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District Court (Arkansas: Eastern District)","Joshua Intervenors"],"dc_date":["1997-12-12"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. 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Any other use requires permission from the Butler Center."],"dcterms_medium":["judicial records"],"dcterms_extent":["53 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  I  FILED U.S. DISTR ICT COURT IN THE UNITED STATES DISTRICT COtmTERN DISTRICT ARKANSAS EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION DEC 1 2 1997 LITTLE ROCK SCHOOL DISTRICT vs. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. NO. LR-C-82-866 RECEIVED DEC 1 5 1997 OFFICE OF DEFENDANTS INTERVENORS INTERVENOR Emergency Motion of ~~Wt{-hWNlmifHGrvenors Concerning The Payment of Attorneys' Fees by the LRSD The Joshua Intervenors respectfully move for the entry of an order providing for the payment of interim attorneys' fees by the LRSD to intervenors, periodically, in the manner described at the conclusion of this motion. The purpose of this motion is to ensure that the plaintiff class has adequate representation in the proceeding to consider the proposed, revised plan of the LRSD, and thereafter. This motion is based upon the accompanying memorandum and the following allegations: (1.) The LRSD has filed a motion, which this court has scheduled for a hearing beginning February 2, 1997, seeking approval of a \"Revised Desegregation and Education Plan.\" This plan is 16 pages in length. In contrast, the current plan of the LRSD is approximately 230 pages in length and the Interdistrict Plan is 64 pages in length. (2.) It is the stated purpose of the LRSD, in part, to have 1 / the Revised Plan \"supersede and extinguish\" the current LRSD Plan and the Interdistrict Plan. Revised Plan, at 1. (3.) The Revised Plan is in substantial part and in areas of critical importance merely an outline for a plan, rather than a plan that could be enforced by the court. For example: (a.) In 15 instances, in paragraphs II.B. through II.P, the words \"LRSD shall implement programs, policies, and\\or procedures,\" followed by a particular subject matter, appear. Revised Plan at 1-3. The \"programs, policies, and\\or procedures\" are not identified in the Plan. Compare Rule 65(d), Fed.R.Civ.Pro. (b . ) In Part V. of the Revised Plan, which deals with \"Student Achievement,\" the Plan specifies outcome goals for students in a way making it impossibe to determine the level of mastery intended. See Parts V.B.1.a. (at 8), V.B.2.a. (at 9-10), and V. B. 3. a. ( at 10) . (c.) In Part VII, the Revised Plan addresses a \"Compliance Program,\" without setting forth compliance standards. Revised Plan at 13. (4 . ) The Joshua Intervenors propounded written discovery requests to the LRSD concerning the Revised Plan. See copy of answers attached as exhibit A. One purpose of the discovery was to determine if the LRSD was willing to work with the Joshua Intervenors to render Part II. of the Plan, addressing \"Obligations,\" more specific. The LRSD made a nonresponsive answer to this query. Interrogatory 4 at 3. 2 /  (5.) One purpose of the discovery was to secure the identification of the underlying \"programs, policies and procedures\" which would appear to be determinative of the efficacy of the plan with regard to the plaintiff class. The answers to written discovery indicate that to a substantial degree, the underlying materials have not been identified. See Interrogatories 2, 18, 19, 20, 21, 22(i), 23, 27, 30. (6.) One purpose of the discovery was to identify the reason or reasons why in many instances the proposed plan did not identify the particular programs, policies or procedures to be implemented. The LRSD responded that \"LRSD believes, in order for the Revised Plan to be successful, the details related to implementation of the revised plan must be subject to modification without district court involvement.\" Interrogatory 3. In responding to an interrogatory about school construction, the LRSD again indicated its intent to have the power to define and redefine standards determinative of the value of the revised plan for the plaintiff class. Interrogatory 23. (7.) The LRSD seeks the approval of a new plan which is vague and standardless in many important respects, and designedly so, in a context in which the court and ODM have, over the years, found the performance of the agents of the LRSD in implementing the court-approved agreements to be deficient. See, for example, the court's statement to the LRSD school board members in March 1993; Mem. and Order, March 11 , 1996, at 8 (\"The LRSD has frequently exhibited indifference or outright recalcitrance 3 I  . ' towards its comitments and has been slow to implement many aspects of its agreements although some improvements have been made.''); Transcript June 23, 1995, at 34, 72, 87; July 6, 1995, at 123-24, 176-77, 241. (8.) In view of the foregoing allegations, it is reasonable to characterize the activities of the Joshua Intervenors in responding to the Revised Plan as protecting the extensive relief, previously agreed upon and approved by the courts. However, the relief sought in this motion is appropriate whether or not the court agrees with the foregoing position regarding the proposed Revised Plan. (9.) Assuming for the purposes of this motion the existence of the agreement on future fees found by this court in its Memorandum Opinion and Order, September 25, 1996, at 6-7, the agreement dealt with \"the life of the settlement plans ... \" (Chachkin); see also Mr. Heller (\"in our settlement plans\"). The activities of the Joshua Intervenors to date and in the future, with reference to the Revised Plan which would \"supersede and extinguish\" the LRSD and Interdistrict plans, are outside the parameters of the agreement found to exist by the court. Therefore, the Joshua Intervenors should be permitted to secure fees and costs for such work, and other work related to the Revised Plan, in accord with the standards last discussed by the Court of Appeals for the Eighth Circuit in Jenkins v. Missouri, 115 F.3d 554 (1997). (10.) Assuming for the purposes of this motion the existence 4 I' of the agreement on future fees found by this court in its Memorandum Opinion and Order, September 25, 1996, at 6-7, it is appropriate, in the totality of the circumstances of this case, to modify the agreement to delete the limitation on fee awards in the post-judgment phase of this case [see Appeal of the LRSD, 949 F.2d 253, 258 {8th Cir. 1991)], thereby restoring the applicability of the standard discussed in Jenkins v. Missouri. supra. The agreement will have been in force for seven years, during which an extraordinary amount of activity by the representatives of the Joshua Intervenors has been necessary, both in and out of court, much due to the deficient performance of the agents of the LRSD. This deficient performance has often been noted by this court, as evidenced by the examples cited above. See also Transcript, August 19, 1996, at 102. In addition, the continuation of the agreement will undermine the ability of the Joshua Intervenors to adequately represent the class. See the attached Affidavit of John W. Walker. (11.) Considerable work will be necessary in connection with the consideration of the Revised Plan, including responding to voluminous written discovery requests submitted by LRSD to intervenors' representatives. In addition, the LRSD proposal is for the Revised Plan to take effect eight months hence and to be in effect for at least three school years. {12.) This court has the authority to provide for an interim .award of fees and litigation costs, particularly when needed to protect the functioning of the private attorney general concept. 5 --- -- - -----  (13,) With regard to the hourly rates sought for the work of the representatives of the Joshua Intervenors, as noted in the prayer for relief below, see the following materials previously filed: John W. Walker -- Fee Petition, Nov. 21, 1995, Aff. of John w. Walker, at 1-7, 12-14; Supplemental Response of the Joshua Intervenors, Aug. 29, 1996, at 7 and Enclosure Two; Robert Pressman -- The Joshua Intervenors Motion for an Award of Attorneys' Fees (Sept. 1996), Sept. 27, 1996, Declaration of Robert Pressman and Attachments; Joy C. Springer -- Fee Petition, Nov. 21, 1995, Affidavit of Joy C. Springer, at 1-5, 19-20. WHEREFORE the Joshua Intervenors respectfully pray that the court enter an order: (a.) declaring that the work of the Joshua Intervenors' representatives concerning the Revised Plan is outside the scope of the agreement, previously found to exist by the court, limiting fee awards; (b.) declaring that the agreement of the Joshua Intervenors and the LRSD is modified, pursuant to the .court's authority to modify a consent decree, by eliminating the limitation on fee awards in the postjudgment stage of this case (with the understanding that the general standard governing fees at the postjudgment stage of a case will then apply); (c.) providing that the LRSD pay the Joshua Intervenors' representatives monthly their reasonable fees and costs, upon submission of adequate documentation, with the court available to rule on any portion of a request considered by the LRSD to be 6 outside the bounds normally governing fee awards; (d.) providing that the fees be paid at the following rates: John w. Walker ($ 250 per hour), Robert Pressman ($ 200 per hour), and Joy c. Springer($ 50 per hour); and (e) providing that the LRSD shall have the right to request the court to reconsider the procedure detailed in (c.) and (d.) after it has been in operation for 12 months; (f) providing such other and\\or different relief as the needs of justice may require. Robert Pressman MA 405900 22 Locust Avenue Lexington, MA 02173 617-862-1955 W. Walker AR 64046 W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 501-374-3758 CERTIFICATE OF SERVICE I do hereby state that a copy of the foregoing pleading was sent via United States mail on thi D e 1997 to all counsel of record and sent via counsel for LRSD. 7 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITTLE ROCK SCHOOL DISTRICT v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. RECEiVED DtL 1 5 1997 I, John W. Walker, a.ffiant herein, state under oath the following: FLED U.S. DISTRICT COURT EASTERN DISTrllCT ARKANSAS DEC 1 2 1997 JAMES W. McCORMACK, CLERK Bv: PLAINTIFF = -~ t:lEP.eLE1:111: DEFENDANTS INTERVENORS INTERVENORS 1. A majority of the cases being handled by my office are in the nature of civil rights litigation. 2. The clients in these cases are usually not fee paying clients whereby this office could on a regular basis bill them for our services. There are in such a practice unexpected losses, such as when the entire fee in the Judy Smith case was lost due to the bankruptcy of Harvest Foods. 3 Many of these cases are handled on a contingency fee basis thus causing the office to utilize a substantial amount of the fees collected on other cases to be a basis for support of these cases. 4. In the case ofLRSD, when the Eighth Circuit awarded fees to be paid in the case herein, a substantial amount was paid to the Legal Defense Fund (LDF) and to the estate of Wiley Branton, Sr. who had worked on this case for many years. Moreover, a substantial amount of the fee award was expended for expenses incurred in connection with the litigation herein. Furthermore, because of the taxing accounting method for purposes of making payments to the Internal Revenue Service (IRS), and the Department of Finance and Administration (DFA), large amounts of the Little Rock portion of the fee award were paid in that year or the next for federal and state income taxes. S. The costs of the representation of the class are enonnous and involve fees and costs to staff who monitor the case and who assist class members in their efforts to secure or retain rights believed by counsel to be afforded by the settlement. 6. The present scheduled hearing involves considerable preparation time including discovery, costs of extensive depositions from the two superintendents and five major level administrators and response to the substantial set of interrogatories propounded to the plaintiff class. This time and expense involvement comes during the period of the holidays, the end of the year, and the beginning of of the new year, when there is a need for attention, not only to legal presentation, but also to the overall business. It also comes at a time when the Pulaski County Special School District (PCSSD) is launching a serious attack upon the court approved settlement plan and is seeking to be declared unitary .. 7. In order to provide the court with insight into the plaintiff, LRSD's, tactic to overburden an already weakened office (no fees for more than $1,000,000.00 worth of work over a seven year period), the Friday firm proposes to take depositions of our representative simultaneously with our deposing the Superintendent and the staff. A response to that undertaking takes considerable time and effort. It distracts from inquiry into the plan. It also comes at a time when we still have our monitoring obligations which become more time consuming as the semester end approaches, based upon past experiences. Moreover, we are further handicapped because of the fact that we do not have the benefit of the usual Office of Desegregation Monitoring (ODM) reports for the past eighteen (18) months which would reflect the current or ongoing status of the LRSD's implementation of the desegregation plan. 8. The class stands to be adversely affected if our preparation for and participation in the February 2, 1998 hearing is not adequate. As it stands now, although the public belief is to the contrary, a fee drought for seven years from this case leaves us unable to meet the efforts of defense - counsel, supported by unregulated and unlimited funds, in an effort to defeat the very plan which they bugled in 1989 before the Court and the 8th Circuit. I have read the foregoing statements and they are true and correct to the best of my knowledge information and belief. SUBSCRIBED and SWORN before me this ~day of December, 1997.  ()fa a' Poivelx  Ex h; h,t A IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. vs. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PLAINTIFF LRSD'S ANSWERS TO PLAINTIFF:S DEFENDANTS INTERVENORS INTERVENORS THE JOSHUA INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LRSD'S MOTION FOR APPROVAL OF THE REVISED DESEGREGATION AND EDUCATION PLAN Plaintiff Little Rock School District (\"LRSD\") for its Answers to The Joshua Intervenors' First Set of Interrogatories and Requests for Production of Documents states: INTERROGATORY NO. 1: Please state the name, title, address and telephone number of each and every individual assisting in the preparation of the answers to these interrogatories. ANSWER: Objection. This inte~rogatory requests information which is privileged under the work product doctrine and/or the attorney-client privilege. Without waiving this objection, LRSD states that the following persons assisted in the preparation of these answers: Dr. Les Carnine, Christopher Heller and John c. Fendley, Jr. INTERROGATORY NO. 2: In 15 instances in paragraphs II. B. through II. P. of the proposed new plan, the words \"LRSD shall implement programs policies and/or procedures\" followed by a particular subject matter appear. Please identify separately for OEC5S97 7 each ot these 15 paragraphs all programs, policies and procedures  which you maintain ar~ currently implemented and are intended to be encompassed by the reference in the particular subparagraph of Pa~t II. of the proposed plan. In addition, please specify when the implementation of the particular program, policy or procedure began. Lastly, as to each sub-paragraph, please indicate whether work is underway to develop a particular program, policy or procedure to implement the obligation and, if so, describe generally the nature of the initiative(s) and the anticipated completion date(s).  ANSWER: Except as otherwise provided in LRSD' s Revised Desegregation and Education Plan (\"Revised Plan\"), the obligations set forth in Section II were not intended to encompass any particular implemented. program, policy and procedure currently being As stated in Section XI of the Revised Plan, the 1997-98 school year will be a transition year in preparation for implementation of the Revised Plan during the 1998-99 school year. During the transition year, LRSD will be evaluating current programs, policies and procedures and developing new programs, policies and procedures to be implemented in order to meet its obligations under the Revised Plan. Some of this work has already been completed and is contained in the work team reports submitted to the LRSD Board of Directors in August of this year. INTERROGATORY NO. 3: Please explain the reason(s) that the proposed plan does not include in the 15 instances referred to in Interrogatory No. 2, or in any instance, the identification of the 11-.\"\"'4..,._jo,I,._ 2  particular programs, policies and procedures to be implemented. (If LRSD believes that there is identification of a particular standard in one or more instances, please answer as to obligations where you agree that there is no identification of a particular standard or program). ANSWER: The Revised Plan includes specific programs, policies and/or procedures with regard to student assignments (Section III \u0026 IV), African-American academic achievement (Section V), equitable allocation of certified personnel (Section VI) and compliance (Section VII). With regard to the remaining obligations, LRSD believes that, in order for the Revised Plan to be successful, the details related to implementation of the Revised Plan must be subject to modification without district court involvement. LRSD firmly believes that flexibility is essential to instilling in the  qistrict a_ sense of responsibility and accountability. INTERROGATORY NO. 4: Would the system refuse to support adoption of the revised plan if the plan included the identification of particular programs, policies and/or procedures, or other steps, to implement the \"obligations\" identified in Part II? If so, explain the reason(s) for the system's position. ANSWER: The Revised Plan does identify particular programs, policies and/or procedures. See Answer to Interrogatory No. 3. INTERROGATORY NO. 5: Do you agree that as written, there would be compliance with the provisions of II.B. through II.P. of the proposed plan if the system implemented, as to the particular sub-paragraph, programs QI: policies QI: procedures regarding the ~11..a\\lonl~-- 3 I I I I \\  particular matter addressed in the paragraph. If the answer is negative, please explain the basis for the answer. ANSWER: Yes. INTERROGATORY NO. 6: As the plan is written, would the court have the authority, in the opinion of the LRSD, to hold a system official (s) (sic) in contempt of court for failure to implement a term of a particular policy of the district, which the LRSD views as encompassed by one of the sub-paragraphs in II.B. through II.P. of the plan, but which is not specified in the plan. If your answer is in the affirmative, please explain the basis f~r the answer. ANSWER: Objection. This interrogatory calls for the lega1 opinion of counsel for LRSD which is privileged under the attorneyclient privilege. Without waiving this objection, LRSD states that the district court would have authority to enforce the Revised Plan using its contempt power. INTERROGATORY NO. 7: As the plan is written, does any provision of paragraphs II.B. through II.P. of the plan require any action on the part of the LRSD if at a particular school there is substantial racial disparity, atypical in the LRSD system, in the numbers of black students suspended, the numbers of black males placed in special education classes, or the numbers of black students in the gifted and talented program. If the answer is affirmative, please identify the provision(s) which is the basis of the answer. 4 \\ ANSWER: Paragraphs G., H. and I. of Section II state LRSD's I obligations with regard to special education, student discipline and gifted and talented, respectively. Compliance with the~e paragraphs would require LRSD to investigate a racial disparity which varies substantially from what would be expected. INTERROGATORY NO. 8: Do you maintain that the .LRSD complies, currently, with each obligation set forth in Part II. of the plan. If not, please describe in detail the area(s) of noncompliance. ANSWER: The obligations set forth in Section II encompass the core obligations from LRSD' s current desegregation plan. LRSD maintains that it has substantially complied with its current desegregation plan. INTERROGATORY NO. 9: With respect to II.B. of the proposed plan, please identify as to each category of positions to which it applies, the proportion black in the relevant labor market and the source of this information, and the proportion black of the work force at present. ANSWER: LRSD intends to rely on federal EEOC statistics for Pulaski County, the State of Arkansas and the nation as a whole to determine the percentage of qualified African-Americans in the relevant labor market. With regard to the proportion of AfricanAmerican teachers and administrators, see Exhibits A, B and C attached. LRSD's noncertified personnel is 73.8% African-American. INTERROGATORY NO. 10: With respect to II.C. of the proposed plan, please identify as to each category of positions to which it applies, the meaning of the words \"the pool of candidates eligible 5 for promotion\", the proportion black in that pool and the source of  the information, and the proportion black of the persons employed in the category at present.  ANSWER: The \"pool of candidates eligible for promotion\" includes current employees who satisfy all eligibility requirements imposed by law or by the Board for a position. LRSD objects to identifying every position for which every employee is currently eligible for promotion as unduly burdensome. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 11: With respect to II.D. of the proposed plan, please identify the positions covered within the term \"certified personnel\" and provide as to each category the number of persons currently employed in the LRSD by race . ANSWER: \"Certified personnel\" are LRSD employees who must possess teaching or administrative certificates issued by the State of Arkansas in order to hold their position. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 12: With respect to II.E. of the proposed plan, please identify any category of certified personnel where the LRSD does not have the right to assign personnel for the good of the system and the basis of the limitation. ANSWER: See Articles XV through XVIII of the PN Agreement, attached hereto as Exhibit D, and the Arkansas Teacher Fair Dismissal Act. 6 \". INTERROGATORY NO. 13: With respect to II.H. of the proposed e plan, please describe in detail any specific initiative(s) in the LRSD a.t present, whether involving particular personnel, or standards, designed to guard against black students' receiving discipline for conduct for which white students are not disciplined, black students' receiving discipline for trivial matters, and/or black students' receiving more severe discipline than white students for similar conduct. ANSWER: LRSD expects all of its students, regardless of race or socioeconomic background, to comply with the Student Rights and Responsibilities Handbook. If a student fails to comply, the student will be disciplined as provided in the Handbook. Discipline information including the race of the student, the race of the administrator, the nature of the offense and the sanction imposed is compiled by the schools and maintained by LRSD. LRSD's Associate Superintendent for information in an attempt discrimination. Student Discipline reviews this to identify possible racial INTERROGATORY NO. 14: With respect to II.I. of the proposed plan, please define, with specificity, the word \"qualified,\" as it applies to each of the three areas discussed in the obligation; namely \"extracurricular activities\", \"advanced placement courses\", and \"gifted and talented\" programs. ANSWER: The phrase \"qualified African-American students\" means African-American students who satisfy the eligibility criteria for an activity or program. For many activities and 7  programs, there are eligibility criteria other than student interest. INTERROGATORY NO, 15: With respect to II.J. of the propos~d plan, does LRSD agree that as written the system would be in compliance with this provision if the system continued to implement any two programs with its federal Title I monies to improve the academic achievement of African-American students. If not, lease (sic) explain the basis for the disagreement. ANSWER: No. LRSD must also implement the programs, policies and/or procedures set forth in Section V of the Revised Plan. INTERROGATORY NO. 16: With respect to II.L. of the proposed plan, please define the terms \"equitable allocation,\" \"technological resources,\" and \"educational resources.\" Also, please identify any data source allowing a determination of whether these resources are equitably allocated to LRSD schools at present. ANSWER: The phrase \"equitable allocation\" means to allocate based on need and without bias or favoritism. The term \"technological resources\" means up-to-date computer and information technology. The term \"educational resources\" includes teachers, teacher aides, equipment and supplies. With regard to a data source for determing whether these resources are currently equitably allocated, see the technology work team report, the individual school profiles and the LRSD budget. INTERROGATORY NO. 17: With respect to II.M. of the proposed plan, please define the term \"equitable\" and identify the matters encompassed in the terms \"maintenance and repair.\" In addition, 8 ., . please identify any source of data available to -ascertain compliance with this obligation on a school-by-school basis. ANSWER: The term \"equitable\" means based on need and witho~t bias or favoritism. The terms \"maintenance and repair\" include the routine upkeep of the building and grounds and the repair or replacement of elements of the building and grounds which are no longer functional. LRSD maintains records which would indicate maintenance requests submitted by schools, the priority assigned to those requests and when and if those requests were acted upon. INTERROGATORY NO. 18: With respect to II.N. of the proposed plan, please identify any specific initiatives currently undertaken in the LRSD to ascertain whether or not guidance or counseling services provided to African-American students involve steering to a restricted range of courses and/or postsecondary educational opportunities. ANSWER: LRSD recognizes that African-American students are underrepresented in upper-level courses and has implemented strategies to address that issue. Specifically with regard to guidance and counseling services, LRSD has requested a National Science Foundation grant to fund training modeled after TESA and EQUALS to assist counselors in motivating African-American students to take the courses necessary to later be successful in upper-level science and math courses. INTERROGATORY NO. 19: With respect to II.O. of the proposed plan, does LRSD maintain that this subparagraph adds anything to 9 other obligations of the plan. If so, please describe with specificity what it adds. ANSWER: Yes. The obligations in Section II should be interpreted consistent with Paragraph o. INTERROGATORY NO. 20: With respect to II. P. of the proposed plan, please set forth the number of persons the LRSD plans to assign on a full-time basis to compliance/monitoring activities and the categories of positions to be staffed. In addition, please describe any steps to insure that the make-up of the staff includes a substantial number of African-American persons and any role which LRSD is willing to give the representative of the Joshua Intervenors in the selection of this staff. ANSWER: These decisions have not yet been made. INTERROGATORY NO. 21: With respect to III. A. 1. of the proposed plan, please identify any document , and any existing analysis stored in any other manner projecting school make-up by race if the steps described in this subparagraph are implemented. If any such data does not currently exist, please describe how such a projection could be done with data and resources available to the LRSO. ANSWER: LRSD is currently working with Edulog software to project school make-up under scenarios consistent with Section III of the Revised Plan. INTERROGATORY NO. 22: With respect to III. B. I.