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Respectfully submitted,
CERTIFICATE OF SERVICE
I hereby certify that, on this 24th day of June 2016, I served a copy of the
foregoing Motion For An Order To Show Cause via CM/ECF on all counsel of record
so registered.
/s/ Michaele N. Turnage Young
MICHAELE N. TURNAGE YOUNG
TABLE OF CONTENTS
I.
INTRODUCTION ............................................................................................... 1
II.
BACKGROUND .................................................................................................. 1
III.
IV.
ARGUMENT ....................................................................................................... 6
A. The Defendants Should Be Ordered To Show Cause Why They Should Not Be
Held In Contempt For Failure To Meet 90% of the Deadlines Set Forth In
The Consent Decree. ........................................................................................... 6
B. The Defendants Should Be Ordered To Show Cause Why They Should Not Be
Held In Contempt For Their Continued Failure To Take Required Steps To
Desegregate The Districts Faculty. ................................................................... 8
1.
2.
3.
C. The Defendants Should Be Ordered To Show Cause Why They Should Not Be
Held In Contempt For Their Continued Failure To Take Required Steps To
Improve The Medical Magnet Program. .......................................................... 15
1.
2.
3.
D. The Defendants Should Be Ordered To Show Cause Why They Should Not Be
Held In Contempt For Their Continued Failure To Take Required Steps To
Equalize Access To Specialized Academic Programs. ..................................... 19
1.
ii
CONCLUSION .................................................................................................. 21
iii
Table of Authorities
Cases
Am. Airlines, Inc. v. Allied Pilots Assn, 228 F.3d 574 (5th Cir. 2000)........................ 4
Frew v. Hawkins, 540 U.S. 431 (2004).......................................................................... 3
Intl Union, United Mine Workers of Am. v. Bagwell, 512 U.S. 821 (1994) ................ 5
Local 28 of Sheet Metal Workers Intl Assn v. E.E.O.C., 478 U.S. 421 (1986) .......... 5
Rambo v. Morehouse Parish Sch. Bd., 37 F. Supp. 2d 482 (W.D. La. 1999) ............... 4
Spallone v. United States, 493 U.S. 265 (1990) ............................................................ 3
Test Masters Educ. Servs., Inc. v. Singh, 428 F.3d 559 (5th Cir. 2005) ...................... 5
Travelhost, Inc. v. Blandford, 68 F.3d 958 (5th Cir. 1995) .......................................... 4
United States v. Alcoa, Inc., 533 F.3d 278 (5th Cir. 2008)........................................... 5
United States v. Latneys Funeral Home, Inc., 41 F. Supp. 3d 24 (D.D.C. 2014) ....... 5
United States v. United Mine Workers of Am., 330 U.S. 258 (1947) .......................... 5
Whitfield v. Pennington, 832 F.2d 909 (5th Cir. 1987) ................................................ 3
iv
I.
INTRODUCTION
Plaintiff-Intervenor United States respectfully submits this memorandum in
support of its motion for an order to show cause why the Monroe City School Board,
its individual members, and the Monroe City Schools superintendent (together, the
Defendants) should not be held in contempt for failure to comply with the
December 11, 2015 Consent Decree, as amended on January 12, 2016, March 24,
2016, and April 14, 2016.1
II.
BACKGROUND
On December 11, 2015, the Court entered a Consent Decree in this matter,
requiring the Defendants to take remedial actions that would desegregate the
Districts faculty and administrative staff, improve and make viable the medical
magnet program at Carroll High School, and equalize access to course offerings, all
of which would help the District achieve unitary status on all remaining Green
factors. ECF No. 113.
The Defendants have repeatedly violated this Courts orders over the past six
months by failing to comply with 90% of the deadlines for which they were
responsible and failing to cure their noncompliance with at least eight provisions
Although the Court, pursuant to the agreement of the parties, amended the Consent Decree
by extending certain deadlines on January 12, 2016, March 24, 2016, and April 14, 2016, and the
latest iteration of the Consent Decree is properly referred to as the Second Amended Consent Decree,
see ECF Nos. 113, 117, 133, and 141, this memorandum will refer to the Second Amended Consent
Decree as the Consent Decree since the substantive requirements other than the dates of some
deadlines have remained the same.
