 8Comprehensive Partnership for Mathematics and Science Achievement ( CPMSA ). NSF trained a team of LRSD staff to produce the mandated annual program evaluations for this initiative and then assembled an external team of practitioners and researchers who came to the LRSD each year to validate findings and provide written feedback. The LRSD team members who our participated in writing of the annual progress reports included Vanessa Cleaver (project director), Dennis Glasgow (director of mathematics and science), Bonnie Lesley (associate superintendent and co-project investigator), Virginia Johnson (CPMSA program evaluator), Ed Williams (statistician), and Ken Savage (computer programmer). 3. 4. Mr. Mark Vasquez, an attorney and former employee of the Office for Civil Rights in Dallas, has been retained by the LRSD for the past three years to provide guidance in the design and production of the English as a Second Language (ESL) program evaluation. Other team members have been Bonnie Lesley (associate superintendent), Karen Broadnax (program supervisor), Ed Williams (statistician), Ken Savage (computer programmer), and Eddie McCoy (program evaluator). Dr. Larry McNeal, a professor at the University of Arkansas at Little Rock in education administration and a private consultant in program evaluation, was retained by the LRSD to lead the team that produced the program evaluation for the Charter School. Other members of that team included Linda Watson (assistant superintendent), Krista Young (program director), and Ed Williams (statistician). Dr. McNeal wrote this report. The team approach, supported by an external expert, ensures that all areas of expertise (program, implementation, techmeal and evaluative) are included. No one person would have all the knowledge and skills that a team would have. As these examples show, the external expert does not always perform the same role in every project. Rather, the role changes, depending the expertise that is required for a credible report. on 5. Submit for Board approval the program evaluations identified on page 148 of the LRSDs Final Compliance Report that have been completed, and complete, with the assistance of an outside expert, the remaining program evaluations identified on page 148 of the LRSDs Final Compliance Report. The follovnng program evaluations identified Report have been completed: on page 148 of the Final Compliance 1. Early Literacy. A comprehensive report for 1999-2000 and 2000-01 was prepared, completed, and presented to the Board in fall 2001. An update to this report for 2001-02 was presented to the Board in June 2002, with an emphasis on 9the improved achievement of African-American students and closing the achievement gap. 2. 3. 4. 6. 7. 8. 9. 10. Mathematics and Science. Three years (1998-99,1999-2000, and 2000-01) of program evaluations as required by the NSF were prepared, presented to the Board, and submitted to NSF, and NSF has responded to each evaluation. Extended Year Schools. The LRSD staff prepared, completed, and presented to the Board in the spring of2002 an evaluation of the Extended Year Schools. Elementary Summer School. The LRSD staff prepared, completed, and provided to the School Services Division an evaluation of elementary summer school programs for 2000-01. 5  HIPPY. The HIPPY program was evaluated by the LRSD staff in July 1999. The , report was prepared, completed, and submitted to the program director and the Cabinet. Charter School. This program evaluation was prepared, completed, and presented to the Board in June 2001. ESL. The Office for Civil Rights has required the LRSD to prepare a program evaluation in this area for each of the past three years\n1999-2000, 2000-01, and 2001-02. The first two of these reports have been prepared, completed, submitted to the Board, and submitted to OCR. (A third program evaluation will be completed in October when state scores arrive and will be ready by the March 15, 2003 deadline). Lyceum Scholars Program. Two separate evaluations of this alternative education school program were prepared by the LRSD staff. Southwest Middle Schools SEDL Program. Southwest Middle School was the recipient of a two-year technical assistance grant from the Southwest Educational Development Lab (SEDL) to build professional community. SEDL prepared a comprehensive program evaluation that included Southwest among other grant recipients outside the LRSD. The LRSD staff provided SEDL data for this evaluation. Onward to Excellence (Watson Elementary). A grant from ADE funded a partnership between Watson Elementary and the Northwest Educational Development Lab to implement a school improvement initiative. The LRSD staff provided data to Watsons principal for preparation of program evaluations. The principal submitted two annual program evaluations to ADE. 1011. 12. Collaborative Action Team (\"CAT). This one-year partnership with SEDL provided in 2000-01 for establishing and training a Collaborative Action Team of parent and community volunteers supported by LRSD staff to improve parent involvement. SEDL wrote a 249-page evaluation of their three-year grant-funded program, of which LRSD was included only the last year. The LRSD staff provided SEDL data for this evaluation. Vital Link. The LRSD staff prepared a program evaluation, and it was provided to the project director. A question arises as to which of these evaluations are acceptable to the Court without additional work. The first sentence of Paragraph C of the Compliance Remedy provides, LRSD must use Dr. Nunnerly (sic) or another expert from outside LRSD with equivalent qualifications and expertise to prepare program evaluations of each of the programs identified on page 148 of \u0026amp;e Final Compliance Report. The second sentence of Paragraph C states that the District Court will accept all program evaluations that have already been completed by Dr. Nunnerly (sic) or someone with similar qualifications. It is unclear whether an expert from outside the LRSD' must have prepared the completed evaluations for them to be accepted by the District Court, whether it is sufficient that they were prepared by someone within LRSD with similar qualifications. I l or The District Courts findings of fact suggest that the District Court will accept only program evaluations already completed by an outside expert. The District Court noted that Dr. Lesley testified that, by the end of November 2000, it was her opinion that no one in PRE had the expertise to prepare program evaluations. Opinion, p. 153. Thus, the District Court likely concluded that the only acceptable program evaluations would be those prepared by persons outside the LRSD. Applying this standard, the Compliance Committee believes that the following evaluations are acceptable to the Court, following Board approval, without additional work: Early Literacy, Mathematics and Science, Charter School, ESL, Southwest Middle Schools SEDL Program and CAT. The remaining program evaluations identified on the bottom of page 148 of the Final Compliance Report must be completed by an outside expert. They are: Extended Year Schools, Middle School Implementation, Elementary Summer School, HIPPY, Campus Leadership Teams (CLTs), Lyceum Scholars Program, Onward to Excellence and Vital Link. The Compliance Committees proposal for completing each of these evaluations will be discussed below. In deciding how to go about completing these evaluations, the Compliance Committee focused on what makes sense to do at this time considering the goal of improving African-American achievement and the limitations inherent in asking an expert to complete an evaluation. 11Extended Year Schools. This evaluation was completed by the LRSD staff. The Comphance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Middle School Implementation. A draft of this evaluation was presented to the Board in July and August 2000, but it was never completed. The Comphance Committee proposes retaining an outside expert to rewrite the report and, if possible, prepare an evaluation based on the existing data. Elementary Summer School. This evaluation was completed by the LRSD staff. The Comphance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing Hata HIPPY. This evaluation was completed by the LRSD staff. The Comphance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. CLTs. The LRSD staff conducted a survey of CLTs during 2000-01. A summary of the survey findings was presented during a CLT training session, but no formal report was ever prepared. The Comphance Committee proposes retaining an outside expert to review the survey data and, if possible, prepare an evaluation based on the existing survey data. Lyceum Scholars Program. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Onward to Excellence. This evaluation was completed by the LRSD staff. The Compliance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. Vital Link. This evaluation was completed by LRSD staff The Comphance Committee proposes retaining an outside expert to review the report and, if possible, draw conclusions and make recommendations based on the existing data. 12Action Plan Timeline The Compliance Committee proposes implementation of this Compliance Plan in accordance with the following timeline. 1. Provide copies of this proposed Compliance Plan to ODM and Joshua for their reactions. 2. Incorporate, as possible, suggested revisions from ODM and Joshua. 3. Place Compliance Plan on the agenda for Board review and approval. 4. Place 2002-03 Program Evaluation Agenda on the Boards agenda for review and approval. 5. Place on Board agenda for approval two previously presented program evaluations (early literacy, and charter school). 6. Place on Board agenda for approval the evaluations of Southwest Middle Schools SEDL program and the Collaborative Action Team (also conducted by SEDL). 7. Place on Board agenda for approval the previously presented ESL program evaluations for 1999-2000 and 2000-01, plus the new evaluation for 2001-02. Week of September 30, 2002 Week of October 7, 2002 October 10,2002 October 24,2002 October 24,2002 November 2002 November 2002 13 I Clay Fendley Ken James Attorneys Ken James Compliance Team Ken James Attorneys Ken James Bonnie Lesley Bonnie Lesley Linda Watson Bonnie Lesley Bonnie Lesley Karen Broadnax8. Place on Board agenda for approval the three previously presented program evaluations for the NSF-funded CPMSA program, plus the new Year 4 report for 2001-2002. 9. Issue Request for Proposals (RFPs) from available external experts to review and complete the eight remaining program evaluations listed on page 148. _____________ 10. Form a screening team to determine recommendations to the Superintendent for designating external experts to review and complete the eight remaining program evaluations listed on page 148._________________ 11. Select and negotiate consulting contracts with designated external experts. 12. Assign appropriate staff to each external expert to provide needed information, data, access to program staff, etc. 13. Monitor the work to ensure timely completion. 14. As each paper is completed and ready for circulation, send copies to ODM and Joshua for their review and comments. December 2002 Mid-October 2002 Late October 2002 Mid-November 2002 Mid-November 2002 Mid-November 2002^February 2003 December 2002February 2003 14 Bonnie Lesley Vanessa Cleaver Dennis Glasgow Bonnie Lesley Darral Paradis Ken James Compliance Team Bonnie Lesley Ken James Bonnie Lesley Bonnie Lesley Bonnie Lesley15. As each paper is completed, place on the Boards agenda the item to be reviewed and approved. 16. Write Interim Compliance Report relating to programs on page 148 to be completed. 17. Establish staff teams for each of the three programs on the Boards Program Evaluation Agenda to be completed fori2002-2003 (Elementary Literacy, Secondary Literacy, and K- 12 Mathematics/ Science). 18. Publish RFPs to identify external experts to serve on each of the two staff teams for the Boards Program Evaluation Agenda (K-12 mathematics/science external experts are provided by NSF). 19. Establish consulting contracts with the two external experts required for the Elementary Literacy and Secondary Literacy program evaluations. 20. Train each program evaluation team, including the external expert, on the requirements of the approved Compliance Plan and IL-R. December 2002February 2003 March 15,2003 March 1, 2003 March 1, 2003 Late March 2003 May 2003 15 Ken James Bonnie Lesley Attorneys Compliance Committee Bonnie Lesley Bonnie Lesley Darral Paradis Bonnie Lesley Bonnie Lesley21. Monitor the completion of the work on all three program evaluations required in the Boards Program Evaluation Agenda. 22. Send copies of the completed Elementary Literacy program evaluation to ODM and Joshua for information. 23. Complete the evaluation of the Elementary Literacy program and place on the Boards agenda for approval. 24. Send copies of the Secondary Literacy program evaluation to ODM and Joshua for information. 25. Complete the evaluation of the Secondary Literacy program and place on the Boards agenda for approval. 26. Send copies of the completed CPMSA program evaluation to ODM and Joshua for information. 27. Complete the five-year evaluation of the CPMSA project (science and mathematics) and place on the Boards agenda for approval. 28. Write Section 2.7.1 Final Compliance Report for federal court and file with Court. MayOctober 2003 With October 2003 Board agenda packet October board meeting, 2003 With November 2003 Board agenda packets November board meeting, 2003 With December 2003 Board agenda packet December board meeting, 2003 March 15, 2004 16 Bonnie Lesley Ken James Bonnie Lesley Bonnie Lesley Pat Price Ken James Bonnie Lesley Bonnie Lesley Pat Price Ken James Bonnie Lesley Bonnie Lesley Vanessa Cleaver Dennis Glasgow Ken James Attorneys Compliance TeamI Appendix 1 Proposed IL-RlLITTLE ROCK SCHOOL DISTRICT NEPN CODE: IL-R1 PROGRAM EVALUATION AGENDA Purpose The purpose of these regulations is to provide guidance to the staff involved in the evaluation of programs required in the Boards Program Evaluation Agenda. They do not necessarily apply to grant-funded programs if the funding source requires other procedures and provides funding for a required evaluation. Criteria for Program Evaluations Policy IL specifies that the evaluations of programs approved in its Board- approved Program Evaluation Agenda shall be conducted according to the standards developed by the Joint Committee on Standards for Educational Evaluation. (See Joint Committee on Standards for Educational Evaluation, James R. Sanders, Chair (1994). The Program Evaluation Standards, 2^^ Edition: How to Assess Evaluations of Educational Programs. Thousand Oaks, CA: Sage Publications.) They are as follows: Utility Standards The utility standards are intended to ensure that an evaluation will serve the information needs of intended users. These standards are as follows: Stakeholder identification. People involved in or affected by the evaluation should be identified so that their needs can be addressed. Evaluator credibility. The people conducting the evaluation should be both trustworthy and competent to perform the evaluation so that the evaluation findings achieve maximum credibility and acceptance. Information scope and sequence. Information collected should be broadly selected to address pertinent questions about the program and should be responsive to the needs and interests of clients and other specified stakeholders. Values identification. The perspectives, procedures, and rationale used to interpret the findings should be described carefully so that the bases for value judgements are clear. Report clarity. Evaluation reports should describe clearly the program being evaluated, including its context and the purposes, procedures, and findings of the evaluation, so that essential information is provided and understood easily. 1Report timeliness and dissemination. Significant interim findings and evaluation reports should be disseminated to intended users so that they can be used in a timely fashion. Evaluation impact. Evaluations should be planned, conducted, and reported in ways that encourage follow-through by stakeholders, so that the likelihood that the evaluation will be used is increased. Feasibility Standards Feasibility standards are intended to ensure that an evaluation will be realistic, prudent, diplomatic, and frugal. Practical procedures. Evaluation procedures should be practical so that the disruption is kept to a minimum while needed information is obtained. Political viability. The evaluation should be planned and conducted with anticipation of the different positions of various interest groups j so that their cooperation may be obtained, and so that possible attempts by any of these groups to curtail evaluation operations or to vias or misapply the results can be averted or counteracted. Cost-effectiveness. The evaluation should be efficient and produce information of sufficient value so that the resources expended can be justified. Propriety Standards The propriety standards are intended to ensure that an evaluation will be conducted legally, ethically, and with due regard for the welfare of those involved in the evaluation, as well as those affected by its results. Service orientation. Evaluations should be designed to assist organizations to address and effectively serve the needs of the full range of targeted participants. Formal agreements. Obligations of the formal parties to an evaluation (what is to be done, how, by whom, and when) should be agreed to in writing so that these parties are obligated to adhere to all conditions of the agreement or to formally renegotiate it. Rights of human subjects. Evaluations should respect human dignity and worth in their interactions with other people associated with an evaluation so that participants are not threatened or harmed. Complete and fair assessments. The evaluation should be complete and fair in its examination and recording of strengths and weaknesses of the program being evaluated so that strengths can be built upon and problem areas addressed. Disclosure of findings. The formal parties to an evaluation should ensure that the full set of evaluation findings, along with pertinent limitations, are made accessible to the people affected by the 2evaluation, as well as any others with expressed legal rights to receive the results. Conflict of interest. Conflict of interest should be dealt with openly and honestly so that it does not compromise the evaluation processes and results. Fiscal responsibility. The evaluators allocation and expenditure of resources should reflect sound accountability procedures and be prudent and ethically responsible so that expenditures are accounted for and appropriate. Accuracy Standards Accuracy standards are intended to ensure that an evaluation will reveal and convey technically adequate information about the features that determine the worth of merit of the program being evaluated. Program documentation. The program being evaluated should be described and documented clearly and accurately so that it programs is identified clearly. Context analysis. The context in which the program exists should be examined in enough detail so that its likely influences on the program can be identified. Described purposes and procedures. The purposes and procedure of the evaluation should be monitored and described in enough detail so that they can be identified and assessed. Defensible information sources. The sources of information used in a program evaluation should be described in enough detail so that the adequacy of the information can be assessed. Valid information. The information-gathering procedures should be chosen or developed and then implemented in a manner that will ensure that the interpretation arrived at is valid for the intended use. Reliable information. The information-gathering procedures should be chosen or developed and then implemented in a manner that will ensure that the information obtained is sufficiently reliable for the intended use. Systematic information. The information collected, processed, and reported in an evaluation should be review systematically so that the evaluation questions are answered effectively. Analysis of quantitative information. Quantitative information in an evaluation should be analyzed appropriately and systematically so that the evaluation questions are answered effectively. Analysis of qualitative information. Qualitative information in an evaluation should be analyzed appropriately and systematically that the evaluation questions are answered effectively. so Justified conclusions. The conclusions reached in an evaluation should be justified explicitly so that stakeholders can assess them. 3Impartial reporting. Reporting procedures should guard against distortion caused by personal feelings and biases of any party the evaluation reports reflect the evaluation findings fairly. Metaevaluation. The evaluation itself should be evaluated so formatively and summartively against these and other pertinent standards so that its conduct is appropriately guided, and on completion, stakeholders can closely examine its strengths and weaknesses. Program Evaluation Procedures The following procedures are established for the evaluation of programs approved by the Board of Education in its annual Program Evaluation Agenda: 1. 