Response of Superintendent To Minute Entry: United States District Court Western District of Louisiana

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Case 3:65-cv-11297-RGJ Document 180 Filed 10/25/16 Page 1 of 2 PageID #: 3431

UNITED STATES DISTRICT COURT


WESTERN DISTRICT OF LOUISIANA
MONROE DIVISION
JIMMY ANDREWS, ET AL
PLAINTIFF,

CIVIL ACTION NO. 3:65-cv-11297

UNITED STATES OF AMERICA,


PLAINTIFF-INTERVENOR,
VERSUS

JUDGE ROBERT G. JAMES

MONROE CITY SCHOOL BOARD, ET AL


DEFENDANTS

MAG. JUDGE KAREN L. HAYES

RESPONSE OF SUPERINTENDENT TO MINUTE ENTRY


NOW INTO COURT, through undersigned counsel, comes Dr. Brent Vidrine,
Superintendent of Monroe City Schools, who files the following documents in the record
under seal in response to the October 18, 2016, Minute Entry (ECF No. 179):
1.

A Threshold Report for the District as of October 14, 2016.

2. The Declaration of the Superintendent attesting to the accuracy of the


Threshold Report based on the following records of the District.
3. The Faculty Roster of each school in the District as of October 14, 2016.
4. A Declaration by a principal and vice principal (where applicable) of each
school in the District attesting to the accuracy of the Faculty Roster.
5. The Declaration of the Executive Director of Human Resources of the District
(a) attesting to the accuracy of the Faculty Roster; and (b) attaching the Birth
Certificates of two (2) teachers who self-identified their race on a September
2016 written survey form submitted by DOJ different from the race listed on
their Birth Certificates in the District personnel files.

Case 3:65-cv-11297-RGJ Document 180 Filed 10/25/16 Page 2 of 2 PageID #: 3432

Respectfully submitted,
BREITHAUPT, DUNN, DUBOS,
SHAFTO & WOLLESON, LLC
1811 Tower Drive, Suite D
P.O. Box 14106
Monroe, Louisiana 71207
Telephone: (318) 322-1202
Facsimile: (318) 322-1984
Email: swolleson@bddswlaw.com
rwoodard@bddswlaw.com

BY: /s/P. Scott Wolleson.


P. Scott Wolleson (#22691)

CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing Movers Motion to for
Leave to Intervene has been served on all counsel of record by this Honorable Courts
CM/ECF system.
Monroe, Louisiana, this 25th day of October, 2016.

/s/ P. Scott Wolleson


P. Scott Wolleson

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