1
The United States has communicated with the District almost every single week since the
Consent Decree was entered. See, e.g., Exs. C, D, E, F, G, H, I, J, K, L, and M. The United States
informed the Board on February 1, February 8, February 18, March 4, March 9, April 22, and May
20 that the United States may seek further relief from the Court if the Board continued its failure to
meet the Consent Decrees deadlines. Exs. C, D, N, G, and L.
3
LEGAL STANDARD
It is well-established that a district court retains power to enforce consent
decrees entered in its cases. See, e.g., Frew v. Hawkins, 540 U.S. 431, 440 (2004)
(Federal courts are not reduced to approving consent decrees and hoping for
compliance. Once entered, a consent decree may be enforced.); Spallone v. United
States, 493 U.S. 265, 276 (1990); Whitfield v. Pennington, 832 F.2d 909, 913 (5th
Cir. 1987) (A consent order, while founded on the agreement of the parties, is
nevertheless a judicial act, enforceable by sanctions including a citation for
contempt.). Consistent with this principle, the Consent Decree at issue in this case
explicitly states that until the District achieves unitary status, the Court will
continue to have supervision of this case to ensure that the District undertakes in
good faith its obligations under [the decree] and federal law. Consent Decree
VIII, ECF No. 141 at 37.
Pilots Assn, 228 F.3d 574, 581 (5th Cir. 2000) (quoting Martin v. Trinity Indus.,
Inc., 959 F.2d 45, 47 (5th Cir. 1992)); see also Travelhost, Inc. v. Blandford, 68 F.3d
958, 961 (5th Cir. 1995) (A party commits contempt when he violates a definite and
specific order of the court requiring him to perform or refrain from performing a
particular act or acts with knowledge of the courts order. (internal quotation
omitted)). Clear and convincing evidence is that proof which is so clear, direct and
weighty and convincing as to enable the fact finder to come to a clear conviction,
without hesitancy, of the truth of the precise facts of the case. Travelhost, Inc., 68
F.3d at 961 (internal quotation omitted).
When establishing a partys actions as contemptuous, a movant need not
demonstrate that those actions (or inactions) are willful but only that they fall short
of compliance with the courts order. Am. Airlines, 228 F.3d at 581. In general, the
lack of malicious intent or the presence of good faith belief in the rectitude of ones
position cannot serve to sterilize conduct otherwise contemptuous. Rambo v.
Morehouse Parish Sch. Bd., 37 F. Supp. 2d 482, 486 (W.D. La. 1999) (internal
quotation omitted).
Once a district court makes a finding of contempt, it enjoys broad discretion
in assessing sanctions to protect the sanctity of its decrees and legal process. Test
Masters Educ. Servs., Inc. v. Singh, 428 F.3d 559, 582 (5th Cir. 2005). Indeed, the
remedies a court adopts need not match those requested by a party or originally
provided by the courts earlier judgment. United States v. Alcoa, Inc., 533 F.3d
278, 288 (5th Cir. 2008).
[S]anctions in civil contempt proceedings may be employed . . . to coerce the
defendant into compliance with the courts order. Local 28 of Sheet Metal Workers
Intl Assn v. E.E.O.C., 478 U.S. 421, 443 (1986) (quoting United States v. United
Mine Workers of Am., 330 U.S. 258, 303-04 (1947)) (other citations omitted). The
arsenal of sanctions available to a court for civil contempt includes compensatory
and coercive fines, as well as imprisonment. United States v. Latneys Funeral
Home, Inc., 41 F. Supp. 3d 24, 36 (D.D.C. 2014). Since civil contempt sanctions are
avoidable through obedience, they may be imposed in an ordinary civil
proceeding upon notice and an opportunity to be heard. Intl Union, United Mine
United Mine Workers of Am., 330 U.S. at 304 (citations omitted). [A] court which
has returned a conviction for contempt must, in fixing the amount of a fine to be
imposed . . . as a means of securing future compliance, consider the amount of
defendants financial resources and the consequent seriousness of the burden to
that particular defendant. Id.
IV.
ARGUMENT
A.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
In total, the Defendants timely met just two deadlines, and did so only because this
Court extended those deadlines.
///
///
///
///
7
B.
were listed, the revised review often omitted required information such as faculty
members years of experience or performance ratings. See id. Although the
Defendants provided a revision of the key of codes and abbreviations on May 13,
2016, that revision still violated Section VII by leaving more than 70 codes and
abbreviations undefined. Compare Ex. P at 4-8 with Ex. S.