2. 3. The Division of Instruction shall recommend to the Superintendent annually, before the budget for the coming year is proposed, the curriculum/instruction programs for comprehensive program evaluation. The recommendation shall include a proposed budget, a description of other required resources, and an action plan for the completion of the reports. Criteria for the proposed agenda are as follows: A. Can the results of the evaluation influence decisions about the program? B. Can the evaluation be done in time to be useful? C. Is the program significant enough to merit evaluation? (See Joseph S. Wholey, Harry P. Hatry, and Kathryn Newcomer (1994). Handbook of Practical Program Evaluation. San Francisco, CA: Jossey- Bass Publishers. 5-7.) The Superintendent shall recommend to the Board of Education for approval the proposed Program Evaluation Agenda^with anticipated costs and an action plan for completion. For each curriculum/instruction program to be evaluated as per the Program Evaluation Agena, the Associate Superintendent for Instruction shall establish a staff team with a designated leader to assume responsibility for the production of the report according to the timelines established in the action plan approved by the Board of Education. 4. Each team shall include, at a minimum, one or more specialists in the curriculum/instruction program to be evaluated, a statistician, a programmer to assist in data retrieval and disaggregation, and a technical writer. If additional expertise is required, then other staff may be added as necessary. 5. An external consultant with expertise in program evaluation, the program area being evaluated, statistical analysis, and/or technical writing shall be retained 4as a member of the team. The role of the external consultant may vary, depending upon the expertise required for the production of the program evaluation. 6. The team leader shall establish a calendar of regularly scheduled meetings for the production of the program evaluation. The first meetings will be devoted to the following tasks: A. B. C. Provide any necessary training on program evaluation that may be required for novice members of the team, including a review of the Boards policy IL and all of the required criteria and procedures in these regulations, IL-R. Assess the expertise of each team member and make recommendations to the Associate Superintendent for Instruction related to any additional assistance that may be required. Write a clear description of the curriculum/instruction program that is to be evaluated, with information about the schedule of its implementation. D. Agree on any necessary research questions that need to be established in addition to the question, Has this curriculum/instruction program been effective in improving and remediating the academic achievement of African-American students? (See Policy IL, 2.7.1 of the Revised Desegregation and Education Plan, and Judge Wilsons Compliance Remedy.) E. Generate a list of the data required to answer each research question, and assign responsibility for its collection and production. All available and relevant student performance data must be included. (See Judge Wilsons Compliance Remedy.) F. Decide who will be the chief writer of the program evaluation. G. Plan ways to provide regular progress reports (e.g., dissemination of meeting minutes, written progress reports, oral reports to the Superintendents Cabinet and/or Compliance Team) to stakeholders, including the Associate Superintendent for Instruction, the Superintendent of Schools, the Office of Desegregation Monitoring (until Unitary Status is achieved), and the Joshua Intervenors (until Unitary Status is achieved). (See Joellen Killion (2002). Assessing Impact: Evaluating Staff Development. Oxford, OH. National Staff Development Council (NSDC)\nRobby Champion (Fall 2002). Map Out Evaluation Goals. Journal of Staff Development. 78-79\n5Thomas R. Guskey (2000). Evaluating Professional Development. Thousand Oaks, CA: ConA/in Press\nBlaine R. Worthen, James R. Sanders, and Jody L. Fitzpatrick (1997). Participant-Oriented Evaluated Approaches. Program Evaluation: Alternative Approaches and Practical Guidelines\n153-169\nBeverly A. Parsons (2002). Evaluative Inquiry: Using Evaluation to Promote Student Success. Thousand Oaks, CA: Corwin Press\nand Joseph S. Wholey, Harry P. Hatry, and Kathryn E. Newcomer (1994). Handbook of Practical Program Evaluation. San Francisco, CA: Jossey-Bass Publishers.) 7. Subsequent meetings of the program evaluation team are required for the following tasks: to monitor the completion of assignments\nto collaborate in the interpretation and analysis of data\nto pose any necessary new questions to be answered\nto review drafts and provide feedback to the writer\nto formulate recommendations, as required, for program improvement, especially to decide if a recommendation is required to modify or abandon the program if the findings reveal that the program is not being successful for the improvement of African- American achievement: to assist in final proofreading\nand to write a brief executive summary, highlighting the program evaluation findings and recommendations. 8. A near-final copy of the program evaluation must be submitted to the Associate Superintendent for Instruction at least one month before the deadline for placing the report on the Boards agenda for review and approval. This time is required for final approval by staff, for final editing to ensure accuracy, and for submission to the Superintendent. 9. When the program evaluation is approved for submission to the Board of Education for review and approval, copies of the Executive Summary and complete report must be made for them, for members of the Cabinet, for ODM (until Unitary Status is achieved), and for the Joshua Intervenors (until Unitary Status is achieved). 10.The program evaluation team shall plan its presentation to the Board of Education on the findings and recommendations. 611 .The Associate Superintendent for Instruction shall prepare the cover memorandum to the Board of Education, including all the required background information (see Judge Wilsons Compliance Remedy)\nA. B. C. D. If program modifications are suggested, the steps that the staff members have taken or will take to implement those modifications. If abandonment of the program is recommended, the steps that will be taken to replace the program with another with more potential for the improvement and remediation of African-American students. (See Section 2.7.1 of the Revised Desegregation and Education Plan and Judge Wilsons Compliance Remedy.) Names of the administrators who were involved in the program evaluation. Name and qualifications of the external expert who served on the evaluation team. Grade-level descriptions of the teachers who were involved in the assessment process (e.g., all fourth-grade math teachers, all eighth grade English teachers, etc.). 10. When the program evaluation is approved by the Board of Education, the team must arrange to have the Executive Summary and the full report copied and design a plan for communicating the program evaluation findings and recommendations to other stakeholders. This plan must then be submitted to the Associate Superintendent for approval. 11. Each program evaluation team shall meet with the Associate Superintendent for Instruction after the completion of its work to evaluate the processes and product and to make recommendations for future program evaluations. (See Joellen Kiliion (2002).  Evaluate the Evaluation. Assessing Impact: Evaluating Staff Development. Oxford, OH: National Staff Development Council. 46, 123-124.) 7Appendix 2. Proposed IL-R2LITTLE ROCK SCHOOL DISTRICT NEPN CODE\nIL-R2 INFORMAL PROGRAM EVALUATION Introduction The purpose of this regulation is to ensure that a written record exists explaining a decision to significantly modify an academic program. It is not the intent of this regulation to require a formal program evaluation before every significant program modification. Definitions Academic Program means one of the core curriculum programs of English/Language Arts, Mathematics, Science or Social Studies. Significantly modify means a material change in the content or delivery of an academic program implemented throughout the entire District. Written Record A written record must be prepared and maintained explaining a decision to significantly modify an academic program. The written record required by this regulation must include the following information: (a) the written criteria used to evaluate the program\n(b) a summary of the student assessment data or other data on which the decision was based\nand (c) the names of the administrators who were involved with the evaluation of each program, as well as at least a grade level description of any teachers who were involved in the evaluation process (e.g., all fourth grade math teachers\nall eighth grade English teachers etc.). 1Appendix 3 Robby Champion, Map Out Evaluation Goals, Journal for Staff Development, Fall 2002 99I a It i n g m e a s ROBBY CHAMPION Map out evaluation goals A master plan can guide you down the rocky path of evaluation w 'hen you launch a major professional development evaluation, regardless of the projects scope, you may quickly find yourself on a slippery, often rocky road, with twists and unexpected turns. Before venturing too far and becoming disillusioned about program evaluation, create a master plan. While it requires an upfront investment of time and may delay starting, it quickly becomes an invaluable road map that helps you avoid delays and detours along the way. Developing an evaluation master plan is most useful when you are launching a major, summative program evaluation. A summative evaluation is done at major junctures in a programs life cycle and emphasizes documenting impact. Information from summative evaluations is used to make important decisions about the initiative, such as whether to continue, alter, expand, downsize, or eliminate it. A formative evaluation, on the other hand, means monitoring and collecting data, often informally and spontaneously, throughout program implementation. Formative evaluation helps show implementers where to make adjustments so a program can eventually achieve significant results. A thoughtfully prepared master plan for a major evaluation effort would:  Focus the evaluation effort and help implementers avoid being sidetracked by leadership changes and new opinions\n Create a realistic timeline and work plan that  Robby Champion is president of Champion Training \u0026amp; Consulting. You can contact her at Champion Ranch at TnimbeD Canyon, Mora. NM 87732, (505) 387-2016, fax (505) 387-5581, e-mail: RobbychampioD@aol.com. provides needed momentum for the work\n Be a key informational document to provide an overview and answer specific questions throughout the process\n Help recruit people to assist with the project on the myriad evaluation tasks\n Give the message that the evaluation wUl be open and not secretive. Whether your evaluation must be completed within a few months or will extend for several years, think through four phases of work before starting. PHASE I: ORGANIZE THE PROCESS 1. Form a steering committee, including any needed outside expertise. 2. Learn more about program evaluation together. 3. Write a clear description of each program to be evaluated. 4. Agree on the primary purpose of the evaluation. .5. Plan how you will keep everyone informed along the way. Steering committees, charged specifically with program evaluation, are important to focus attention and maintain the energy and momentum needed for the evaluation. They also help build a spirit of collaboration and open inquiry. And they keep the evaluation on track when other priorities might push the effort aside. Provide steering committee members with the tools to succeed. Members need not be evalu- 78 National Staff Development Council JSD Fall 2002I i I i I m e a s u r e ation-experts, but they do need information, support, and guidance to make informed decisions. They need background material to learn about program evaluation and examples of good evaluation studies. Finally, they need access to experts on professional development, measurement, and the content areas of the training programs. Before launching any evaluation effort, have a written description of each program to be evaluated. You would be amazed at the number of people who do not have a clear idea of what you mean by the New TeacherJnduction Program or the Early Literacy Initiative since so many different initiatives are being undertaken simultaneously around the school or district. PHASE II: DESIGN THE EVALUATION 1. Generate questions to guide the evaluation. 2. Generate potential data sources/ instruments to address the questions. 3. Using a matrix to provide a birds-eye view, agree on the most important questions and the best data sources. 4. Decide if collecting data from a sample group is warranted to make the evaluation manageable. 5. Determine the evaluation approach that makes sense: quantitative vs. quahtative/naturalistic. 6. Gather or create the instruments for data collection. 7. Determine a realistic schedule for collecting data. 8. Create a system for collecting, analyzing, and interpreting data. Decisions made in Phase n are critical. They determine the technical quality of your evaluation. In the questions you select, you determine what to examine and what to ignore. When you finish with the design phase, your program evaluation will be shaped to use a quantitative or a , qualitative model  or a mixture of the two. In the design phase, you make other major decisions, such as whether to use a sample group. You also decide whether to do an in-dep case study, whether to ON THE WEB. See an example of a matrix to help guide evaluations at: www.nsdc.org/libraryrjsd/ champion234.html. survey the whole population, whether to use examples of student work instead of official documents such as student grades or standardized test scores, or whether to judge adult learners understanding of the training content with performance tasks during training or by exit tests, classroom observations, or student feedback. If the programs to be evaluated already have stated indicators of longterm impact, generating appropriate evaluation questions is much simpler than when programs have only vague, lofty goals. The steering committee may drift into the realm of program planning as you encounter hurdles tike fuzzy program outcomes. To avoid making misinformed evaluation design decisions, involve program leaders in your discussions. Developing or gathering instruments and then collecting the data are the most expensive steps in any evaluation. Think strategically about which data to collect, from whom to collect it or where to find it, and the best time to collect it. Your organization may already be collecting data for another purpose that now can be used for program evaluation. Some pubhc records, such as student attendance, may be valuable if, for example, 20% increase in student attendance at all grade levels is one of your programs indicators of impact PHASE III: PREPARE TO REPORT 1. Determine which audiences will want to know the results. 2. Consider several forums and formats to disseminate the results. 3. Plan reports, presentations, photo displays, graphs, charts, etc. Remember that your job is to make the evaluation results useful to your organization, so consider a range of ways to provide information to various groups. Consider briefs in the school or district newsletter, a handout updating staff about the schedule for data collection, five- minute progress updates in faculty meetings, bulleted statements on your web site, a digital picture- album of the programs results in classrooms with photos of students, and hallway displays of student work. If your final report is a formal document complete with examples of your data collection instruments, consider writing an executive summary of five pages or less to help,readers get the essential information. PHASE IV: CREATE THE WORK PLAN 1. List all tasks to be completed for the whole evaluation. 2. Create a realistic timeline. 