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V. NO. LRC-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. MQJIQN EQB ENLARGEMENT Of IIME PLAINTIFFS DEFENDANTS INTERVENORS INTERVENORS On March 24, 1998, this Court ordered PCSSD and Joshua to submit, within ten days, the agreed amendment to the PCSSD Desegregation Plan together with a joint motion, brief in support and proposed notice. The parties desire an enlargement of time to comply with the Court's Order until and including April 9, 1998. WHEREFORE, Joshua and the PCSSD pray for an enlargement of time until and Including April 9, 1998 within which to comply with the Court's directive. PULASKI COUNTY SPECIAL SCHOOL DISTRICT Wright, Lindsey \u0026 Jennings, LLP 200 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 c00d THEJOSHUAINTERVENORS John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 dll SEIN I NH3.f '8 '.!-.3S@ I 7 'lH':l I ~M \u003e t CERTIFICATE OF EBYICE On April ___(_ ~_, 1998, a copy of the foregoing was served by U.S. Mail to each of the following: Mr. Richard Roachell Roachell \u0026 Street 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon \u0026 Janes 425 West Capltol Avenue Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Bldg., Ste. 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Chris Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 00d 2 dll S':JN I tlN3f '8 ' X3SCTN I 7 ' lH':J I df~ RECEIVED FILED U.S. DISTRICT COURT EASTERN DISTRICT AP.KANSAS APR 8 1998 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION APR O 71998 OFFICE OF DESEGREGATION MONITORING JA~AES ! M~MACK, C~ERK By. ~ ) c}_ ~ D!:P CL.fR.~ ' UTILE ROCK SCHOOL DISTRICT,  Plaintiff,  vs.  No. LR-C-82-866  PULASKI COUNTY SPECIAL SCHOOL  DISTRICT NO. 1, et al., * Defendants,   MRS. LORENE JOSHUA, et al.,  lntervenors,   KATHERINE KNIGHT, et al.,  Intervenors.  ORDEB. Before the Court is a motion filed by the Pulaski County Special School District  (\"PCSSD\") and the Joshua Intervenors (\"Joshua\") requesting a continuance to and including April 9, 1998 in which to file their agreed proposed Revised PCSSD Desegregation Plan, in addition to a joint motion and brief in support requesting that the Court approve the proposed Revised Plan and a notice regarding the proposed Revised Plan.  This Court grants the parties' request. The PCSSD and Joshua have to and including April 9, 1998 in which to file these documents and pleadings. IT IS SO ORDERED THIS 7~ day of April 1998. rHIS DOCUMENT ENTER COMP~ce T RuJ~e c:g,0OcRK7er SHEET IN ON  7/ 8 l!Y 7Z1-:: 9(a) FRCP FILED U.S. DISTRICT COURT APR 8 199,9 EASTERN DISTRICT ARKANSAS OFFICE OF DESE6REGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION APR O 7 1998 LITTLE ROCK SCHOOL DISTRICT, * JA~ES W. ~~ORMACK, CLERK By.. 'L 'QI ,u D 41 V'-:a DEP CI.ERll Plaintiff, * vs. * No. 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. * ORDER Attached hereto as Exhibit A is a reply filed by Ms. Hafeeza Majeed on April 6, 1998 on - behalf of Toe Fact-Finding Committee for the Little Rock School Desegregation Plan--Is It Working for African-American Youth?\" Ms. Majeed filed this reply in response to Mr. John Walker's letter regarding Ms. Majeed's initial objection to the proposed January 16 Revised LRSD Desegregation Plan. 1 The Clerk is hereby directed to serve the parties involved in this case with copies of this Order and attached Exhibit A. 2 By separate Order, the Court will inform the parties how the   Court will proceed in regard to Ms. Majeed's latest filing. 1 See Docket No. 3130 for a copy of Ms. Majeed's initial objection. See Docket No. 3135 for Mr. Walker's response to Ms. Majeed's objection. 2 The Clerk should also send copies to the following individuals: Mr. Markton Cole Ms. Hafeeza B. Majeed 7320 S. Ridgeland Ave. 2A 8505 Holmes, #174. .. Chicago, Illinois 60649 Kansas City, Missouri 64131 ; . i IT IS SO ORDERED TiilS  day of April 1998. fHIS DOCUMENT E1.JTERED ON DOCKET SHEET IN ;~~ t'$RULE s:;N~(a) FRCP - . ,, \\. 2 .. ,. . ' . ~:' : \" : April 6, 1998 TO: FROM: ;-;:: ,. :l rr.: --..... U~- -~ - . _ ) ... .'?  :.. . I'~., , . 1. I l I  , _ _ EAs, .:Hr, c:, ie:~ -\u003c, ~.'-: .. ,1r The Honorable Susan Webber Wright -'..' .. l.-f  ' :_;,:s,\\s Federal Judge Eastern District of Arlamsas, Western Di~ U 6 [SJ J/l.~:1:::~ ,., i i~l'.C'R . \" The Fact-Findina Conmiittee for the Little Rock S:choortiisTtfor ,,\\,,.._, /(, CCRK D~H,,-.,-in ftllBl h It w~ Pw MHv1B1Amm,1m Ym;f,91'' THROUGH: Hafeeza B. Majeed, Cbairpenon RE; LITI'LE ROCK SCHOOL DISTRICT Judge Wright: V: LR-C-82-866 PULASKI COUN1Y SPECIAL SCHOOL DISTRICT NOTICE (EXHIBIT C, JANU'ARY 16 REVISED DESEGREGATION PLAN'') The following open letter to Little Rock School District students.parents. and friends. is also a formal request desiring your approval: \"OPEN LETTER JO 11IE UITLI ROCK COMMUNITY\" \"Thank yor/' to the maoy friends and supporters ofThe Fa.rt-Finding Committee with whom I met and enjoyed talkin! to during the weekend. A special iha:nk yor/\u003e to those who supported our efforts with your signatures. AB promised to you, the following request to the Honorable Susan Webber Wright has been submitted in your behalf 1. We, the 1D1dersigned, recognize that we are represented in the Joshua Class, as defined by the attached \"Notice.'' (Exhibit C. LRSD January 16 Revised ..,. . 3. Plan)  We agree that we were provided a copy of the ~otice .. by the Fact-Finding Committee, represented by Ms. HafeezaB. Majeed. We agree, like several others who chose not place their signatures, that we have not been informed about the information contained in the attached \"Notice'' regarding the proposed Revised Desegregation and Education Plan. We believe that the responsibility for BIDlOIDlcing this information to the cormmmity should rest with ColDlSel for Joshua, Attorney Jolm W. Walker, as well as with the LR.SD Board ofDirectors, as designated in the \"Notice.\" We ~e that we have not been informed by the Little Rock School District regarding information contained in the \"Notice.'' Therefore, we respectfully request that you delay your approval or disapproval of the Revised LR.SD Desegregation and Education Plan, pending the following:  Court's Exhibit A 1. Counsel for the Joshua Class, Attorney John W. Walker, should schedule a fonnal hearing to adequately iofonn the Joshua Cius about the Revised LRSD Desesregation and Education Piao. This hearing shall be scheduled at a time conducive to the schedules of working parentl. 2. The hearing shall be attended by a representative fi-om The Fact-Finding Committee, a representative from the LRSD , a represeotative :from ODM. and the Joshua Class. 3. Io sight of the fact that many persons who are defined as \"Joshua\" have not been afforded adequate and timely information regarding the Revised LRSD Desegregation and Education Plan; we request that the LRSD anno1mce an extended deadline to receive written objections to the Piao. The Fact-Finding Committee prayermlly seeks yow approval of this request that represents the concerns ofLRSD Pareots, students, aod friends who were interviewed by our representative, Ms. Hafeeza B. Majeed, during the weekend. Again, ''thank yoli' :from The Fact-Finding Committee. and we shall continue to \"Fight For Our Children.