On May 6 and 12, 2016, the ICM forwarded two charts sent to her by the
Superintendent and a District Human Resources employee one for teachers, Ex. U
at 5, and one for principals and assistant principals, Ex. T at 4. The chart for
teachers shows the number of teachers the District believes would need to move
from each school to desegregate the Districts faculty. See Ex. U at 5. The chart for
principals and assistant principals merely showed the number of principals and
assistant principals, by race, that serve each school. See Ex. T at 4. Neither the
ICM nor the Superintendent or District Human Resources employee advised
whether these charts were submitted to satisfy Section VI.A.2.i, but if so, they are
clearly deficient. See Exs. T & U.
In letters dated May 6 and May 20, 2016, which addressed the May 3 review,
the United States advised the Defendants of their failure to provide a faculty review
that comports with Section VI.A.2.i and requested that the Defendants cure the
noncompliance no later than June 1, 2016. See Exs. H & L. Counsel responded to
the United States May 6, 2016 letter in a May 8, 2016 email, writing: It is evident
that the errors and inconsistencies that you raise are easily substantiated by what
is revealed (or not revealed) regarding staffing credentials in the spreadsheet. Ex.
A. Counsel wrote that it was his expectation that the School District will be able to
address these matters and make the needed corrections immediately. Id.
In his May 23, 2016 response to the United States May 20, 2016 letter
repeating the earlier requests for compliance, Counsel said that the District would
correct the two charts provided, perform an analysis of administrators, verify the
raw teacher demographic data included in the charts, identify faculty by position
held, and analyze transfers necessary to equalize faculty credentials. Ex. O. To
date, the Defendants have not provided information indicating that they have taken
the action promised,4 much less a compliant Section VI.A.2.i review.
As the Defendants have acknowledged,5 their noncompliance with Section
VI.A.2.i leaves them, the United States, and others charged with implementing the
Consent Decree unable to identify, with precision, the number and type of faculty
who need to transfer, be reassigned, or be assigned to desegregate the Districts
faculty. Moreover, the Defendants failure to timely comply with Section VI.A.2.i
has hindered the United States and the Defendants ability to comply with seven
other deadlines that depended on timely compliance with Section VI.A.2.i.
On June 14, 2016, the ICM sent the United States several documents without indicating
whether the documents were being provided on behalf of the District or to satisfy Section VI.A.2.i.
See Ex. V. In any event, the documents do not cure the Defendants noncompliance with that
provision, as they do not reveal sufficient information about faculty credentials or show which
principals, assistant principals, deans of students, curriculum coordinators, accountability
specialists, or counselors would need to transfer to meet the requirements of the Consent Decree.
4
Indeed, as Counsel noted in his May 23, 2016 letter: It is agreed that detailed school-specific
information indicating which personnel are needed at which schools is essential in order to correctly
determine how many black teachers/principals/administrators, or white
teachers/principals/administrators are needed to transfer in or out of a school. Ex. O. Counsel also
noted, In addition, the same type information is needed to identify the number of
highly effective teachers, credentialed teachers and teachers with less than three years
experience that need to transfer out of individual schools to achieve the staffing balance
required for compliance with the Consent Decree. Id.
5
10
2.
11
In addition, the Board informed the United States on June 1, 2016 that nearly half of the
provisions of their draft incentive plan were implemented prior to the Boards submission of the draft
plan to the United States, see Ex. X, thereby depriving the United States of the opportunity to
comment and ensure those aspects of the plan were reasonably calculated to meet the Consent
Decrees requirements.
7
12
schools faculty shall not indicate that the school is intended for black students or
white students.
3.
13
14
18 n.7. The untitled, one-page document does not provide for such trades,
indicating that the Defendants have again failed to comply. See Ex. Y at 11.
C.