3. Assign work. 4. Distribute the master plan. You will have to be creative to accomphsh all the evaluation tasks. In education, we rarely have the luxury of contracting outsiders for the entire project Enlist steering committee members, partners, graduate students from the local university, and other talented critical friends to get the work done. One caution: For formal or summa- tive evaluations to be credible, avoid using insiders such as the program designers or implementers (coaches, mentors, trainers, or facilitators) to perform critical evaluation tasks that call for objectivity and distance. And be sure to get ongoing, high-quality technical expertise for the critical technical analysis. A CATALYST FOR REFLECTION Completing a major program evaluation usually serves as the catalyst for serious reflection on the current designs, policies, and practices of your professional development programs  their goals, content, processes, and contexts. In fact, revelations are often so powerful that they bring about the realization that major changes are needed if significant results' are really expected from professional development. People frequently conclude that designing the evaluation should be the first step in the program planning process, rather than an afterthought during implementation. E I I JSD Fall 2002 National Staff Development Council 79Office 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 October 7, 2002 Dr. Ken James, Superintendent Little Rock School District 810 West Markham Street Little Rock, AR 72201 Dear Ken: I enjoyed our telephone chat today and look forward to meeting for coffee and more conversation on October 31 (all treats, no tricks!) Thanks for understanding our frustration at receiving the districts Proposed Compliance Plan at noon last Friday, October 4, 2002, giving us very few days in which to respond by your deadline of this coming Thursday, October 10'\\ Although youd been kind to notify me September 23' that your proposal would be forthcoming in the near future, Id not known exactly when to expect it. As a result, were trying to squeeze our review into an already crowded schedule. rd As I explained, the tight timeline will preclude as thorough a review of your plan as we might otherwise have been able to do. Nevertheless, as you and I agreed, well write up some of our preliminary observations and questions for you to factor into your deliberations. My associate. Gene Jones, has been monitoring program evaluation in the district and will continue to do so. Unless otherwise notified, we will assume that our primary contacts for information are those named in the Action Plan Timeline. We intend to do our best in continued support of the district, and will always appreciate ample lead time for our input. Thank you very much. Sincerely yours, Ann S. Marshall 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 Date: October 10, 2002 To: Dr. Ken James, LRSD Frorn^^ni in Marshall, ODM Re: LRSDs Evaluation Compliance Plan Thank you for forwarding the LRSDs Proposed Compliance Plan, Revised Plan 2.7.1, which was delivered to us last Friday, October 4, 2002. ODM is happy to provide comments when requested, and we will appreciate being accorded adequate time in which to do so. Our feedback, attached, is limited as a result of the very short lead time. We hope the enclosed observations and questions will be helpful as you fine-tune your compliance plan. We look forward to working with you over the coming months as we monitor implementation of the plan. Please let us know how we may be of assistance. Enc. cc: Judge William R. Wilson Judge J. Thomas Ray All Counsel of RecordOctober 10, 2002 ODMs Observations and Questions LRSD Proposed Compliance Plan, Revised Plan 2.7.1 1. 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-writes be limited to the data that were used at the time the eight evaluations had been written? 2. Page 7 of the Proposed Compliance Plan identifies Primary Reading/Langiiage Arts as a program to be evaluated as part of the evaluation agenda, while the term Elementary Literacy is used on page 15. The first term connotes PK-3, while the second connotes K-5. Do the different titles actually identify different programs? Which grades are to be included in the evaluation? 3. 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? 4. 5. 6. 7. 8. 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? The proposed regulation, 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? The proposed regulation requires that all relevant student performance data will be used in the evaluations. Will other data, such as interviews with teachers or students, case studies, and classroom observations, supplement the performance data for the evaluation? 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? 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 or 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 of 2003. We note that the spring 2003 tests will not only be the final assessment, but also the only student 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?9. 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. 10. 11. 12. Given the assignments in the Action Plan Timeline, what is the role of the districts Planning, Research and Evaluation department under the new compliance plan? Under the envisioned Program Evaluation Agenda? The 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 informal 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? 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 purchases of evaluation services?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. JAMBS 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 III. 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. DIANS 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. 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. JEFFREY H. MOORE. P.A. DAVID M. GRAP. P.A. 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.frldayfirm.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 479-805-2011 FAX 479-605-2147 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. IF RAH JAY T. TAYLOR MARTIN A. KASTEN RYAN A BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON PHILIP B. MONTGOMERY KRISTEN S. RIGGINS ALANG. BRYAN LINDSEY MITCHAM SLOAN KHAYYAM M. EDDINGS JOHN F. PEISERICH AMANDA CAPPS ROSE BRANDON J. HARRISON 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 870-762-2808 FAX 870-762-2918 OCT 1 1 2002 OFFICE OF DESEGREGATION MONITORING October 11,2002 JOHN C. FENDLEY. JR. LITTLE ROCK TEL 501-970-3323 FAX 501-244-5341 fandltyQf^c.ntt ( By Hand Delivery ) Mr. John W. Walker Mr. Sam Jones Mr. Steve Jones JohnW. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 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 Mr. Richard Roachell Roachell Law Firm ( By Hand Delivery ) Ms. Ann Marshall Mr. Dennis Hanson 11800 Pleasant Ridge Road, #146 Desegregation Monitor 1 Union National Plaza Office of the Attorney General 323 Center Street P.O. Box 17388 Little Rock, Arkansas 72222 124 W. Capitol, Suite 1895 Little Rock, Arkansas 72201 200 Tower Building Little Rock, Arkansas 72201 RE\nCompliance Remedy 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 administrations 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: F:\\HOME\\FENDLEY\\LRSD 200I\\unitary-all-counsd-10-l 1-02.wpdAll Counsel and Ms. Marshall October 11, 2002 Page 2 1. 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-writes be limited to the data that were used at the time the eight evaluations had been written? RESPONSE: The re-writes will be limited to the data that were used at the time the eight evaluations were written. 2. Page 1 of the Proposed Compliance Plan identifies Primary Reading/Language Arts as a program to be evaluated as part of the evaluation agenda, while the term. Elementary Literacy is used on page 15. The first term connotes PK-3, while the second connotes 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. 3. 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. 4. 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 administering student assessments through its training of teachers in administering the assessments and monitoring the results of assessments. 5. In the evaluation ofprimary 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 2001\\unitary-aJl-counsel-10-l 1-02. wpdAll 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 of 2003. 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: Yes, 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:\\HOMEVFENDLEY\\LRSD 2001\\unitary-ail-counsd-10-ll-02.wpdAll 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 Planning, Research and Evaluation department imder 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 xmclear. 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 Compliance 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 that this may be done in a timely manner, the LRSD asks all parties to F:\\HOME\\FENDLEY\\LRSD 200l\\uniury-al!-counsci-10-11-02. wpdAll 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 vmting, 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, John C. Fendiey, Jr. cc: Dr. Ken James F:\\HOME\\FENDLEY\\LRSD 2001\\unitary-all-counsd-10-l 1-02. wpdec: JOHN W. WALKER SHAWN CHILDS Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Bank Center 400 West Capitol Little Rock, AR 72201 John W. Walker, P.A. Attorney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (601) 374-3758 FAX (501) 374-4187 Via Facsimile -376-2147 October 9, 2002 OF COUNSEL ROBERT McHENRY. P.A. DONNAJ.McHENRY 8210 Hendesson Road Little Rook, Aekans.as 72210 Phone (501) 372-3425  F.ax (501) 372-3428 Email\nmclieiiryd@swbelLnet RECEIVED OCT 11 2102 OmCEOF DESEGREGATION MONITORING Re: LRSD Compliance Plan Dear Chris: This is to inform you that I received your Compliance Plan on Monday, October 1, 2002. I was in court on Monday and Tuesday. Incidentally, I am again in court today and have not had adequate time to even read what you propose. I understand that you will be presenting this matter to the Board on tomorrow evening. I have called you several times and have been informed that you were not in. Accordingly, when you present this matter to the Board, please let them know that I have not had an opportunity to review what you have proposed nor to have any discussions regarding the matter with you or the ODM. 1 // Sincerely, / 4 jefhn W. Walker JWW:js cc: Ms. Ann Marshall All Counsel of Record e\u0026lt;r: 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 - 376-2147 October 10, 2002 OF COUNSEL ROBERT McHENEY. P.A DONNA J. McHenry 8210 Henderson Ro.ad Little Rock, Arkansas 72210 Phone: (501) 372-3425  Fax (501) 372-3428 Email: mchenryd@swbell.net Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, AR 72201 RECEIVED OCT 1 1 2002 Re: Little Rock School District v. PCSSD, et al. Case No. 4:82CV00866 OFRCEOF DESEGREGATION MONITORING Dear Chris: Plan. This refers to your letter of October 4, 2002, providing LRSDs proposed Compliance The courts remedy and the general subject matter are too complex for us to provide all comments and objections we may ultimately have before todays Board meeting. We do note the following: 1. More consideration is needed of the programs to be identified as implementation pursuant to Section 2.7 . . . , which are to be subjected to a comprehensive program evaluation. . . Your document at page 7 identifies three areas. We note the absence of specific reference and detail regarding interventions / scaffolding - areas of vital importance given the achievement patterns of African American students. We note also that the LRSD compliance report cited many more programs as designed to fulfill Section 2.7. 2. In a discussion prior to his testimony in the hearing Judge Wilson, we understood Dr. Ross to indicate that the existing evaluation of the Pre-K - 2 literary program was not adequate. The notation at page 4 of your document of the changed use of the Observation Survey and the DRA relates to part of the concerns he expressed. This undermines the LRSD argument (page 11) that the existing evaluation, upon Board approval, will satisfy a part of the courts remedy. 3. The LRSD discussion about satisfying the courts order regarding the evaluationsmentioned at page 148 of the compliance report does not seem to take account of the material provided, which describes an adequate evaluation. 4. We question the period for implementation of a remedy which the court has identified and, therefore, the LRSD schedule. Once again, these comments should not be taken to be the full range of concerns which Joshua may ultimately have about the courts remedy and the Compliance Plan. Nor do we intend to waive our concerns about the court setting forth a remedy, without first hearing from the parties and the ODM with regard to the courts views on an appropriate remedy. Sitic^ly, / .\u0026gt;John W. Walker JWW.'js cc: Ms. Ann Marshall All Counsel of RecordFriday Eldredge \u0026amp; Clark HERSCHEL H. FRIDAY (1922-1994) WILUAM H. SUTTON. P.A. Byron m. eiseman, jr, p.a JOE D. BELL. P.A. JAMES A. BUTTRY. P.A. FREDERICKS. URSERY. P.A. OSCAR B 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. 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 UI. 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. SHAFER. P.A. WILLIAM M. GRIFFIN HI. 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. 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. JEFFREY H. MOORE. P.A. DAVID M. GRAF. P.A. ATTORNEYS AT LAW A LIMITED LIABILITY PARTNERSHIP www.fridayfirm.cofT\u0026gt; 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 479-695-2011 FAX 479-665-2147 CARLA GUNNELS SPAINHOUR. P.A. JOHN C. FENDLEY, JR.. P.A. JONANN ELIZABETH CONIGLIO. P.A. 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. CLIPFORD W. PLUNKETT, P.A. DANIELL. 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 Q. BRYAN LINDSEY MITCHAM SLOAN KHAYYAM M. EDDINGS JOHN F. PEISERICH AMANDA CAPPS ROSE BRANDON J. HARRISON 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: 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2868 FAX 870-762-2918 October 14,2002 OPCOUNSEL B.S. CLARK WILLIAM L. TERRY WILUAM L. PATTON. JR H.T. LARZELERE, P.A. JOHN C. ECHOLS. P.A AD. MCALLISTER JOHN C. FENDLEY. JR. LITTLE ROCK TEL S01-370-3323 FAX 501-244-S341 fn4lyQfc.nt RECEIVED OCT 1 6 2002 OmCEOF DESEGREGATION MONITORING 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. Pendley, Jr. V F:\\HOME\\BBrown\\Fa\u0026gt;dley\\LRSD\\deseg\\judge wilsoo k.wpdHonorable William R. Wilson, Jr. October 14,2002 Page 2 cc: Mr. John W. Walker Mr. Sam Jones Mr. Steve Jones Mr^chard Roachell ^Ms. Ann Marshall Ms. Sammye Taylor Mr. Ken James F:\\HOME\\BBrown\\FcndJcy\\]J\u0026lt;SEMcscg\\/udge wibon h.wpdI . JOO JOHN W. WALEtER SHAWN CHILDS John W. walker, pa. Attohney At Law 1723 Broadway Little Rock, Arkansas 72206 Telephone (501) 374-3758 FAX (501) 374-4187 October 23,2002 OF COUNSEL ROBERT McHENEY, PA. DONNA J. McHENRY 8210 Hendesson HoaL Uttle Rock, Arkansas 72210 Phone: (601) 372-3426  Pax (501) 372-3428 RUAn,: mchearyd^awLelLxket Mr. Christopher Heller FRIDAY. ELDREDGE \u0026amp; CLARK . 400 W. CapitoU Suite 2200 Little Rock, Arkansas 72201 RECEIVED OCT 2 4 2002 Re\nLRSD V, PCSSD OFFICE OF DESEGREGATION MONITORING Dear Chris\nThis letter sets forth additional comments of the Joshua Intervenors concerning the I PSD 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 perform anrA 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 itI, Page Two October 23,2002 ^^0 dertake should make clear that the actual implementation of remediation ^vittes in distnct schools is to receive careful consideration. This is surely an important contextual factor (see Accuracy Standards, para. 2).  / 1 the LRSD plans evaluations of programs deemed to be paiticul^ly directed to achievement of African American students for the indefinite future, not smply for the period necessary to satisfy the court. We would like to receive the Boards assurance that this IS the case. We would appreciate yourproviding this letter to the Superintendent and the members of the school board. RffW. Walker Sincere^, JWW:lp cc: All Counsel Ms. Ann Marshall Judge Thomas Ray Dazs: .J- O JOHN W. NHLKER, Aitomsy ar Law 1723 Sroad'.way J2od^ Aakar\u0026lt;aas 72206 Telephons (501) 37a.375S Fea (501) 374-4137 RAH TR.liVSMI3SICiN COVTS S7TTF.F e Ltui L I fk- J 271-d/a-i} [. L Rz: SznRsr: / 70USHOULD HSCDD/E [ (iTiclzuimg caver shssi)} PAC-D(S). OfCLUDlHG THIS COVER SHEET. IF TOUDO HOT RECEIVE ALL THE PACES, r.4r.r \"\u0026lt;(501) 574-375S\u0026gt;\" The iMarmationconiaiaedin diis iiesiniilemessage is sitoiaeypri'/iiegedand coafideatial infSrmgrinn mr.qnripd eniy for the use of the iadivimial ar enrity named above, if ms .^ader of this message is not the intended tecipieat. ot the employes or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissetnination, oistibiinon or copying of mis conmunicahon. is strictly prohibited. If you have received dhs communication in error, please immediate aoui^us by teleptons. and return the original message to us at the above address via the U.S. Postal SerAce. Thank you. received OCT 2 9 2002 OFFICE OF DESEGREGATION MONITORING 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 OF COUNSEL ROBERT McHENRY, P a DONNA J. McHenry 3210 Henderson Road Little Rock, Ahkans.as 72210 Phone: (501) 372-3425  P.4X (501) 372-3428 Email\nmchenryd@swbeil.net Via Facsimile - 376-2147 October 25, 2002 Mr. Chris Heller Friday, Eldredge \u0026amp; Clark 2000 Regions Center 400 West Capitol Little Rock, AR 72201 Re: Little Rock School District v. PCSSD, et al. Case No. 4:82CV00866 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. Si-Hcerely, .hn W. Walker JWW\njs cc: Ms. Ann Marshall All Counsel of Record(TC: 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 IIL 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. 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 III. P.A. MICHAEL S. MOORE. P.A. DIANES. MACKEY. P.A. WALTER M. EBEL III. P.A. KEVIN A. CRASS. P.A. WILLIAM 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 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. JEFFREY H. MOORE. P.A. DAVID M. GRAF. P.A. RECEIVED OCT 2 5 2002 OFFICE OF DESEGREGATION MONITORING 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 342S NORTH FUTRALL DRIVE. SUITE 103 FAYETTEVILLE. ARKANSAS 72703-4811 TELEPHONE 479-665-2011 FAX 479-695-2147 208 NORTH FIFTH STREET BLYTHEVILLE. ARKANSAS 72315 TELEPHONE 870-762-2696 FAX 870-762-2918 October 25, 2002 CARLA GUNNELS SPAINHOUR, P.A. JOHN C. FENDLEY. JR.. P.A, JONANN ELIZABETH CONIGLIO. P.A 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 A. KASTEN BRYAN W. DUKE JOSEPH G. NICHOLS ROBERT T. SMITH RYAN BOWMAN TIMOTHY C. EZELL T. MICHELLE ATOR KAREN S. HALBERT SARAH M. COTTON PHILIP 8. MONTGOMERY KRISTEN S. RIGGINS ALAN 0. BRYAN LINDSEY MITCHAM SLOAN KHAYYAM M. EDDINGS JOHNF. PEISERICH AMANDA CAPPS ROSE BRANDON J. HARRISON OF COUNSEL B.S. CLARK WILLIAM L. TERRY WILLIAM 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 501-244-5341 fsndlay^fac.nct (By Hand Delivery ) Mr. John W. Walker Mr. Sam Jones Mr. Steve Jones John W. Walker, P.A. 1723 Broadway Little Rock, Arkansas 72201 Wright, Lindsey \u0026amp; Jennings 2200 Bank of America Bldg. 200 West Capitol Little Rock, Arkansas 72201 Jack, Lyon \u0026amp; Jones, P.A. 425 W. Capitol, Suite 3400 Little Rock, Arkansas 72201 Mr. Richard Roachell Roachell Law Firm ( By Hand Delivery ) Ms. Ann Marshall Mr. Dennis Hanson Plaza West Building 415 N. McKinley, Suite 465 Little Rock, Arkansas 72205 Desegregation Monitor 1 Union National Plaza Office of the Attorney General 323 Center Street 124 W. Capitol, Suite 1895 Little Rock, Arkansas 72201 200 Tower Building Little Rock, Arkansas 72201 RE\nCompliance Remedy Dear Counsel and Ms. Marshall: In our letter dated October 11,2002, we asked the parties to specifically identify in writing any perceived deficiency in the Board-approved Compliance Plan on or before Monday, October 21, 2002. No responses were received on or before that date. However, Mr. Pressman called on October 21,2002, and advised that Joshua would rely on tlie comments contained in Mr. Walkers October 10, 2002, facsimile. On October 24, 2002, additional comments were received from Mr. Walker. All of Mr. Walkers comments will be addressed in turn.All Counsel and Ms. Marshall October 25, 2002 Page 2 October 10, 2002 Facsimile 1. More consideration is needed of the programs to be identified as implementat[ed] pursuant to Section 2.7 .. which are to be subjected to comprehensive program evaluation .. \u0026gt; Your document at page 7 identifies three areas. We note the absence of specific reference and detail regarding interventions/ scaffolding - areas of vital importance given the achievement patterns of Afiican-American students. We note also that the LRSD compliance report cited many more programs as designed to fulfill Section 2.7. Mr. Pressman clarified this concern during our October 21, 2002 telephone conversation. Mr. Pressman explained that Joshua was concerned that interventions designed to assist low achieving students, for example SAIPs, were not being fully implemented and wanted some assurance that the comprehensive program evaluations would assess implementation of these programs. LRSD RESPONSE: On October 24,2002, the Board approved the Division of Instructions Plan to Support Low-Performing Schools, a copy of which is enclosed for your review. Under that plan, the LRSD will conduct curriculum, instruction and classroom management audits at low performing schools. Data gathered through these audits and other monitoring under the plan may be used by a program evaluation team to identify possible causes of poor performance, including poor implementation of interventions such as SAIPs. The LRSD lacks the resources to implement this plan at every school. Approximately 10 schools will receive the full compliment of services outlined in the plan. Those 10 schools will be identified based on the priority system set forth in the plan. 2. In a discussion prior to his testimony in the hearing [before] Judge Wilson, we understood Dr. Ross to indicate that the existing evaluation of the PreK-2 literacy program was not adequate. The notation on page 4 of your document of the changed use of the Observation Survey and the DRA relates to part of the concerns he expressed. This imdermines the LRSD argiunent (page 11) that the existing evaluation, upon Board approval, will satisfy a part of the Courts remedy. LRSD RESPONSE: As the LRSD understands this statement, Joshua objects to the LRSD considering the PreK-2 literacy evaluation to have been completed pursuant to Paragraph C of the Compliance Remedy. Attached are the comments received by the LRSD from Dr. Ross related to that evaluation. As can be seen. Dr. Ross did not advise the LRSD that the evaluation was inadequate. Moreover, it does not make sense for the LRSD to expend resources to have this evaluation completed by an outside expert while it also prepares a new, comprehensive evaluation of the same program with the assistance of an outside expert.All Counsel and Ms. Marshall October 25, 2002 Page 3 3. The LRSD discussion about satisfying the courts order regarding the evaluations mentioned at page 148 of the compliance report does not seem to take accoimt of the material provided, which describes an adequate evaluation. LRSD RESPONSE: As the LRSD understands this statement, Joshua objects to the LRSD not completing the evaluations identified on page 148 of the Final Compliance Report in a manner consistent with IL-Rl. As the LRSD understands Paragraph C of the Compliance Remedy, the District Court simply wants the LRSD to do what it said it did and complete the evaluations identified on page 148 of the Final Compliance Report. That is what the LRSD intends to do. It is true that those evaluations, even after being completed, may not be model program evaluations as envisioned by IL-Rl. The LRSD decided, however, that the most prudent use of its limited resources would be to focus on the new, comprehensive evaluations of programs designed to improve Afiican-American achievement. 