United States v. South Bend Community School Corporation, et al. - Joint Motion for Approval of Stipulation of the Parties Regarding Consent Decree Compliance
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION
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UNITED STATES OF AMERICA, )
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Plaintiff, )
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v. ) 3:80-cv-00035-TLS-CAN
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SOUTH BEND COMMUNITY )
SCHOOL CORPORATION, et al., )
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Defendants. )
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JOINT MOTION FOR APPROVAL OF
STIPULATION OF THE PARTIES REGARDING CONSENT DECREE COMPLIANCE
The United States and the South Bend Community School Corporation (“District”), through undersigned counsel, respectively move the Court for an order approving a stipulation between the parties. On June 7, 2018, this Court approved the parties’ prior Joint Stipulation, which required the parties to exchange information and identify agreed upon action steps regarding the District’s compliance with the original 1980 Consent Decree in this case. [DE 162]. Since that time, the parties have devised a set of action steps in the areas of student assignment to high schools, transportation, and student discipline, as reflected in the attached Stipulation of the Parties Regarding Consent Decree Compliance. The parties agree that these steps aim to bring the District into full compliance with its desegregation obligations.
Therefore, for the reasons discussed in the accompanying Memorandum in Support, the parties respectfully request the Court to approve the attached Stipulation of the Parties Regarding Consent Decree Compliance.
Respectfully submitted,
/s/ Alyson R. Schwartz |
/s/ John W. Borkowski |
Veronica Percia |
John W. Borkowski (#25985-49) |
Alyson R. Schwartz |
Husch Blackwell LLP |
Educational Opportunities Section PHB |
1251 North Eddy St., Suite 200 |
Civil Rights Division |
South Bend, Indiana 46617 |
U.S. Department of Justice |
Telephone: (574) 239-7010 |
950 Pennsylvania Ave., NW |
Facsimile: (574) 287-3116 |
Washington, DC 20530 |
Email: [email protected] |
Telephone: 202-514-4092 |
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Fax Number: 202-514-8337 |
Amy Steketee Fox (#25112-53) |
Email: [email protected] |
Church, Church, Hittle & Antrim |
Email: [email protected] |
Lincoln Tower, Suite 548 |
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116 East Berry Street |
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Fort Wayne, Indiana 46802 |
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Telephone: (260) 428-2207 |
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Facsimile: (260) 426-3360 |
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Email: [email protected] |
CERTIFICATE OF SERVICE
The undersigned certifies that on the 31st day of August, 2018, a copy of the above and foregoing document was filed with the Clerk of Court using the CM/ECF system which sent electronic notification of such filing to all those individuals currently electronically registered with the Court.
/s/ John W. Borkowski