\" Respectfully,  J L ~ 1f. fr[a1u,f Hafee:1-~*ed, Chairperson f' cc: All Signees ColDlSel for Joshua Class LRSD ODM Attachments ---------- - - --- -- - - - ---- ---- - ------ - -- - -  .. - - -------- - - --  --- - - . . . -  - - - . . - ---- EDWARD L. WRIGHT ( 1003-1 071) ROBERT S. LINOSEY ( 1013- 1001) ISAAC A. SCOTT,_./R . JOHN G. LILE GORDON S. RATHER, JR. TERRY L. MATHEWS DAVID M. POWELL ROGER A. GLASGOW C. DOUGLAS BUFORD , JR. PATRICK J. GOSS ALSTON JENNINGS, JR. JOHN R. TISDALE KATHLYN GRAVES M. SAMUEL JONES Ill JOHN WILLIAM SPIVEY Ill LEE J. MULOROW-N. M. NORTON EDGAR J. TYLER CHARLES C. PRICE CHARLES T. COLEMAN JAMES J. GLOVER EDWIN L. LOWTHER, JR. CHARLES L. SCHLUMBERGER SAMMYE L. TAYLOR WALTER E. MAY GREGORY T . JONES H. KEITH MORRISON BETTINA E. BROWNSTEIN WALTER McSPAODEN WRIGHT, LINDSEY \u0026 JENNINGS LLP ATTORNEYS AT LAW 200 WEST CAPITOL AVENUE SUITE 2200 llTTLE ROCK, ARKANSAS 72201-3699 (501) 371-0808 FAX (501) 379-0442 OF COUNSEL ALSTON JENNINGS RONALD A. MAY M. TODD WOOD April 9, 1998 ROGER 0 . ROWE NANCY BELLHOUSE MAY JOHN 0 . DAVIS JUDY SIMMONS HENRY KIMBERLY WOOD TUCKER RAY F. COX, JR . HARRY S. HURST . JR . TROY A. PRICE PATRICIA A. SIEVERS JAMES M. MOODY, JR . KATHRYN A. PRYOR J. MARK DAVIS CLAIRE SHOWS HANCOCK KEVIN W. KENNEDY JERRY J. SALLINGS FRED M. PERKINS Ill WILLIAM STUART JACKSON MICHAEL 0. BARNES STEPHEN R. LANCASTER JUDY M. ROBINSON BETSY MEACHAM AINSLEY H. LANG KYLE R. WILSON C. TAD BOHANNON DON S. McKINNEY MICHELE SIMMONS ALLGOOD KRISTI M. MOODY J. CHARLES DOUGHERTY M. SEAN HATCH PHYLLIS M. McKENZIE ELISA MASTERSON WHITE Honorable Susan Webber Wright United States District Judge 600 W. Capitol, Room 302 Little Rock, Arkansas 72201 HAND DELIVERED Re: LRSD v. PCSSD, et al. Dear Judge Wright: APR 1 0 1998 OFFICE OF DESEGREGATION MONITORING Enclosed are copies of each of the items you directed the PCSSD and Joshua to prepare as regards the amendment to the PCSSD Plan. I have retained the originals for the moment as they do not bear Mr. Walker's signature. Mr. Walker has indicated some doubt about his execution of these documents and I am simply submitting copies so as to comply with the Court's deadline as best I can. By copy of this letter to Mr. Walker, I am asking him to communicate his current position .~o the Court. MSJ/jhs Enclosures Cordially yours, WRIGHT, LINDSEY \u0026 JENNINGS LLP Jon~_,/ I I I cc: Counsel of record (w/encl.) IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. RECE!VED APR 1 0 1998 OFFICE OF DESEGREGATION MONITORING PLAINTIFFS DEFENDANTS INTERVENOR$ INTERVENORS JOINT MOTION OF PCSSD AND JOSHUA FOR APPROVAL OF PCSSD'S MARCH 24 PLAN Defendant Pulaski County Special School District (\"PCSSD\") and the Joshua - lntervenors (\"Joshua\") for their Joint Motion for Approval of PCSSD's March 24, 1998 Plan state: 1. Joshua and PCSSD move for tentative and, ultimately, final approval of PCSSD's March 24, 1998 Plan (attached hereto as Exhibit \"A\"). 2. On October 14, 1997, PCSSD filed its Petition seeking release from federal court jurisdiction (the Petition). Prior to the start of the hearing on the Petition, PCSSD and Joshua engaged in extensive negotiations in an effort to develop an amended plan which both parties could support. Those negotiations resulted in PCSSD's March 24, 1998 Plan. The PCSSD Board of Directors approved the Plan on March 23, 1998 and authorized submission of the Plan to this Court for approval. 3. PCSSD and Joshua stipulate to the following facts in support of this tit Motion: a. That the record in this case supports modification of PCSSD's desegregation obligations; b. That the March 24, 1998 Plan is an appropriate modification of PCSSD's desegregation obligations. c. That the March 24, 1998 Plan is constitutional, workable and fair to Joshua class members; and, d. That, upon approval of the Plan, the PCSSD should be dismissed as a party to this case except as respects its financial claims arising under the settlement agreement. 4. PCSSD and Joshua recognize that their compromise and settlement should not be approved by this Court without notice to Joshua class members. See Fed. R. Civ. P. 23(e). Accordingly, PCSSD and Joshua propose dissemination of the notice attached hereto as Exhibit B. This notice shall be published no less than thirty (30) days before a deadline established by this Court for Joshua class members to submit written objections to approval of the March 24, 1998 Plan. PCSSD shall bear all costs associated with publication of the notice. PCSSD shall cause the notice to be published in the Arkansas Democrat-Gazette; shall print and distribute copies of the notice to teachers; and shall prominently post the notice at all schools. 5. PCSSD and Joshua have prepared for the Court's consideration an Order (attached hereto) granting the relief sought in this Motion. WHEREFORE, PCSSD and Joshua pray that this Court tentatively approve PCSSD's March 24, 1998 Plan, pending the filing of objections filed by Joshua class members; that the notice attached hereto as Exhibit B be published at least thirty (30) 2 days bef~re the deadline for Joshua class members to submit written objections; and that this Court finally approve PCSSD's March 24, 1998 Plan upon consideration of any objections filed by Joshua class members. PULASKI COUNTY SPECIAL SCHOOL DISTRICT Wright, Lindsey \u0026 Jennings, LLP 200 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 By: 3 THEJOSHUAINTERVENORS John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 By: _________ _ John W. Walker CERTIFICATE OF SERVICE On April ___ , 1998, a copy of the foregoing was served by U.S. Mail to each of the following: Mr. Richard Roachell Roachell \u0026 Street 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 425 West Capitol Avenue Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Bldg., Ste. 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Chris Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 M. Samuel Jones, Ill 4 Section 1: Pulaski County Special School District Plan Dated March 24, 1998 Prior Agreements and Orders. RECEIVED APR 1 0 1998 OFFICE OF DESEGREGATION MONITORING 1. This Plan, which is a \"Desegregation and Education Plan,\" shall supersede and extinguish all prior agreeme:nts and orders in Little Rock School District v. Pulaski County Special School District, U.S.D.C. No. LR-C-82-866, and all consolidated cases related to the desegregation of the Pulaski County Special School District (\"PCSSD\") with the following exceptions: a. The Pulaski County School Desegregation Case Settlement Agreement as revised on September 28, 1989 ( \"Settlement Agreement\"); b. The Magnet School Stipulation dated February 27, 1987; c. Order dated September 3, 1986, pertaining to the Magnet Review Committee; d. The M-to-M Stipulation dated August 26, 1986; e. The Interdistrict Plan; and f. Orders of the district court and court of appeals interpreting or enforcing sections a. through d. above to the extent not inconsistent with this Plan. SECTION 2: Obligations. 2.1. PCSSD shall in good faith exercise its best efforts to - comply with the Constitution, to remedy the effects of past EXHIBIT 1 I A APR 1 0 1998 OFFICE OF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. MEMORANDUM BRIEF IN SUPPORT OF PLAINTIFFS DEFENDANTS INTERVENORS INTERVENORS JOINT MOTION OF PCSSD AND JOSHUA FOR APPROVAL OF PCSSD'S PLAN This motion is brought pursuant to the amendment provision of the Pulaski County Special School Distirict permanent Desegregation Plan dated April 29, 1992, as well as Little Rock Sch. Dist. v. Pulaski County Special Sch. Dist. No. 1., 56 F.3d 904, 914 (8th Cir. 1995); Appeal of the Little Rock Sch. Dist., 949 F .2d 253 (8th Cir. 1991 ); Little Rock Sch. Dist. v. Pulaski County Special Sch. Dist. No. 1, 921 F.2d 1371 (8th Cir. 1990). PULASKI COUNTY SPECIAL SCHOOL DISTRICT Wright, Lindsey \u0026 Jennings, LLP 200 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 THEJOSHUAINTERVENORS John W. Walker, P.A. 1723 S. Broadway Little Rock, Arkansas 72206 By: _________ _ John W. Walker CERTIFICATE OF SERVICE On April ___ , 1998, a copy of the foregoing was served by U.S. Mail to each of the following: Mr. Richard Roachell Roachell \u0026 Street 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 425 West Capitol Avenue Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Bldg., Ste. 