4. We question the period of implementation of a remedy which the court has identified and, therefore, the LRSD schedule. LRSD RESPONSE: The LRSD is willing to agree that any agreement between the LRSD and Joshua related to implementation of the Compliance Remedy will not prejudice Joshuas appeal of the District Courts September 13,2002, Memorandum Opinion. October 24, 2002 Facsimile 1. In using historical student assigiunent results, attention should be given to the quality of the data. In the past, LRSD has used results on the [D]RA and the Observation Survey in ways not consistent with the purposes of those instruments. In addition, because teachers provided scores for their ovra 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. LRSD RESPONSE\nParagraph A of the Compliance Remedy requires the LRSD to use all available data in its evaluations. It will be the responsibility of the evaluation team to weigh the reliability and validity of the available data. The Arkansas Department of Education and national organizations with expertise in early literacy recommend the use of the DRA and Observation Surveys. The primary piupose of those assessments is to determine whether students are learning the essential components of the reading curriculum. As to the integrity of the data from those assessments, the LRSD monitored student scores year-to-year to discoinage teachers from inflating scores in an effort to show improvement. Moreover, the ultimate success of the LRSDs early literacy program willAll Counsel and Ms. Marshall October 25,2002 Page 4 be judged by performance on the States Benchmark examinations, rather than the DRA and Observation Surveys. 1. 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 maimer which we describe, there would be no bar to LRSD staff preparing comments to the Board with a differing interpretation of the evaluation results. LRSD RESPONSE: The LRSD rejects the implication that LRSD personnel cannot be trusted to write an honest program evaluation. The LRSDs commitment to improving student achievement is second to none. To fulfill that commitment, it is in the LRSDs best interest to effectively evaluate its programs. The success of the programs and program evaluations will ultimately be measured by the States Benchmark evaluations. All evaluation team members will be actively involved in the evaluation process and are expected to provide a check against the self-interest of any one team member. The evaluation team will decide who writes the report based on the expertise of team members. The outside expert will be asked to take to the Superintendent any concerns about the evaluation not being addressed by the evaluation team. The outside expert will also be asked to be present when the evaluation is presented to the Board so that the Board can be advised of any concerns the outside expert may have about the final evaluation. 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 apohcy 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 requires the staff to undertake 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). LRSD RESPONSE\nAs the LRSD understands this comment, it is a restatement of the first number paragraph in Mr. Walkers October 10, 2002 facsimile, and the LRSD hereby incorporates its response thereto.All Counsel and Ms. Marshall October 25, 2002 Page 5 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 term, not simply for the period necessary to satisfy the court. We would hke to receive the Boards assurance that this is the case. LRSD RESPONSE: The Boards approval of IL-Rl was not limited to the term of the Compliance Remedy, and at this time, the Board anticipates continuing to evaluate programs pursuant to Policy IL after the term of the Compliance Remedy. Conclusion The LRSD hopes that it has been able to address all of Joshuas concerns. If any party has any questions about the LRSDs responses to Joshuas comments, we ask that those be submitted in writing, and the LRSD will promptly provide a written response. If Joshua continues to have concerns about the LRSDs Compliance Plan, Joshua should consider this the LRSDs written response to alleged noncompliance in accordance with Revised Plan  8. Pursuant to Revised Plan  8.2.4, Joshua has 15 days of receipt of this letter to submit the issue to ODM for facilitation of an agreement. Thank you for your cooperation. Sincerely, ohn C. Jr. John Pendley, cc: Dr. Ken James (via hand-delivery)received cc 1 2 5 2002 OESEGREGWION MONITORING Plan to Support Low-Performing Schools Division of Instruction Little Rock School District 2002-2003 Background The Little Rock School District obtained approval from the federal court in spring 1998 for its Revised Desegregation and Education Plan. In submitting its plan to the. judge, the District willingly assumed accountability for its numerous obligations, several of which addressed the issues of student achievement. The following sections were most relevant: 2.7 LRSD shall implement programs, policies, and/or procedures designed to improve and remediate the academic achievement of African-American students. 2.7.1 LRSD shall assess the academic programs implemented pursuant to Section 2.7 after each year in order to determine the effectiveness of the academic programs in improving African- American achievement. If this assessment reveals that a program has not and likely will not improve African-American achievement, LRSD shall take appropriate action in the form of either modifying how the program is implemented or replacing the program. 5.1 Early Childhood Education. LRSD shall implement an early childhood education program which shall include a HIPPY program and a four-year-old program with no less than 720 seats. LRSD contemplates that the four-year-old classes will remain at their present site or in the same general location. 5.2.1 Primary Grades. LRSD shall implement at least the following strategies to improve the academic achievement of students in kindergarten through the third grade: a. Establish as a goal that by the completion of the third grade all students will be reading independently and show understanding of words on a page\ng. Monitor student performance using appropriate assessment devices. 5.2.2 Intermediate Grades. LRSD shall implement at least the following strategies to improve the academic achievement of students in grades four through six: a. Adopt as a goal that by completion of the sixth grade all students will master and use daily higher-level reading comprehension skills for learning in all subject areas, for 1making meaning in real life experiences, and for personal growth and enjoyment\ne. Monitor student performance using appropriate assessment devices. 5.2.3 Secondary Schools. LRSD intends to implement the following strategies to improve the academic achievement of students in grades six through twelve: a. Adopt as a goal that upon graduation all students will read independently with comprehension in all subject areas and be proficient in language arts, as necessary to be successful workers, citizens, and life-long learners\nf. Monitor student progress and achievement using appropriate assessment devices. 5.3 Mathematics. LRSD shall implement the following strategies to improve mathematics instruction. 5.3.2 Develop appropriate assessment devices for measuring individual student achievement and the success of the revised curriculum. 5.3.5 Adopt as a goal that all students in regular classes will complete Algebra and Geometry by the end of their eleventh grade year and that students will be proficient in mathematics by graduation. On September 13,2002, the federal court ruled that the District was substantially in compliance in all areas of the obligations, except Section 2.7.1, and the judge established a Compliance Remedy for the completion of a number of program evaluations. The work to meet those requirements is in progress. In the Districts Covenant for the Future, the Little Rock School District pledged to the commumty and to all employees, students, and parents to continue its efforts for the improved academic achievement of aU the children: improve the academic achievement of all students, comply with the Constitution, and ensure that no person is discriminated against on the basis of race, color, or ethnicity in the operation of the District, and provide equitable educational resources, programs, and opportunity in a nondiscriminatory environment for all students attending District schools. In June 1999 the Arkansas Department of Education published its statewide accountability plan, the Arkansas Comprehensive Testing, Assessment, and Accountability Program (ACTAAP), which was subsequently revised in June 2000. The 2'f introduction states that ACTAAP is a comprehensive system encompassing high academic standards, professional development, student assessment, and accountability for schools and students. The four stated purposes are as follows: To improve student learning and classroom instruction\nTo provide public accountability by establishing expected achievement levels and reporting on student achievement\nTo provide program evaluation data\nand To assist policymakers in decision-making. Expected outcomes include the following: It will result in improved teaching and learning. It will identify successful schools and programs and encourage replication of those successes. It will encourage individual schools and school districts to reflect on then- practices, take corrective actions, and receive support from state agencies. It will fulfill the requirements of various Arkansas statutes, including Act 999 of 1999, which mandates that all students in the public schools of this state demonstrate grade-level academic proficiency through the application of knowledge and skills in the core academic subjects consistent with state curriculum frameworks, performance standards, and assessments. At the centerpiece of ACTAAP is the states new assessment program, which in 2002- 2003 includes annual criterion-referenced Benchmark examinations in literacy and mathematics at grades 4,6, 8, and high school end-of-course/level tests in Algebra I, Geometry, and Literacy. The states testing program also includes the administration of the SAT9 at grades 5,7, and 10. Accountability indicators for the three tiers of the accountability program are established. Tier I includes the following: Performance on Benchmarks and End-of-Course/Level tests School dropout rates Average daily attendance Classes taught by an appropriately licensed teacher 3Professional development (at least 30 hours) School safety. Tier n includes the same indicators, but the assessment is based on growth over multiple years, not absolute scores. Mandated subgroups to examine include the general population, special education, limited English proficient, and high mobility students. Tier HI is a narrative of approximately 500 words, developed by staff of each school. The narrative may include the progress that the school has made in implementing its school improvement plan. Page 19 of the plan includes the following definition of adequate yearly progress to be used until the ACTAAP can be fully implemented.\nIn order to meet federal mandates, a temporary system will be developed to identify those schools designated for school improvement. Beginning in 2000- 2001 and continuing until the ACTAAP accountability system is fully operational, a school will be designated in school improvement under the following condition: Seventy-five percent or more of the students perform below proficient on either the literacy (reading and writing) or the mathematics section of the Benchmark Exam for the designated grade or grades represented by the school. It has been this paragraph upon which the Little Rock School District has based much of its decision-making relating to school improvement since 1999-2000. Clearly, both in the description of Tier I and Tier n indicators and in the page 19 paragraph, it was not the performance on the SAT9 that mattered. SAT9 scores were included only as an optional indicator. A schools entire accountability for Title I depended on its performance on the Benchmarks. In January 2001 the No Child Left Behind (NCLB) Act, which included the reauthorization of the Elementary and Secondary Education Act (ESEA), became law. The accountability provisions in Title I of this new law included, for the most part, the same language as several of the most recent reauthorizations^requirements that states and districts identify low-performing schools for improvement and requirements that progressively more intense consequences should occur for schools continuing not to improve over time. One difference in the 2001 law is that the first year a school is identified for improvement, the school must, in addition to the usual consequences, offer public school choice to the children and parents of that school so that they may elect to attend another higher performing school in the district. This option will remain in effect until the home school has earned its way out of the school improvement designation. Transportation costs must be paid out of the Title I allocation. The second year that a school is identified for improvement, the school must continue to offer choice, but must also offer, at no cost to the parent, a choice of state-approved supplemental services, or tutoring. Again, the cost of this service must be paid from Title I funds. 4NCLB requires states to establish curriculum standards and to test all students every year in both language arts and mathematics, grades 3-8, and once in grades 10-12. States must also establish an accountability system for all its public schools. The new law was to become effective at the beginning of the 2002-2003 school-year. However, implementation has been guided chiefly at both the state and local levels through Dear Colleague Letters fiom the Secretary of Education, since the formal regulations were still not complete as of late October 2002. Many, many questions regarding definitions of the mandated adequate yearly progress (AYP), what flexibility districts have in implementing the choice options, and other major issues remained unanswered. Arkansas educators assumed that the Arkansas Department of Education (ADE) plan described in the ACTAAP document for accountability remained in force, and ADE announced in June 2002 that no Arkansas schools would be identified for improvement under NCLB until the end of the 2002-2003 school year, given the phase-in of the states Benchmarks and high school tests. In September 2002 everyone awoke one morning to a headline in the newspaper that the state had been required by the federal government to change its accountability plan, that schools would be identified based upon SAT9 data, not Benchmark data, and that the public school choice and supplemental services requirements must be implemented no later than the beginning of the 2002-2003 schoolyears second semester. ADE aimounced its list of identified schools on October 16, 2002. The 1998-99 schoolyear was established as the baseline year for making the identification decisions, the percent of students performing at/above the 50* percentile of the SAT9 Basic Battery score was selected as the measurement, and the first screening of schools included all Title I schools with fewer than 25 percent of its students performing at/above the 50* percentile. Schools in that pool could also be identified for improvement if they had failed to decrease the percentage of students performing in the bottom quartile for two consecutive years. From that pool of low-performing schools, schools failing to make AYP for the two subsequent years (1999-2000 and 2000-2001), based on SAT9 data, were identified for improvement. These ongoing commitments in the Revised Desegregation and Education Plan and in the Covenant for the Future, plus the adoption of the Arkansas Comprehensive Testing, Assessment, and Accountability Program (ACTAAP) by the State of Arkansas, the passage of the No Child Left Behind (NCLB) act by the United States Congress, and ADEs identification of schools for improvement all compel the Little Rock School District to enhance its efforts to provide a higher level of monitoring, support, and intervention for its low-performing schools. Through the activities outlined in this plan, the District adds another strategy to improve the academic achievement not only for Afiican American children, but for all children, whether representing a race/ethnicity, gender, firee/reduced lunch status, disability, or limited English proficiency subgroup. Stq)s have already been taken by the Division of Instruction to assume new roles and responsibilities in supporting school improvement. For the past two years curriculum 5staff and PRE staff have provided principals meeting in small groups a complete set of school performance data, including assistance in analyzing those data and support in implementing their school improvement plans. Division of Instruction staff concentrated many of their efforts on low-performing schools in 2001-2002, including the monitoring of Student Academic Improvement Plans (SAIPs), targeting those schools for grant proposals (Comprehensive School Reform grants and the Reading Exellence Act grants), providing follow-up professional development, consultation, and school visits. Needs Assessment According to the Arkansas Department of Education in its October 16, 2002, communication to the Superintendent, the following Little Rock School District schools have been identified in 2002-2003 for improvement: Bale Elementary (1 year) Baseline Elementary (2** year) Chicot Elementary (2\" year) Dodd Elementary (1* year) Fair Park Elementary (P* year) Mabelvale Elementary (L year) Mitchell Elementary (Pyear) Stephens Elementary (2\" year) Wakefield Elementary (2\" year) Watson Elementary (2\" year) Henderson Middle (1 year) Mabelvale Middle (1 year) Southwest Middle (l year) ADEs letter to the Superintendent included the following information relating to Removal from School Improvement: All schools, except high schools, listed in this notification will be eligible for removal from school improvement based on AYP as measured by the Benchmark exams and described in the Arkansas Comprehensive Testing, Assessment, and Accountability Program (ACTAAP). Specifically, these schools will be eligible for removal following the 2003 administration of these exams based on two consecutive years ofAYP with 2000-2001 designated as the baseline year. Several issues remain unclear\n1. Whether AYP will be defined based on ten years or twelve years to reach 100 percent proficient/advanced\n2. Whether AYP will be defined for one year or over a two-to-three year period\n63. 