‘Docusign Envelope iD: DC3A73F8-7678-4898.A880-7E7102175727 NO. DIV OSL ou 7 ROY CARY, THE PEOPLES PROMISE * YOUTH DIVISION, INC., ALL STREETS * ALL PEOPLE, INC. * 1ST JUDICIAL DISTRICT COURT 2 vs * CADDO PARISH LEISA G. WOOLFOLK IN HER * STATE OF LOUISIANA OFFICAL CAPACITY AS _ SUPERINTENDENT OF CADDO PARISH * SCHOOL BOARD AND CADDO PARISH * SCHOOL BOARD : HERE EEE CHE EOE ee nner moa a onan iat eee PETITION NOW INTO COURT, through undersigned counsel, comes collectively the Petitioners, Roy Cary, a person of full age and of majority, resident and domicile of Caddo Parish, State of Louisiana, The Peoples Promise Youth Division, Inc. (“PPYD"), a non-profit corporation, which is domiciled and has a principal place of business in Caddo Parish, State of Louisiana, and All Streets All People, Inc. (“ASAP”), a non-profit corporation, which is domiciled and has a principal place of business in Caddo Parish, State of Louisiana respectfully brings forth this action for the following reasons: 1. Made Defendants in this action are the following: a) Leisa G. Woolfork, a person of full age and of majority, resident and domicile in Caddo Parish, is the interim superintendent of Caddo Parish School Board; b) CADDO PARISH SCHOOL BOARD, (“CPSB”) the autonomous political subdivision of the State of Louisiana that administers and operates the public school system in Caddo Parish, Louisiana and are collectively and solely responsible for selecting the position of superintendent of Caddo Parish Schools. 2 ‘The Petitioners have the capacity to bring this action since Mr, Cary is a citizen of Caddo Parish and both PPYD and ASAP are both located in Caddo Parish and its members are domiciled in Caddo Parish. VENUE AND JURISDICTION a! Caddo Parish is the appropriate venue since the cause of action and parties to this, proceeding are in Caddo Parish, [$22 F 2D FILED | LS SEP 10 th & yale jaDDocusign Envelope IO: DC3ATSF8-7678-4886-A88O-7E7 102176727 4. The 1* Judicial District Court has jurisdiction over this matter due to the subject matter and that the CPSB is a named Defendant in these proceedings. FACTS 3. In May of 2024, the CPSB engaged with McPherson & Jacobson, LLC (“M&J”) to search for candidates for the position of superintendent for Caddo Parish Schools (RFP 08-24) 6. MAJ presented a 48 page document for the CPSB to consider prior to hiring M&J. This document describes in detail the step by step process M&J would go through for the CPSB to select a successful candidate. 7 According to the cover letter to the CPSB, M&J stated that they “understand that students have diverse needs, thus we focus on the intentional recruitment of a diverse candidate pool that includes ethnic and cultural identity as well as experience in culturally proficient practices that have proven successful in addressing educational equity gaps.” & ‘On Wednesday September 11, 2024, the CPSB will possibly go into an executive session to interview only one (1) of six (6) superintendent finalists. Petitioners allege that the CPSB does not have any plans to interview any other candidates, thus making the lone interviewee for all practical purposes the de facto choice for the new superintendent of Caddo Parish Schools. 9. ‘The Petitioners aver many crucial steps in the search and recruitment process by M&J did not happen in the quest to find a new superintendent of Caddo Parish Schools, The Petitioners will provide this Court with a list for this Court’s consideration. 10. First, on page four (4), under Section three (3) entitled: Scope of Services to be Provided, M&J promises in bullet point three (3), that “we take the entire board through a consensus of decision-making process to identify the top criteria for the selection of a new superintendent.” ‘The Petitioners aver that this did not happen. The matrix was implied but never implemented in‘Bocusign Envelope ID: OC3ATSFE-T679-4898-AGGO-7E7102175727 a formal document or job description provided to the CPSB. This can be verified via CPSB meeting videos given all meetings have been public and live streamed. I Additionally, Phase IV is where M&J is to assist the board members in selecting the final candidates to be interviewed, prepare the board for the interview process, schedule and coordinate interviews, and keep all candidates informed of their status in the selection process. This has not happened based on: M&J did not assist the CPSB is selecting the final candidates to be interviewed given the CPSB has not had any input as to the persons to be considered and the statement clearly indicates multiple candidates would be interviewed, 12. ‘M&J were also to meet with groups identified by the CPSB to provide stakeholder input into the selection. To date the community stakeholders committee the CPSB were supposed to nominate have not met with M&J or the CPSB regarding the selection process. 13. Its further alleged that the consultants did not provide information to the board on all applicants that completed the application process as indicated on page 29 of the RFP. This information was not provided to the CPSB even after a board member requested this information in an open board meeting on August 27, 2024. 