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Chris Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 little Rock, Arkansas 72201 M. Samuel Jones, Ill 2 OFFICE OF DESEGREGATION MONITORING IN THE UNITED STAff.S DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, * * * * vs. PULASKI COUNTY SPECIAL SCHOOL * DISTRICT NO. 1, et al., * Defendants, * * MRS. LORENE JOSHUA, et al., * Intervenors, * * KA IBERINE KNIGHT, et al., * Intervenors. * No. LR-C-82-866 MEMORANDUM OPINION AND ORDER FBLED US. ulS T;;:1cT COURT EASTERN DISTRICT AR!\u003cANSAS APR 1 0 1998 Before the Court are the initial joint motion and the renewed joint motion filed by the Little Rock School District (\"LRSD\") and the Joshua Intervenors (\"Joshua\") requesting that this Court approve the LRSD's proposed Revised Desegregation and Education Plan dated January 16, 1998 (\"LRSD Proposed Revised Plan\" or \"proposed Plan\").1 L Approval of the Proposed Plan After evaluating the LRSD Proposed Revised Plan, this Court hereby grants the joint motions filed by the LRSD and Joshua and hereby approves the proposed Plan. 1 Docket Nos. 3107 and 3136. 1 A. In 1990, the Eighth Circuit Court of Appeals approved the current version ofLRSD Desegregation and Education Plan or the 1990 Plan. In 1996, after the LRSD had operated under the 1990 Plan for six (6) years, this Court scheduled a series of hearings to gather evidence upon which to evaluate the success of the 1990 Plan, along with the settlement plans of the other districts, and the desegregation remedies endorsed therein. 2 At that time, even though the Court had withdrawn supervision over certain aspects of the 1990 Plan, there remained portions of that Plan which were of concern to the Court. Therefore, the Court called expert witnesses to testify, and invited the parties to call other expert witnesses to testify, regarding desegregation remedies in general in an attempt to aid the Court and the parties in evaluating the effectiveness of the 1990 Plan. Those evidentiary hearings were held in May of 1996.3 At those hearings and on several other occasions, the Court has noted that the parties themselves must develop and present for Court approval any proposed modifications to the desegregation and education plans under which they operate. In December of 1996, the LRSD requested and this Court approved a \"plan development period\" in which the LRSD could concentrate its efforts on developing such modifications to the 1990 Plan, in an attempt to 2 Docket No. 2631. 3 The following expert witnesses testified: (1) Herbert J. Walberg, Ph.D., then a Professor at the University of Illinois at Chicago . See Docket No. 2692. (2) David J. Armor, Ph.D., then a Research Professor at George Mason University in the Institute of Public Policy. See Docket Nos. 2693, 2694. (3) Gary Orfield, Ph.D., then a Professor of Education and Social Policy at Harvard University and the Director of The Harvard Project on School Desegregation. See Docket No. 2768. 2 improve education and desegregation within the district. Some time during this period, the LRSD commenced negotiations with Joshua regarding modifications to the 1990 Plan. As a result of those negotiations, the LRSD and Joshua agreed upon the provisions included in the LRSD Proposed Revised Plan currently before the Court. B. The LRSD and Joshua have agreed that, if approved, the proposed Plan: shall supersede and extinguish all prior agreements and orders in the Little Rock School District v. Pulaski County Special School District, U.S .D.C. No. LR-C-82-866, and all consolidated cases related to the desegregation of the Little Rock School District (\"LRSD\") with the following exceptions: a. The Pulaski County School Desegregation Case Settlement Agreement as revised on September 28, 1989 (\"Settlement Agreement\"); b. The Magnet School Stipulation dated February 27, 1987; c. Order dated September 3, 1986, pertaining to the Magnet Review Committee; d. The M-to-M Stipulation dated August 26, 1986; and, e. Orders of the district court and court of appeals interpreting and enforcing sections a. through d. above to the extent not inconsistent with this Revised Plan. 5 Based upon this provision, this Court considers the LRSD Proposed Revised Plan an entirely new consent decree or settlement agreement between the LRSD and Joshua. The Eighth Circuit Court of Appeals has determined that because the law strongly favors settlements, courts should hospitably receive them, especially in cases such as this in which the parties have engaged in protracted, highly divisive litigation and in which any lasting solution necessarily depends upon the good faith and cooperation of all of the parties. Little Rock Sch. Dist. v. Pulaski County Spec. Sch. Dist., 921 F.2d 1371, 1383 (811, Cir. 1990). When evaluating a settlement agreement, \"O]udges should not substitute their own 4 Docket No. 2901. 5 Docket No. 3107, Exhibit A, at 1. 3 judgment as to optimal settlement terms for the judgment of the litigants and their counsel.\" 921 F.2d at 1385 (quoting Armstrong v. Board of Sch. Dirs. of the City of Milwaukee, 616 F.2d 305, 315 (7111 Cir. 1980)). The district court must consider the proposal as submitted by the parties. \"Of course, the district court may suggest modifications but ultimately, it must consider the proposal as a whole and as submitted. Approval must then be given or withheld.\" Id. at 1383 ( quoting Officers for Justice v. Civil Serv. Comm 'n of the City and County of San Francisco, 688 F.2d 615, 630 (91h Cir. 1982), cert. denied, 459 U.S. 1217 (1983)). Although settlement agreements carry with them a presumption of acceptability, id at 1385, a district court need not automatically approve every settlement agreement the parties submit, id at 13 83 . A court has a strong interest in not involving itself, along with the prestige of the law, in  an ongoing equitable decree which is either manifestly unworkable or plainly unconstitutional on its face. In addition, this is a class action, and courts are not obliged (indeed, they are not pennitted) to approve settlements that are unfair to class members, or negotiated by inadequate class representatives. Id. at 1383 . \"[B]efore a settlement agreement may be rejected because it initiates or authorizes a clearly illegal or unconstitutional practice, prior judicial decisions must have found that practice to be illegal or unconstitutional as a general rule.\" Id at 1385 (quoting Armstrong, 616 F.2d at 321). In the area of desegregation law, the Supreme Court has detennined that the Constitution does not of its own force forbid all-African-American schools. Swann v. Charlotte-Mecklenburg Bd of Educ., 402 U.S. 1, 26 (1971). The Constitution of its own force also does not require any particular racial percentage in various schools in the districts. Milliken v. Bradley, 418 U.S. 717, 740-41 (1974). Furthermore, the Constitution of its own force does not demand that all students 4 regardless of race satisfy national achievement norms. Missouri v. Jenkins, 515 U.S. 70, 100-01 (1995). Obviously, parties in a desegregation case may and indeed should agree to eliminate the effects of prior de Jure segregation to the extent practicable. However, the details of such efforts are not specifically dictated by the Constitution. Even if the court is uncertain that the means proposed in the settlement agreement will succeed in integrating the district or concerned that the lack of sufficient detail in the settlement agreement may impede successful implementation, such concerns alone do not render the settlement agreement unconstitutional on its face, especially when the parties to the settlement agreement have consented to continued monitoring. 