Section VI.D.1.i of the Consent Decree requires that the District implement
all recommendations outlined in the [Medical Magnet Experts] report no later than
April 15, 2016. ECF No. 141 at 31. Although the District received these
recommendations by March 1, 2016, see Ex. CC, a May 2, 2016 email from the ICM
indicated that, as of April 28, 2016, the Medical Magnet Experts recommendations
had not been implemented, see Ex. BB at 4. The Districts May 11, 2016 response to
an April 22, 2016 letter from the United States outlining deficiencies in the
Districts compliance further confirmed that the Medical Magnet Experts
recommendations had not been implemented. See Ex. W at 10. On May 20, 2016,
the United States reminded the Defendants of the noncompliance with Section
VI.D.1.i and requested that the noncompliance be cured by June 1, 2016. See Ex. L.
The Defendants have failed to provide information indicating that all of the
recommendations have been implemented.
To the extent the Defendants have provided a strategic plan that identifies a
goal of increasing student enrollment/opportunities in the medical magnet program
and outlines the actions the District intends to take to meet that goal, the strategic
plan does not account for all of the Medical Magnet Experts recommendations. See
15
Ex. DD at 9-10; see also Ex. EE at 18-19. The strategic plan is silent, for example,
on those recommendations pertaining to the hiring of staff and the need for facility
upgrades. See Ex. DD at 9-10; see also Ex. EE at 18-19. The strategic plan also
neglects to allocate funding for the implementation of the recommendations. See
Ex. DD at 9-10; see also Ex. EE at 18-19. This is in direct violation of the Consent
Decrees requirement that the District implement all of the Medical Magnet
Experts recommendations or provide written justification to the United States why
such recommendations should not be implemented. See ECF No. 141 at 31. Since
the Defendants have failed to implement all of the Medical Magnet Experts
recommendations or explain why they have not done so, they have failed to comply
with Section VI.D.1.i.
2.
Per Section VI.D.1.ii of the Consent Decree, by January 15, 2016, the Board
was to contact ULM and LDCC to negotiate transition assistance opportunities
(such as discounted tuition) for medical magnet students who later enroll as fulltime students at ULM or LDCC. ECF No. 141 at 31-32. However, the Defendants
have failed to describe efforts to negotiate transition assistance such as
discounted tuition for Carroll medical magnet students who may later enroll as
full-time students at ULM or LDCC. In response to the United States April 22,
2016 written request for documentation describing efforts the District has made to
16
See Ex. W at 6. This response does not indicate that the District has contacted
ULM to negotiate transition assistance, let alone identify the details of such
contact. See id. The response is therefore insufficient to demonstrate compliance
with Section VI.D.1.ii. Despite the United States May 20, 2016 letter reiterating
its April 22, 2016 request that the District comply with Section VI.D.1.ii, the
Defendants have failed to provide information indicating that they have taken
further action to cure their noncompliance with Section VI.D.1.ii. See Ex. L.
3.
Per Section VI.D.1.iv, by April 4, 2016, the District was to ensure that the
homepage of the website for each of its high schools prominently features
information regarding the medical magnet program, including at a minimum, a
description of the medical magnet program and specific guidance regarding the
timeline and process for applying for admission to the program. ECF No. 141 at
32. While the homepages of each of the Districts high schools now contain
information about the medical magnet program and links to a timeline and
Recruitment Form, there is no specific guidance regarding the process for applying
17
for admission to the medical magnet program. See generally Ex. FF. In particular,
there is no link to a program application. See generally id. Nor are there any
instructions describing how a student and his or her family can find and submit
such an application. See generally id.
In addition, the timeline does not provide specific dates indicating when
applications are due or when other important deadlines occur. See Ex. FF at 30.
For example, the timeline notes, May Screening and selection of candidates for
the program for the upcoming school year, notification to parents/students of
acceptance/rejection (opportunity for second chance), completion of parent/student
contracts for program. Id. This is particularly problematic given that the links
leading to the medical magnet programs course offerings and recruitment form did
not work until sometime in May after the United States asked in its April 22,
2016 letter for these problems to be fixed. Given this delay, the date applications
were due may have passed before the application deadline was properly announced
and before interested students and parents could access either the recruitment form
or information about course offerings.
