Document Request of Plaintiffs

October 19, 2001

Plaintiffs request of the KCMSD, the following:

    1. Job description for the Executive Assistant to the Superintendent and all documents showing when the job description was created, by whom, and when it was adopted by the KCMSD.
    2. KCMSD board policies concerning the creation of jobs or positions in the KCMSD administration, i.e., written board policies stating who may create new positions, titles, or jobs.
    3. Documents showing the creation by the school board of the position of Executive Assistant to the Superintendent.
    4. Resume and application of Linwood Tauheed for any position of employment with the KCMSD from 1997 to the present, including applications for the positions of Superintendent, Director of Information Technology, Executive Assistant to the Superintendent, and any other positions for which he has applied since January 1, 1997, and documents indicating when the KCMSD received or processed such applications, and any documents generated by the KCMSD in connection with each such application, including letters of reference or notes recording comments or endorsements.
    5. Personnel files or documents generated or maintained by the KCMSD with respect to each application for employment by Tauheed from January 1, 1997 to present, including notes or other documents with respect to any interviews of Tauheed for any position for which he applied.
    6. Budget documents with respect to the position of Executive Assistant to the Superintendent, including documents that indicate when the position was created, at what funding level, with what source of funds, and for what periods of time.
    7. Employment contract, memorandum of understanding or other documents offering Tauheed employment or contracting with Tauheed for employment by or services for the KCMSD.
    8. Copies of advertisements for the position of Executive Assistant to the Superintendent, including documentation of where and when such advertisements appeared and for what periods of time.
    9. Copies of the application and personnel documents of all applicants for the position of Executive Assistant to the Superintendent, including documents indicating when and by whom each such applicant was interviewed and notes from all such interviews.
    10. Board policies on the creation of board committees or the creation by board members of committees.
    11. Documents or records in the budget and personnel departments reflecting the hiring of Linwood Tauheed by the KCMSD in 2001, including all documents that authorize that hiring or provide for the establishment of salary payments, including documents that reflect what KCMSD administrative official signed the documents providing for that hiring of Tauheed.
    12. Documents concerning or reflecting the creation, membership, and work of any committee or sub-committee during the year 2001 for the purpose of or related to drawing lines or boundaries for school board sub-district elections or the re-districting of existing school board sub-districts, including documents reflecting: a) the membership of such committees; b) how the members of such committees were appointed or selected; c) the dates and places such committees met; d) all minutes, recordings, or other records of the proceedings of such committees; e) the budget for all such committees; f) the assignments, duties, or responsibilities of such committees; g) school board minutes concerning the creation, membership, existence, or work of such committees; h) all records of the secretary of the school board concerning such committees; i) the employment or retention of employees, consultants, or other service providers by or on behalf of such committees; and, j) all drafts, maps, charts, data compilations, correspondence, reports, memoranda, email or other documents reflecting the work, proceedings, meetings, minutes, product, or out-put of such committees.
    13. All minutes, tape-recordings, and other documentation of consideration by or comments of school board members at meetings of the school board or committees or subcommittees thereof during the year 2001 concerning a) re-districting or re-drawing the lines of school board sub-districts, b) creating the position of Executive Assistant to the Superintendent, or c) filling the position of Executive Assistant to the Superintendent.
    14. All documents, notes, or other records concerning notification by the school district or the school board to the Implementation Monitor of any meetings of any committee that met on or after June 20, 2001 concerning the re-districting or re-drawing of the lines of school board sub-districts.