921 F.2d at 1385-86. This Court has carefully reviewed the LRSD Proposed Revised Plan as jointly submitted by the LRSD and Joshua and concludes that the Revised Plan is not manifestly unworkable or plainly unconstitutional on its face. The parties have consented to continued monitoring by this Court. Although the Court acknowledges that the Revised Plan will present new challenges in regard to monitoring, these anticipated challenges do not render the Revised Plan unworkable or plainly unconstitutional. Therefore, this Court concludes that the LRSD Proposed Revised Plan should be and hereby is approved. C. In the alternative, if this Court were to consider the proposed Plan as simply a modification of the 1990 Plan, this Court would approve the LRSD Proposed Revised Plan. A party seeking modification of a consent decree \"must establish that a significant change in facts or law warrants revision of the decree.\" Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367, 393 (1992). If the moving party meets this burden, the District Court 5 must then detennine \"whether the proposed modification is suitably tailored to the changed circumstance.\" Id. at 39 1. The modification \"must not create or perpetuate a constitutional violation,\" nor \"strive to rewrite a consent decree so that it confonns to the constitutional floor.\" Id. Little Rock Sch. Dist. v. Pulaski County Special Sch. Dist. , 56 F.3d 905, 914 (8th Cir. 1995). This Court concludes, after reviewing the circumstances of this case and the LRSD Proposed Revised Plan, that this standard for modifying a consent decree has been satisfied. Based upon the voluminous Court record generated by this case since the 1990 Plan was instituted and based upon the conclusions which may be drawn from the evidentiary hearings conducted by this Court in May of 1996, this Court concludes that circumstances and conditions have changed which warrant modifying the 1990 Plan. Specifically, there are certain aspects of the 1990 Plan that have been successfully implemented by the LRSD. Some areas of the 1990 - Plan have been so successfully implemented that this Court has withdrawn supervision over those areas. However, there are other stated goals in the 1990 Plan which have not been achieved. Evidence in the record tends to indicate that the LRSD has put forth minimal effort to achieve certain of these stated goals. More importantly, however, there are certain goals in the 1990 Plan which are out of date for the current situation that exists in the LRSD6 and other specific, rigid goals in the 1990 Plan which expert testimony indicates may never be met, regardless of the amount of effort and good faith put forth by the LRSD. 7 Therefore, the 1990 Plan warrants 6 For example, the sections of the 1990 Plan regarding Student Assignment and Facilities are out of date with regard to the current situation that exists in the LRSD. 7 Specifically, the goals in the 1990 Plan regarding achievement disparity may never be met, regardless of the effort put forth by the LRSD. See the testimony of Dr. Walberg, Docket No. 2692, at 17-25; Dr. Armor, Docket No. 2693, at 18-39; and Dr. Orfield, Docket No. 2768, at 25-31. 6 - -- - - - modification. Furthermore, this Court concludes that the LRSD Proposed Revised Plan furthers the original purpose of the decree in a more efficient way, without upsetting the basic agreement between the parties. The LRSD Proposed Revised Plan is suitably tailored to the changed circumstances, does not create or perpetuate a constitutional violation, and has not been rewritten to conform only to the constitutional floor. Therefore, this Court concludes that the LRSD Proposed Revised Plan should be approved. D. Having approved the LRSD Proposed Revised Plan, this Court notes that once a modification to a consent decree or a decree itself has been approved by the Court, its terms, . including the details, become binding on the parties. 921 F.2d at 1384. Although at this time the - Court does not anticipate the need for further modification, the Court does wish to clarify that if progress under this Revised Plan is clearly insufficient or if certain sections of the Revised Plan should prove to be unworkable, the parties may again apply for a modification of the Revised Plan. Consent decrees partake of the nature of contracts, as well as of judicial action, and parties seeking to change them bear an extremely heavy burden. They are not, however, immutable in any absolute sense, and extraordinary circumstances can arise that would enable the District Court, within its discretion, to consider modifications. Id. at 1387. II. Objections to the LRSD Proposed Revised Plan By previous Order, this Court directed the LRSD to provide notice of the LRSD Proposed Revised Plan and set March 13, 1998 as the deadline for receiving objections to the 7 - proposed Plan from individual members of the Joshua Class and from other parties to the litigation. 8 Dr. Leslie V. Carnine, Superintendent of the LRSD, submitted an affidavit indicating that the LRSD had complied with the Court's Order regarding notice of the proposed Plan. 9 A. The Court notes that although the other school districts and parties in this case were not involved in the negotiations which produced this proposed Plan, those parties were given notice of the proposed Plan and of their ability to object. 10 None of those parties have filed an objection with this Court to the LRSD Proposed Revised Plan. B. On the last day for filing objections, Mr. Markton Cole, on behalf of \"The FactFinding Committee for the LRSD Desegregation Plan--Is It Working For African-American Youthr (\"Fact-Finding Committee\"), filed several documents which he characterized as an objection to the proposed Plan. 11 The documents which Mr. Cole filed included a letter from Ms. Hafeeza Majeed, the Chairperson of the Fact-Finding Committee, and a report initially submitted by the Fact-Finding Committee to the Court on September 20, 1996. In response to the documents filed by Mr. Cole, Mr. John Walker, counsel for Joshua, filed a letter essentially requesting that this Court strike the documents and not consider the 8 Docket No. 3114. 9 Docket No. 3131. 10 Docket No. 3114. 11 Docket No. 3130. 8 - documents an objection to the LRSD Proposed Revised Plan. 12 Mr. Walker claims inter alia: (1) that the documents filed by Mr. Cole and Ms. Majeed had been previously submitted to and considered by this Court; (2) that the documents pertained to the LRSD Desegregation and Education Plan entered into by the LRSD and Joshua in 1990 (\"the 1990 Plan\"), not the LRSD Proposed Revised Plan currently before the Court; and (3) that Mr. Cole and Ms. Majeed lack legal standing to object because they are not residents of the LRSD and do not otherwise allege that either they or their own children will be harmed by the LRSD Proposed Revised Plan. This Court agrees with Mr. Walker's assertions and hereby strikes the documents filed by Mr. Cole on behalf of the Fact-Finding Committee and Ms. Majeed. 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Carnine; District Court, order; District Court, notice of filing, Office of Desegregation Monitoring report, ''Disciplinary Sanctions in the Pulaski County Special School District (PCSSD)''; District Court, order; District Court, renewed joint motion for approval of Little Rock School District's (LRSD's) revised desegregation and education plan; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool  The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  JOHN W. WALKER, P.A. ATTORNEY AT LAW 1723 BROADWAY MAR 9 1QGP lv ...., v LITTLE ROCK, ARKANSAS 72206 TELEPHONE (501) 374-3758 FAX (501) 374-4187 OFFlCE OF DESEGREGATION MONITORING JOHN W. WALKER RALPH WASHINGTON MARK BURNETTE AUSTIN PORTER JR. ENCLOSURE MEMORANDUM DATE: March 6, 1998 TO: Sam Jones, Esq. Wright, Lindsey \u0026 Jennings 2200 Worthen Bank Building Little Rock, AR 72201 Steve Jones, Esq. . Jack, Lyon \u0026 Jones, P.A. A ~oo Capitol Towers ~apitol \u0026 Broadway Streets Little Rock, AR 72201 Christopher Heller, Esq. Friday, Eldredge \u0026 Clark 2000 First Commercial Building Little Rock, AR 72201 FROM: John W. Walker Richard Roachell, Esq. Roachell \u0026 Streett 401 W. Capitol Ave. Suite 504 Little Rock, AR Ms. Ann Brown, Monitor Office of Desegregation Monitoring 201 East Markham, Suite 510 Little Rock, AR 72201 RE: LRSD, et al. v. PCSSD, et al.; NO. LR-C-82-866 ENCLOSURES: JOSHUA'S EXHIBIT LIST FOR MARCH 24, 1998 HEARING JOSHUA'S WITNESS LIST FOR MARCH 24, 1998 HEARING IF ANY OF THE ABOVE LISTED DOCUMENT(S) ARE NOT ENCLOSED, PLEA.SE CALL THE A.BOVE NUMBER. THANK YOU. --:;_ _----------- .,._ RECE,rlED - MAR 9 i998 OfflCE OF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION .--, -  - ~ ..J -i _ , ' ! LITTLE ROCK SCHOOL DISTRICT PLAINTIFF VS. 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 JOSHUA'S EXHIBIT LIST FOR MARCH 24, 1998 HEARING The Joshua Intervenors submits the documents as exhibits for the hearing scheduled herein for the week of March 24, 1998: 1. PCSSD assessments and evaluations of programs 2. PCSSD academic achievement statistics from 1993 to present . 3. PCSSD discipline statistics from 1992 to present 4. PCSSD recruitment report from 1994 to present 5. PCSSD staff development reports from 1994 to present 6. PCSSD gifted and talented reports from 1994 to present 7. PCSSD extracurricular activities including athletic and nonathletic programs reports from 1994 to present 8. ODM report on Achievement Disparity dated 6/21/95 9. 1998 ODM report on Racial Balance 10. 1998 ODM report on Discipline 11. ODM Report on Staffing dated 9/15/95 12. Excerpts of testimony from Gary Orfield dated May 30, 1996 13. PCCSD reports on Racial Isolation from 1994 to present 14. PCSSD reports 15. PCSSD Discipline Management system 16. PCSSD reports on In-School Suspension and Saturday School 17. PCSSD reports on Pupil Personnel Committee regarding expulsion recommendations 18. PCSSD reports on multicultural education frdm 1994 to present 19. PCSSD reports on special education from 1994 to present 20. UALR reports of PCSSD programs on academic achievement 21. PCSSD reports from the Office of Desegregation from 1994 to present 22. Report of Billy Bowles and Charles Green re: Robinson High School dated November 11, 1996 . 23. ODM Recommmendations regarding Robinson High School 24. Photographs of racial epitah on PCSSD school bus 25. Diagram of racial epitahs on PCSSD property 26 . Excerpts of Deposition Testimony of Bobby Lester 27. Excerpts of Deposition Testimony Bobby Altom 28. Excerpts of Deposition Testimony of Billy Bowles 29. Excerpts of Deposition Testimony of Eddie Collins 30. Excerpts of Deposition Testimony of Charles Green 31. Excerpts of Deposition Testimony of Tommie Anthony 32. Excerpts of Deposition Testimony of Gary Miller By: Respectfully submitted, JOHN W. WALKER, P.A. 1723 Broadway Little Rock, Arkansas 72206 ( 374-3758 CERT I FI CAT I hereby certify that a copy of the foregoing pleading has been served upon all counsel of record, by placing a copy of the same in the United States Mail with sufficient postage prepaid, on this 6th day of March, 1998. RECEIVED ' MAR 9 1998 OFFICE OF DESEGREGATION MONITORING Ey: - - -----=----=--,- ...,..~ -~, IN THE UNITED STATES DISTRICT COURT v...: :'  .._ _.: ,. .. \\ EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF VS. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, NO. 1, ET AL. DEFENDANTS MRS. LORENE JOSHUA, ET AL. INTERVENORS KATHERINE KNIGHT, ET AL. INTERVENORS JOSHUA'S WITNESS LIST FOR MARCH 24, 1998 HEARING The Joshua Intervenors submits the following persons as witnesses for the hearing scheduled herein for the week of March 24, 1998: 1. Bobby Lester, Superintendent of Schools 2. Billy Bowles, Asst. Supt. for Desegregation 3. Eddie Collins, Asst. Supt. for Pupil Personnel 4. Bobby Altom, Asst. Supt. for Instruction 5. Gary Miller, Asst. Supt for Personnel 6. Charles Green, Director of Secondary Education 7. Sarah Womble, Director of Elementary Education 8. Tommie sue Anthony, Coordinator of Talented and Gifted 9. Brenda Bowles, Coordinator of Multicultural Education 10. Martha Asti, Director of Special Education 11. Ruth Hertz, Director of Desegregation 12. Jerry Welch, Coordinator of Student Hearings 13. Doug Ask, Director of Staff Development 14. Mildred Tatum, Member of Board of Education 15. Gwendolyn Williams, Member of Board of Education 16. Georgia Norris, Pupil Personnel Specialist 17. Ann Clem, Pupil Personnel Specialist 18. Bill Barnes, Principal - Mills High School 19. Michael Nellums, Asst. Principal - Mills High School 20. Charles Green, Principal - Jacksonville Middle School 21. _____ Wilson, Asst. Principal - Jacksonville Middle 22. Florine Boone, Asst. Pricnipal Robinson Jr. High 23. Joy Plant, Asst. Principal - Robinson High School 24. Phil Clark, Asst. Principal - Jacksonville 25. Georgia Norris, Pupil Personnel Specialist 26. Dinah Withers, parent 27. Derrick Withers, student 28. Christopher Withers 2 9. Mr. ______ Withers 30. Earnestine Morgan, parent . 31. Antwine Wilson, student 32. Quentin Bailey, parent 33. Emory Moore, parent 34. Emmanuel Moore, student 35. Keith Straughan, Principal - Robinson Jr. 36. Linda Nuggent 37. Sue Martin, Principal, Adkins Elementary 38. Brenda Allen, Principal - Oak Grove High School 39. Coach Steve Adair - Oak Grove High School 40. Linda Clark, parent 41. Ashley Tate, parent 42. James Wiley, parent 43. Jamaal Wiley, parent 44. Marcia Warren 45. Bernice Hooks 540. Marcia Warren 46 . Sharon Patten, parent 47. Coach Wayne Davenport, Robinson High School 48. Peggy Flowers, parent 49. Lakia Watkins, student 50. Lawrence Stewart, parent 51. Lawrence Stewart, Jr., student 52. Janie Lawson, parent 53. Robin Wakefield, parent 54. Velma Moore, parent 55. Lisa Little, parent 56. Mary Anderson, parent -57. James Guy, parent 58. Kim Guy, parent 59. Stephanie Nichols, student 60. Melanie Nichols, student 61. Barbara Trotter, parent 62. Ashley Bush, student 63. Sue Clark, Prinicipal - Sylvan Hills Junior High 64. Charles Ferriter, Asst. Principal - Sylvan Hills High 65. Verna Finney, parent 66. Chris Bolden, parent 67. Mansell Twillle, Asst. Principal - Sylvan Hills Junior 68. Teresa Young, parent 69. Herman Lee, parent 70. Cathy Lee, parent 71. Anita Straw, parent 72. Michael Woods, parent 73. Bertha Farmer, parent 74. Joyce Lowrey, parent 75. Jackie Robinson, parent 76. Gary Parson, Principal - Jacksonville High School 77. Doug Ask, Coordinator of Staff Development 78. Jo Wilcox, Coordinator of Extracurricular Activities 79. Ann Brown, Office of Desegregation Monitoring 80. Margie Powell, Office of Desegregation Monitoring 81. Horace Smith, Office of Desegreation Monitoring 82. Gene Jones, Office of Desegregation Monitoring 83. Melissa Gauldin, Office of Desegregation Monitoring . 