-5 of the proposed plan, please: (i) identify all written standards governing these transfers and (ii) describe any unwritten practices governing flllaN\"\"-1'\"711 ....... ,...._ 10 one or more of these transfers. (iii) In addition, please define the concepts of \"capacity limitations\" and \"reasonable requirement\" identifying any designations of schools capacities to be utilized. (iv) In addition, please explain the language \"a special need arising out of circumstances unique to a particular student\" by reference to the circumstances of youth receiving such transfers in 1997-98 and explain who does and who would decide that the requisite circumstances exist. (v) Lastly, please identify the numbers of students by race utilizing each category of such transfers in 1997-98. ANSWER: (i) No additional standards have been developed beyond what is contain in the Revised Plan. (ii) None. (iii) A school's capacity is a function of the physical plant and the educational programs being implemented at a school. At this time, LRSD is using the school capacity numbers attached hereto as Exhibit E. The \"reasonable requirements\" described in subparagraphs 1 through 5 of Section III.B. relate to procedural requirements which may be imposed by LRSD to ensure that student assignment occurs in a timely and efficient manner. ( iv) Special circumstances transfers as described by the Revised Plan are currently handled through an appeals committee composed of five members with individual members selected by the LRSD Board of Directors, the Biracial Committee, the PTA Council 11 and the Little Rock CTA. The committee reviews requests for transfers based on geographic isolation, racial isolation, medical hardship and other extenuating circumstances. This committee was established by the Tri-District plan and has been continued by LRSD under its current plan. (v) Records concerning transfers will be made available upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 23: With respect to III. E. of the proposed plan, please identify any potential sites for the school in west Little Rock, including any sites set forth in any study. In addition, please state whether the LRSD envisions the court's approving the site prior to its final approval. ANSWER: No potential site has been identified. Although LRSD anticipates keeping both the court and the parties informed about the site selection process, the site would not have to be approved by the court except as provided in Section IX.B. of the Revised Plan. INTERROGATORY NO. 24: With respect to IV.E. of the proposed plan, please describe any existing agreements, standards, and practices relating to cooperative efforts of the LRSD and PCSSD. ANSWER: See Interdistrict Desegregation Plan. INTERROGATORY NO. 25: With respect to V.B. and C. of the proposed plan, please (i) identify the author or authors of the provisions, committees and entities, designating the provision or provisions associated with each such author; ( ii) identify any document(s) providing further explanation of any provision(s) of r:--~Jooh.- 12  the proposal; (iii) regarding parts B.l.a., B.2.a., and B.J.a., I please identify any standards describing the level of competency envisioned in each instance and how it would be assessed; is developing the standards and the general timelines for that effort; and (iv) regarding these three parts of the plan, please state whether LRSD plans to have students satisfy a test requirement prior to moving to the next grade; if the matter is not decided, but such a requirement remains an option, please indicate. ANSWER: See curriculum work team report. INTE "},{"id":"kdl_abrad_19971212","title":"Interview with Anne Braden, December 12, 1997","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Fosl, Catherine"],"dcterms_spatial":["United States, Alabama, Calhoun County, Anniston, 33.65983, -85.83163","United States, Alabama, Jefferson County, Birmingham, 33.52066, -86.80249","United States, New York, New York County, New York, 40.7142691, -74.0059729","United States, Rhode Island, Newport County, 41.4998, -71.281","United States, Rhode Island, Newport County, Little Compton, 41.5101, -71.17116","United States, Virginia, City of Danville, 36.58597, -79.39502","United States, Virginia, Hanover County, 37.76015, -77.49087","United States, Virginia, Hanover County, Ashland, 37.75903, -77.47998"],"dcterms_creator":["Braden, Anne, 1924-2006"],"dc_date":["1997-12-12"],"dcterms_description":["Interview with Anne Braden, December 12, 1997 conducted by Catherine Fosl.","Anne Braden was a white southern anti-racist activist, organizer and journalist from Louisville, Kentucky. In this interview Anne Braden discusses her perceptions of her mother, father, and other Annistonians. She talks about the social climate of Anniston during and after World War II and the ways in which it impacted her and her family. Braden also discusses her early journalism career at The Anniston Star, the stories she covered there, her intellectual awakening to racism, and her friendships with fellow journalists. She speaks of college days at Randolph-Macon and Stratford, the friendships she established there, and how they evolved in her post-college life. She particularly speaks about her life-long friendship with Harriet Fitzgerald and Harriet's life as a lesbian and artist. Other topics include Braden's thoughts on dualism, historical materialism, educational reform, and the establishment of black schools in segregationist Anniston, Alabama."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Women civil rights workers--Interviews","Civil rights movements--United States","African Americans--Civil rights","Anniston Star (Anniston, Ala.)","Racism","Friendship","Educational change","Dualism","Historical materialism","College students","World War, 1939-1945--Alabama--Anniston","African Americans--Education","Randolph-Macon College","Stratford College (Danville, Va.)","United Service Organizations (U.S.)","Women college students--Virginia","United States. Congress. House. Committee on Un-American Activities","Peace movements--United States","Picketing--New York (State)--New York","Lesbians--United States","Education, Rural--Alabama","Race relations","Southern States--Race relations","Alabama--Race relations","Anniston (Ala.)--Race relations","Segregation in education--Alabama--Anniston","Poll tax--Alabama","Reporters and reporting--Alabama","Newspapers--Alabama--Anniston","Newspapers--Alabama--Birmingham","Drinking of alcoholic beverages--Alabama","Traffic accidents--Alabama","Dance","Civil rights workers--Alabama","African American civil rights workers--Alabama","Women civil rights workers--Alabama","Clergy--Alabama"],"dcterms_title":["Interview with Anne Braden, December 12, 1997"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt71jw86hr3t"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:34:26]"],"dlg_subject_personal":["Braden, Anne, 1924-2006","Braden, Anne, 1924-2006--Childhood and youth","Braden, Anne, 1924-2006--Interviews","Arnall, Ellis Gibbs, 1907-1992","McCarty, Anita","McCarty, Gambrell","Fitzgerald, Harriet, 1904-1984","Beech, Gould","Folsom, James Elisha","Silver, Dorothy B. (Dorothy Berea), 1925-2008","Roosevelt, Franklin D. (Franklin Delano), 1882-1945","Shuttlesworth, Fred L., 1922-2011","Vivian, C. T."],"dcterms_subject_fast":null,"fulltext":null},{"id":"kdl_abrad_19971211yater","title":"Interview with George Yater and Marjorie Yater, December 11, 1997","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Yater, Marjorie"],"dcterms_spatial":["United States, Indiana, Clark County, 38.47718, -85.70728","United States, Indiana, Clark County, Jeffersonville, 38.27757, -85.73718","United States, Kentucky, Daviess County, 37.73177, -87.08723","United States, Kentucky, Daviess County, Owensboro, 37.77422, -87.11333","United States, Kentucky, Jefferson County, Louisville, 38.25424, -85.75941"],"dcterms_creator":["Yater, George H."],"dc_date":["1997-12-11"],"dcterms_description":["Interview with George Yater and Marjorie Yater, December 11, 1997 conducted by Catherine Fosl.","In this interview George and Marjorie Yater, who were friends of Anne and Carl Braden at the time of their 1954 trial for sedition, give their impressions of the Bradens and their political activities. They describe the social and political climate of Louisville during the 1950s, including discussions of racial relations and McCarthyism. George Yater was working as a journalist at the time and explains how McCarthyism affected members of the media in the Louisville area. In addition, the Yaters describe the court proceedings and the trial's impact on the community."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Women civil rights workers--Interviews","Civil rights movements--United States","African Americans--Civil rights","Fellowship of Reconciliation (U.S.)","Kentucky Alliance Against Racist and Political Repression","Segregation","Racism","Courier-journal (Louisville, Ky.)","Veterans--Education--Kentucky","Libel and slander--Kentucky--Louisville","Reporters and reporting--Kentucky","Reporters and reporting--Indiana","Cold War--Influence","McCarthy, Joseph, 1908-1957--Influence","Fear--Kentucky","Intimidation--Kentucky","Communist Party of the United States of America","Communists--United States","Race relations","Louisville (Ky.)--Race relations","Segregation--Kentucky--Louisville","Civil rights demonstrations--Kentucky--Louisville","Lawyers--Kentucky--Louisville","Progressive Party (U.S. : 1948)","Strikes and lockouts--Kentucky--Louisville","Trials--Kentucky--Louisville","Subpoena--Kentucky--Louisville","Employees--Dismissal of--Kentucky--Louisville","Women's International League for Peace and Freedom","United States. Federal Bureau of Investigation","Trials (Sedition)--Kentucky","American Civil Liberties Union","Bombings--Kentucky--Louisville","African Americans--Violence against--Kentucky--Louisville","Discrimination in housing--Kentucky--Louisville","Governors--Kentucky"],"dcterms_title":["Interview with George Yater and Marjorie Yater, December 11, 1997"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt72jm23bx29"],"dcterms_temporal":null,"dcterms_rights_holder":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:29:10]"],"dlg_subject_personal":["Yater, George H.--Interviews","Yater, Marjorie--Interviews","Braden, Anne, 1924-2006","Braden, Carl, 1914-1975","McCarthy, Joseph, 1908-1957","Johnson, Lyman T., 1906-1997","Ethridge, Mark F. (Mark Foster), 1896-1981"],"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1693","title":"Court filings: District Court, interrogatories and requests for production to the Joshua intervenors","collection_id":"bcas_bcmss0837","collection_title":"Office of Desegregation Management","dcterms_contributor":null,"dcterms_spatial":["United States, 39.76, -98.5","United States, Arkansas, 34.75037, -92.50044","United States, Arkansas, Pulaski County, 34.76993, -92.3118","United States, Arkansas, Pulaski County, Little Rock, 34.74648, -92.28959"],"dcterms_creator":["United States. District Court (Arkansas: Eastern District)"],"dc_date":["1997-12-10"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Little Rock School District","Joshua Intervenors","Education--Arkansas","Educational law and legislation","Court records"],"dcterms_title":["Court filings: District Court, interrogatories and requests for production to the Joshua intervenors"],"dcterms_type":["Text"],"dcterms_provenance":["Butler Center for Arkansas Studies"],"edm_is_shown_by":null,"edm_is_shown_at":["http://arstudies.contentdm.oclc.org/cdm/ref/collection/bcmss0837/id/1693"],"dcterms_temporal":null,"dcterms_rights_holder":null,"dcterms_bibliographic_citation":null,"dlg_local_right":["Available for use in research, teaching, and private study. Any other use requires permission from the Butler Center."],"dcterms_medium":["judicial records"],"dcterms_extent":["49 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS ' WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT v. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL INTERROGATORIES AND REQUESTS FOR PRODUCTION TO THE JOSHUA INTERVENORS PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Plaintiff Little Rock School District (\"LRSD\") submits the following Interrogatories and Requests for Production to the Joshua Intervenors (\"Joshua\") in accordance with Fed. R. Civ. P. - 33 and 34: GENERAL DEFINITIONS AND INSTRUCTIONS (A) \"you\" or \"your\" Shall mean Joshua or any person acting on Joshua's behalf; (B) \"person\" Shall mean any individual, corporation, partnership, joint venture, firm, associaiion, proprietorship, agency, board, authority, commission, and other such entities; (C} \"communicate\" or \"communication\" Shall mean every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of f:\\homolfendlcy~rod-jooh.m. information whether orally or by document or whether face to face, by telephone, mail, personal delivery, or otherwise; (D) \"document\" Shall mean any original written, typewritten, handwritten, printed or recorded material, as well as all tapes, disks, non-duplicate copies and transcripts thereof, now or at any time in your possession, custody or control; and, without limiting the generality of the foregoing definition, but for the purposes of illustration only, \"document\" includes notes, correspondence, memoranda, business records, diaries, calendars, address and telephone records, photographs, tape recordings, financial statements and records. Without limitation of the term \"control\" as used in the preceding sentence, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person or a public or private entity having actual possession thereof. If a document that is responsive to a request for identification or production is in your control, but is not in your possession or custody, identify the person with possession or custody. If any document that is responsive to a request for identification or production was, but is no longer, in your possession or subject to your control, state what disposition was made of it, by whom, and the date or dates or approximate date or dates on which disposition was made, and why; f:\\homolfcnd l.:yU ...ildoo-jcoh..- 2 (E) \"identify\" (i) As to a person (as defined), shall mean the persons name, business and residence address(es); and, if not an individual, state the type of entity and the address of its principal place of business; (ii) As to a document, shall mean the type of document (letter, memo, etc.) the identity of the author or originator, the date authored or originated, the identity of each person to whom the original or copy was addressed or delivered, the identity of such person known or reasonably believed by you to have present possession, custody, or control thereof, and a brief description of the subject matter thereof, all with sufficient particularity to request its production under Rule 34 of the Federal Rules of Civil Procedure; (iii) As to a communication, shall mean the date of the communication, the type of communication (telephone conversation, meeting, etc.), the place where the communication took place, the identity of the person who made the communication, the identity of each person who received the communication, and of each person present when it was made and the subject matter discussed; (F) \"Pertaining to\" Shall mean constituting, embodying, arising out of, incident to, referring to, mentioned, bearing upon, reflecting, evidencing, affecting, concerning, providing evidence for, or relating to the transaction, individual, entity, act, object, 3 conference, contention, communication, allegation or activity identified; (G) To \"describe in detail\" Shall mean to provide with respect to any act, occurrence, transaction, event, statement, communication or conduct (hereinafter collectively, \"act\") all facts pertaining to any such act known to the person answering after due inquiry, including but not limited to a description of each act, the d~te, the location, and the identify of each person involved; (H) \"or\" shall be construed either conjunctively or disjunctively to bring within the scope of these Interrogatories any information which might otherwise be construed to be outside their scope; (I) \"Revised Plan\" shall mean LRSD Revised Desegregation - and Education Plan dated September 18, 1997; (J) \"current plan\" shall mean the LRSD Desegregation Plan dated April 29, 1992; all page and line citations to the current plan shall refer to current plan as set forth in LRSD's \"Desegregation Tool Kit,\" a copy of which is enclosed; (K) \"Interdistrict Plan\" shall mean the Interdistrict Desegregation Plan dated April 29, 1992; all page and line citations to the Interdistrict Plan shall refer to Interdistrict Plan as set forth in LRSD's \"Desegregation Tool Kit,\" a copy of which is enclosed; The singular includes the plural number, and vice versa. The masculine includes the feminine and neuter genders. The past l:lhomolfcndleyUn,d'dco-jooh.Ull 4 tense includes the presence tense where the clear meaning is not distorted by change of tense. If you do not answer any Interrogatory or Request for Production because of a claim of privilege, set for the privilege claimed, the facts upon which you rely to support the claim of privilege, and identify all documents for which such privilege is claimed. INTERROGATORY NO. 1: Please identify all persons who participated in the preparation of responses to these interrogatories and requests for production of documents . INTERROGATORY NO. 2: Please identify all persons who you intend to call as a lay witness at the hearing on the Revised Plan . INTERROGATORY NO. 3: Please identify all persons who you - intend to call as an expert witness at the hearing on the Revised Plan. REQUEST FOR PRODUCTION NO. 1: Please produce a written report signed by each expert witness identified in your response to Interrogatory No. 3 which contains a complete statement of all opinions to be expressed and the basis and reasons therefor; the data or other information considered by the witness in forming the opinions; any exhibits to be used as a summary of or support for the opinions; the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten years; the compensation to be paid for his testimony; and a listing of any other cases in which the witness f:lhcmo\\kndieyUrod\\deo-jcoh.w 5 has testified as an expert at trial or by deposition within the preceding four years. ' REQUEST FOR PRODUCTION NO. 2: Please produce all items, th~ngs and documents which you intend to introduce as an exhibit at the hearing on the Revised Plan. INTERROGATORY NO. 4: Do you contend that LRSD is not unitary with regard to student assignments? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 3: Please produce all documents identified in your response to Interrogatory No. 4 above. INTERROGATORY NO. 5: Do you contend that LRSD is not unitary with regard to faculty? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 4: Please produce all documents identified in your response to Interrogatory No. 5 above. INTERROGATORY NO. 6: Do you contend that LRSD is not unitary with regard to staff? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 5: Please produce all documents identified in your response to Interrogatory No. 6 above. INTERROGATORY NO. 7: Do you contend that LRSD is not unitary with regard to transportation? If so, describe in detail f:lhcmo\\fcndlcyUnod\\doo-joah.inl 6 the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 6: Please produce all documents identified in your response to Interrogatory No. 7 above. INTERROGATORY NO. 8: Do you contend that LRSD is not unitary with regard to extra-curricular activities? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 7: Please produce all documents identified in your response to Interrogatory No. 8 above. INTERROGATORY NO. 9: Do you contend that LRSD is not unitary with regard to facilities? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 8: Please produce all documents identified in your response to Interrogatory No. 9 above. INTERROGATORY NO. 10: Do you contend that LRSD has failed to substantially comply with the Early Childhood Education component (pp. 4-19) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 9: Please produce all documents identified in your response to Interrogatory No. 10 above. INTERROGATORY NO. 11: Do you contend that LRSD has failed to substantially comply with the Special Programs component (pp. 20-27) of the current plan? If so, describe in detail the f:\\homolfcrdlcyUr,d\\doe-j\u003c\u003eoh ... 7 basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 10: Please produce all documents identified in your response to Interrogatory No. 11 above. INTERROGATORY NO. 12: Do you contend that LRSD has failed to substantially comply with the School Operations component (pp. 28-47) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 11: Please produce all documents identified in your response to Interrogatory No. 12 above. INTERROGATORY NO. 13: Do you contend that LRSD has failed to substantially comply with the Program for Accelerated Learning/Academic Support Programs (pp. 48-57) of the current - plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 12: Please produce all documents identified in your response to Interrogatory No. 13 above. INTERROGATORY NO. 14: Do you contend that LRSD has failed to substantially comply with the Gifted Education component (pp. 58-62) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 13: Please produce all documents identified in your response to Interrogatory No. 14 above. f:lhomolfcndlcyllrod'doo-jooh.u,t 8 INTERROGATORY NO. 15: Do you contend that LRSD has failed to substantially comply with the Multicultural Curriculum component (pp. 63-80) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 14: Please produce all documents identified in your response to Interrogatory No. 15 above. INTERROGATORY NO. 16: Do you contend that LRSD has failed to substantially comply with the Focused Activities component (pp. 81-85) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 15: Please produce all documents identified in your response to Interrogatory No. 16 above. - INTERROGATORY NO. 17: Do you contend that LRSD has failed to substantially comply with the Parkview Science Magnet School component (pp. 86-92) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 16: Please produce all documents identified in your response to Interrogatory No. 17 above. INTERROGATORY NO. 18: Do you contend that LRSD has failed to substantially comply with the McClellan Community School component (pp. 93-94) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. f:\\homclfcndleyllnd'dcojooh.mi 9 REQUEST FOR PRODUCTION NO. 17: Please produce all documents identified in your response to Interrogatory No. 18 above. INTERROGATORY NO. 19: Do you contend that LRSD has failed to substantially comply with the Recruitment of Private School students component (p. 95) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO . 18: Please produce all documents identified in your response to Interrogatory No. 19 above. INTERROGATORY NO . 20: Do you contend that LRSD has failed to substantially comply with the Federal Programs component (pp. 96-97) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 19: Please produce all documents identified in your response to Interrogatory No. 20 above. INTERROGATORY NO. 21: Do you contend that LRSD has failed to substantially comply with the Vocational Education component (pp. 98-99) of the current plan? If so, describe in detail the basis(es) for this contention and i dentify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 20: Please produce all documents identified in your response to Interrogatory No. 21 above. INTERROGATORY NO. 22: Do you contend that LRSD has failed to substantially comply with the Library Media Services component (pp. 106-10) of the current plan? If so, describe in detail the f:\\homc\\/erdlcyUnd'\u003cbjooh.inl 10 basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 21: Please produce all documents identified in your response to Interrogatory No. 22 above. INTERROGATORY NO. 23: Do you contend that LRSD has failed to substantially comply with the Special Education component {pp. 111-23) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 22: Please produce all documents identified in your response to Interrogatory No. 23 above. INTERROGATORY NO. 24: Do you contend that LRSD has failed to substantially comply with the Staff Development component {pp. 20-27) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 23: Please produce all documents identified in your response to Interrogatory No. 24 above. INTERROGATORY NO. 25: Do you contend that LRSD has failed to substantially comply with the Support Services component (pp. 129-30) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 24: Please produce all documents identified in your response to Interrogatory No. 25 above. f:lhomo\\kmlcyllrodldcojooh.n 11 INTERROGATORY NO. 26: Do you contend that LRSD has failed to substantially comply with the Parent Involvement/Community Linkages component (pp. 131-38) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 25: Please produce all documents identified in your response to Interrogatory No. 26 above. INTERROGATORY NO. 27: Do you contend that LRSD has failed to substantially comply with the Student Assignments component (pp. 139-44) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 26: Please produce all documents identified in your response to Interrogatory No. 27 above. - INTERROGATORY NO. 28: Do you contend that LRSD has failed to substantially comply with the New Futures For Little Rock component (p. 145) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 27: Please produce all documents identified in your response to Interrogatory No. 28 above. INTERROGATORY NO. 29: Do you contend that LRSD has failed to substantially comply with the Facilities component (pp. 146- 148) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. lc\\home\\fcndlcyllnodldoejooh.inl 12 REQUEST FOR PRODUCTION NO. 28: Please produce all documents identified in your response to Interrogatory No. 29 above. INTERROGATORY NO. 30: Do you contend that LRSD has failed to substantially comply with the Incentive School Academic Programs and Curriculum Development component (pp. 152-70) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 29: Please produce all documents identified in your response to Interrogatory No. 30 above. INTERROGATORY NO. 31: Do you contend that