4. 5. 6. Whether schools identified for school improvement in this first group will be accountable for subgroup performance\nHow AYP for subgroups will be determined\nWhat the minimum number of students will be to be considered a subgroup\nWhether the high priority schools will continue to be defined as those with fewer than 25 percent performing at the proficient/advanced levels. The deadline for states to submit their accountabihty plans, definitions for AYP, and related issues to the U. S. Department of Education for approval is the end of the calendar year. It is likely, therefore, that districts will not know until late spring or early summer what the rules will be for some of these issues related to schools already identified for improvement and for the new identification that will occur when 2002-2003 Benchmark scores are received. The Little Rock School District, however, cannot wait for answers to all these questions in order to begin providing the necessary support, assistance, interventions, and monitoring required to help the identified schools exit the School Improvement designation and to prevent as many additional schools as possible from being identified at the end of 2002-2003. To assess greatest need and to enable the Division of Instruction to determine priorities, a more complete needs assessment was conducted. The following matrix lists the schools that have been formally identifi\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":"wgbh_tdcr_019","title":"Concerned White Citizens of Alabama scrapbook","collection_id":"wgbh_tdcr","collection_title":"Teachers' Domain Civil Rights Special Collection","dcterms_contributor":null,"dcterms_spatial":["United States, Alabama, Dallas County, Selma, 32.40736, -87.0211","United States, Alabama, Jefferson County, Birmingham, 33.52066, -86.80249"],"dcterms_creator":["WGBH Educational Foundation"],"dc_date":["2002"],"dcterms_description":["Instructional Web site recommended for grades nine through twelve featuring the documents related to the Concerned White Citizens of Alabama. In response to the strict segregation and racial violence that dogged Alabama's black community in the 1960s, 72 whites formed the Concerned White Citizens of Alabama. They promoted equality and marched in support of voting rights for African Americans. This scrapbook contains the group's constitution, a flyer from 1965, membership cards, and a statement of purpose that was used in a voting rights demonstration.","Includes a background essay, discussion questions, and alignments to teaching standards.","Major funding for this project is provided by the Institute of Museum and Library Services. Supported in part by a grant from the Open Society Institute.","Grade range: 6-12.","The Teachers' Domain Civil Rights Collection is a collaborative production of WGBH Education Productions, the WGBH Media Library, and WGBH Interactive, in partnership with the Birmingham Civil Rights Institute and Washington University in St. Louis.","The Civil Rights Digital Library received support from a National Leadership Grant for Libraries awarded to the University of Georgia by the Institute of Museum and Library Services for the aggregation and enhancement of partner metadata."],"dc_format":["text/html","application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["WGBH Educational Foundation"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Concerned White Citizens of Alabama","Civil rights workers--Alabama","Alabama--Race relations","Nonviolence","African Americans--Civil rights--Alabama--Birmingham","Civil rights movements--Alabama--Birmingham"],"dcterms_title":["Concerned White Citizens of Alabama scrapbook"],"dcterms_type":["Text"],"dcterms_provenance":["Birmingham Civil Rights Institute (Birmingham, Ala.)"],"edm_is_shown_by":null,"edm_is_shown_at":["https://pbslearningmedia.org/resource/iml04.soc.ush.civil.concern/"],"dcterms_temporal":["1945/1975"],"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["instructional materials","teaching guides","resource units","fliers (printed matter)","administrative records","membership cards","constitutions"],"dcterms_extent":["501.8 Kb"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1722","title":"Court filings: District Court, Joshua intervenors' preliminary exhibit list regarding January 28, 2002, hearings; District Court, three orders; District Court, District Court, notice of filing, Arkansas Department of Education (ADE) project management tool","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["2002-01"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--21st Century","Joshua Intervenors","Arkansas. Department of Education","Education--Arkansas","Education--Evaluation","Education--Standards","Educational law and legislation","School management and organization","School integration","School discipline","Student activities","Parents","School administrators","School employees"],"dcterms_title":["Court filings: District Court, Joshua intervenors' preliminary exhibit list regarding January 28, 2002, hearings; District Court, three orders; District Court, District Court, notice of filing, Arkansas Department of Education (ADE) project management tool"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1722"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["judicial records"],"dcterms_extent":["143 pages"],"dlg_subject_personal":["Springer, Joy C."],"dcterms_subject_fast":null,"fulltext":"This transcript was create using Optical Character Recognition (OCR) and may contain some errors.   IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION CEIVED 2 2001, OFFICE OF DESEGREGATION M0NITOR!NQ LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V CASE NO. 4:82CV00866 SWW PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. DEFENDANT INTER VENO RS INTER VENO RS l\\llRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. JOSHUA INTERVENORS' PRELIMINARY EXHIBIT LIST REGARDING JANUARY 28. 2002 HEARINGS The Joshua Intervenors plan to use the following documents during the January 28, 2002 hearings: 1. E-mail dated July 2, 200 l from Virginia Johnson to Bonnie Lesley (page 182) 2. E-mail dated October 19, 2000 from Gary Smith to Bonnie Lesley ( page 290) 3. E-mail dated June 29, 2001 from Sueellen Vann to Gail Hester and subsequent dated July 2, 2001 (page 167) 4. E-mail dated January 18, 2001 from Junious Babbs to Kathy Lease (page 12) 5. E-mail dated July 2, 2001 from Mona Briggs to Bonnie Lesley ( page 191) 6. E-mail dated November 16, 2000 from Les Carnine to Bonnie Lesley 7. E-mail dated November 21, 2000 from Ken Savage to Kathy Lease (page 38) 8 E-mail dated March 7, 2001 from Kathy Lease to T Rose and subsequent dated March 7, 2001 at 12:44 p.m. (page 7) 9. E-mail dated July 15, 2001 from Bonnie Lesley to Lionel Ward and subsequent dated July 16, 2001 (page 88) 10. E-mail dated July 14, 2001 , July 15, 2001 and July 16, 2001 from Bonnie Lesley to Ken James (page 96) 11 . E-mail dated July 15, 2001 from Bonnie Lesley to Chris Heller (page 102) 12. E-mail dated April 18, 2001 from Bonnie Lesley to Kathy Lease and subsequent response (pages 708 and 709) 13 . E-mails dated October 25, 2001 from Bonnie to Irma Truett and Kathy Lease re: Benchmark scores (pages 16 and 1 7) 14. E-mail dated June 28, 2001 8:00 p.m from Mona Briggs to Bonnie Lesley (page 192 15. E-mail dated June 28, 2001 9:08 a.m from Bonnie Lesley to members of her staff (Page 192 and 193) 16. E-mails dated September 29, 2000 between Bonnie Lesley and Kathy Lease re: Priorities 2000-01 (Page 51) 17. E-mail dated October 3, 2000 between Les Carnine. Bonnie Lesley and Kathy Lease Re: ALT Check-in (Page 50) 18. E-mail dated June 20, 2001 from Bonnie Lesley to Beverly Griffin re: semester test Exemption (Page 3 51) 19. E-mail dated June 25, 2001 from Bonnie Lesley to Clay Fendley (page 297) 20. E-mails dated June 29, 2001 between Sadie Mitchell, Deanna Eggeston and Bonnie Lesley (page 219) 21. E-mails dated February 12 and 13, 2001 Lesley, Ruffins, Lease and Carnine (page 19) 22. Email dated February 13m 2001 from Kathy Lease to Les Carnine (Pages 17 and 18) 23. Memo dated November 17, 2000 from Dr. Faucette to Mrs. Hargis re: exclusion of Regular English students fro Jennie Calder lecture 24. Email dated September 27, 2000 from Saie Mitchell to Junious Babbs (Page 1) 25. Letter dated December 16, 1998 to Les Carnine from Joy Springer 26. Letter dated February 18, 1999 to Sadie Mitchell from Joy Springer - 27. Letter dated March 17, 1999 to Rudolph Howard from Joy Springer 28. Letter dated October 14, 1999 to James Washington from Joy Springer 29. Letter dated Februa1y 28, 2000 to James Washington from Joy Springer 30. Letter dated February 28, 2000 to James Washington from Joy Springer re: Scouts 31. Letter dated August 28, 2000 to Ray Gillespie from Joy Springer \"') .)~. Letter dated September 12, 2000 to Les Carnine from Joy Springer \"_)\".) . Letter dated October l 0, 2000 to Les Carnine from Joy Springer 34. Letter dated September 13 , 2000 to James Washington from Joy Springer 35 . E-mail dated June 6, 2000 to Les Carnine from Don Stewart (Pages 100-01) 36. E-mail dated April 19, 200 l from Deanna Eggeston to Don Stewart ( Page 3 7) 37. E-mail dated April 25, 200 l from Kathy Lease to Mark Millhollen - 38. E-mail dated May 25 , 200 l from Bonnie Lesley to Debbie Berry (Page 3 58) 39. E-mail dated .June 7, '.?.000 from Clay Fendley to Bonnie Lesley 40 E-mail dated June 7, 2000 from Bonnie Lesley to Mary Paa! (Page 136) 4l . E-mail dated April 17-18, 2001 to Don Stewart from Bonnie Lesley 42. E-mail dated July 12, 2001 to Bonnie Lesley from Don Stewart (240) 43 . E-mail dated February 28, 200 I to Bonnie Lesley from Don Stewart 44. Memo dated February 24, 1999 to Gayle Bradford from James Washington 45 . Memo dated March 11 , l999 to Les Carnine from James Washington 46. Letter dated April 12, 1999 to Gayle Bradford from James Washington 47. Letter dated March 22, 1999 to Gayle Bradford from James Washington 48 . Letter dated April 26, 1999 to John Walker from Les Carnine - 49. Memo dated tvJay 3, 1999 regarding visit to Pupil Services \u0026 Administration buildings Joshua reserves the right to utilize exhibits listed by Little Rock School District and further reserves the right to sup plement this list after additional discovery. Respectfully submitted, John W. Walker, P A. 1723 Broadway Little Rock, AR 72206 501-374-3758 501-374-4187 fax Byf)4W~ CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing exhibit list and exhibits have been hand carried to counsel for the Little Rock School District and the Office of Desegregation Monitoring on this 2nd day of Janaury, 2002. LESLEY, BONNIE From: LESLEY, BONNIE Sent: Monday, July 02, 2001 2:24 PM To: 'heller@fec.net' Subject: Latest Fax I had Anita fax over to you the latest--a bunch of stuff on our literacy plan. 1. He already has a copy of the PreK-3 Literacy Plan. Other information is in the Interim and Final Compliance Reports. 2. He also has the test results for SAT9, Grade 4 Benchmark, and DRA--so those are the results. 3. I don't know what he means by monitoring reports. 4. The assessment program is outlined in several pages in the Compliance Report. 5. I can copy those policies and regs for him. Want me to go ahead and send? Dr. Bonnie A. Lesley, Associate Superintendent for I nstruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/ 324-0567 (fax) - LESLEY, BONNIE From: LESLEY, BONNIE Sent: Monday, July 02, 2001 1 :44 PM To: JOHNSON, VIRGINIA Subject: RE: Needed Information-Important! Do you have dates for those three times? - Original Message- From: JOHNSON, VIRGINIA Sent: Monday, July 02, 2001 1 :15 PM To: LESLEY. BONNIE Subject: RE: Needed Information-Important! Three times I sat in on sessions with Steve Ross along with other PRE staff. At no time did we review anv NSF documents. The sessions focused on document review of the ESL and Pre-K Literacy reports. I have never \"consulted\" with him. I have never consulted with Dr. Roberts either. -Original Message- From: LESLEY, BONNIE Sent: Monday, July 02, 2001 12:07 PM To: __ ADAMS, LEON; ARNOLD, LAURA BETH; AUSTIN, LINDA; BRANDON, BARBARA; BRIGGS, MONA R.; BROADNAX, KAREN; BUSBEA, PAT; CARR, MARCELLINE; CARSON, RENE'; CLEAVER, VANESSA; CLIFFORD, ELIZABETH; CRAWFORD, PAMELA; DAVIS, SUZI; DEBBIE MILAM; DILLINGHAM, YVETTE; DONALDSON, MABLE; FINNEY, ANTONETTE; FLETCHER, DANNY; FREEMAN, ANN; GILLIAM, ANITA; GLASGOW, DENNIS; HARDING, CASSANDRA; HUFFMAN, KRIS; JACKSON, MARION; JOHNSON, VIRGINIA; JONES, DOCIA; JONES, STEPHANIE; KIILSGAARD, SHARON; KILLINGSWORTH, PATRICIA; KOVACH, RENEE; LAJUANA RAINEY; LOYA, STELLA; MARION BALDWIN; MARTIN, PAULETTE; McCOY, EDDIE; McNEAL, MARIE; MILA.M, JUDY; NEAL, LUCY; PAAL, MARY M.; PAUL. ANNITA; PERRITT, YORIKO U.; PRICE, PATRICIA; RYNDERS, PAULA; SMITH, GARY; SMITH, PAULA; TE::TER, JUDY; WALLS, COLLEEN; WARD, LIONEL; WILLIAMS, BARBARA; WILLIAMS, ED; WILSON, LEVANNA; WOODS, MARION Subject: Needed Information-Important! 182 smmitch@lrsdadm.lrsd.k12.ar.us -Original Message- From: CARNINE, LESLIE V. Sent: Thursday, October 19, 2000 1 :59 PM To: MITCHELL, SADIE Cc: NEAL, LUCY: LESLEY, BONNIE; LEASE, KATHY R.; SMITH, GARY Subject: RE: Will we have the software available by 2nd Semester? What system(s) are being looked at? -Original Message- From: MITCHELL, SADIE Sent: Thursday, October 19, 2000 10:33 AM To: CARNINE, LESLIE V. Subject: FW: Sadie Mitchell smmitch@lrsdadm.lrsd.k12.ar.us -Original Message-' From: SMITH, GARY Sent: Thursday, October 19, 2000 10:25 AM To: LESLEY, BONNIE Cc: WARD, LIONEL: GADBERRY, BRADY L.; NEAL, LUCY; MITCHELL, SADIE: CAWTHON, FRANCES H.; LACEY, MARIAN G.: Subject: Dr. Lesley, ADAMS, LEON; AUSTIN, LINDA; BRADFORD, GAYLE; BRIGGS, MONA; BROADNAX, KAREN; CLEAVER, VANESSA; COLFORD, SUSAN: DAVIS, SUZI: DONALDSON, MABLE: Eddie McCoy; ELSTON, JO; FULLERTON, JAMES; GLASGOW, DENNIS; HAWKS, EVERETT; KEOWN, ADA: MARION BALDWIN; NORMAN, CASSANDRA R.; PRICE, PATRICIA; TATUM, KATHY; WYATT-ROSS, JANICE The consensus recommendation of the SAIP committee is for a SAIP be created for students at all grade levels who are not proficient based state mandated benchmark tests and/or District mandated Achievement Level Tests (ALT) - Our specific recommendations to implement this are;  obtain/create the software necessary to identify students not proficient on state benchmarks/district assessment that will also generate/print the adopted SAIP form with student information and test scores printed on the SAIP form  obtain/create the software that will generate/print specific strategies (along with and printed checklists for those who wish not to use computer) developed by a committee made up of teachers and curriculum specialists as a resource available for teachers to use (especially secondary teachers) - this can be attached to the SAIP form as needed  develop an \"instructional\" sheet for the SAIP form that will explain in more detail the information to documented and procedures to follow  provide training on the use of SAIP form directly to teachers (the exact training may have to be determined at a future date based on the development of software noted above) - delivery of training would need to be coordinated with staff development for most effective and comprehensive presentation to all teachers to all of you in Cyber Land - is there anything e!se I forgot? - thanks Gary 290 LESLEY, BONNIE From: BABBS, JUNIOUS Sent: To : Monday, July 02, 2001 8:08 AM ELSTON, JO Cc: Subject: NEWBURN, LINDA; LESLEY, BONNIE RE: Counseling Program Kit Message Flag: Follow up Due By: Flag Status: Monday, July 09, 2001 5:00 PM Flagged It is positive to see that things are moving forward on this \"01 - 02 priority. Prior to coming to closure, I ask that your look to set up a time to fill me in on the \"buy in\" of players called upon (committee members) to develop districtwide literature to be distributed. The connection to Curriculum and Instruction is a biggee that should be run through Dr. Lesley. I will look to give you a call a bit later regarding B/W high school scholarship information and the 3 - 4 year comparisons. To date, this information has not been provided. Junious C Babbs, Jr ' jcbabbs@stuasn.lrsd.kl 2. ar. us Little Rock School District -Original Message- From: VANN, SUELLEN Sent: Friday, June 29, 2001 11 :08 AM To: HESTER, GAIL Cc: ELSTON, JO; BABBS, JUNIOUS Subject: Counseling Program Kit Jo Evelyn Elston is in my office, and we're working on a counseling program kit with insert sheets. Mr. Babbs will pay for this out of his budget. I'm going to talk with Kristy Black about the design of the kit and sheets, but I figured we'd better give you the info for the quote since it looks like a pretty good-sized job. The kit will be one-pocket on right side with a business card slot; the kit will print front and back with one pocket. There won't be a separate \"wing\" like the recruitment kit had. Quantity: 25,000 Jo Evelyn likes the paper we used for the recruitment kit and insert sheets, so we could just go with those. The insert sheets: 1. JOB BS sheet - print front only; quantity 30 ,000 2. Early college planning sheet - print front only; quantity 20,000 3. PCEP sheet - print front only; quantity 20,000 4. What Does Counselor Do? sheet - print front only; quantity 30,000 5. Counseling program sheet - print front and back; quantity 30,000 6. Couseling fact sheet - print front only; quantity 30,000 The kit and insert sheets would print 4-color. Have I forgotten anything? No bleeds. THANKS! (Mr. Babbs, you might want to set up a lemonade stand on Sherman to pay for this!!!!!) Suellen 5. Vann, APR Director of Communications Little Rock School District (501) 324-2020 167 LESLEY, BONNIE A,From: LEASE, KATHY R. W,Sent: To: Thursday, January 18, 2001 6:06 PM BABBS, JUNIOUS Subject: RE: Seciion 2 Thanks for the input! We have been with the program evaluation consultant all day, so I just finished editing the report to send to Bonnie. I will incorporate your changes and suggestions, and send it to her again. Do you want the Power Point as an Appendix or the outline for it incorporated into the body of the report? I'm so sorry I am just getting around to my email, but I'll take the heat for sending another correction. Not enough hours in the day!! Kathy PS--Thanks for the encouragement! ----Original Message----- From: BABBS, JUNIOUS Sent: Thursday, January 18, 2001 10:53 AM To: LEASE, KATHY R. Cc: GADBERRY, BRADY L. Subject: FW: Section 2 Good information. Working with timelines and specific report information submissions for this division, I have not been able to dissect in great detail but my original thinking touches upon 2 - 3 items that may warrant some review. You will note that Brady is also being forwarded who can provide his thinking as well. Future compliance sessions will toss this about for further revision. 