84. Norman W. Marshall, Office of Desegregation Monitoring 85. Dr. Steve Ross, Joshua expert witness 86. Michael Anderson, Director of Safety and Security 87. Michael Dobson 88. Richard Rowland 89. Charity Smith, ADE 90. Frank Anthony, ADE Joshua also reserves the right to call any witnesses listed on the list of the defendant, Pulaski county Special School District. Respectfully submitted, John W. Walker, P.A. 1723 Broadway Little R ck, -~ CERTIFICATE OF SERVICE I do hereby state that a copy of the fore~~ing was been hand delivered to all counsel of record on this \u0026ffe day of March, 1998. IN THE .UN!TED STATES DISTRICT COUrtT EASTERN DISTRICT OF ARKANS.ll.S \\JESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF VS. LR-C-82-865 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, NO . l, ET AL. DEFENDANTS MRS . LORE~ JOSHUA, ET AL. !NTERVENORS :\\ . .:..THERINE KNIGHT , ET AL. ::::Jfl'ERVEHORS JOSHUA'S SUPPLEMENTAL EXHIBIT LIST POR MARCH 2-1..t 19S8 HEARING The Joshua I ntervenors s~brnits the following supplenental documen~s as e xh ibits for the hearing scheduled herein for the week of Earch 24 , 1998 : 1. Curriculum Vitae of Dr . Stave Ross 2. Excerpt s oi Dep::,si-c2.on test ir::.:::-11y of ;::: a ,.,,- i ,j .::..r::,cr 3 . Excerpts of Deposition te.s-:: L-:10ny of Hs~be~i:. Walbe1g 4. ?CSSD a~s~ers to Jos ~~a Inte~rogator~ss 5. PCSSD B~dgets for 199~ to present 6 . PCU 0072 0 7. PCU 1 8. PCU 14-16 9 . ?CU :36 -54 10. PCSSD School Profiles for 1994-95 school year 11. PCTJ ~04 12 . PCG 7 2 1 - 72 2 13. PCSSD TAG Facilitators from 1992 to present 14. PCSSD Advanced Classes and AP Enrollment for 1992 to present 15. ?CSSD Discipline reports dated 1992 to present 16 . PCSSD Special Education Monitoring Reports ~rom 1996 to present Joshua f~r~ter reserves the rights to adopt any exhibit submitted by the defenda~ts, Pulaski County Special School District. ?espectfully sub~i~tad, CERrIFICATE OF SE_R\\TICE I do hereby s~ate that a cop7 cf the foregc!~g was been delievered via ~acs ~~ il~ tc all c cc~sel cf reccrd c~ ~~is Stj of March, 19 98 . day ----- - ----- ------------ SC 137-1 -:11:3':' l,iHLk EF- LHld FI PM John W Walker, P.A. 1 723 Broadwqy Little Rock, AR 72206 (501) 374-3758 Fax: (501) 374-4187 Ffu--X TRA\"/\\lSMISSION COVER SHEET .Date: To: . . -.. Fax: 371- 0 !0V Re: Sender: YOU SHOULD F.ECEIVE ]._ PAGE(S), INCLUDING THIS COVER SHEET. IF YOU DO NOT RECEIVE ALL THE PAGES, PLF-ASE C4LL (501) 374-3758. The informAtion conta..ined in this facsimile message is attorney privileged and. co:.fidential informa.t.ion intended on:y for the u.se cf th: individual or entity urned above. If 6e re.s.der cf this message is not the intended recipient, or the employee or agent responsible to delive: it to the l.ntended recipient, you are hereby notified that any dissemination, distribution o:- copy.ng of this cowmunicatlon is strictly prohibited. If you have received this commtL\":ication in error, please immediate noti~; us by t.::lephMe, and return the original message to us at the above address via the U.S. Pest.al Sen,ice. Thank you. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. NO. LR-C-82 - 866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. PCSSD'S WITNESS AND EXHIBIT LIST RECE,IED MAR q 1998 OFFICE OF DESEGREGATION MONITORING PLAINTIFFS DEFENDANTS INTERVENORS INTERVENORS The PCSSD submits the following as its exhibit and witness list: , EXHIBIT LIST 1. 1989 Releases (attached to Settlement Agreement) 2. ODM Racial Balance Reports 3 . Charts from PCSSD Petition for Release From Federal Court Supervision. 4. Staff Development Data 5. Charts pertaining to cheerleading, drill team, student government, Beta Club, and National Honor Society. 6. Affirmative Action Reports 7. Discipline Reports 8. Handbook for Student Conduct and Discipline i . 9. Secondary Education Report 10. Counselor's Reports 11. Special Education Reports 12. Gifted and Talented Reports 13. Athletic Reports 14. Non-Athletic Reports 15. Biracial Committee Minutes 16. PCSSD Desegregation Plan 17. Interdistrict Desegregation Plan 18. PCU 1039 (Minority AP student recruitment). 19. PCU 1040 (Social Studies Advanced Placement Recommendation Notice). 20. PCU 1041 (Social Studies Advanced Placement Recommendation Followup Student Conference form). 21. The Special Master's Interim Findings and Recommendations concerning PCSSD geography and demographics , dated August 19, 1988, as previously transmitted to the Court on January 20, 1994. WITNESS LIST 1. Bobby Lester, Superintendent, PCSSD; 2. Bill Bowles, Assistant Superintendent for Desegregation, PCSSD; 3 . Eddie Collins, Assistant Superintendent for Pupil Personnel Services, PCSSD; 2 4. Dr. Bobby Altom, Assistant Superintendent for Instruction; 5. Gary Miller, Assistant Superintendent for Personnel; 6. Don Stewart, Assistant Superintendent for Business Affairs; 7. Ed Hogan, Assistant Superintendent for Support Services; 8. Charles Green, Director of Secondary Education; 9. Tommie Sue Anthony, Director of Gifted and Talented Programs; 10. Martha Kay Asti, Director of Special Education; 11. Brenda Bowles, Coordinator of Multi-Cultural Education. WITNESSES VIA PREVIOUS TESTIMONY 12. 1988 Testimony of Ed Hogan, docket No. 1059-A, dated June 16, 1988, page Nos. 6 through 213; and docket No. 1060 -A, dated June 17, 1988, page Nos. 6 through 162. 13. Douglas A. Ask, Docket No. 2540, testimony beginning at page 95. 14 . Bill Bowles, by recent deposition not yet transcribed. 15. Dr. Bobby Altom, by recent deposition not yet transcribed (including previous testimony given in open court in this case, the docket reference for which we have not yet located) . 3 16. Eddie Collins, by recent deposition not yet transcribed, 17. Charles Green, by recent deposition not yet transcribed. 18. Tommie Sue Anthony, by recent deposition not yet transcribed. 19. Brenda Bowles, by recent deposition not yet transcribed. 20. Dr. Herbert Walberg, Docket No. 2662A (hearing held May 13-15, 1996), transcript filed with the Clerk as Docket No. 2692) 21. Dr. David Armor, Docket No. 2662B (hearing held May 13-15, 1996), transcript filed with the Clerk as Docket Nos. 2693-94). PCSSD reserves the right to use any exhibit or witness referred to or used by the Joshua Intervenors. WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 4 , - . CERTIFICATE OF SERVICE On March __ f __ , 1998, a copy of the foregoing was served by hand delivery to Mr. Walker and by U.S. Mail on the remainder of the service list: Robert Pressman 22 Locust Avenue Lexington, MA 02173 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 Mr. Richard Roachell Roachell Law Firm 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 5 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 425 West Capitol Avenue Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Bldg., Ste. 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Chris Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. NO. LR-C-82 - 866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS . LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. RECEIV~i MAR 1 8 1998 OFFICE OF . DESEGREGATION MONITOR/NG PLAINTIFFS DEFENDANTS INTERVENORS INTERVENORS SUPPLEMENTAL RESPONSES TO THE JOSHUA INTERVENOR$' INTERROGATORIES AND REQUESTS FOR PRODUCTION TO THE PCSSD (FEBRUARY 1998) The PCSSD for its supplemental responses to the Joshua Intervenors' Interrogatories and requests for production to the PCSSD states the following: INTERROGATORY NO. 3: If any of the persons identified in the answer to interrogatory No . 1 are expert witnesses, please state: (a) (b) (c) all opinions to be expressed by each expert; the basis and the reason for each opinion; all data or other information considered by the witness in forming such opinion. Please include in responding to this interrogatory each (i) employee of the PCSSD to give testimony as an expert, and (ii) any expert to \"te.stify\" by reliance on previous testimony in 1 this case (although intervenors do not concede the appropriateness of reliance on such testimony where there was no opportunity for normal discovery). SUPPLEMENTAL RESPONSE: As previously stated in response to Interrogatory No. 3, it is possible that Dr. Altom may be called to testify concerning achievement disparity. His opinion, the bases for them, and some of the information considered by him is set forth in his deposition. Some of the reference/research materials used by Dr. Altom in formulating his opinion are as follows: Title Lies My Teacher Told Me The Promised Land American Slavery Warriors Don't Cry Crusaders in the Courts Civil Rights and Civil Wrongs The Content of Our Character The Closing Door Stepping Over the Color Line Beyond the Classroom Forced Justice America in Black and White The End of Racism Outcome Equity in Education Dismantling Desegregation