Case 2:09-cv-02095-MMB Document 71-4 Filed 03/19/10 Page 1 of 3

EXHIBITB

 Case 2:09-cv-02095-MMB Document 71-4 Filed 03/19/10 Page 2 of 3

Morgan. Lewis & Bockius llP

1701 Market Street

Philadelphia, PA 19103·2921
Morgan Lewis
COUNSELORS AT LAW
Tel: 215.963.5000

Fax: 215.963.5001

www.morganlewis.com

Joy F. Grese
215.963.5085
jgrese@MorganLewis.com

March 17,2010

VIAE-MAIL

David G. C. Arnold, Esquire

Suite 106, 920 Matsonford Rd.
West Conshohocken, PA 19428

Re: Student Doe v. School District of Lower Merion, United States District Court for the
Eastern District of Pennsylvania, Civil Action No. 09-20905

Dear Mr. Arnold:

I am writing in response to your letter dated March 15,2010 concerning the District's Pretrial
Memorandum.

First, the titles of Ms. Anderson, Dr. Jarvis, and Dr. Lyles are listed in Defendant's Pretrial
Memorandum. The District intends to elicit testimony from these individuals concerning their
knowledge of the work and activities Dr. McGinley has conducted in connection with
achievement gap and diversity issues in schools. You will recall that you examined Dr.
McGinley regarding these areas during his deposition. See McGinley Dep. at 14-20. These
individuals were not previously identified in the discovery record because Plaintiffs' discovery
requests did not seek information that included them.

Second, as for your questions regarding Exhibits 25-30, each of these maps has been produced in
discovery:

• Exhibit D-25 is the map ofthe high school attendance zones prior to redistricting and was
produced at LMSDRH0237.

• Exhibit D-26 is the map of the attendance zone under proposed Plan 1 and was produced
at LMSDRH025I.

Philadelphia Washington New York Los Angeles San Francisco Miami Pittsburgh Princeton Chicago Minneapolis

Palo Alto Dallas Houston Harrisburg Irvine Boston London Paris Brussels Frankfurt Beijing Tokyo

 Case 2:09-cv-02095-MMB Document 71-4 Filed 03/19/10 Page 3 of 3

Morgan Lewis
COUNSELORS AT LAW
David G.G Arnold, Esquire

March 17,2010

Page 2

• Exhibits D-27 and D-28 are the maps of the attendance zones under proposed Plans 2 and
3, and are located within the PowerPoint presentations ofthese plans, at Students Doe
00297 and Students Doe 00218, respectively.

• In addition, D-26 through D-28 are located on the District's website, as Plaintiffs'
themselves noted in their Complaint. See Complaint, at footnotes 2-4.

• D-29 is the current map of Plan 3R, which was attached as Exhibit 1 to the Declaration of
Dr. Christopher McGinley, filed on January 22,2010. As noted in paragraph 8 of Dr.
McGinley's Declaration, and as Plaintiffs are well aware, this map also is located on the
District's website, at http://www.lmsd.orgldocumentsltransportationlhigh_l.pdf.

• D-30 is a demonstrative exhibit created from each of the above-referenced maps. We

will provide a copy of this demonstrative exhibit in accordance with the applicable
procedural rules.

Finally, as for your questions regarding Dr. Haber and Dr. Jamie Savedoff, neither is employed
by the District and, consequently, the District has no ability to require them to appear at trial.
We represented Dr. Haber solely for purposes of his deposition. We do not represent Dr.
Savedoff and previously provided you with his contact information.

Sincerely,

q;1.~.
tfo~ F. Grese
cc: Judith E. Harris, Esquire