Additionally, the description of the medical magnet program appears under
the latest news, recent news, or headlines and features RSS feed section of
each of the homepages. See Ex. FF at 4, 7, & 9. Although the Defendants have
acknowledged that the medical magnet program information is under recent news
and will remain thus allowing it to always be featured prominently on the web
pages, Ex. W at 7-8, the United States review of the Boards homepage has made
18
clear that information about the medical magnet program becomes increasingly less
prominent as the District posts more recent news. See Ex. HH at 8-10. On April
22, 2016 and May 20, 2016, the United States reminded the Defendants of the
failure to comply with the requirements of Section VI.D.1.iv and requested that the
noncompliance be cured no later than June 1, 2016. The Defendants have not
provided any information indicating that they have taken corrective action. A
recent review of the relevant homepages indicates that the failures have not been
cured.
D.
The United States wrote on April 22, 2016 and May 19, 2016 and spoke to the
Defendants on May 18, 2016 about the Districts anticipated noncompliance with
Section VI.C.1.v, which required the submission, by June 1, 2016, of a plan
implementing the IDRAs recommendations for equalizing access to specialized
academic programs unless the District first provides the United States with
written justification why any such recommendation should be excluded. ECF No.
141 at 30.
As Counsel noted in his May 23, 2016 letter: It is agreed that the May 12,
2016 District Strategic Improvement Plan [(which contained the Districts plan for
19
Section V.B.2 provides: The District will work with the Independent Court
Monitor in good faith to ensure that the Independent Court Monitor has the
appropriate information and personnel s/he needs to ensure the timely completion
of the reports discussed in Sections VI.C.2, VI.D.2, and VII. ECF No. 141 at 15.
However, the Defendants have not given the ICM the assistance she needs to
complete the required reporting. See, e.g., Ex. BB at 5 (In a May 2, 2016 email, the
ICM wrote to the District: All Documentation must be emailed to [me] as soon as
20
possible. These activities should have been completed within the first and second
quarterly report . . . .); see also Ex. GG at 4 (A May 4, 2016 email indicates the ICM
wrote the following to the District: Please email the missing components from the
first and second quarterly reports related to training and the list of courses. You
received a data request regarding the information needed. Again, I havent
received the information.). The United States asked the Defendants on March 9,
2016, April 22, 2016, and May 20, 2016 to ensure the ICM received the information
she needed to fulfill her duties. See, e.g., Exs. G & L. However, the Defendants
continue to fail to do so. For example, the Defendants still have not given the ICM
the information required by Sections VI.D.2.i (requiring documentation of the
Districts efforts to negotiate with ULM and LDCC to establish, inter alia,
transition assistance for medical magnet students) and VII.B.8 (requiring certain
information about the Districts faculty).
V.
CONCLUSION
The United States moves the Court to order the Defendants to show cause
why they should not be held in contempt for failing to: (1) meet 90% of the
deadlines for which they have been responsible to date, and (2) cure their
noncompliance with Sections VI.A.2.i, VI.A.2.ii(2)(b), VI.A.2.iii, VI.D.1.i, VI.D.1.ii,
VI.D.1.iv, VI.C.1.v, and V.B.2 of the Consent Decree. The United States
respectfully requests that if the Defendants have not brought the District into
compliance with the cited Sections within two weeks of a finding of contempt, that
the Court: (1) order the Defendants, as individuals, to pay a civil fine of $100 per
21
day for each day that the Defendants continue to fail to comply with the Consent
Decree, and (2) double the amount of that civil fine for each calendar week of
continued noncompliance.
The United States further requests the following relief, and any additional
relief that the Court deems appropriate: given the failure to prominently feature
required information about the medical magnet program on the Districts high
schools websites, the United States moves the Court to order the Defendants to
extend the deadline for medical magnet program applications for the 2016-17 school
year to at least a month after the District has cured its noncompliance with Section
VI.D.1.iv.
Respectfully submitted,
23
CERTIFICATE OF SERVICE
I hereby certify that, on this 24th day of June 2016, I served a copy of the
foregoing Memorandum In Support Of Plaintiff-Intervenor United States Motion
For An Order To Show Cause Why The Monroe City School Board, Its Individual
Members, And The Monroe City Schools Superintendent Should Not Be Held In
Contempt For Failure To Comply With The December 11, 2015 Consent Decree, As
Amended via CM/ECF on all counsel of record so registered.