LRSD has failed to substantially comply with the Incentive School Operations component (pp. 171~189} of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 30: Please produce all documents . identified in your response to Interrogatory No. 31 above. INTERROGATORY NO. 32: Do you contend that LRSD has failed to substantially comply with the Incentive School Staffing component (pp. 190-204) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 31: Please produce all documents identified in your response to Interrogatory No. 32 above. INTERROGATORY NO. 33: Do you contend that LRSD has failed to substantially comply with the Incentive School Parent f:\\hamolfendleyllradldeo-jooh.w 13 Involvement component (pp. 205-14) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 32: Please produce all documents identified in your response to Interrogatory No. 33 above. INTERROGATORY NO. 34: Do you contend that LRSD has failed to substantially comply with the Incentive School Parent Recruitment (pp. 215-23) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 33: Please produce all documents identified in your response to Interrogatory No. 34 above. INTERROGATORY NO. 35: Do you contend that LRSD has failed to substantially comply with the Educational Equity Monitoring component (pp. 224-26) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 34: Please produce all documents identified in your response to Interrogatory No. 35 above. INTERROGATORY NO. 36: Do you contend that LRSD has failed to substantially comply with the Computerized Transportation System component (pp. 227-29) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 35: Please produce all documents identified in your response to Interrogatory No. 36 above. l:\\hamollordlcyllrtd\\doo-Jo,h.bo 14 INTERROGATORY NO. 37: Do you contend that LRSD has failed to substantially comply with the Introduction component (pp. 1-2) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 36: Please produce all documents identified in your response to Interrogatory No. 37 above. INTERROGATORY NO. 38: Do you contend that LRSD has failed to substantially comply with the Overview component (pp. 3-7) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 37: Please produce all documents identified in your response to Interrogatory No. 38 above. - INTERROGATORY NO. 39: Do you contend that LRSD has failed to substantially comply with the student Choices and Options component (pp. 8-12) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 38: Please produce all documents identified in your response to Interrogatory No. 39 above. INTERROGATORY NO. 40: Do you contend that LRSD has failed to substantially comply with the Summer School component (pp. 13- 20) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. f:\\homclfc.-dlcyUnid'dcojcob.inl 15 REQUEST FOR PRODUCTION NO. 39: Please produce all documents identified in your response to Interrogatory No. 40 above. INTERROGATORY NO. 41: Do you contend that LRSD has failed to substantially comply with the Staff Development component (pp. 21-22) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 40: Please produce all documents identified in your response to Interrogatory No. 41 above. INTERROGATORY NO. 42: Do you contend that LRSD has failed to substantially comply with the School Operations component (pp. 23-34) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 41: Please produce all documents identified in your response to Interrogatory No. 42 above. INTERROGATORY NO. 43: Do you contend that LRSD has failed to substantially comply with the Special Education component (pp. 35-53) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 42: Please produce all documents identified in your response to Interrogatory No. 43 above. INTERROGATORY NO. 44: Do you contend that LRSD has failed to substantially comply with the Guidance and Counseling Program component (pp. 54-55) of the Interdistrict Plan? If so, describe f:lhom\u003c\\fcrdlcylll'ld'd.,o-jooh.n 16 in detail the basis(es) for this contention and identify all - facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 43: Please produce all documents identified in your response to Interrogatory No. 44 above. INTERROGATORY NO. 45: Do you contend that LRSD has failed to substantially comply with the Parental Involvement/Community Linkages component (pp. 56-58) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 44: Please produce all documents identified in your response to Interrogatory No. 45 above. INTERROGATORY NO. 46: Do you contend that LRSD has failed to substantially comply with the Public Relations component (pp. i-2) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 45: Please produce all documents identified in your response to Interrogatory No. 46 above. INTERROGATORY NO. 47: Do you contend that LRSD has failed to substantially comply with any order of the District Court pertaining to the current plan or Interdistrict Plan? If so, identify the order of the district court, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 46: Please produce all documents identified in your response to Interrogatory No. 47 above. r:lhorno1ren:11cy11nw1-.i..-jooh.in 17 INTERROGATORY NO. 48: Please describe .in detail Joshua's monitoring of LRSD during the 1992-93 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 47: Please produce all documents identified in your response to Interrogatory No. 48 above. INTERROGATORY NO. 49: Please describe in detail Joshua's monitoring of LRSD during the 1993-94 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 48: Please produce all documents identified in your response to Interrogatory No. 49 above. INTERROGATORY NO. 50: Please describe in detail Joshua's monitoring of LRSD during the 1994-95 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 49: Please produce all documents identified in your response to Interrogatory No. 50 above. INTERROGATORY NO. 51: Please describe in detail Joshua's monitoring of LRSD during the 1995-96 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO . . 50: Please produce all documents identified in your response to Interrogatory No. 51 above. INTERROGATORY NO. 52: Please describe in detail Joshua's monitoring of LRSD during the 1996-97 school year, including the f:lhomolfcndloyllndldco-jo,h.in 18 identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 51: Please produce all documents identified in your response to Interrogatory No. 52 above. INTERROGATORY NO. 53: Please describe in detail Joshua's monitoring of LRSD during the 1997-98 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 52: Please produce all documents identified in your response to Interrogatory No. 53 above. INTERROGATORY NO. 54: Please identify all persons not currently employed by LRSD known to you to have personal knowledge of LRSD's failure to comply with any obligation under either the current plan or the Interdistrict Plan. INTERROGATORY NO. 55: Please identify all of your communications with persons currently employed by LRSD pertaining to LRSD's compliance with either the current plan or the Interdistrict Plan. REQUEST FOR PRODUCTION 53: Please produce all documents pertaining to the communications identified in your response to Interrogatory No. 55 above. INTERROGATORY NO. 56: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in academic achievement? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. f:lhcmclfcndlcyllnd'dcejooh.inl 19 REQUEST FOR PRODUCTION NO. 54: Please produce all documents identified in your response to Interrogatory No. 56 above. INTERROGATORY NO. 57: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in student discipline? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 55: Please produce all documents identified in your response to Interrogatory No. 57 above. INTERROGATORY NO. 58: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in special education? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 56: Please produce all documents identified in your response to Interrogatory No. 58 above. INTERROGATORY NO. 59: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in the gifted and talented program? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO . 57: Please produce all documents identified in your response to Interrogatory No. 59 above . INTERROGATORY NO. 60: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in participation in honors and advanced f:lhome\\fc,d loyllrodldco-jcoh.ir\u003c 20 placement courses? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 58: Please produce all documents identified in your response to Interrogatory No. 60 above. INTERROGATORY NO. 61: Do you believe that continued implementation of the current plan and the Interdistrict Plan would result in LRSD achieving unitary status? If so, please identify when LRSD would be unitary and describe in detail the basis(es) for your response. If not, please describe in detail why and identify those aspects of school operations which would not be unitary. INTERROGATORY NO. 62: Please identify by page number(s) the components of the current plan and Interdistrict Plan which you believe should be modified , and for each component identified, please: a. describe in detail why you believe the component should be modified; b. identify all facts and documents which support your belief that the component should be modified; c. describe in detail the program, policy or procedure which you believe should be substituted for the component; and, d. identify all facts and documents which support your belief that the program, policy or procedure described inc. above should be substituted for the component . f:lhomclfcndlcyll..d\\dco-jooh. in. 21 REQUEST FOR PRODUCTION NO. 59: Please produce all documents identified in your response to Interrogatory No. 62 above. INTERROGATORY NO. 63: Please identify by page number(s) those components of the current plan and Interdistrict Plan which you contend should be continued under the Revised Plan, and with regard to each component identified, please describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 60: Please produce all documents identified in your response to Interrogatory No. 63 above. INTERROGATORY NO. 64: Do you agree with the recommendations 9on~ained in the Student Assignment Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identi fy all facts and documents which support your position. REQUEST FOR PRODUCTION NO. 61: Please produce all documents identified in your response to Interrogatory No. 64 above. INTERROGATORY NO. 65: Do you agree with the recommendations contained in the Curriculum Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identify all facts and documents which support your position. !:\\homo\\fcndlcy\\l..dldco-jooh.inl 22 REQUEST FOR PRODUCTION NO. 62: Please produce all documents identified in your response to Interrogatory No. 65 above. INTERROGATORY NO. 66: Do you agree with the recommendations contained in the Technology Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identify all facts and documents which support your position. REQUEST FOR PRODUCTION NO. 63: Please produce -all documents identified in your response to Interrogatory No. 66 "},{"id":"kdl_abrad_19971209wallace","title":"Interview with Henry Wallace and Carla Wallace, December 9, 1997","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Wallace, Carla, 1957-"],"dcterms_spatial":["United States, Kentucky, Jefferson County, Louisville, 38.25424, -85.75941"],"dcterms_creator":["Wallace, Henry F., 1915-2006"],"dc_date":["1997-12-09"],"dcterms_description":["Interview with Henry Wallace and Carla Wallace, December 9, 1997 conducted by Catherine Fosl.","In this interview Henry Wallace, a longtime friend of the Bradens, and Henry's daughter, Carla Wallace, an activist who worked closely with Anne Braden, discuss Anne and Carl Braden. Henry Wallace talks about the Bradens during the 1950s and 1960s and describes the political and social climate surrounding their 1954 trial for sedition. He also discusses the Communist Party and the leftist presence in Louisville, Kentucky during that era. Carla Wallace discusses Anne Braden's personality, her career as an activist, and her contribution to the Louisville community. Carla describes the lifestyle of a full-time activist and shares anecdotes from her years of activism and community-organizing with Anne. She also mentions other Louisville activists who have been important to their work."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Civil rights workers--Interviews","African Americans--Civil rights","Civil rights movements--United States","Sedition--United States","Civil rights workers--Kentucky--Louisville","Women civil rights workers--Kentucky--Louisville","Trials (Sedition)--Kentucky","Woodberry Forest School","Kentucky Military Institute (1845-1971)","Communists--United States","McCarthy, Joseph, 1908-1957--Influence","Cold War--Influence","Labor unions--Kentucky--Louisville","Fear--Kentucky--Louisville","Race relations","Louisville (Ky.)