1. Inclusion of the power point presentation. 2. When touching upon Or. Ross - It may be advantageous to refer to \"looks to build or acknowledges\" specific district A.efforts as opposed to \"praising\". W,3. It would be appropriate to list current data that is available. Be reminded that when writing materials for our report submission, we wi ll include \"districtwide\" not be there yet but this will help to serve as an indicator of established base Ine information from which we will jump off of. - Keep your ch in up . . Junious C Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District --Original Message- From: LEASE, KATHY R. Sent: Wednesday, January 17, 2001 6:14 PM To: LESLEY, BONNIE Cc: BABBS, JUNIOUS; DILLINGHAM, YVETTE; HUFFMAN, MAC; JOHNSON, VIRGINIA; McCOY, EDDIE; SUMMERVILLE, ROSALYN P.; TRUETT, IRMA; WILLIAMS, ED Subject: Section 2  File: Deseg Report (2. 7.1 ).doc  Bonnie, Here is the first draft of Section 2.7.1. Please let me know what additions or revisions you want made. Thanks, Kathy PS--PRE folks--Look to see what I left out, what typos I have, and what needs to be edited. Thanks 12 Chris, I am in LR this week-end and you can reach me at 868-4289. I can come to your office to help, or I can work from my office. Call if you need me. - Are we having fun yet? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District  3001 S. Pulaski Little Rock, Arkansas 72206 501/ 324-2131 501/ 324-0567 (fax) LESLEY, BONNIE From: LESLEY, BONNIE Sent: To: Monday, July 02, 2001 8: 16 AM BRIGGS, MONA R. Subject: RE: Thank you, my friend. I \"vegged\" all week-end, seriously \"vegged.\" I know this will be a HARD week. Yes, I hear Kathy is on his witness list It'll be interesting. --Original Message- F rom: BRIGGS, MONA R. Sent: Monday, July 02, 2001 6:53 AM To: LESLEY, BONNIE Subject: RE: I have been thinking a lot about you. You can't let this bring on a stroke or something. You don't need this kind of pressure all by your self!! It is not worth it-no job is worth it . And you can't take on the woes of a district that has been screwing up for a decade or more. I hope Kathy does get called to testify. She needs to have to answer to John Walker and if it bodes ill for the district so be it! She and Carnine just waltzes out of here and leaves everyone else holding the rope. You make time for sleep and food!! Mona R. Br iggs Middle Level Specialist Little Rock School District 501-324- 2412 \"Seek rirst to Unders tand; then to be understood\" (Covey) - - - --Original Message--- -- - From: LESLEY, BONNIE Sent : Friday, June 29, 2001 7:55 AM To: BRIGGS, MONA R. 191 STEWARr;oo~ALD M~ . From: CARNINE, LESLIE V. Sent: Thursday, November 16, 2000 12:23 PM To: LESLEY, BONNIE Cc: BABBS, JUNIOUS; Mitchell, Sadie; GADBERRY, BRADY L.; STEWART, DONALD M. Subject: Upper Division Classes and African Americans Were you able to pull together the numbers--last year and this year's enrollment? John Walker also has called and is questioning his non involvement in the policy development(IKF). I told him I thought the evidence was so strong for Black kids and that I would send him the information . When was the first time he would have received the policy for comment? He is raising much the same issue--impact on black kids as Katherine ... lKF Cc: Subject: LESLEY, BONNIE; CARNINE, LESLIE V. RE: Chart Revisions Ken, Thanks so much for this explanation of what happened. The important thing about making a mistake is finding a way not to make it again. I think you have done this, and we will all profit from it. I know you feel really badly about this, but the most important thing is to correct the process. We all make mistakes. We are committed to quality in PRE and that includes continuous improvement and continuous learning. This experience has provided us with both. What a bonus!! Thanks for helping with the corrections. I will take care of getting them to the appropriate Cabinet people and getting them redistributed to the Board. - OriginalMessage- From: SAVAGE, KEN Sent: Tuesday, November 21, 2000 10:31 AM To: LEASE, KATHY R. Subject: Chart Revisions Dr Lease, I have reviewed the charts that I created from the benchmark data. When I created the charts originally I had encountered a problem similar to the one described by Dr. Lesley, but I specifically remember correcting the error prior to sending the charts to you. Needless to say, I was more than a little alarmed that the charts you received contained errors because the charts I have appear to coincide with the data I have. I went on further to investigate by looking at the email I sent you. And there, big as day, the error had reappeared. So the charts I had sent you were incorrect because they were never updated in the manner that I expected. Here is what I believe happened based on what I remember and what I learned th is morning: I created the charts in an Excel document that contained the data. I copied the charts only out into another document, creating what is called a linked object. I printed and reviewed the charts and this is when I found the error. I corrected the error and reopened the \"linked\" charts. They appear to have accepted the corrections. I emailed the file with the linked charts to you rather than the file containing the charts and data. Here's where the problem arose and information that I have just become aware of this morning.  First, when using linked objects, each time you open the file you are given a choice to update the information. Unfortunately, I only sent you the charts and not the data that drives them. So regard less, you could not have updated the charts.  Second, and more importantly, even though a chart has been updated previously, it will always revert back to the original chart that was corrected no matter how many times the data has been updated. Third, if the file with the original data is already open, when the \"linked\" item is opened it automatically updates without intervention. I believe that the second option above is what occurred. The charts were created, an error was encountered and corrected, the link was updated but the chart reverted back to its original when the file was closed. What I propose to do to prevent th is kind of fiasco in the future is: 1. Only send charts embedded in files which contain the data--no linking. 2. Only create the \"linked\" charts after ALL data has been proofed and corrected. \" The erroneous data was only last year's data for black students in the comparison between this year and last'year for both) Math and Literacy. I am printing and will send ten revised copies of the charts. Ken. 38 LESLEY, BONNIE From: LEASE, KATHY R. Sent: To: Wednesday, March 07, 2001 12:44 PM BABBS, JUNIOLJS - Subject: RE: Research Committee Meeting Bonnie said that the evaluations weren't part of the court submission. Is that still correct? If so, then it looks like we shou ld slow down a bit and do it ngm. Are you In agreement? ._ KL  -----Original Message----- From: BABBS, JUNIOUS Sent: Wednesday, March 07, 2001 12:36 PM To: LEASE, KATHY R. Subject: RE: Research Committee Meeting Original thinking was to get another date scheduled prior to the March 15th court submission but with information you have noted, consideration of a later date is necessary. I don't see major conflict. Junious C Babbs, Jr jcbabbs@stuasn.lrsd.kl2.ar.us Little Rock School District -Original Message- From: LEASE, KATHY R. Sent: Wednesday, March 07, 2001 12:27 PM To: 'trrose@ualr.edu'; BABBS, JUNIOUS Subject: Research Committee Meeting Importance: High We have had another committee member who will not be able to come to the meeting on the 13th. We now have agenda meeting at 5:00, and Steve can only be with us by phone. What do you all think about postponing the meeting until after spring break? That would give John plenty of time to make revisions, and we can schedule a meeting when Steve can be with us. I hope to have the template/program evaluation guidelines completed by then as well. Let me know what you think! Kathy Kathy Lease, Ed.D. Assistant Superintendent Planning, Research, and Evaluation 3001 S. Pulaski Little Rock, AR 72206 501-324-2122 (VM) 501-324-2126 (Fax) krlease@irc.lrsd. kl2.a r. us 7 LESLEY, BONNIE From: LESLEY, BONNIE Sent: Monday, July 16, 2001 7:2'1 PM To: MITCHELL, SADIE Subject: RE: Documents yes, thanks. I need asap. - Original Message- From: MITCHELL, SADIE Sent: Monday, July 16, 2001 5:51 PM To: LESLEY, BONNIE Cc: WASHINGTON, CHARLOTTE Subject: Documents We got the list of documents on file done but I forgot to remind Charlotte to send it to you. She is gone for the day and it is on her computer. You will have it first th ing in the morning. Sadie Sadie Mitchell smmitch@lrsdadm.lrsd.kl2.a r. us LESLEY, BONNIE From: LESLEY, BONNIE Sent: Monday, July 16, 2001 7:24 PM A To: WARD, LIONEL W subject: RE: SAIP He requested info from me. I to ld him I had given him all I had but that you are the administrator on this issue. I was following up to see if he had contacted you. -Original Message- From: WARD, LIONEL Sent: Monday, July 16, 2001 4:29 PM To: LESLEY, BONNIE Subject: RE: SAIP Are you trying to tell me something? I have not received any such request from Mr. Walker. If he talks with me, I will talk to you about a proper response first. One basic problem with implementation is in the thought some might harbor which explains why their efforts started late in the game. I am sure some folks faced more struggles than others. Clearly, schools must satisfy the requ irements with wise, careful and timely deliberations this year. ( -----------O- riginal MeSSoge--- ' From: LESlc--Y, BONNIE Sent: Sunday, July 15, 2001 3:49 PM To: WARD, UONEL Subject: SAIP - Lionel, has Mr. Walker requ ested anything from you about the implementation of SAIPs? If so, what did you send to him? Thanks. v- Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 88 501/324-0567 (fax) - LESLEY, BONNIE From: LESLEY, BONNIE . Sent: Monday, July 16, 2001 8: 16 AM To: JAMES, KENNETH Subj ect: RE: Work in Progress Absolutely! -Original Message- From: JAMES, KENNETH Sent: Monday, July 16, 2001 7:54 AM To: LESLEY, BONNIE Subject: RE: Work in Progress Bonnie: I agree. The work and time that you have invested in this will indeed pay off, as the testimony unfolds. It will be interesting to see how the judge handles all of this information and to observe her thought process. Ken ---Original Message----- From: LESLEY, BONNIE Sent : Sunday, July 15, 2001 9:\u003cl.2 PM To: JAMES, KENNETH Subject: RE: Work in Progress When I left today, I left a lot still un-done, but I left feeling more and more certain that we have strong evidence that we did the plan. This is going to be helpful to me in remembering all the efforts-even if Chris decides not to use some of it as evidence. I think it will particularly be strong when we combine what Sadie has with ours in this Division. -Original Message- From: JAMES, KENNETH Sent: Sunday, July 15, 2001 9:34 PM To: LESLEY, BONNIE Subject: RE: Work in Progress Bonnie: I have reviewed both documents and they are excellent at showing what has been accomplished in the areas of evaluation and assessment. Great job! We will touch base tomorrow. Ken - --Original Message----- From: LESLEY, BONNIE Sent: Saturday, July 14, 2001 6:24 PM To: 'heller@fec.net'; JAMES, KENNETH; MITCHELL, SADIE .. Subject: Work in Progress I've worked today on getting the ideas laid out about assessment/program evaluation. That includes collecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback.  File: 1 Program Evaluation.doc \u003e\u003e  File: 1 Assessment Grid.doc  96 Uttle Rock, Arkansas 72206 501/324-2131 501/ 324-0567 (fax) LESLEY, BONNIE From: Sent: To: Cc: Subject: LESLEY, BONNIE Sunday, July 15, 2001 3:41 PM 'heller@fec.net' JAMES, KENNETH SAIPs Mr. Walker requested on June 20 the follow: \"Please advise whether you have information regarding the District's implementation of STudent Academic Improvement Plan (SAIP} as required by the State. If so, please share with this this office.\" I replied: \"You will find that information in the March 2001 Compliance Report in Section 2.7. I do not have any information beyond what you will find there since the implementation is done at the school level. Leonel Ward is in charge of implementation.\" When I searched everything for the documents I needed from you, I found several memos in Learn ing Links that I had fo rgotten about--about the philosophy in implementing SAIP, sample SAIPs done by Price, Glasgow, and Davis, the memo establishing the committee to develop the program, the memo to the board, etc. Should I forward those to Mr. Walker as well? . Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 6 501;324-2131 W 501/324-0567 (fax) LESLEY, BONNIE From: LESLEY, BONNIE Sent: Saturday, July 14, 2001 6:24 PM To: Subject: 'heller@fec.net'; JAMES, KENNETH; MITCHELL, SADIE Work in Progress I've worked today on getting the ideas laid out about assessmenUprogram evaluation. That includes coJlecting and organizing stacks of paper that document our work and processes. In addition, please see the attached documents to determine if this is where we want to go. I welcome your feedback. 1 Program E.va!uation.ooc 1 Assessment Grid.doc Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School -District 3001 S. Pulaski Little Rock, Arkansas 72206 501/ 324-2131 - 0l/ 324-0S67 (fax) 102 LESLEY, BONNIE A From: W sent: To: Cc: Subject: Don Crary [dcrary@newfuturesforyouth.org] Wednesday, April 18, 2001 1 :33 PM LESLEY, BONNIE mopierce@newfuturesforyouth.org Re: Computer with Access Great. We can pay for it. I'm sure it will be cheaper if it is purchased through the'district contract. The district can invoice us and we will reimburse them for the cost. Don -----Original Message--- From: LESLEY, BONNIE \u003cBALESLE@IRC.LRSD.K12.AR.US\u003e To: 'dcrary@newfuturesforyouth.org' \u003cdcrary@newfutu resforyouth .org\u003e Cc: BRIGGS, MONA R. \u003cMRBRIGG@ANNEX.LRSD.K12.AR.US\u003e; PAAL, MARY M. \u003cMMPAAL@ANNEX.LRSD.K12.AR.US\u003e Date: 04/18/2001 12:50 PM Subject: Computer with Access \u003eI talked with Mona about your need for a dedicated computer somewhere in the \u003edistrict so that your evaluator can come work on direct access to the data \u003ebase. She is arranging for an additional computer drop in the office that \u003eMary Paal will have at Garland. Can you all purchase the computer out of \u003eyour budget? \u003e - Dr. Bonnie A Lesley, Associate Superintendent for Instruction \u003eLittle Rock School District \u003e3001 S. Pulaski \u003eLittle Rock, Arkansas 72206 \u003e501 /324-2131 \u003e501 /324-0567 (fax) \u003e \u003e LESLEY, BONNIE From: Sent: To: Cc: Subject: Bonnie, LEASE, KATHY R. Wednesday, April 18, 200112: 32 PM LESLEY, BONNIE MITCHELL, SADIE; CAWTHON, FRANCES H. ; LACEY, MARIAN G. RE: ALT Results What group of principals did you meet with yesterday? Do I need to contact them? I explained to all of them when we did the testing calendar that we could get results back to everyone before school was out, if they followed the schedule. If there are some that we need to follow up with, please let me know who they are. We are returning ALT results as quickly as schools get them in. The whole purpose of setting up the schedule like it is centers around being able to get the results back to everyone before school is out. District results can't be calculated until all schools are in. That is why it is imperative that everyone stay on schedule. Both teachers and parents will get their results unless someone doesn't follow the schedule. A Second grade results have all been returned to the schools, along with two copies of the parent report. W High school preliminary results have been returned to Parkview and Fair. McClellan's results are here and are being scored. Central and Hall have not turned in their answer sheets yet. All make-ups were to have been completed by this past Monday. Retests for high schools are due back on Friday. The first page of the parent report can be printed, but we can't print the longitudinal report for parents unless all high schools are in. 708 Our elementary schools did a great job during 2nd grade testing; so if they keep that up, we will sail right through their scoring and printing. They have all of their results. We're still missing two of the middle schools' Algebra I / geometry resu lts as of this morning. We are having a scoring M robiem with the high school science tests, but NWEA is working on it. The subject specific math and science tests w equire no retests, so that shouldn't hold things up. Also, we have provided data on request any school who wants to know last fall's ALT scores for their rising grade students. If you have any other questions, please let me know. Kathy -----Original Message----- From: LESLEY, BONNIE Sent: Wednesday, April 18, 2001 10:37 AM To: LEASE, KATHY R. Subject: ALT Results I met with a group of principals yesterday who suggested to me that if they can't receive their ALT results before school is out that there is no use in sending them at all. Kids and parents need them quickly, and the school needs them quickly in order to plan for next school year. What our your chances of being able to do that? Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/324-0567 (fax) LESLEY, BONNIE From: .aient: w o: Subject: ~ ~ Rose.doc Paulette Mabry [pmabry@newfuturesforyouth.org] Wednesday, April 18, 2001 10:59 AM Bonnie Lesley; Brady Gadberry; Junious Babbs; Linda Austin; Marian G. Lacey; Sadie Mitchell Words to encourage us Thought you might enjoy this today as a way to jumpstart the afternoon when things seem impossible. Paulette LESLEY, BONNIE From: Sent: To: Subject: Importance: BRIGGS, MONA R. Wednesday, April 18, 2001 10:10 AM LESLEY, BONNIE Cost of Tools for Learn ing (Fred Jones); Parent Component High The discounted costs of books is: 500 books @-$18.00 (regula rly priced at 29.95) 300-499@ $18.50 200-299@ $18.95  0-199@ $19.95 Shipping for 500 is $546.75; it may be slightly less for fewer numbers but not significantly. RE: Parent involvement with train ing 709 From: LESLEY, BONNIE Sent: Wednesday, October 25, 2000 9:44 AM To: TRUETT, IRMA Subject: Benchmark Scores I need copies of the state test results by school in my office asap. Board members and others are calling for information. Dr. Bonnie A. Lesley, Associate Superintendent for Instruction Little Rock School District 3001 S. Pulaski Little Rock, Arkansas 72206 501/324-2131 501/.324-0567 (fax) GADBERRY, BRADY L. From: Sent: To: Subject: Bonnie, LEASE, KATHY R. Wednesday, October 25, 2000 8:17 PM LESLEY, BONNIE Benchmark Scores Irma forwarded your messages to her about the test scores. As I told you when we met with Suellen, I would have your curriculum copies ready by Friday. They are ready now. After learning that you were insistent on having the scores immediately, I s "},{"id":"bcas_bcmss0837_980","title":"Discipline: ''Analysis of Disciplinary Actions, District Level,'' North Little Rock School District, 2 copies","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":["2002/2003"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. 