October 19, 2001

Ms. Kathy Walter-Mack, General Counsel

School District of Kansas City, Missouri

1211 McGee Street

Kansas City, MO 64106

Re: Jenkins v. School District of Kansas City, Missouri

Dear Kathy:

As you know, plaintiffs have an obligation to monitor and enforce the orders of the District Court in this case. As the Court has noted, a culture of micromanagement or patronage "would handicap the KCMSD in its efforts to close the achievement gap", Order of August 16, 2001, at 2, that is the District’s most important remaining goal in this case. Such a culture includes favors given or requested without following prescribed procedures, id. at 5-6; any action contrary to school district policies or procedures, id. at 6; or, to assure District compliance with statutory or board policy obligations, failing to give the required twenty-four notice to the Implementation Monitor of any meeting of the school board or any committee meeting. Order of June 16, 2001, at 6.

As you know, there have been allegations reported in the media that suggest potential violations of these obligations in the hiring of an executive assistant to the superintendent and attempts to adopt re-districting maps for school board sub-districts. Those potential violations include patronage, micro-management, failure to follow school board polices, and failure to notify the IM of committee meetings. To that end, as a part of plaintiffs’ monitoring and enforcement duties, plaintiffs request that the KCMSD provide them with the documents listed in the enclosure as soon as practicable. We request that these documents be provided no later than Monday, October 29, 2001.

After we have reviewed these documents, it is our present intention to take depositions during the week of November 5, 2001, and to depose Board President Ragsdale, Board Member Byrd, Superintendent Taylor, Executive Assistant Tauheed, and others. Please select dates and times for the depositions of the four named persons, in the order named, for the week of November 5, 2001, and advise me of those dates by October 29.

If you have any questions give me a call.

Yours very truly,

Arthur Benson

/AB

Encl.

cc: Dr. Charles McClain

Mr. Richard Marien

Ms. Patricia Brannan

Mr. Brian Wood