--Race relations","Discrimination in education--Kentucky--Louisville","Employees--Dismissal of--Kentucky--Louisville","Civil rights movements--Kentucky--Louisville","Civil rights demonstrations--Kentucky--Louisville","Ku Klux Klan (1915- )--Kentucky","Youth--Political activity--Kentucky--Louisville","Stigma (Social psychology)--Kentucky--Louisville","Political activists--Kentucky--Louisville","Political participation--Kentucky--Louisville","Leisure--Kentucky--Louisville","Presidents--Election--1984","Gay activists--Kentucky--Louisville","Gays--Civil rights--Kentucky--Louisville","Women's rights--Kentucky--Louisville","Mentoring--Kentucky--Louisville","Conflict management--Kentucky--Louisville","Solidarity--Kentucky--Louisville","Work-life balance--Kentucky--Louisville","Smoking--Kentucky--Louisville","Communities--Kentucky--Louisville","Trust--Kentucky--Louisville","Coalitions--Kentucky--Louisville","Fellowship of Reconciliation (U.S.)"],"dcterms_title":["Interview with Henry Wallace and Carla Wallace, December 9, 1997"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt759z909071"],"dcterms_temporal":null,"dcterms_rights_holder":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:27:05]"],"dlg_subject_personal":["Braden, Anne, 1924-2006","Braden, Carl, 1914-1975","Wallace, Henry F., 1915-2006--Interviews","Wallace, Carla, 1957- --Interviews","Yater, George H.","Pearce, John Ed.","Jackson, Jesse, 1941-","Edwards, George R., 1920-","Jones, Mattie","Freibert, Lucy M., 1922-"],"dcterms_subject_fast":null,"fulltext":null},{"id":"kdl_abrad_19990420lusky","title":"Interview with Louis Lusky, April 20, 1999","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Fosl, Catherine"],"dcterms_spatial":["United States, Georgia, Fulton County, Atlanta, 33.749, -84.38798","United States, Kentucky, Jefferson County, Louisville, 38.25424, -85.75941","United States, Kentucky, Jefferson County, Shively, 38.20007, -85.82274","United States, New York, New York County, New York, 40.7142691, -74.0059729"],"dcterms_creator":["Lusky, Louis"],"dc_date":["1997-12-09"],"dcterms_description":["Interview with Louis Lusky, April 20, 1999 conducted by Catherine Fosl.","Louis Lusky, a native of Louisville, Kentucky, was a well-respected civil liberties attorney, member of the ACLU, Betts Professor of Law at Columbia Law School, and, in his early career, a clerk for Supreme Court Justice Harlan Stone. In this interview, Lusky discusses the socio-political climate of Louisville during the 1950s, the presence of McCarthyism, liberalism, and the general state of race relations, the mixture of which constituted the atmosphere wherein the Braden sedition trial unfolded. He speaks of the evolution of his legal career, his involvement with the ACLU/KCLU, his relationship with Carl Braden as a member of his defense team, and of the general dynamics of the trial. Lusky also speaks of Anne Braden, of his general impressions of her and her life's mission."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["American Civil Liberties Union of Kentucky","American Civil Liberties Union","Race relations","Louisville (Ky.)--Race relations","Shively (Ky.)--Race relations","McCarthy, Joseph, 1908-1957--Influence","Cold War--Influence","Reporters and reporting--Kentucky--Louisville","African Americans--Segregation--Kentucky--Louisville","Discrimination in housing--Kentucky--Shively","Bombings--Kentucky--Shively","Racism--Kentucky--Shively","Insurance agents--Kentucky--Shively","Discrimination in insurance--Kentucky--Shively","Communists--United States","Trials (Sedition)--Kentucky--Louisville","United States. Supreme Court","Emergency Civil Liberties Committee","Judges--Kentucky--Louisville","Lawyers--Kentucky--Louisville","African American lawyers--Kentucky--Louisville","Discrimination in restaurants--Kentucky--Louisville","Arrest--Georgia--Atlanta","Communist Party of the United States of America","Segregation in education--Kentucky--Louisville","Courage--Kentucky--Louisville","Lawyers--New York (State)--New York","Law firms--New York (State)--New York"],"dcterms_title":["Interview with Louis Lusky, April 20, 1999"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt7gms3jxd7f"],"dcterms_temporal":null,"dcterms_rights_holder":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:06:44]"],"dlg_subject_personal":["Boudin, Leonard, 1912-","Lusky, Louis--Interviews","Wade, Andrew, IV","Braden, Anne, 1924-2006","Braden, Carl, 1914-1975","Tachau, Eric, 1924-2002","Stone, Harlan Fiske, 1872-1946","Grafton, C. W. (Cornelius Warren), 1909-","Root, Elihu, 1881-1967","Ballantine, Arthur A. (Arthur Atwood), 1883-1960","Dewey, Thomas E. (Thomas Edmund), 1902-1971"],"dcterms_subject_fast":null,"fulltext":null},{"id":"kdl_abrad_19971206shuttlesworth","title":"Interview with Fred Shuttlesworth, December 6, 1997","collection_id":"kdl_abrad","collection_title":"Anne Braden Oral History Project","dcterms_contributor":["Fosl, Catherine"],"dcterms_spatial":["United States, Alabama, Jefferson County, Birmingham, 33.52066, -86.80249","United States, Alabama, Montgomery County, 32.22026, -86.20761","United States, Alabama, Montgomery County, Montgomery, 32.36681, -86.29997","United States, Kentucky, Jefferson County, Louisville, 38.25424, -85.75941","United States, North Carolina, Guilford County, Greensboro, 36.07264, -79.79198"],"dcterms_creator":["Shuttlesworth, Fred L., 1922-2011"],"dc_date":["1997-12-06"],"dcterms_description":["Interview with Fred Shuttlesworth, December 6, 1997 conducted by Catherine Fosl.","Reverend Fred Shuttlesworth is an African American Baptist minister who was a leader of the civil rights movement and worked alongside Dr. Martin Luther King, Jr. In this interview, Shuttlesworth describes his work in the movement, particularly in Birmingham, Alabama. He talks about some protests and demonstrations in which he participated, including the Freedom Rides of 1961. Shuttlesworth describes the violence and intimidation that he and his fellow activists faced from the Ku Klux Klan and others. He talks about his friendship with Anne and Carl Braden and their collaboration on civil rights activism. Shuttlesworth describes their role in the civil rights movement and assesses their contributions to the causes of freedom and equality. He also mentions other notable civil rights activists with whom he worked."],"dc_format":null,"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":null,"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC/1.0/"],"dcterms_is_part_of":null,"dcterms_subject":["Civil rights workers--Interviews","Civil rights movements--United States","African Americans--Civil rights","Freedom Rides, 1961","Christians--Political activity","Ku Klux Klan (1915- )","Segregation","Southern Conference Educational Fund","Southern Organizing Committee for Economic and Social Justice","African Americans--Violence against--Southern States","Race relations","Southern States--Race relations","Segregation--Alabama--Birmingham","Courage","United States. Congress. House. Committee on Un-American Activities","Communism--United States","Cold War--Influence","Harassment--Southern States","Faith","Reporters and reporting--Southern States","Trust--Southern States","National Association for the Advancement of Colored People","National Urban League","Alabama Christian Movement for Human Rights","Southern Christian Leadership Conference","Congresses and conventions--Kentucky--Louisville","Traffic accidents--Kentucky--Louisville","Marriage","Humility","Discrimination in housing--Kentucky--Louisville","Civil rights demonstrations--Kentucky--Louisville","Black power--United States","Boards of directors--Southern States","Montgomery Improvement Association","Widowhood--Kentucky--Louisville","Grief--Kentucky--Louisville","Youth--Political activity--Southern States","Civil rights demonstrations--North Carolina--Greensboro","Arrest--Alabama--Montgomery","Civil rights demonstrations--Alabama--Montgomery","Imprisonment--Alabama","Clemency--Kentucky"],"dcterms_title":["Interview with Fred Shuttlesworth, December 6, 1997"],"dcterms_type":["Sound","Text"],"dcterms_provenance":["University of Kentucky"],"edm_is_shown_by":null,"edm_is_shown_at":["https://kentuckyoralhistory.org/ark:/16417/xt7jm61bkr9t"],"dcterms_temporal":null,"dcterms_rights_holder":["All rights to the interviews, including but not restricted to legal title, copyrights and literary property rights, have been transferred to the University of Kentucky Libraries."],"dcterms_bibliographic_citation":null,"dlg_local_right":null,"dcterms_medium":["oral histories (literary works)","sound recordings","transcripts"],"dcterms_extent":["1 interview : [01:34:36]"],"dlg_subject_personal":["Braden, Anne, 1924-2006","Braden, Carl, 1914-1975","King, Martin Luther, Jr., 1929-1968","Shuttlesworth, Fred L., 1922-2011--Interviews","Dombrowski, James A. (James Anderson), 1897-1983","Williams, Aubrey Willis, 1890-1965","Wilkins, Roy, 1901-1981","Current, Gloster B. (Gloster Bryant), 1913-1997","Jackson, Mahalia, 1911-1972","Abernathy, Ralph, 1926-1990","King, Coretta Scott, 1927-2006","Lowery, Joseph E.","Roosevelt, Eleanor, 1884-1962","Davis, Angela Y. (Angela Yvonne), 1944-","Bond, Julian, 1940-2015","Stembridge, Jane","Curry, Constance, 1933-","Farmer, James L., Jr. (James Leonard), 1920-1999","Kennedy, Robert F., 1925-1968","Connor, Eugene, 1897-1973"],"dcterms_subject_fast":null,"fulltext":null},{"id":"bcas_bcmss0837_1691","title":"Court filings: District Court, plaintiff Little Rock School District's (LRSD's) answers to the Joshua intervenors' first set of interrogatories and requests for production of documents regarding Little Rock School District's (LRSD's) motion for approval of the revised desegregation and education 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":["United States. District Court (Arkansas: Eastern District)","Little Rock School District"],"dc_date":["1997-12-03"],"dcterms_description":null,"dc_format":["application/pdf"],"dcterms_identifier":null,"dcterms_language":["eng"],"dcterms_publisher":["Little Rock, Ark. : Butler Center for Arkansas Studies. Central Arkansas Library System"],"dc_relation":null,"dc_right":["http://rightsstatements.org/vocab/InC-EDU/1.0/"],"dcterms_is_part_of":["Office of Desegregation Monitoring records (BC.MSS.08.37)","History of Segregation and Integration of Arkansas's Educational System"],"dcterms_subject":["Little Rock (Ark.)--History--20th century","Little Rock School District","Joshua Intervenors","Education--Arkansas","Education--Evaluation","Educational law and legislation","Educational planning","School management and organization","School integration","School improvement programs","Student assistance programs","Educational innovations"],"dcterms_title":["Court filings: District Court, plaintiff Little Rock School District's (LRSD's) answers to the Joshua intervenors' first set of interrogatories and requests for production of documents regarding Little Rock School District's (LRSD's) motion for approval of the revised desegregation and education 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/1691"],"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":["155 pages"],"dlg_subject_personal":null,"dcterms_subject_fast":null,"fulltext":"The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. vs. LR-C-82-866 PLAINTIFFS :~~~~I COUNTY SPECIAL SCHOOL DISTRICTRECEIVED DEFENDANTS MRS . LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. DEC ~ 1997 OFFICE OF PLAINTIFF LRSD, s AKiii~Ti MONITORING INT ERVEN ORS INTERVENORS THE JOSHUA INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LRSD'S MOTION FOR APPROVAL OF THE REVISED DESEGREGATION AND EDUCATION PLAN Plaintiff Little Rock School District ( \"LRSD\") for its Answers to The Joshua Intervenors' First Set of Interrogatories and Requests for Production of Documents states: INTERROGATORY NO. 1: Please state the name, title, address and telephone number of each and every individual assisting in the preparation of the answers to these interrogatories. ANSWER: Objection. This interrogatory requests information which is privileged under the work product doctrine and/or the attorney-client privilege. Without waiving this objection, LRSD states that the following persons assisted in the preparation of these answers: Dr. Les Carnine, Christopher Heller and John c. Fendley, Jr. INTERROGATORY NO. 2: In 15 instances in paragraphs II. B. through II. P. of the proposed new plan, the words \"LRSD shall implement programs policies and/or procedures\" followed by a particular subject matter appear. Please identify separately for l:lhomollct'd lcy\\lrod'dco-joob.ra  ' . each of these 15 paragraphs all programs, policies and procedures - which you maintain are currently implemented and are intended to be encompassed by the reference in the particular subparagraph of Part II. of the proposed plan. In addition, please specify when the implementation of the particular program, policy or procedure began. Lastly, as to each sub-paragraph, please indicate whether work is underway to develop a particular program, policy or procedure to implement the obligation and, if so, describe generally the nature of the initiative(s) and the anticipated completion date(s). ANSWER: Except as otherwise provided in LRSD's Revised Desegregation and Education Plan (\"Revised Plan\"), the obligations set forth in Section II were not intended to encompass any particular program, policy and procedure currently being implemented. As stated in Section XI of the Revised Plan, the 1997-98 school year will be a transition year in preparation for implementation of the Revised Plan during the 1998-99 school year. During the transition year, LRSD will be evaluating current programs, policies and procedures and developing new programs, policies and procedures to be implemented in order to meet its obligations under the Revised Plan. Some of this work has already been completed and is contained in the work team reports submitted to the LRSD Board of Directors in August of this year. INTERROGATORY NO. 3: Please explain the reason(s) that the proposed plan does not include in the 15 instances referred to in Interrogatory No. 2, or in any instance, the identification of the l:lh:\u003en-cllcndlcylll'ld'doo-jooh.,.. 