/s/ Michaele N. Turnage Young
MICHAELE N. TURNAGE YOUNG
24
Exhibit FF
Screenshot of Wossman
High Schools homepage
taken on June 22, 2016
Credit: 1
The First Responder course is a foundation for the Emergency Medical Technician Education Program. Students
will receive in-depth training for most medical emergencies. The students will also become a registered First
Responder through the State of Louisiana and will obtain certification in CPR (BLS Health Care Provider CPR)
through the American Red Cross. Some of the topics to be covered include first aid, burn treatment, childbirth,
patient extrication, human anatomy, AED training, CPR, airway management, hemorrhage control, bandaging, simple
spinal immobilization, and simple splinting and infection control. Upon completion of the course, students can pursue
specialty career fields such as EMT, CNA, LPN, RN, or MD. This course is also a valuable program for community
service programs, such as a fire department volunteer.
In order to receive certification, the student must meet the following requirements: (1) must attend 90% of the total
course hours, (2) must pass the course with a 70% or better, (3) must pass the written and practical exams that are
administered as part of the course, and (4) must submit an accurate and complete certification application and fee to
the Bureau of EMS.
Prerequisites: Student must be at least 16 years old of age to enroll, must have an overall GPA of 2.0 or better, be in
good physical health and able to perform the duties of a First Responder, have certification in Professional Rescuer
Level CPR (Heartsaver CPR)), complete a criminal background affidavit in their own handwriting, no physical or
psychological dependence on substances other than those recognized as therapeutic treatments for valid medical
conditions for which they are currently under the care of a physician, a Letter of Good Standing from the high scool
principal/guidance counselor verifying the required GPA which must be submitted to the Bureau of EMS with the
initial roster and student applications
This course provides students with the ability to identify medical terms by analyzing their components. Emphasis is
placed on defining medical prefixes, root words, suffixes, and abbreviations. The primary focus is on skill
development, both oral and written, of the language utilized for communication in the health care professions.
Opportunities for application of clinical and leadership skills are provided by participation in career and technical
student organization activities.
Credit: 2
This two-hour blocked course is designed to prepare students to become Certified Nursing Assistants in the state of
Louisiana. The Nurse Assistant Certificate Program prepares students for employment in long-term care facilities,
home health agencies, and hospitals where basic bedside nursing care is needed. Classroom instruction (200 hours of
classroom/theory) includes an introduction to health care, essential OBRA skills required for certification, body
structure and function, and the job-seeking process, with an introduction to computer skills, as they relate to the health
care industry. Students participate in a minimum of 100 hours of clinical experience through internships at nursing
homes, acute hospitals, and/or other health care facilities under the supervision of the instructor (10 hours simulated
clinical experience, 90 hours on site clinical experience with a minimum of 40 hours in a nursing home).
Reinforced in this course are medical terminology, science, mathematics, written and oral communication, as well as
basic nursing assistant clinical skills. Instruction in CPR and First Aid is presented/reinforced in this course.
Students successfully completing the course with the required grade in clinical experience, a grade of 70% or better on
the written examination, and performance assessment will be eligible to become Certified Nursing Assistants in the
state of Louisiana.
Prerequisite: Minimum 17 years of age to participate; must have successfully completed Introduction to Health
Occupations and Medical Terminology prior to enrollment.
participate in skills that healthcare providers utilize to reduce injuries to sports medicine settings. Important skills that
healthcare providers are oriented to during their professional career are basic life support fo adults and pediatrics.
Students are given the opportunity to obtain American Heart Association Cardiopulmonary Resuscitation (CPR) in the
Schools certification.
Sports Medicine II (090721)
Grades: 11-12
Credit: .5
This course will provide students with an overview of the pathology of sports injuries and basic management skills.
Students will learn about the bodys response to an injury and how to apply emergency action principles and skills. An
emphasis is placed on an athletes psychological and sociological response to an injury and coping strategies utilized by
healthcare professions to assist them in recovery. Students will also learn the systematic process healthcare
professionals use when evaluating an injury and planning a rehabilitation plan.
Sports Medicine III (090722)
Grade: 12
Credit: 1
This course will provide an overview of common injuries and illnesses in sports and management strategies utilized by
healthcare professionals. Students will also work on a variety of projects that require them to synthesize information
learned from previous sports medicine courses. Students will learn how to analyze information relevant to the study of
sports medicine and investigate it through a systematic process.
Prerequisite: Sports Medicine I and Sports Medicine II with a C or better in each
Exhibit HH
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______________________________
The Honorable Robert G. James
United States District Judge for the
Western District of Louisiana