Good Intentions are Not Enough Inside American Education Race 2 Author James Loewen Nicholas Leman Peter Kolchin Melba Beal Jack Greenberg Harry Ashmore Shelby Steele Gary Orield \u0026 Carol Ashkimaze Amy Wells, Robert Crain Laurence Steinberg David Armor Stephan \u0026 Abigail Thernstrom Dinesh D'Souza Robert Berne, Lawrence Picus Gary Orfield, Susan Eaton Katherine Kersten Thomas Sowell Studs Terkel I i I  I I I Statistics. Research Measurement Resource(s) Authors Gerald W. Bracey R. L. Linn, N.E. Gronlund Gilbert Sax WRIGHT, LINDSEY \u0026 JENNINGS LLP 200 West Capitol Avenue, Suite 2200 Little Rock, Arkansas 72201-3699 (501) 371-0808 FAX: (501) 376-9442 By '-,?1~ M. ,s-\u0026muel;Jone ~(76060) ~ for PCSSD CERTIFICATE OF SERVICE On March --/ 7- -, 1998, a copy of the foregoing was serv ed by hand delivery to Mr. Walker and by U. S. Mail on the remainder of the service list: Robert Pressman 22 Locust Avenue Lexington, MA 02173 John W. Walker John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 Mr . Richard Roachell Roachell \u0026 Street 401 W. Capitol, Suite 504 Little Rock, Arkansas 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, Arkansas 72201 3 Mr. Stephen W. Jones Jack, Lyon \u0026 Jones 425 West Capitol Avenue Little Rock, Arkansas 72201 Ms. Ann Brown ODM Heritage West Bldg . , Ste. 510 201 East Markham Street Little Rock, Arkansas 72201 Mr. Chris Heller Friday, Eldredge \u0026 Clark 400 W. Capitol, Suite 2200 Little Rock, Arkansas 72201 , III IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL Mi\\R l 8 iS~B Q(-f\\CEOF DESEGREGATIOK MOKllORlNG DEFENDANTS J;NTERVENORS INTERVENORS NOTICE OF FILING The Little Rock School District (\"LRSD\") hereby gives notice ~f the filing of the Affidavit of Dr. Leslie v. Carnine related to LRSD's compliance with the notice requirements of the District Court's Order entered January 30, 1998. LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE \u0026 CLARK 2000 First Commercial Building 400 West Capitol Avenue Little Rock, AR 72201-3493 (501) 376-2011 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people ~X depositing a copy of same in the United States mail on this _rL_ day of 414fd...lk,,, , 1998. Mr. John w. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Sam Jones Wright, Lindsey \u0026 Jennings 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON \u0026 JONES, P.A. 425 w. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Mr. Travis Creed Roachell Law Firm First Federal Plaza 401 West Capitol, Suite 504 Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center street 200 Tower Building Little Rock, AR 72201 Ms. Ann Brown - HAND DELIVERED Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 nc. Fendley, Jr; IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT PLAINTIFF V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL AFFIDAVIT DEFENDANTS INT ERVEN ORS INTERVENORS I, Dr. Leslie V. Carnine, being first sworn, state under oath as follows: 1. I am the Superintendent of the Little Rock School - District. 2. I have reviewed the district court's order of January 30, 1998 which directs the Little Rock School District (\"LRSD\") to publish notice to the class of Joshua-Intervenors (\"Joshua\") of the pending motion by the LRSD and Joshua for approval of the LRSD Revised Desegregation and Education Plan dated January 16, 1998. 3. LRSD has complied with the notice publication requirements of the district court's order of January 30, 1998. 4. Copies of the notice were made and distributed to all LRSD teachers on February 13, 1998. 5. The notice was posted in all LRSD schools beginning on February 11, 1998. 6. The notice was broadcast on LRSD' s cable channel on February 13, 18 and 24 and on March 2 and 9, 1998. 7. Attached as Exhibit A to my affidavit is a true and correct copy of proof of publication of the notice in the Arkansas Democrat-Gazette on February 8, 21 and 28 and on March 7, 1998. Further affiant sayeth not. STATE OF ARKANSAS COUNTY OF PULASKI ) ) ss. ) Dr. LslV. Carnine Superintendent Little Rock School District DATE: ___.3_ -_t,_-~'1~r:....-____ SUBSCRIBED AND SWORN to before me, a Notary Public, on this day of March, 1998. My Comi~s1on Expires: .. 8-1-j{Jo'f 2 Arkana Democrat ~Q5azettc STATEj)'IENT OF LEGAL ADVERTISING Date :=to a..,,.._J__ ~ , ' 9 9 g Remit To; In Account With: Little Rock Newspapers, Inc. P.O. Box 2221 Little Rock, Ark. 72203 To Insure Proper Credit Refer To No ________________ _ Please remit yellow copy with payment .. Invoice No._ 5 '--f ~ 9 AD COPY 3~ Lines at _L_lLl ( ') \u0026 . ----- on the following dates: ____________ _ ~-J, Total Charge - Please Remit do solemnly swear that I am the legal billing clerk of the Arkansas Democrat-Gazette, a daily newspaper printed and published in said County, State ef Arkansas; that I was so related to this publicatioi:i at and during the publication qf the annexed legal advertisement in the matter of_ ___ _ ____________________ L/L-( -~d::-i ( Q ( Q pending in the _______ Court, in said County, and at the dates of the several publications of said advertisement stated above, and that during said periods and at said dates, said newspaper was printed and had a bona fide circulation in said County; that said newspaper had been regularly printed and published in said County, and had a bona fide circulation therein for the period of one month brf.ore the date of the first publication of s~id adv~rtisement; and that said ~d.ver.; iscmeut was ~uolished in ti1c regular daily issues of said newspaper at s~c1icu above. Subscrib~d and sworn to before me this) day oft 'rr\\.c~ ,1~2 -~__L._--~~- OFFICIAL SEAl VICKI A. MCBRIDE NOTARY PUBLIC. AR.rANSAs PULASKI COUNTY MY COMMISSION EXPIRES: 04-15-2006 Notary Puhl ic    C0 en -en  : . WllElHTEOSTATES .  .  DISTRICT COURT . ; - ....  E.ASTcRN OISTRICT  \u003e OF AOONSAS ..  .. WESTERN DIVISlON Um:E  ROCX\" SCHOOl DISTRICT. PI..AINTIFF ~- (  Ul~-866 PUtASKI COUNTY SPECIAL SC/iOOl DISTRICT NO. 1, ET AL OE FENOliNTS MRS. tORENE JOSHUA; ET AL INTERVENORS KAJliERINE KNIGHT, ET AL INTERVENORS .   - NOTICE . TOJ\u003etE JOSHUA ClASS;  All 'PAST. PRESEHT ANO FUTURE .81.ACK OR AfRICAH.AMERICAN PUPILS WHO RESIDE IN PULASKI COUNTY, ARKANSAS. ANO WHQ. ATTEND, HAVE ATTENOEO, Will: ATTENO. OR WHO ARE EUGleLE., WERE EUGl8lE OR Will BE ELK.IBLE TO ATTEND THE PU8UC SCHOOLS OF ONE OF THE THREE PUtASKI COUNTY SCHOOL DISTRICTS (UTllE ROCK. NORlH UT nE POCK OR PUI.ASKJ COUNTY!. THEIR PARENTS ANO/OR NEXT FRIENDS WHO CLAIM, HAVE CLAIMED. OR MAY CLAIM THAT THEY HAVE BEEN DENIED EOUAL PROTECTION OF THE LAWS. OR WHO Cl.AIM. HAVE CLAlMEO OR MAY. CLAIM THAT THEY HAVE BEEN OR' WILL BE THE VICTIMS Of RACE DISGAIMINA TlON IN EOUCA TlON SY. ONE OR MORE OF THE THREE PUl:ASl\u003cl COUNTY SCHOOL OISTRICJS Al:llOR BY THE STA TE Of AR~ arises cu defforts ,. nrq.. ii. 1956 to desegregate Ille~ . Rodi.: Nof1h Utllt Rodi and Naski Coanrr sd'oal dis1rids. In 1989 a SIi ilem1I - radled and apprOl'ld \"' wlich Ille Ult Rodi Sdl00I Oislrid (1.RSO'.) ~ 10 inplemenl lhe !UeIiSdiO\u0026 a~id Plan aPndla nI.l le Olnn- ~ 26. 1 . UISD submiUld ri = Yisect. . apprc r,al aonld LRESdOu'csa Rliotn- Ptaif dated ember 18. 1997. Fcl-lowi, g mnission. LASO and canel fer Jilt Josl'ua ~ (lwerlalt 'Jasllla1 enaaQld \"' el1enSNe Mgl)! lnonul an edoi1 10 dMIOp a rMed 1)1311 ).nic:11 ball, p3l1ies a:iuld SIJIIP0II. Those 118g0lialians resulted ii LRSO's Al!'lised Oesegregaticn and Educalion Plan-dated Jaooa,y 16. 1998 (\"~ 16.A!Med Ptan1,  Clo Januaiy 21, 1997, LASO and Jona filed a jcint request with lhe United  Slates Oisllid Court fer flt Easteni OisliCI ol Arkansas. Ille Hantfabll -Susan Wtib!t Wr91, lar ap, proval ti Ille J3lllll'f 16 ReviMd Plan. Tllc Jrua,y 16 Re'tised Plan baicaly pro:,ideS folows:  -~ ~: Prior Ageements and Or dets:  The:~ 16 Revised Plan wl rtpiace !ht amn1 LASO dese\u003c7egalian !)Ian., !ht lnrimtt ~ Piao-and al exiAng ~ and OlUrt\"oraets wilt1 some exceplians. It wil ~ no did on lhe Sepcern1Jer 21. 