2 particular programs, policies and procedures to be implemented. (If LRSD believes that there is identification of a particular standard in one or more instances, please answer as to obligations where you agree that there is no identification of a particular standard or program). ANSWER: The Revised Plan includes specific programs, policies and/or procedures with regard to student assignments (Section III \u0026 IV), African-American academic achievement (Section V), equitable allocation of certified personnel (Section VI) and compliance (Section VII). With regard to the remaining obligations, LRSD believes that, in order for the Revised Plan to be successful, the details related to implementation of the Revised Plan must be subject to modification without district court involvement. LRSD firmly believes that flexibility is essential to instilling in the - qistrict a sense of responsibility and accountability. INTERROGATORY NO. 4: Would the system refuse to support adoption of the revised plan if the plan included the identification of particular programs, policies and/or procedures, or other steps, to implement the \"obligations\" identified in Part II? If so, explain the reason(s) for the system's pos i tion. ANSWER: The Revised Plan does identify particular programs, policies and/or procedures. See Answer to Interrogatory No. 3. INTERROGATORY NO. 5: Do you agree that as written, there would be compliance with the provisions of II.B. through II.P. of the proposed plan if the system implemented, as to the particular sub-paragraph, programs or policies or procedures regarding the r:lhom,lr\u003cndlcyllr\u003e\u003cl'dca-jah.ra 3 particular matter addressed in the paragraph. If the answer is negative, please explain the basis for the answer. ANSWER: Yes. INTERROGATORY NO. 6: As the plan is written, would the court have the authority, in the opinion of the LRSD, to hold a system official (s) (sic] in contempt of court for failure to implement a term of a particular policy of the district, which the LRSD views as encompassed by one of the sub-paragraphs in II.B. through II.P. of the plan, but which is not specified in the plan. If your answer is in the affirmative, please explain the basis for the answer. ANSWER: Objection. This interrogatory calls for the legal opinion of counsel for LRSD which is privileged under the attorneyclient privilege. Without waiving this objection, LRSD states that the district court would have authority to enforce the Revised Plan using its contempt power. INTERROGATORY NO. 7: As the plan is written, does any provision of paragraphs II.B. through II.P. of the plan require any action on the part of the LRSD if at a particular school there is substantial racial disparity, atypical in the LRSD system, in the numbers of black students suspended, the numbers of black males placed in special education classes, or the numbers of black students in the gifted and talented program. If the answer is affirmative, please identify the provision(s) which is the basis of the answer. (:\\homolfcndlcyllndldoojooh.,.. 4 ANSWER: Paragraphs G., H. and I. of Section II state LRSD's obligations with regard to special education, student discipline and gifted and talented, respectively. Compliance with these paragraphs would require LRSD to investigate a racial disparity which varies substantially from what would be expected. INTERROGATORY NO. 8: Do you maintain that the .LRSD complies, currently, with each obligation set forth in Part II. of the plan. If not, please describe in detail the area(s) of noncompliance. ANSWER: The obligations set forth in Section II encompass the core obligations from LRSD' s current desegregation plan. LRSD maintains that it has substantially complied with its current desegregation plan. INTERROGATORY NO. 9: With respect to II.B. of the proposed plan, please identify as to each category of positions to which it applies, the proportion black in the relevant labor market and the source of this information, and the proportion black of the work force at present. ANSWER: LRSD intends to rely on federal EEOC statistics for Pulaski County, the State of Arkansas and the nation as a whole to determine the percentage of qualified African-Americans in the relevant labor market. With regard to the proportion of AfricanAmerican teachers and administrators, see Exhibits A, B and C attached. LRSD' s noncertified personnel is 73. 8% African-American. INTERROGATORY NO. 10: With respect to II.C. of the proposed plan, please identify as to each category of positions to which it applies, the meaning of the words \"the pool of candidates eligible f:lhomolfcndlcyllnd'dc.-jc,oh.1W 5 for promotion\", the proportion black in that pool and the source of the information, and the proportion black of the persons employed in the category at present. ANSWER: The \"pool of candidates eligible for promotion\" includes current employees who satisfy all eligibility requirements imposed by law or by the Board for a position. LRSD objects to identifying every position for which every employee is currently eligible for promotion as unduly burdensome. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 11: With respect to II.D. of the proposed plan, please identify the positions covered within the term \"certified personnel\" and provide as to each category the number of persons currently employed in the LRSD by race. ANSWER: \"Certified personnel\" are LRSD employees who must possess teaching or administrative certificates issued by the State of Arkansas in order to hold their position. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 12: With respect to II.E. of the proposed plan, please identify any category of certified personnel where the LRSD does not have the right to assign personnel for the good of the system and the basis of the limitation. ANSWER: See Articles XV through XVIII of the PN Agreement, attached hereto as Exhibit D, and the Arkansas Teacher Fair Dismissal Act. r:lhomellcndlcyUrld'da-jooh.,a 6 I I I I I I I I I I I I INTERROGATORY NO. 13: With respect to II.H. of the proposed plan, please describe in detail any specific initiative(s) in the LRSD at present, whether involving particular personnel, or standards, designed to guard against black students' receiving discipline for conduct for which white students are not disciplined, black students' receiving discipline for trivial matters, and/or black students' receiving more severe discipline than white students for similar conduct. ANSWER: LRSD expects all of its students, regardless of race or socioeconomic background, to comply with the Student Rights and Responsibilities Handbook. If a student fails to comply, the student will be disciplined as provided in the Handbook. Discipline information including the race of the student, the race of the administrator, the nature of the offense and the sanction imposed is compiled by the schools and maintained by LRSD. LRSD's Associate Superintendent for Student Discipline reviews this information in an attempt to identify possible racial discrimination. INTERROGATORY NO. 14: With respect to II.I. of the proposed plan, please define, with specificity, the word \"qualified,\" as it applies to each of the three areas discussed in the obligation, namely \"extracurricular activities\", \"advanced placement courses\", and \"gifted and talented\" programs. ANSWER: The phrase \"qualified African-American students\" means African-American students who satisfy the eligibility criteria for an activity or program. For many activities and (:\\hoorcll'endlcyll..dldoo-jolh.ra 7 programs, there are eligibility criteria other than student interest. INTERROGATORY NO. 15: With respect to II.J. of the proposed plan, does LRSD agree that as written the system would be in compliance with this provision if the system continued to implement any two programs with its federal Title I monies to improve the academic achievement of African-American students. If not, lease (sic) explain the basis for the disagreement. ANSWER: No. LRSD must also implement the programs, policies and/or procedures set forth in Section V of the Revised Plan. INTERROGATORY NO. 16: With respect to II.L. of the proposed plan, please define the terms \"equitable allocation,\" \"technological resources,\" and \"educational resources.\" Also, please identify any data source allowing a determination of whether these resources are equitably allocated to LRSD schools at present. ANSWER: The phrase \"equitable allocation\" means to allocate based on need and without bias or favoritism. The term \"technological resources\" means up-to-date computer and information technology. The term \"educational resources'' includes teachers, teacher aides, equipment and supplies. With regard to a data source for determing whether these resources are currently equitably allocated, see the technology work team report, the individual school profiles and the LRSD budget. INTERROGATORY NO. 17: With respect to II.M. of the proposed plan, please define the term \"equitable\" and identify the matters encompassed in the terms \"maintenance and repair.\" In addition, /:lhomo,1/crdlcylltod'doo-jch.,.. 8 please identify any source of data available to ascertain compliance with this obligation on a school-by-school basis. ANSWER: The term \"equitable\" means based on need and without bias or favoritism. The terms \"maintenance and repair\" include the routine upkeep of the building and grounds and the repair or replacement of elements of the building and grounds which are no longer functional. LRSD maintains records which would indicate maintenance requests submitted by schools, the priority assigned to those requests and when and if those requests were acted upon. INTERROGATORY NO. 18: With respect to II.N. of the proposed plan, please identify any specific initiatives currently undertaken in the LRSD to ascertain whether or not guidance or counseling services provided to African-American students involve steering to a restricted range of courses and/or postsecondary educational opportunities. ANSWER: LRSD recognizes that African-American students are underrepresented in upper-level courses and has implemented strategies to address that issue. Specifically with regard to guidance and counseling services, LRSD has requested a National Science Foundation grant to fund training modeled after TESA and EQUALS to assist counselors in motivating African-American students to take the courses necessary to later be successful in upper-level science and math courses. INTERROGATORY NO. 19: With respect to II.O. of the proposed plan, does LRSD maintain that this subparagraph adds anything to r:\"\"'-lfcndley~r,d\\deo-jcoh.ra 9 other obligations of the plan. If so, please describe with specificity what it adds. ANSWER: Yes. The obligations in Section II should be interpreted consistent with Paragraph 0. INTERROGATORY NO. 20: With respect to II. P. of the proposed plan, please set forth the number of persons the LRSD plans to assign on a full-time basis to compliance/monitoring activities and the categories of positions to be staffed. In addition, please describe any steps to insure that the make-up of the staff includes a substantial number of African-American persons and any role which LRSD is willing to give the representative of the Joshua Intervenors in the selection of this staff. ANSWER: These decisions have not yet been made. INTERROGATORY NO. 21: With respect to III. A. 1. of the proposed plan, please identify any document and any existing analysis stored in any other manner projecting school make-up by race if the steps described in this subparagraph are implemented. If any such data does not currently exist, please describe how such a projection could be done with data and resources available to the LRSD. ANSWER: LRSD is currently working with Edulog software to project school make-up under scenarios consistent with Section III of the Revised Plan. INTERROGATORY NO. 22: With respect to III.B. I . -5 of the proposed plan, please: (i) identify all written standards governing these transfers and (ii) describe any unwritten practices governing l:ll,anollcndlcy\\Jnd'du-jooh.,a 10 one or more of these transfers. (iii) In addition, please define the concepts of \"capacity limitations\" and \"reasonable requirement\" identifying any designations of schools capacities to be utilized. (iv) In addition, please explain the language \"a special need arising out of circumstances unique to a particular student\" by reference to the circumstances of youth receiving such transfers in 1997-98 and explain who does and who would decide that the requisite circumstances exist. (v) Lastly, please identify the numbers of students by race utilizing each category of such transfers in 1997-98. ANSWER: (i) No additional standards have been developed beyond what is contain in the Revised Plan. (ii) None. (iii) A school's capacity is a function of the physical plant and the educational programs being implemented at a school . At this time, LRSD is using the school capacity numbers attached hereto as Exhibit E. The \"reasonable requirements\" described in subparagraphs 1 through 5 of Section III.B. relate to procedural requirements which may be imposed by LRSD to ensure that student assignment occurs in a timely and efficient manner. (iv) Special circumstances transfers as described by the Revised Plan are currently handled through an appeals committee composed of five members with individual members selected by the LRSD Board of Directors, the Biracial Committee, the PTA Council r:lhomo\\fendlcyUnod'dc.