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JACKSON Director of Student Affairs ' ) uu.l mcEoF OESEGREMmilOnKo RGI Ref: Date: Time: DIS032 9/16/03 13: 38: 18 Analysis of Disciplinary Actions DISTRICT LEVEL From AUGUST Through JUNE ---================================---------------------------------------==---- 2 0 0 1 - 0 2 --===================-==============-------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------=-------------------------=====---=-----------==========------====------- 09 S.A.C. 1276 55.2% 574 24.8% 354 15.3% 107 4.6% 2311 566 322 205 68 1161 10 HOME SUSP. 692 66.6% 234 22.5% 92 8.9% 21 2.0% 1039 370 135 68 11 584 11 BOYS CLUB 210 59.0% 83 23.3% 52 14.6% 11 3.1% 356 135 55 39 11 240 12 E.I.C. 342 56.8% 164 27.2% 67 11.1% 29 4.8% 602 172 84 46 19 321 17 EXPULSION 1 25.0% 0 .0% 2 50.0% 1 25.0% 4 1 0 2 1 4 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 1903 52.3% 1050 28.9% 513 14.1% 172 4.7% 3638 632 421 233 109 1395 10 HOME SUSP. 522 66.0% 193 24.4% 63 8.0% 13 1. 6% 791 280 121 49 11 461 11 BOYS CLUB 244 55.6% 86 19.6% 84 19.1% 25 5. 7% 439 151 56 66 20 293 12 E.I.C. 252 61. 2% 97 23.5% 52 12.6% 11 2.7% 412 130 52 36 10 228 17 EXPULSION 2 40.0% 0 .0% 3 60.0% 0 .0% 5 2 0 3 0 5 COMPARISON -----BM------ -. ---BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 627 49.1 % 476 82.9 % 159 44.9 % 65 60.7 % 1327 66 99 28 41 234 10 HOME SUSP. 170- 24.6-% 41- 17.5-% 29- 31. 5-% 8- 38.1-% 248- 90- 14- 19- 0 123- 11 BOYS CLUB 34 16.2 % 3 3.6 % 32 61. 5 % 14 127.3 % 83 16 1 27 9 53 12 E.I.C. 90- 26.3-% 67- 40.9-% 15- 22.4-% 18- 62.1-% 190- 42- 32- 10- 9- 93- 17 EXPULSION 1 100.0 % 0 . 0 % 1 50.0 % 1- 100.0-% 1 1 0 1 1- 1 Ref: Date: Time: DIS032 9/16/03 13:38:19 Analysis of Disciplinary Actions ELEMENTARYK -5 From AUGUST Through JUNE 2 0 0 1 - 0 2 -----BM------ -----BF------ -----NBM----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU -----NBF----- # REF PCT/TOT # STU -------------------------------------------------------------------------------- 09 S.A.C. 4 80.0% 1 20.0% 0 .0% 0 .0% 5 4 1 0 0 5 10 HOME SUSP. 335 68.5% 105 21. 5% 42 8.6% 7 1. 4% 489 186 64 28 3 281 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C. 341 56. 7% 164 27.3% 67 11.1% 29 4.8% 601 171 84 46 19 320 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU --------------------------------------------------------------================== 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 401 74. 7% 93 17.3% 41 7.6% 2 .4% 537 198 53 31 2 284 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C. 252 61.2% 97 23.5% 52 12.6% 11 2. 7% 412 130 52 36 10 228 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 ----------------------------------------=-=-==================================== COMPARISON -----------------------------------------=----====-============================= -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 4- 100.0-% 1- 100.0-% 0 . 0 % 0 . 0 % 5- 4- 1- 0 0 5- 10 HOME SUSP. 66 19.7 % 12- 11. 4-% 1- 2.4-% 5- 71. 4-% 48 12 11- 3 1- 3 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 12 E.I.C. 89- 26.1-% 67- 40.9-% 15- 22.4-% 18- 62.1-% 189- 41- 32- 10- 9- 92- 17 EXPULSION 0 .0 % 0 . 0 % 0 . 0 % 0 . 0 % 0 0 0 0 0 0 Ref: Date: Time: DIS032 9/16/03 13:38:19 Analysis of Disciplinary Actions MIDDLE SCHOOLS From AUGUST Through JUNE ===---==========================------------------------------------------------ 2 0 0 1 - 0 2 ==-===========================-------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU =-=========================----------------------------------------------------- 09 S.A.C. 688 55.2% 342 27.4% 182 14.6% 34 2. 7% 1246 319 193 108 25 645 10 HOME SUSP. 205 62. 9% 94 28.8% 22 6. 7% 5 1.5% 326 102 52 17 4 175 11 BOYS CLUB 125 53.9% 66 28.4% 33 14.2% 8 3.4% 232 73 42 26 8 149 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 . 0% 0 0 0 0 0 0 17 EXPULSION 1 33.3% 0 .0% 1 33.3% 1 33.3% 3 1 0 1 1 3 ==========================------------------------------------------------------ 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 1296 52.4% 742 30.0% 327 13.2% 107 4.3% 2472 369 267 119 63 818 10 HOME SUSP. 33 47.1% 31 44.3% 5 7.1% 1 1. 4% 70 29 25 4 1 59 11 BOYS CLUB 165 55.6% 60 20.2% 54 18.2% 18 6.1% 297 92 35 38 13 178 12 E. I .C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 1 100.0% 0 .0% 0 .0% 0 .0% 1 1 0 0 0 1 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 09 S.A.C. 608 88.4 % 400 117.0 % 145 79. 7 % 73 214.7 % 1226 50 74 11 38 173 10 HOME SUSP. 172- 83.9-% 63- 67.0-% 17- 77.3-% 4- 80.0-% 256- 73- 27- 13- 3- 116- 11 BOYS CLUB 40 32.0 % 6- 9.1-% 21 63.6 % 10 125.0 % 65 19 7- 12 5 29 12 E.I.C. 0 .0 % 0 .0 % 0 . 0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 1- 100.0-% 1- 100.0-% 2- 0 0 1- 1- 2- Ref: Date: Time: DIS032 9/16/03 13:38:19 Analysis of Disciplinary Actions HIGH SCHOOLS From AUGUST Through JUNE =------------------------------------------------------------------------------- 2 0 0 1 - 0 2 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU ================================---------------------========-=----------------- 09 S.A.C. 584 55.1% 231 21.8% 172 16.2% 73 6.9% 1060 243 128 98 43 512 10 HOME SUSP. 152 67.9% 35 15.6% 28 12.5% 9 4.0% 224 82 19 23 4 128 11 BOYS CLUB 85 68.5% 17 13. 7% 19 15.3% 3 2.4% 124 62 13 13 3 91 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 1 100.0% 0 .0% 1 0 0 1 0 1 2 0 0 2 - 0 3 -------------------------------------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 607 52.1% 308 26.4% 186 16.0% 65 5. 6% 1166 263 154 114 46 577 10 HOME SUSP. 88 47.8% 69 37.5% 17 9.2% 10 5.4% 184 53 43 14 8 118 11 BOYS CLUB 79 55.6% 26 18.3% 30 21.1% 7 4.9% 142 59 21 28 7 115 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 1 25.0% 0 .0% 3 75.0% 0 .0% 4 1 0 3 0 4 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 23 3.9 % 77 33.3 % 14 8.1 % 8- 11. 0-% 106 20 26 16 3 65 10 HOME SUSP. 64- 42.1-% 34 97 .1 % 11- 39.3-% 1 11.1 % 40- 29- 24 9- 4 10- 11 BOYS CLUB 6- 7.1-% 9 52.9 % 11 57.9 % 4 133.3 % 18 3- 8 15 4 24 12 E.I.C. 0 .0 % 0 .0 % 0 . 0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 1 100.0 % 0 .0 % 2 200.0 % 0 . 0 % 3 1 0 2 0 3 Ref: DIS032S Date: 7/14/03 Time : 10 : 0 8 : 4 9 School: 012 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E.I.C. 17 EXPULSION Analysis of Disciplinary Actions by School From AUGUST Through JUNE NORTH LITTLE ROCK HIGH SCHOOL - 11/12 2 0 0 1 - 0 2 -----BM------ -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU 148 47.9% 80 25.9% 62 20.1% 94 53 43 4 33.3% 2 16.7% 6 50.0% 4 2 6 28 62.2% 7 15. 6% 9 20.0% 25 6 8 0 .0% 0 .0% 0 .0% 0 0 0 0 .0% 0 .0% 0 .0% 0 0 0 2 0 0 2 - 0 3 -------- -----BM------ -----BF------ -----NBM----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU 09 S.A.C. 190 54.6% 65 18.7% 73 21.0% 108 51 53 10 HOME SUSP. 3 27.3% 3 27.3% 4 36.4% 3 3 4 11 BOYS CLUB 16 59.3% 2 7.4% 7 25.9% 14 2 6 12 E.I.C 0 .0% 0 .0% 0 .0% 0 0 0 17 EXPULSION t .0% 0 .0% 0 .0% f 0 0 -----NBF----# REF PCT/TOT # STU 19 6.1% 13 0 .0% 0 1 2.2% 1 0 .0% 0 0 .0% 0 309 203 12 12 45 40 0 0 0 0 ----------------- -----NBF----- # REF PCT/TOT # STU 20 5.7% 348 16 228 1 9.1% 11 1 11 2 7.4% 27 2 24 0 .0% 0 0 0 0 .0% 0 0 0 -----------------=-------------=--============================================== COMPARISON -----------------------------------============================================= -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 09 S.A.C. 42 28.4 % 15- 18.8-% 11 17.7 % 1 5.3 % 39 14 2- 10 3 25 10 HOME SUSP. 1- 25.0-% 1 50.0 % 2- 33.3-% 1 100.0 % 1- 1- 1 2- 1 1- 11 BOYS CLUB 12- 42.9-% 5- 71. 4-% 2- 22.2-% 1 100.0 % 18- 11- 4- 2- 1 16- 12 E.I.C. 0 .0 % 0 .0 % 0 .0 % 0 .o % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 .0 % 0 .o % 0 0 0 0 0 0 Ref: DIS032S Date: 7/14/03 Time: 10:08:50 School: 013 Analysis of Disciplinary Actions by School From AUGUST Through JUNE NORTH LITTLE ROCK HIGH SCHOOL - 09/10 ======================================================-------------------------- 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----- -----NBF----# REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU ====-=-===-================----------------------------------------------------- 09 S.A.C. 433 57.9% 151 20.2% 110 14. 7% 54 7.2% 748 149 76 55 30 310 10 HOME SUSP. 29 76.3% 1 2.6% 8 21.1% 0 .0% 38 24 1 8 0 33 11 BOYS CLUB 57 72.2% 10 12.7% 10 12.7% 2 2.5% 79 38 7 5 2 52 12 E. I .C. 0 .0% 0 .0% 1 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 1 100.0% 0 .0% 1 0 0 1 0 1 2 0 0 2 - 0 3 -------------------------------------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU ------------------------------------------------------------------------------- 09 S.A.C. 416 51.1% 242 29. 7% 111 13.6% 45 5.5% 814 156 103 59 30 348 10 HOME SUSP. 11 39.3% 13 46.4% 2 7.1% 2 7.1% 28 10 11 2 2 25 11 BOYS CLUB 63 54.3% 24 20. 7% 24 20. 7% 5 4.3% 116 45 19 23 5 92 12 E.I.C 0 .0% 0 .0% 0 .0% 0 . 0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 :\n0 0 0 0 --------- COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 09 S.A.C. 17- 3.9-% 91 60.3 % 1 . 9 % 9- 16.7-% 66 7 27 4 0 38 10 HOME SUSP. 18- 62.1-% 12 1200.0 % 6- 75.0-% 2 200.0 % 10- 14- 10 6- 2 8- 11 BOYS CLUB 6 10.5 % 14 140.0 % 14 140.0 % 3 150.0 % 37 7 12 18 3 40 12 E.I.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 1- 100.0-% 0 . 0 % 1- 0 0 1- 0 1- Ref: DIS032S Analysis of Disciplinary Actions Date: 7/14/03 by School Time: 10:08:50 From AUGUST Through JUNE School: 020 ARGENTA ACADEMY 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU -----BF------ # REF PCT/TOT # STU -----NBM----- -----NBF----# REF PCT/TOT # REF PCT/TOT # STU # STU ===========================----------------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 224 66. 7% 81 24.1% 20 6.0% 11 3.3% 336 87 33 12 5 137 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 ==========================----------------------------------------------------- 2 0 0 2 - 0 3 =--=--==================-------------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU 09 S.A.C. 1 33.3% 1 33.3% 1 33.3% 0 .0% 3 1 1 1 0 3 10 HOME SUSP. 76 51.7% 53 36 .1% 11 7.5% 7 4.8% 147 42 32 8 5 87 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON - --- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 1 100.0 % 1 100.0 % 1 100.0 % 0 . 0 % 3 1 1 1 0 3 10 HOME SUSP. 148- 66.1-% 28- 34.6-% 9- 45.0-% 4- 36.4-% 189- 45- 1- 4- 0 50- 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 .o % 0 0 0 0 0 0 12 E.I.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 . 0 % 0 .o % 0 0 0 0 0 0 N __, 0 0 0 ...  '\"d 0 ti:, 0 ~ ' 00 __, z 0 ...... ::r ..-.... ,. :,:I 0 (\u0026gt; :,\n--  :,:I __, N '\"\"' '\"\"' \\J1 0 ' _00_ , \\J1 0 00 0 0 0 The  Choice North Little Rock School District RECEIVED MEMORANDUM TO: FROM: CC: DATE: RE: Margie Powell, Associate Monitor Office of Desegregation Monitoring Francical J. Jackson, Director Office of Student Affairs Bobby J. Acklin, Assistant Superintendent Office of Desegregation Monitoring September 25, 2003 Analysis of Disciplinary Actions 2002-2003 SEP2 9 2003 OFFIOCFE DESEGREGMAOTNIIOTNO RING Enclosed you will find a copy of the 2002-2003 Analysis of Disciplinary Actions report. Per our phone conference on Thursday, September 25, 2003, the report contains the following errors: School - 012 - North Little Rock High School -11112 Should reflect one (I) black male expelled . School - 013 - North Little Rock High School - 09/10 Should reflect three (3) non-black males expelled. School - 025 - Lakewood Middle School - 718 Should reflect one (I) black male expelled. Ridgeroad Middle Charter School The school is being reviewed to insure accuracy due to the large increase in suspensions in SAC (Student Assignment Class). A copy of the revised report will be forwarded to you.  An Equal Opportunity Employer www.nlrsd.k12.ar.us Ref: DIS032S Date: 7/14/03 Time: 10:08:50 School: 024 Analysis of Disciplinary Actions by School From AUGUST Through JUNE RIDGEROADM IDDLE SCHOOL 2 0 0 1 - 0 2 -----BM------ -----BF------ -----NBM----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU -----NBF----- # REF PCT/TOT # STU ------------===================------------------===--==------------------------ 09 S.A.C. 318 59.2% 123 22.9% 84 15.6% 12 2.2% 537 127 66 46 8 247 10 HOME SUSP. 64 75.3% 13 15.3% 6 7.1% 2 2.4% 85 42 10 6 2 60 11 BOYS CLUB 97 63.4% 39 25.5% 13 8.5% 4 2. 6% 153 50 21 9 4 84 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 ------------------------------------------------------------------------------ -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 764 53.4% 465 32.5% 161 11. 3% 40 2.8% 1430 155 116 37 22 330 10 HOME SUSP. 10 27.0% 23 62.2% 3 8.1% 1 2.7% 37 10 19 2 1 32 11 BOYS CLUB 2 33.3% 1 16.7% 1 16. 7% 2 33.3% 6 2 1 1 2 6 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 09 S.A.C. 446 140.3 % 342 278.0 % 77 91. 7 % 28 233.3 % 893 28 50 9- 14 83 10 HOME SUSP. 54- 84.4-% 10 76.9 % 3- 50.0-% 1- 50.0-% 48- 32- 9 4- 1- 28- 11 BOYS CLUB 95- 97.9-% 38- 97.4-% 12- 92. 3-% 2- 50.0-% 147- 48- 20- 8- 2- 78- 12 E.I.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 .o % 0 . 0 % 0 0 0 0 0 0 ~ 1L 'i ~1 Ref: DIS032S Date: 7 /14/03 Time: 10:08:50 School: 025 Analysis of Disciplinary Actions by School From AUGUST Through JUNE LAKEWOOMD IDDLES CHOOL 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----- -----NBF----# REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU 09 S.A.C. 110 45.3% 66 27.2% 53 21. 8% 14 5.8% 58 39 33 11 10 HOME SUSP. 2 66. 7% 1 33.3% 0 .0% 0 .0% 2 1 0 0 11 BOYS CLUB 11 29. 7% 14 37.8% 10 27.0% 2 5.4% 10 10 9 2 12 E. I.C. 0 .0% 0 .0% 1 .0% 1 .0% 0 0 0 0 17 EXPULSION 1 33.3% 0 .0% 1 33.3% 1 33.3% 1 0 1 1 2 0 0 2 - 0 3 ---------------------------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU 09 S.A.C. 146 42.3% 72 20.9% 95 27.5% 32 9.3% 66 41 50 21 10 HOME SUSP. 2 66. 7% 0 .0% 1 33.3% 0 .0% 2 0 1 0 11 BOYS CLUB 51 51.0% 20 20.0% 26 26.0% 3 3.0% 25 9 22 2 12 E. I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% f 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF---'-- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 243 141 3 3 37 31 0 0 3 3 345 178 3 3 100 58 0 0 0 0 ------------------------------------------------===-============================ 09 S.A.C. 36 32.7 % 6 9.1 % 42 79.2 % 18 128.6 % 102 8 2 17 10 37 10 HOME SUSP. 0 .0 % 1- 100.0-% 1 100.0 % 0 . 0 % 0 0 1- 1 0 0 11 BOYS CLUB 40 363.6 % 6 42.9 % 16 160.0 % 1 50.0 % 63 15 1- 13 0 27 12 E.I.C. 0 .0 % 0 . 0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 17 EXPULSION 1- 100.0-% 0 .o % 1- 100.0-% 1- 100.0-% 3- 1- 0 1- 1- 3- Ref: DIS032S Date: 7/14/03 Time : 10 : 0 8 : 5 0 School: 026 Analysis of Disciplinary Actions by School From AUGUST Through JUNE ROSE CITY MIDDLE SCHOOL 2 0 0 1 - 0 2 -----BM------ -----BF------ -----NBM----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU -----NBF----- # REF PCT/TOT # STU =============================================-==---=---------------------------- 09 S.A.C. 90 48.4% 70 37.6% 23 12.4% 3 1. 6% 186 53 41 15 2 111 10 HOME SUSP. 7 33.3% 10 47.6% 4 19.0% 0 .0% 21 7 10 3 0 20 11 BOYS CLUB 14 40.0% 10 28.6% 9 25. 7% 2 5.7% 35 11 8 7 2 28 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 ------- ------ 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU 09 S.A.C. 65 60.2% 28 25.9% 6 5.6% 9 8.3% 108 43 23 3 4 73 10 HOME SUSP. 0 .0% 1 100.0% 0 .0% 0 .0% 1 0 1 0 0 1 11 BOYS CLUB 33 68.8% 3 6.3% 7 14.6% 5 10.4% 48 23 2 5 4 34 12 E. I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 25- 27.8-% 42- 60.0-% 17- 73.9-% 6 200.0 % 78- 10- 18- 12- 2 38- 10 HOME SUSP. 7- 100.0-% 9- 90.0-% 4- 100.0-% 0 . 0 % 20- 7- 9- 3- 0 19- 11 BOYS CLUB 19 135.7 % 7- 70.0-% 2- 22.2-% 3 150.0 % 13 12 6- 2- 2 6 12 E.I.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14 /03 Time: 10:08:51 School: 027 Analysis of Disciplinary Actions by School From AUGUST Through JUNE ROSE CITY MIDDLE LEVEL ACADEMY =-=================================-------------------------------------------- 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU -----NBF----# REF PCT/TOT # STU =-----------------------===-===================------=-------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E. I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT /TOT # STU # STU # STU # STU 09 S.A.C. 3 75.0% 0 .0% 1 25.0% 0 .0% 4 3 0 1 0 4 10 HOME SUSP. 5 41. 7% 7 58.3% 0 .0% 0 .0% 12 3 5 0 0 8 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 1 100.0% 0 .0% 0 .0% 0 .0% 1 1 0 0 0 1 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 09 S.A.C. 3 300.0 % 0 .0 % 1 100.0 % 0 .o % 4 3 0 1 0 4 10 HOME SUSP. 5 500.0 % 7 700.0 % 0 .0 % 0 . 0 % 12 3 5 0 0 8 11 BOYS CLUB 0 .0 % 0 .0 % 0 . 0 % 0 . 0 % 0 0 0 0 0 0 12 E.I.C. 0 .o % 0 . 0 % 0 . 0 % 0 . 0 % 0 0 0 0 0 0 17 EXPULSION 1 100.0 % 0 . 0 % 0 .0 % 0 . 0 % 1 1 0 0 0 1 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 030 Analysis of Disciplinary Actions by School From AUGUST Through JUNE POPLAR STREET MIDDLE SCHOOL - ------------------------------------------------------ 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU -----NBF----# REF PCT/TOT # STU ======-=====================---------------------------------------------------- 09 S.A.C. 173 61.1% 83 29.3% 22 7.8% 5 1.8% 283 88 50 15 4 157 10 HOME SUSP. 27 49.1% 21 38.2% 6 10.9% 1 1.8% 55 20 16 5 1 42 11 BOYS CLUB 3 42.9% 3 42.9% 1 14.3% 0 .0% 7 3 3 1 0 7 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 318 54.3% 177 30.2% 65 11.1% 26 4.4% 586 110 91 30 16 247 10 HOME SUSP. 14 93.3% 0 .0% 1 6. 7% 0 .0% 15 12 0 1 0 13 11 BOYS CLUB 79 55.2% 36 25.2% 20 14.0% 8 5.6% 143 42 23 11 5 81 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 145 83.8 % 94 113.3 % 43 195.5 % 21 420.0 % 303 22 41 15 12 90 10 HOME SUSP. 13- 48.1-% 21- 100.0-% 5- 83.3-% 1- 100.0-% 40- 8- 16- 4- 1- 29- 11 BOYS CLUB 76 2533.3 % 33 1100.0 % 19 1900.0 % 8 800.0 % 136 39 20 10 5 74 12 E.I.C. 0 .o % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14 /03 T irne : 10 : 0 8 : 51 School: 031 Analysis of Disciplinary Actions by School From AUGUST Through JUNE AMBOYE LEMENTARYSC HOOL ======-~-=====================------=------------------------------------------- 2 0 0 1 - 0 2 ===================================================----=------------------------ -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU ===--===-===============================-----=--------==-----------------------= 09 S.A.C. 4 100.0% 0 .0% 0 .0% 0 .0% 4 4 0 0 0 4 10 HOME SUSP. 78 71. 6% 24 22.0% 7 6.4% 0 .0% 109 39 12 4 0 55 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C. 33 56.9% 14 24.1% 0 19.0% 0 .0% 58 21 11 9 0 41 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 ----. BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------- --------------------- - --------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 36 67.9% 7 13.2% 10 18.9% 0 .0% 53 25 4 6 0 35 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 . 0% 0 0 0 0 0 0 12 E.I.C 42 71.2% 5 8.5% 8 13.6% 4 6.8% 59 23 5 6 4 38 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -------------------------------------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU ------------ 09 S.A.C. 4- 100.0-% 0 . 0 % 0 . 0 % 0 .o % 4- 4- 0 0 0 4- 10 HOME SUSP. 42- 53.8-% 17- 70.8-% 3 42.9 % 0 .0 % 56- 14- 8- 2 0 20- 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 12 E.I.C. 9 .0 % 9- . 0 % 3- . 0 % 4 .0 % 1 0 1- 3- 4 3- 17 EXPULSION 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14 /03 Time: 10:08:51 School: 032 Analysis of Disciplinary Actions by School From AUGUST Through JUNE LAKEWOODE LEMENTARYS CHOOL ==-========================-==-=------------------------------------------------ 2 0 0 1 - 0 2 ==-====================================------------------------------------===-- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU =-======================================--------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 3 37.5% 5 62.5% 0 .0% 0 . 