1989 . .setllemelt ~ -lhe Ma9- net Sdloal S1i1xmon daled Fellru3ly 2?,)987; lhe (Blrict COlll'I onlef dated ~ 3. {986, pet13r'ling 10 lhe Mq,et, Rt'liew Conrnittee; and. lhe IA-it\u003e-M ~ daled AuC)ust 2E.' 1986. ' Section 2: Otiigalions. LASO's basic ~ obligallons' tlfflain ~ ,. __ lllder lbr;Jaooa,y 16 AMed Plan as lllder Ille amnl ~ plal. The ollliJa1lals ate dea,ty and simply staled and ctNfif Mt'/ asped ol SCll00I ~ - The J3ll,aiy 16 Rl'fised l?tan .irldudes an r,en srong9f c:ommitmtfil 10 an equiCablt disrilution ol lacii11y ),y race. educalion and ezperiencir: .. .')lfp,gh some specifics n inculect; lhe' Jaroaty 16 Revised Plan conltf1'. 911h !hal ~ Ille lr1/1Si1ion ptriocl ~ dis1rid wil idenlily a/ld/Ol de- , Yei011' prog,wns. policies and ~  dw9I relalld IO HCII ollliga1ion. MU pen .setec1ed by lhe dis1ricl and a,\u003eptCIYld _by Joshua w,I assist Ille disn:I ~: ___ . '~ ~ (i/itiiiiiiic~,:mal \"' ltis process. Sealon 3; S1udenC AssicJwnenlS, Under 111t Jaooar, 16 llMld Plan. .,..~movtslromracillt.anca IO quality ecilc:alion. CMnJ 1111 ltrm ol lhe plan. ...,.,..., and ,... lm'igaMy libded lfell t1sWcllI0I cl1 0 alClen:d-a.n c,a. .-,,,.. hoed sd'oals with II many ol llmt neicfblrhoad sd'oals beina ..,.. !llled II p!1dical. Higll scnoal alllllaain zones may be rlli'awn 111 adWtt racial balanca wid'iil pu Of ni- 1111 lllerly P1rt11QJt p0l1IS flall Ill perter1agl ol AiicAmerican ... dents lcr hql sd'oals II I whale and. 10 lhe U1llnl praa,allle. fflli1llin a consislenl leeder paaem. V~ nlradislncl nnsl.s w,I a:intirlll 10 be alowtd I.Im NIis siNar IO !ht 116 111151Udeltassqvnertplan. The sa,dent wqrner'II plan also provides IOr Ille affifflion ol al U1SO ' ~ hql sd'oals 10 middle sdl00ls Jar grades six. - and eigtt a. cause ol capacily lrnllalionl  LRSO's Higll Sdloais. lhe aJnYtlSDI ID rridlll sa100ls may ~ lht aealion ol lllO IW11II grade scnools. Fc,ally. Ille Jaruary 16 AIYist Plan alls for Ille ainslruaion ol at least IIIO new aiea elementary sd1cois. one ii wes1 Lilllt Rod\u003c and one  Ille  ol !ht lormet Stepnens scllaal. When lhe new Stephens Elementa,y opens. one  Ol men Ille lncenM Sdloals wil be dosed. Seoon : lnlenislrid Sdloals. i lnferdaic:I sd'oals wil Cllf1lirue Ill : ~111ht'(dd:lhtlnlenis-l ~Adlievement The Jnlaly 16 Rl'lised Plan is loundld on a. belief lhal llf0'li:ing .,. err S1Udelt a quu1y edUCalion is ll1t j 111051 piomisr,g means ID lhe lq-tlrm deseqregalion ol LASO. It 0Ullines UISO's 1lasic sraiegy 1or 11\\uing a  S1Udents reaM a quality eclJcatiaa.  . indules an ur1y clildl00d dJCllion ' prt)113111.11Med~ ' ans am:wn lffl!)llasimg lhe prima-ry gr1deS. a rl'lised malhtmalics a,. ri:wn,anabmaMeciJCllianpn,grarn and pnntJI and CXlffll1Uily nvclYefflenl prt)l13l1I. MtfM ~ piece ol lht SIUdtnl achilMmel1  lion is a \u003cXllege scnolal!lip progra,n lar al studenlS who attend raa4y idenli6- ablt elemenWy sd1cois. Seoon 6: LRSD Compiance Pro- ~ wil ~ a ~ siYe ~ ~ ID ensure l subslanlialy ccmplies widl i1s desagr.gation ollligalicns and i1s Olher legal andet'ic:alobliQalions. . Sedion 7: Plan Mocillca1ion Pro-  Q!SS. The .Jaruaty 16 Re'lised Plan ndudes a pt0CeSS fer plan mocific3lion designed IO !date CXl0!)ffl1ion and disaxnge itigillion. LASO wil S1irni1 proposed plan mocilicalionl ID lhe ofl. \" panes wno wl hM an eSlabislled time lr3lne lor oomments and su,pslions. LASO wil !hen submil i1s ,_ ' mended plan modi6calion lar aut ap, prova. Pat1in would gane,aly be pnlholld lrom   issues belare .. dis1ricl CIJUtl ~ M1g .. c:ommenl period. ~~~~ r,g ~~~~ow:- . ganllng _,,...,_ yeaIrIs-. I  The plan establishes a process lar adffl! ing QlfflPlianca issues again desqled 10 ldlart C00!)ttalion and m- Cllln9' itigalion. Al ~ issues wil l'nl be subniatd Ill LASO. I no ageornen1 is readied. !he issue wil : be subnit1ed 10 OOM lar lacililalion. Only i OOM's ettons ii lacililating an aq,eemn Iii would lht issut be subnilted Ill lhe dislriclaut larresolueion. Seoon 9: T em1. The tenn ol Ille Rl'lised Oesegr lion and Educalion Plan wil be !hrN sctoa1 years begiming !he 1998-99 sd'oal yea, and enor-,q on Ille lasl day ol classes ol Ille ~1 sdl00I yeat. Fedefal court supervision wil end ii !NI time, and Ille dislricl wil rn#II IO local conllOI. Sedion 10: Transition. Thi 1997-98 SChool yea, and 1he 1n1 - ol lhe 1998-99 SChool ye wil be a rnitioA period in ptlpllllion ~ ~llalioll ol Ille Jaooa,y Section 11: ~ Stalus. I LASO subslanlialy metlS its obligalior, s l6idef lhe Jnwy 16 Rl'fised Plan. U1SO wil be inwy at lhe condusicll ol its llml and released from aut SllllMlion. The al\u003eowe is nol intended 10 be I U, dllailed-... of !ht RIIIIIY 16 flMtd Plan. The Jniary 16 RMld Pal. along with lhe amnt U1SO 0.. ~ Plan and lnletdislrict 0.. SIIJegation Plan. will be made MialJlt IO Josbla dass members cuinQ ~ business hotn ii LASO's aorrwilnM olbs al 810 W. Mar1lharn, UlltRodl.Arkwas. The purpose ol llis noCica is 10 advise Jos/111 dass membets ol lhe J3lllll'f 16 Revised \"'-1 and 10 rjve '- an appotmiy Ill show cause Ol III pivwidt - objeclions which ~ ,ol,y Ill nary 16 Rftised Plan shoud nol be ilj)plOYtd by lhe Dislrict Cotrt. Joslm Cius membets hM ,  lll'!.l t,e !~li',y of Marth, 1998 ID lit - Cl0rllMU Ol objeaions wifl lk. James McConnidl. U.S. Oislrid CCIII Oedt. U.S. Ccu1nouse, 600 W. ~ I.JIit Rock. Mansas 72201. Al Joslm class membets will be ll0lrd by lhe Dislrict Court's decision IJlllllMl!IOlrejec:!irq lhe~ 16 Al'listd  Plan. Absenl good cause --. there will be no heamg on whether flt J3lllll'f 16 Revised Plan shoud bl approved. ~. hs Hoict l)ffMdes Jona class nwnbtrs their Olly opporu,ity Ill olljed Ill ~oval \u003cJI lht Jnwy 16 Revised UNITED ST A TES DISTRICT COURT, EASTERN DISTRICT OF ARl\u003cANSAS. WESTERN DIVISION \u0026166578 IN THE UNITED STA TES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION UTILE ROCK SCHOOL DISTRICT, * Plaintiff, * vs. * No. LR-C-82-866 * PULASKI COUNTY SPECIAL SCHOOL * FILED U.S . DISTRICT COURT EASTERN DISTRICT ARKANSAS MAR t 7 1998 DISTRICT NO. 1, et al., * RECEIVED Defendants, * * MRS. LORENE JOSHUA, et al., * MAR 1 8 1998 Intervenors, * * OFFICE OF KATHERINE KNIGHT, et al., * DESEGREGATION MONITORING Intervenors. * ORDER By prior Order, 1 this Court set March 13, 1998 as the deadline for receiving objections regarding the January 16 Revised Plan. Attached hereto as Exhi "},{"id":"loc_rosaparks_48151","title":"[Evangeline Redfern playing miniature golf, Irvine, California] [graphic].","collection_id":"loc_rosaparks","collection_title":"Rosa Parks Papers","dcterms_contributor":null,"dcterms_spatial":["United States, California, Orange County, 33.67691, -117.77617","United States, California, Orange County, Irvine, 33.66946, -117.82311"],"dcterms_creator":null,"dc_date":["1998-03"],"dcterms_description":["Title devised by Library staff."],"dc_format":["image/jpeg"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":null,"dcterms_is_part_of":null,"dcterms_subject":["Miniature golf"],"dcterms_title":["[Evangeline Redfern playing miniature golf, Irvine, California] [graphic]."],"dcterms_type":["StillImage"],"dcterms_provenance":["Library of Congress"],"edm_is_shown_by":null,"edm_is_shown_at":["http://hdl.loc.gov/loc.pnp/ppmsca.48151"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Please contact holding institution for information regarding use and copyright status."],"dcterms_medium":["photographic printscolor1990-2000.gmgpc"],"dcterms_extent":null,"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":null}],"pages":{"current_page":420,"next_page":421,"prev_page":419,"total_pages":6766,"limit_value":12,"offset_value":5028,"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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