-jooh.,a 11 and the Little Rock CTA. The committee reviews requests for transfers based on geographic isolation, racial isolation, medical hardship and other extenuating circumstances. This committee was established by the Tri-District plan and has been continued by LRSD under its current plan. (v) Records concerning transfers will be made available upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 23: With respect to III. E. of the proposed plan, please identify any potential sites for the school in west Little Rock, including any sites set forth in any study. In addition, please state whether the LRSD envisions the court's approving the site prior to its final approval. ANSWER: No potential site has been identified. Although LRSD anticipates keeping both the court and the parties informed about the site selection process, the site would not have to be approved by the court except as provided in Section IX.B. of the Revised Plan. INTERROGATORY NO. 24: With respect to IV.E. of the proposed plan, please describe any existing agreements, standards, and practices relating to cooperative efforts of the LRSD and PCSSD. ANSWER: See Interdistrict Desegregation Plan. INTERROGATORY NO. 25: With respect to V.B. and C. of the proposed plan, please (i) identify the author or authors of the provisions, committees and entities, designating the provision or provisions associated with each such author; ( ii) identify any document(s) providing further explanation of any provision(s) of f:lhomo\\fcndlcyllrod\\doo-jooh.,_ 12 the proposal; (iii) regarding parts B.l.a., B.2.a., and B.3.a., please identify any standards describing the level of competency envisioned in each instance and how it would be assessed; is developing the standards and the general timelines for that effort; and (iv) regarding these three parts of the plan, please state whether LRSD plans to have students satisfy a test requirement prior to moving to the next grade; if the matter is not decided, but such a requirement remains an option, please indicate. ANSWER: See curriculum work team report. INTERROGATORY NO. 26: With respect to V.C.4. of the proposed plan, what is the reason for evaluating Algebra I placement procedures and what would be done with the evaluation results. ANSWER: See curriculum work team report. INTERROGATORY NO. 27: With respect to V.D. of the proposed plan, please identify any standards for use of the \"additional funding.\" If none currently exist, how would standards be developed and in what time period. Lastly, what is the position of the LRSD regarding the use of some funds to pay area college students to tutor in these schools, during and outside the regular school day, on a one-to-one basis. ANSWER: See incentive school work team report and incentive school individual school plans. LRSD has not taken a position on the use of some funds to pay area college students to tutor in the incentive schools. INTERROGATORY NO. 28 : With respect to V.F. of the proposed plan, please identify any standards for this effort and provide a (:lhonwlfcrdlcyUtwd'-\"jcoh.- 13 definition of the language \"parental and community relations linkage system.\" ANSWER: See community links work team report. INTERROGATORY NO. 29: With respect to V.I. of the proposed plan, please explain why the title and the first paragraph apply to teachers and the next two paragraphs apply to certified personnel. As to V.B., what person or persons would decide when the desegregative impact would be outweighed. ANSWER: All of Section VI applies to certified personnel. The superintendent or his designee would decide when the desegregative impact would be outweighed by the educational benefit from allowing a teacher to remain in his or her present assignment or to transfer to another assignment. INTERROGATORY NO. 3 0: With respect to Part VII. of the proposed plan, please identify all documents alluded to in this part, including but not limited to \"compliance standards and procedures\", and/or further explanatory of the meaning of this part. ANSWER: The compliance standards and procedures have not yet been developed. Section VII is based on the requirements for an effective corporate integrity program under the Federal Sentencing Guidelines 8Al.2. INTERROGATORY NO. 31: What if any impact would the court's approval of the proposed plan, or a modified version, have on the life of the agreement which LRSD maintains was made regarding fee payments to counsel for the Joshua Intervenors after the payment of (:lhomo\\lcrdlcyllnd'da,-jo,11.,_ 14 the amount described in the Settlement Agreement. If the LRSD view is that the agreement would continue in force, please set forth the terms of the agreement on which LRSD relies and explain how the agreement could continue in view of the terms of the agreement asserted by the LRSD. ANSWER: The fee agreement was part of the settlement agreement which is not being modified by the Revised Plan. REQUEST FOR PRODUCTION NO. 1: Please provide a copy of each document which you have identified in responding to interrogatories numbered 2 through 30. RESPONSE: LRSD will make the documents identified herein available for inspection upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 32: Do you consider these interrogatories and req~est for documents as continuing and agree to supplement your answers as required by the Court's order of October 23, 1997? ANSWER: LRSD will comply with the Federal Rules of Civil Procedure and the orders of the district court. r:\\homolfc..dlcy\\lr,d\\dao-_jool,.ra 15 VERIFICATION STATE OF ARKANSAS) ) ss. COUNTY OF PULASKI) I, Dr. Leslie V. Carnine, state under oath that I am the Superintendent of the Little Rock School District, that the foregoing answers have been prepared from information gathered from personnel and records of the District, that the information provided herein is true and correct to the best of my knowledge and belief, and that I am authorized to execute this document on behalf of the District. LITTLE ROCK SCHOOL DISTRICT BY:~ DR. LESIEV.CARNINE SUBSCRIBED AND SWORN TO before me, a notary public, on this day of December, 1997. r:lhomolfcndl,:yllnodldco-jooh.,.. Christopher J. Heller John C. Fendley, Jr. FRIDAY, ELDREDGE \u0026 CLARK 2000 First Commercial Building 400 West Capitol Avenue Little Rock, Arkansas 72201-3493 Attorneys for Plaintiff, Little Rock School District BY: 16 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 this 3rd day of December, 1997. 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 ~ittle 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 f:'llornolfcndlcyUl'ICl'da-jooll.,.. 17 Elementary Teachers - 1993 , 17 i . 4 t---15--- --25.o ---- -- -1L2% - 18.2% -18.0% 3 Total ---  246 r 434  ...  i .f i IC PLAINTIFF'S EXHIBIT A Elementary Teachers - 1994 --- -- 18 - --- -- --- . 17 191)% -L5.3% . '---- --  61 . 5 % - -27. 2% - ' 0 Elementary Teachers - 1995 -,_,-----+--.,.,----+---- --------- ------ -- . 0 . 0 Elementary Teachers - 1996 I I ;- -r-- -- 56.3% -- ....... 22. I%- 2 12 4 Elementary Teachers - 1997 3 - -  9 r6   60. o -1 24.2 - 12 : \\  -- 2r- - 46.2% - --1 OA% - Elementary Teachers - 1998 i ! 3 ........... - 51.3% - .. 15.5% -- Secondary Teachers -1993 ALTLRN 4 2 66.7% CENTRAL 21 49 30.0% CLOVERDALE 2 30 6.3% DUNBAR 8 23 25.8% FAIR 7 29 19.4% FOREST HEIGHTS 9 20 31.0% HALL 9 35 20.5% HENDERSON 9 26 25.7% MABELVALE 3 20 13.0% MANNM/S 13 22 37.1% MCCLELLAN 12 24 33.3% PARK.VIEW 9 28 24.3% PULASKI HEIGHTS 4 28 12.5% SOUTHWEST 15 15 50.0% 93 Total 125 351 26.3% Secondary Teachers - 1994 ALTLRN 4 2 66.7% CENTRAL 25 48 34.2% CLOVERDALE 5 30 14.3% DUNBAR 8 25 24.2% FAIR 8 28 22.2% FOREST HEIGHTS 9 19 32.1% HALL 10 34 22.7% HENDERSON 8 30 21.1% MABELVALE 6 21 22.2% MANNM/S 13 25 34.2% MCCLELLAN 12 27 30.8% PARKVIEW 11 28 28.2% PULASKI HEIGHTS 4 29 12.1% SOUTHWEST 15 15 50.0% 94 Total 138 361 27.6% 40.4% 3.7% -20.0% -.5% -6.8% 4.8% -5.8% -.5% -13.2% 10.9% 7.1% -1.9% -13.8% 23.7% er;- -~=~ ... ;J~mlg,\u0026;? ',~zj~g,~~ 39.0% 6.6% -13.4% -3.4% -5.4% 4.5% -4.9% -6.6% -5.4% 6.6% 3.1% .5% -15.5% 22.3% PLAINTIFF'S 1 EXHIBIT s :5 J Secondary Teachers - 1995 Scn\"o' ~~- '~-~ . - ,._, . ::;;:. , . ..  - .. ---: -  ...,  - ~~ 1:eme..\" r:i-,i ..~... ~ ~ n,_i.c,..a, .i ,,f~ :-.-:..:.P.. ~e,rc\" ent,a_.g e , ' . . -  , ~- , . . . ~.  .-~-- -.: -~:~1:-.-- : .r.:. :':\"'=:\" -.::-  .. :- ! .. -  . ~  . ;- -}~- ;..,,f.,.   _; ,  ~ capj ~ ;~~~~~c.AA,:;::,.:~ ~:...: Y.anance ;. ALTLRN 4 2 66.7% 36.0% CENTRAL 24 42 36.4% 5.7% CLOVERDALE 5 24 17.2% -13.4% DUNBAR 10 20 33.3% 2.6% FAIR 13 23 36.1% 5.4% FOREST HEIGHTS 12 19 38.7% 8.0% HALL 10 34 22.7% -8.0% HENDERSON 10 26 27.8% -2.9% MABELVALE 5 21 19.2% -11.5% MANNM/S 10 26 27.8% -2.9% MCCLELLAN 12 24 33.3% 2.6% PARK.VIEW 10 28 26.3% -4.4% PULASKI HEIGHTS 7 29 19.4% -11.2% SOUIBWEST 15 14 51.7% 21.0% 95 Total 147 332 30.7% Secondary Teachers - 1996 s~il~l~l~fillE1~ ~JH~tt~~,r.:i ~~~pt~~!~: ALT LRN ' 4 2 66.7% 33.1% CENTRAL 23 41 35.9% 2.4% CLOVERDALE 11 20 35.5% 2.0% DUNBAR 15 18 45.5% 11.9% FAIR 15 25 37.5% 4.0% FOREST HEIGHTS 12 20 37.5% 4.0% HALL 10 36 21.7% -11.8% HENDERSON 19 20 48.7% 15.2% MABELVALE 5 22 18.5% -15.0% MANNM/S 12 25 32.4% -1.1% MCCLELLAN 10 32 23.8% -9.7% PARK.VIEW 12 29 29.3% -4.3% PULASKI HEIGHTS 6 32 15.8% -17.7% SOUTHWEST 15 13 53.6% 20.0% 96 Total 169 335 33 .5% Secondary Teachers - 1997  ~=ifl ~\"I- m11me'rc'efiliifff ' ..- .. ~Rercenta e, . CENTRAL 24 44 35.3% .4% CLOVERDALE 12 19 38.7% 3.8% DUNBAR 14 21 40.0% 5.1% FAIR 14 20 41.2% 6.3% FOREST HEIGHTS 11 18 37.9% 3.1% HALL 11 33 25.0% -9.9% HEDERSON 17 19 47.2% 12.4% MABELVALE 5 20 20.0% -14.9% MANNM/S 12 25 32.4% -2.4% MCCLELLAN 13 30 30.2% -4.6% PARK.VIEW 14 28 33.3% -1.5% PULASKI HEIGHTS 4 35 10.3% -24.6% SOUTHWEST 19 10 65.5% 30.6% 97 Total 174 325 34.9% Secondary Teachers - 1998 . :.:f.i~:~~~~17:(f-;~.;BpiJ .~ --~~:n . caira ' ~- ' ~caw an\"'---.; ~ercefftre.~canl ~ :r.ercen~ge.:. ' Sclioolf:f:~,:t~\".. .~ _,; , aniei ~~-~ ~ :.,.-.:~} ~:~~,~J.;: ~- ; --:~~4t.lm.;i -~-~~~- i~~~.~ ;:i;. ~3:~e;;, ALTLRN ' 2 5 28.6% -7.4% CENTRAL 27 48 36:0% .0% CLOVERDALE 13 19 40.6% 4.6% DUNBAR 17 22 43 .6% 7.6% FAIR 11 23 32.4% -3 .6% FOREST HEIGHTS 14 17 45 .2% 9.2% HALL 11 33 25.0% -11.0% HENDERSON 16 19 45 .7% 9.7% MABELVALE 4 21 16.0% -20.0% MANN MIS 15 23 39.5% 3.5% MCCLELLAN 14 29 32.6% -3.4% PARK.VIEW 16 29 35.6% -.4% PULASKI HEIGHTS 6 31 16.2% -19.8% SOUTHWEST 19 10 65.5% 29.5% 98 Total 185 329 36.0% Central Office Administrators - 1993 Superintendent 0 Assistant Superintendent 4 2 Departmental Directors 5 12 93 Total 9 15 Central Office Administrators - 1994 Superintendent 0 Assistant Superintendent 3 2 Departmental Directors 5 13 94 Total 9 IS Central Office Administrators - 1995 Superintendent 0 Assistant Superintendent 3 3 Departmental Directors 6 14 95 Total 10 17 Central Office Administrators - 1996 Superintendent 0 Assistant Superintendent 2 3 Departm,ental Directors 5 13 96 Total 8 16 Central Office Administrators - 1997 Superintendent 0 Assistant Superintendent 2 2 Departmental Directors 4 12 97 Total 6 IS 0.0% 66.7% 29.4% 37.5% 100.0% 60.0% 27.8% 37.5% 100.0% 50.0% 30.0% 37.0% 100.0% 40.0% 27.8% 33.3% 0.0% 50.0% 25.0% 28.6% ~ PLAINTIFF'S EXHIBIT c,., Central Office Administrators - 1998 Superintendent 0 2 0.0% Assistant Superintendent 2 2 50.0% Departmental Directors 4 10 28.6% 98 Total 6 14 30.0% Principals and Assistant Prlnlclpals -1993 Principals and Assistant Prlnlclpals - 1994 s 8 18 16 52.9% S2 47 S2.So/o Principals and Assistant Priniclpals - 1995 Principals and Assistant Prinlclpals - 1996 r--- -- - ; - :~ . ~:.::-,..1- 11: -11 -~\\:::;:t~: ~~ l~-;''._~::'.i~~i~~;:f.:i!: l L-.ac ~ :-~--~t~(_I~ . - - ~r ~'l.,.t.~~l:~:..!! Elementarv Princioals 17 18 48.6% Elementary Assistant Principals II s 68.8% Secondary Principals 8 6 57.1 o/o Secondary Assistant Principals 20 13 60.6% 96 Total S6 42 53.1 o/o Principals and Assistant Prinicipals - 1997 Secondary Ass 20 16 55.6% 97 Total 57 44 56.4% Principals and Assistant Priniclpals - 1998 11 5 s 9 5 64.3% s 20 16 55 .6% - 98 Total S6 4S 55.4% ARTICLE XV TEACHING ASSIGNMENTS A. The procedure outlined below shall be followed in making teaching assignments: 1. Teaching assignments shall be based upon training, experience, competence, seniority, tenure, and such other factors as would indicate success in the position to be filled. 2. To assure that students are taught by teachers working within their areas of competence, teachers shall not be assigned, except temporarily and for good cause, outside the scope of their teaching certificates of their major or minor field of study. Teachers assigned outside their major or minor fields shall not be penalized on the salary schedule in any way. When requested, the Director of Personnel will make available to the Association a list of teachers assigned outside their major or minor fields.  3. All teaching assignments will be made by the principal or his/her superiors after the following steps are taken: a. Each year all teachers will submit in writing their personal preference for grade level, group and subject assignments, and such preference shall be a factor in making assignments. b. Department Coordinators will be consulted before assignments are made in their departments. 4. Secondary teachers shall not be required to teach more than two (2) subject matter areas with no more than two (2) preparations involved. Basic, regular, and enriched classes shall be considered separate preparations. Exceptions will only be made when it would otherwise be impossible to enroll all students who have registered for a required course. Teachers assigned more than two (2) preparations will be so notified as soon as possible and in no case later than three (3) weeks before the teach ing assignment is to commence. No teacher shall be assigned more than three (3) preparations under any circumstances. 5. Schedules of teachers who are assigned to more than one (I) school shall be arranged so that such teachers shall not be required to engage in an unreasonable amount of interschool travel. 6. The principal shall or should consult with the Building Coordinating Committee in regard to the tentative master schedule for the following year, and all teachers will be given an opportunity to discuss their tentative assignments with the principal if they so request. B. The following procedure shall be used for notifying teachers of their assignments: 1. Returning teachers shall be given written notice of their tentative grade levei, grouping, subject area assignments, building assignments, and room assignments by the end of the current school year. 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