0% 8 2 3 0 0 5 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 =======================---=--------=-====--------------------------------------- 2 0 0 2 - 0 3 ===============================================--------------------------------- -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU -----NBF----# REF PCT/TOT # STU --------------------.----------------------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 3 100.0% 0 .0% 0 .0% 0 .0% 3 3 0 0 0 3 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU ------------------------ -- - -- ---------------- 09 S.A.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 10 HOME SUSP. 0 .0 % 5- 100.0-% 0 .0 % 0 .0 % 5- 1 3- 0 0 2- 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 12 E. I.C. 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 .0 % 0 .o % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 033 Analysis of Disciplinary Actions by School From AUGUST Through JUNE BOONE PARK ELEMENTARY SCHOOL =------------------========================---=--------------------------------- 2 0 0 1 - 0 2 ==--===================================----------------------------------------- -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU -----NBF----# REF PCT/TOT # STU =------------------------------------------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 90 67.2% 35 2,6.1% 4 3.0% 5 3. 7% 134 39 18 2 1 60 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C. 77 63.1% 38 31.1% 0 .8% 0 4.9% 122 44 22 1 4 71 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 161 78.9% 38 18.6% 5 2.5% 0 .0% 204 57 17 3 0 77 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E. I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 10 HOME SUSP. 71 78.9 % 3 8.6 % 1 25.0 % 5- 100. 0-% 70 18 1- 1 1- 17 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 12 E.I.C. 77- .0 % 38- .o % 1- .0 % 6- .o % 122- 1- 1- 1- 6- 71- 17 EXPULSION 0 .0 % 0 .0 % 0 .0 % 0 .o % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 035 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E.I.C. 17 EXPULSION 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E.I.C 17 EXPULSION Analysis of Disciplinary Actions by School From AUGUST Through JUNE SEVENTH STREET ELEMENTARY SCHOOL 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU 0 .0% 0 .0% 0 .0% 0 0 0 16 94.1% 1 5.9% 0 .0% 10 1 0 0 .0% 0 .0% 0 .0% 0 0 0 74 63.2% 37 31. 6% 0 1. 7% 40 21 2 0 .0% 0 .0% 0 .0% 0 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU 0 .0% 0 .0% 0 .0% 0 0 0 22 91. 7% 2 8.3% 0 .0% 16 2 0 0 .0% 0 .0% 0 .0% 0 0 0 58 75.3% 19 24.7% 0 .0% 30 11 0 0 .0% 0 .0% 0 .0% 0 0 0 ------------------------------- COMPARISON -----BM------ -----BF------ -----NBM----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU 09 S.A.C. 0 .0 % 0 .0 % 0 . 0 % 0 0 0 10 HOME SUSP. 6 37.5 % 1 100.0 % 0 . 0 % 6 1 0 11 BOYS CLUB 0 .0 % 0 . 0 % 0 .0 % 0 0 0 12 E.I.C. 16- .0 % 18- . 0 % 2- .0 % 0 0 2- 17 EXPULSION 0 .0 % 0 .o % 0 .0 % 0 0 0 -----NBF----# REF PCT/TOT # STU 0 .0% 0 0 0 0 .0% 17 0 11 0 .0% 0 0 0 0 3.4% 117 4 67 0 .0% 0 0 0 -----NBF----- # REF PCT/TOT # STU 0 .0% 0 0 0 0 .0% 24 0 18 0 .0% 0 0 0 0 .0% 77 0 41 0 .0% 0 0 0 -----NBF----- # REF PCT(+/-) # STU - - -- 0 .0 % 0 0 0 0 . 0 % 7 0 7 0 .0 % 0 0 0 4- .0 % 40- 4- 26- 0 .0 % 0 0 0 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 037 Analysis of Disciplinary Actions by School From AUGUST Through JUNE LYNCH DRIVE ELEMENTARY SCHOOL ======---======================================-===-----=----=------------------ 2 0 0 1 - 0 2 =========================================================================-----=~ -----BM------ -----BF------ # REF PCT/TOT # REF PCT/TOT # STU # STU 09 S.A.C. 0 .0% 0 .0% 0 0 10 HOME SUSP. 16 72. 7% 2 9.1% 14 2 11 BOYS CLUB 0 .0% 0 .0% 0 0 12 E.I.C. 10 100. 0% 0 .0% 7 0 17 EXPULSION 0 .0% 0 .0% 0 0 -----NBM----- # REF PCT/TOT # STU 0 .0% 0 4 18.2% 1 0 .0% 0 0 .0% 0 0 .0% 0 -----NBF----# REF PCT/TOT # STU 0 .0% 0 0 .0% 0 0 .0% 0 0 .0% 0 0 .0% 0 0 0 22 17 0 0 10 7 0 0 -------------------------------------------------------------------------------- 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU ---------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 12 70.6% 4 23.5% 1 5.9% 0 .0% 17 11 3 1 0 15 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E. I.C 24 63.2% 12 31. 6% 1 2.6% 1 2.6% 38 15 8 1 1 25 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 -------------- COMPARISON ----------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU ---------- 09 S.A.C. 0 .0 % 0 .0 % 0 . 0 % 0 .0 % 0 0 0 0 0 0 10 HOME SUSP. 4- 25.0-% 2 100.0 % 3- 75.0-% 0 .0 % 5- 3- 1 0 0 2- 11 BOYS CLUB 0 .0 % 0 .0 % 0 . 0 % 0 .0 % 0 0 0 0 0 0 12 E.I.C. 14 .0 % 12 .o % 1 .0 % 1 . 0 % 28 1 12 1 1 18 17 EXPULSION 0 .0 % 0 .0 % 0 . 0 % 0 .0 % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 040 Analysis of Disciplinary Actions by School From AUGUST Through JUNE MEADOWP ARK ELEMENTARYS CHOOL 2 0 0 1 - 0 2 -------------------------------------------- ---------------------------------- 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E. I.C. 17 EXPULSION -----BM------ # REF PCT/TOT # STU 0 .0% 0 51 67.1% 26 0 .0% 0 0 .0% 0 0 .0% 0 -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU 0 .0% 0 .0% 0 0 21 27.6% 4 5.3% 12 3 0 .0% 0 .0% 0 0 0 .0% 0 100.0% 0 2 0 .0% 0 .0% 0 0 -----NBF----# REF PCT/TOT # STU 0 .0% 0 0 .0% 0 0 .0% 0 0 .0% 0 0 .0% 0 0 0 76 41 0 0 2 2 0 0 ------------==-====-------=-----============----=---===-=-=-=================== 2 0 0 2 - 0 3 ------------============---=-================================================== -----BM------ # REF PCT/TOT # STU -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU -----NBF----# REF PCT/TOT # STU ---------------------------------==-=-========================================== 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 28 70.0% 8 20.0% 4 10.0% 0 .0% 40 19 5 3 0 27 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON ------------------------------------=-------=--=-==--=-==-==============-------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -----------------------------------------------------===============------------ 09 S.A.C. 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 10 HOME SUSP. 23- 45.1-% 13- 61. 9-% 0 .o % 0 . 0 % 36- 7- 7- 0 0 14- 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 12 E. I.C. 0 .0 % 0 . 0 % 2- . 0 % 0 .o % 2- 0 0 2- 0 2- 17 EXPULSION 0 .0 % 0 . 0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 041 Analysis of Disciplinary Actions by School From AUGUST Through JUNE NORTH HEIGHTS ELEMENTARY SCHOOL 2 0 0 1 - 0 2 ==-===================---------------------------------------------------------- -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU =------------------------------------------------------------------------------ 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E. I.C. 17 EXPULSION 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E.I.C 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 0 0 15 57.7% 2 7.7% 9 34.6% 13 2 7 0 .0% 0 .0% 0 .0% 0 0 0 110 52.6% 51 24.4% 0 16. 7% 38 14 20 0 .0% 0 .0% 0 .0% 0 0 0 2 0 0 2 - 0 3 -----BM------ # REF PCT/TOT # STU 0 .0% 0 10 52.6% 8 0 .0% 0 31 60.8% 15 0 .0% 0 -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU 0 .0% 0 .0% 0 0 0 .0% 8 42.1% 0 6 0 .0% 0 .0% 0 0 2 3.9% 16 31. 4% 2 11 0 .0% 0 .0% 0 0 COMPARISON 0 .0% 0 0 .0% 0 0 .0% 0 0 6.2% 7 0 .0% 0 -----NBF----# REF PCT/TOT # STU 0 .0% 0 1 5.3% 1 0 .0% 0 2 3.9% 2 0 .0% 0 -----BM------ -----BF------ -----NBM----- -----NBF----# REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 0 0 26 22 0 0 209 79 0 0 0 0 19 15 0 0 51 30 0 0 -------------------------------------------------------------------------------- 09 S.A.C. 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 10 HOME SUSP. 5- 33.3-% 2- 100.0-% 1- 11.1-% 1 100.0 % 7- 5- 2- 1- 1 7- 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 12 E.I.C. 79- .0 % 49- .o % 19- .0 % 11- . 0 % 158- 1- 1- 19- 11- 49- 17 EXPULSION 0 .0 % 0 .o % 0 .0 % 0 . 0 % 0 0 0 0 0 0 Ref: DIS032S Date: 7 /14/03 Time: 10:08:51 School: 042 Analysis of Disciplinary Actions by School From AUGUST Through JUNE CRESTWOOD ELEMENTARY SCHOOL 2 0 0 1 - 0 2 =============================================----==----=----------------------= -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU ------------------------------------------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 30 83.3% 5 13. 9% 0 .0% 1 2.8% 36 17 5 0 1 23 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E. I.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU -------------------------------------------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 54 85.7% 7 11.1% 2 3.2% 0 .0% 63 17 5 2 0 24 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 ------------------------------------------------------------------------======== COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU ------------------------------------ ------------ ------- 09 S.A.C. 0 .o % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 10 HOME SUSP. 24 80.0 % 2 40.0 % 2 200.0 % 1- 100.0-% 27 0 0 2 1- 1 11 BOYS CLUB 0 .0 % 0 .0 % 0 . 0 % 0 .o % 0 0 0 0 0 0 12 E. I.C. 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 0 0 17 EXPULSION 0 .0 % 0 .0 % 0 . 0 % 0 .o % 0 0 0 0 0 0 Ref: DIS032S Date: 7/14/03 Time: 10:08:51 School: 043 Analysis of Disciplinary Actions by School From AUGUST Through JUNE PARK HILL ELEMENTARYS CHOOL ====-=--========================================================--------------== 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E.I.C. 17 EXPULSION 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E. I.C 17 EXPULSION 2 0 0 1 - 0 2 -----BM------ # REF PCT/TOT # STU 0 .0% 0 10 66.7% 6 0 .0% 0 6 40.0% 6 0 .0% 0 -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # STU # STU 0 .0% 0 .0% 0 0 1 6.7% 4 26. 7% 1 4 0 .0% 0 .0% 0 0 1 6. 7% 0 46.7% 1 7 0 .0% 0 .0% 0 0 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- # REF PCT/TOT # REF PCT /TOT # REF PCT/TOT # STU # STU # STU 0 .0% 0 .0% 0 .0% 0 0 0 11 64.7% 1 5.9% 5 29.4% 8 1 5 0 .0% 0 .0% 0 .0% 0 0 0 3 60.0% 0 .0% 1 20.0% 3 0 1 0 .0% 0 .0% 0 .0% 0 0 0 -----NBF----# REF PCT/TOT # STU 0 .0% 0 0 .0% 0 0 .0% 0 0 6.7% 1 0 .0% 0 -----NBF----- # REF PCT/TOT # STU 0 .0% 0 0 .0% 0 0 .0% 0 1 20.0% 1 0 .0% 0 0 0 15 11 0 0 15 15 0 0 0 0 17 14 0 0 5 5 0 0 ------------------------------------------------====-=----=--------====~======== 09 S.A.C. 10 HOME SUSP. 11 BOYS CLUB 12 E.I.C. 17 EXPULSION COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----# REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 1 10.0 % 0 .0 % 1 25.0 % 0 . 0 % 2 0 1 0 0 .0 % 0 .0 % 0 .0 % 0 . 0 % 0 0 0 0 3- .0 % 1- .0 % 6- .0 % 0 . 0 % 1- 1- 6- 0 0 .0 % 0 .0 % 0 .o % 0 .0 % 0 0 0 0 0 0 2 3 0 0 10- 10- 0 0 Ref: DIS032S Date: 7 /14 /03 Time: 10:08:51 School: 044 Analysis of Disciplinary Actions by School From AUGUST Through JUNE PIKE VIEW ELEMENTARYSC HOOL 2 0 0 1 - 0 2 ==============================================-==------------------------------ -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU ====-==-================-=-------=---------------------------------------------- 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 10 55.6% 6 33.3% 2 11.1% 0 .0% 18 8 5 2 0 15 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E. 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I.C. 17 EXPULSION 2 0 0 1 - 0 2 -----BM------ -----BF------ -----NBM----# REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU 0 .0% 0 .0% 0 .0% 0 0 0 6 100.0% 0 .0% 0 .0% 4 0 0 0 .0% 0 .0% 0 .0% 0 0 0 0 .0% 0 .0% 0 .0% 0 0 0 0 .0% 0 .0% 0 .0% 0 0 0 -----NBF----# REF PCT/TOT # STU 0 .0% 0 0 .0% 0 0 .0% 0 0 .0% 0 0 .0% 0 0 0 6 4 0 0 0 0 0 0 ------------------------------------------------------------------------------- 2 0 0 2 - 0 3 -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # REF PCT/TOT # STU # STU # STU # STU 09 S.A.C. 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 10 HOME SUSP. 7 77.8% 2 22.2% 0 .0% 0 .0% 9 2 1 0 0 3 11 BOYS CLUB 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 12 E.I.C 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 17 EXPULSION 0 .0% 0 .0% 0 .0% 0 .0% 0 0 0 0 0 0 COMPARISON -----BM------ -----BF------ -----NBM----- -----NBF----- # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # REF PCT(+/-) # STU # STU # STU # STU -------------------------=----=--==-=============--=-=========================== 09 S.A.C. 0 .0 % 0 . 0 % 0 .o % 0 .0 % 0 0 0 0 0 0 10 HOME SUSP. 1 16.7 % 2 200.0 % 0 .0 % 0 .o % 3 2- 1 0 0 1- 11 BOYS CLUB 0 .0 % 0 .0 % 0 .0 % 0 .0 % 0 0 0 0 0 0 12 E. 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I School Year 2002-2003 I District Level I Elementary I Middle Schools I High Schools I 9 Year Comparison North Little Rock Public Schools Analysis of Disciplinary Actions District Level Action 09: SAC 2000 1800 1600 1400 1200 1000 800 600 400 200 0 BM BF NBM NBF  01-02 1276 574 354 107 02-03 1903 1050 513 172  01-02  02-03 North Little Rock Public Schools Analysis of Disciplinary Actions District Level Action 10: Home Suspension ---~.....-....~~-----~~ - =--- [t[\nJ\n:!iittllt~~~~~~~ 700 600 500 400  01-02 300 ml 02-03 200 100 0 BM BF NBM NBF  01-02 692 234 92 21 02-03 522 193 63 13 250 200 150 100 50 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions District Level Action 11: Boys Club BM BF NBM NBF 210 83 52 11 244 86 85 25  01-02 G'.i102-03 350 300 250 200 150 100 50 0  01-02 13 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions District Level Action 12: Alt School Susp K-5 BM BF NBM NBF 342 164 67 29 253 97 52 11  01-02  02-03 3 2.5 2 1.5 1 0.5 0  01-02  02-03 North Little Rock Public Schools Analysis of Disciplinary Actions District Level Action 17: Expulsion ~ BM BF NBM NBF 1 0 2 1 2 0 3 0  01-02  02-03 4 3.5 3 2.5 2 1.5 1 0.5 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Elementary K-5 Action 09: SAC BM BF NBM NBF 4 1 0 0 0 0 0 0  01-02  02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Elementary K-5 Action 10: Home Suspension ..-1..-.~-~- --~ ----~~-i-~J4]E\n.\n.~~~~ 450 400 350 300 250 200 150 100 50 0 BM  01-02 335 02-03 401 BF NBM 105 42 93 41 NBF 7 2  01-02 ml 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Elementary K-5 Action 11: Boys Club 1 _,, 0.9 _., 0.8 _v 0.7_/ 0.6 _\n0.5-\" 0.4- 0.3 _\n0.2- 0.1 _,, 0 BM BF NBM NBF  01-02 0 0 0 0 GI 02-03 0 0 0 0  01-02 lLl 02-03 350 300 250 200 150 100 50 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Elementary K-5 Action 12: Alt School Susp K-5 BM BF NBM NBF 341 164 67 29 252 97 52 11  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Elementary K-5 Action 17: Expulsion 1 _/ 0.9 _v 0.8 _v 0.7-\" 0.6- 0.5-L, 0.4- 0.3 _v 0.2 _v 0.1 _v 0 BM BF NBM NBF  01-02 0 0 0 0 lliil 02-03 0 0 0 0  01-02 EJ 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Middle Schools Action 09: SAC 1400 1200 1000 800 600 400 200 0 BM BF NBM NBF  01-02 688 342 182 34 02-03 1296 742 327 107  01-02 IJI 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Middle Schools Action 10: Home Suspension - - J-~-\n:::\n~~~~.....,..,.- 250 200 150 100 50 0 BM  01-02 205 02-03 33 BF NBM 94 22 31 5 NBF 5 1  01-02 02-03 180 160 140 120 100 80 60 40 20 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Middle Schools Action 11: Boys Club BM BF NBM NBF 125 66 33 8 165 60 54 18  01-02 Q 02-03 2 1.8 1.6 1.4 1.2 1 0.8 0.6 0.4 0.2 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions Middle Schools Action 17: Expulsion BM BF NBM NBF 2 0 0 0 1 0 0 0  01-02 l2102-03 700 600 500 400 300 200 100 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions High Schools Action 09: SAC BM BF NBM NBF 584 231 172 73 607 308 186 65  01-02 l4102-03 160 140 120 100 80 60 40 20 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions High Schools Action 10: Home Suspension - - -.---- BM BF NBM NBF 152 35 28 9 88 69 17 10  01-02 GJ0I 2-03 90 80 70 60 50 40 30 20 10 0  01-02 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions High Schools Action 11: Boys Club BM BF NBM NBF 85 17 19 3 79 26 31 7  01-02 ~02-03 3 2.5 2 1.5 1 0.5 North Little Rock Public Schools Analysis of Disciplinary Actions High Schools Action 17: Expulsion 0 ...i.-1111111.S~~--11111 BM BF NBM NBF  01-02 0 0 1 0 0 02-03 1 0 3 0  01-02 DI 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions 10 Year Comparison Action 09: SAC 2000 1800 1600 1400 1200 1000 800 600 400 200 0 BM BF NBM NBF  93-94 977 529 449 156 El 94-95 869 460 411 126  95-96 1052 446 410 140  96-97 1264 55 469 142  97-98 1801 862 547 132  98-99 1443 718 458 138  99-00 1468 662 401 139  00-01 1092 556 267 69  01-02 1276 574 354 107  02-03 1903 1050 513 172  93-94 CD94 -95  95-96  96-97  97-98  98-99  99-00  00-01  01-02  02-03 North Little Rock Public Schools Analysis of Disciplinary Actions 10 Year Comparison Action 10: Home Suspension 700 600 500 400 300 200 100 0 BM BF NBM NBF  93.94 231 60 76 22 94-95 236 106 103 20  95-96 162 46 47 3  96-97 591 208 125 17  97-98 511 125 104 13  98-99 566 141 125 22  99-00 406 113 102 18 D 00-01 385 92 64 7  01-02 692 234 92 21 522 193 63 13  93-94 E19I4 -95  95-96  96-97  97-98  98-99  99-00  00-01  01-02 D 02-03 North Little Rock Public Schools Analysis of Disciplinary Actions 10 Year Comparison Action 11: Boys Club 600 500 400 300 200 100 0 BM BF NBM NBF  93-94 119 39 39 9 94-95 133 44 31 8  95-96 334 82 72 12  96-97 357 146 85 20  97-98 515 148 112 8  98-99 359 148 88 22  99-00 351 129 90 27  00-01 325 136 56 12  01-02 210 83 52 11  02-03 244 86 85 25  93-94  94-95  95-96  96-97  97-98  98-99  99-00  00-01  01-02  02-03 North Little Rock Public Schools Analysis of Disciplinary Actions 10 Year Comparison Action 12: Alt School Susp K-5 1600- 1400 1200 1000 800- 600 400 200- Ii _I-fl~ 0- ~ _...,  - BM BF NBM NBF  93-94 168 54 45 8 1139 4-95 178 68 58 5  95-96 1563 492 510 71  96-97 154 30 32 3  97-98 0 0 0 0  98-99 211 106 27 6  99-00 246 63 75 16  00-01 162 55 40 21  01-02 342 164 67 29  02-03 253 97 52 11  93-94 8 94-95  95-96  96-97  97-98  98-99  99-00  00-01  01-02  02-03 North Little Rock Public Schools Analysis of Disciplinary Actions 10 Year Comparison Action 17: Expulsion 7 6 5 4 3 2 1 0 BM BF NBM NBF  93-94 6 4 3 0 Cil 94-95 7 0 1 0  95-96 2 1 0 2  96-97 3 7 0 0  97-98 6 5 0 0  98-99 7 2 1 1  99-00 3 0 2 0  00-01 3 0 5 3  01-02 1 0 2 1  93.94  94-95  95-96  96-97  97-98  98-99  99-00  00-01  01-02  02-03\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 "}],"pages":{"current_page":353,"next_page":354,"prev_page":352,"total_pages":6766,"limit_value":12,"offset_value":4224,"total_count":81191,"first_page?":false,"last_page?":false},"facets":[{"name":"educator_resource_mediums_sms","items":[{"value":"lesson plans","hits":319},{"value":"teaching guides","hits":53},{"value":"timelines (chronologies)","hits":43},{"value":"online exhibitions","hits":38},{"value":"bibliographies","hits":15},{"value":"study guides","hits":11},{"value":"annotated bibliographies","hits":9},{"value":"learning modules","hits":6},{"value":"worksheets","hits":6},{"value":"slide shows","hits":4},{"value":"quizzes","hits":1}],"options":{"sort":"count","limit":16,"offset":0,"prefix":null}},{"name":"type_facet","items":[{"value":"Text","hits":40200},{"value":"StillImage","hits":35114},{"value":"MovingImage","hits":4552},{"value":"Sound","hits":3248},{"value":"Collection","hits":41},{"value":"InteractiveResource","hits":25}],"options":{"sort":"count","limit":16,"offset":0,"prefix":null}},{"name":"creator_facet","items":[{"value":"Peppler, Jim","hits":4965},{"value":"Phay, John E.","hits":4712},{"value":"University of Mississippi. 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