14, Nominated stakeholders identified by the CPSB were to have an opportunity to meet the candidates. To date the following nominated stakeholders identified by the CPSB have not had the opportunity to meet the lone candidate. The CPSB did not nominate the stakeholders committee that would have worked with M&J to narrow the list of applicants and finalist, 1S. Moreover, on page 35 of the RFP, itis clear more than one candidate should be interviewed as it outlines for the CPSB how to rank the candidates. Presenting one (1) candidate for the interview process is inconsistent with the rules of the selection process outlined throughout the RFP. RELIEF SOUGHT 16. ‘The Petitioners are seeking relief under La CCP Art. 3603.DDocusgn Envelope (0: DCSATSFE-7679-4898-A99D-TE7 102178727 17, The relevant parts of La CCP Art. 3603 states: A. A temporary restraining order shall be granted without notice from the court when all the following occur: (1) It clearly appears from specific facts shown by a verified petition, by supporting affidavit, or by affirmation as provided in Article 3603.1(C)(3) that immediate and irreparable injury, loss, or damage will result to the applicant before the adverse party, or his attorney can be heard in opposition. 18, Here, if the new superintendent of Caddo Parish Schools is selected through a circumvented process there would be immediate and irreparable injury, loss, and damage to the Petitioners, 19, First, Mr. Cary and any of the members of the two non-profit corporations who pay taxes will suffer immediate irreparable injury, because it is their (and all the other citizens of Caddo Parish) tax dollars that were used to hire M&J and will be used to pay the new superintendent's salary. 20. Further, as M&J stated in their cover letter “students have diverse needs, thus we focus (on the intentional recruitment of a diverse candidate pool that includes ethnic and cultural identity as well as experience in culturally proficient practices that have proven successful in addressing educational equity gaps.” Bee The Petitioners wholeheartedly agree with the above statement, however by omitting vital steps to the outlined RFP which was voted on and approved by the CPSB in addition to presenting only one candidate for consideration strikes at the heart of that statement. eee The Peoples Promise, Youth Division, Inc. are comprised of students from Caddo Parish Schools, If the CPSB selects a new superintendent through a controverted process were only one (1) candidate is considered during the interview they will suffer immediate and irreparable injury because that candidate would be essentially anointed by the CPSB and not selected.eee Docusign Envelope ID: OCSA7SFS-7679-4898-A99D-767102175727 aa 2. Thus, the sole finalist “experience in culturally proficient practices that have proven successful in addressing educational equity gaps,” would not be compared to the other finalist for consideration. 24. MAJ indicates in their letter to the CPSB that the most important segment of the recruitment for a new superintendent is the “interview and selection of the successful candidate.” 25. The Petitioners argue that the most important segment of this process (i.e. CPSB and community involvement) cannot and should not according to the REP only include one (1) candidate. 26. ‘The Petitioners argue that the decision by the CPSB to skip vitally important steps in the voted on and approved process while only interviewing one finalist is arbitrary and capricious as they did not offer any reason for this decision. 27. The Petitioners are seeking a temporary restraining order against the CPSB from conducting the scheduled interview of the sole interviewee on Wednesday September 11, 2024 at 9:00am during an open session or executive session. 28, The Petitioners are also seeking a permanent injunction be issued upon the CPSB. preventing any and all interviews from being conducted or selecting of a new superintendent of ‘Caddo Parish Schools until they first follow the process detailed in M&J’s REP. 29. Counsel for the Petitioners certifies that he contacted the CPSB through the Attorney of the CPSB and provided him with a courtesy copy of the foregoing pleading. Wherefore the Petitioners, Roy Cary, The People’s Promise Youth Division, Inc., and All Streets All People, Inc. pray that: a) The Defendants be cited and served with a copy of this Petition and ordered to answer the same within the delays provided by law and after the lapse of all legal delays that there be a judgment, herein, in favor of the Plaintiffs and against the Defendants, ordering the relief sought herein with all costs of these proceedings cast against the Defendant, Caddo Parish School Board, including attomney’s fees;DDocusign Envelope ID: DCSATSFS-TE79-4898-ABSD-7E7 102175727 b) A temporary restraining order be immediately issued in accordance with La. Code of Civ. Pro. 3603 before this Honorable Court and show cause why the relief requested herein should not be continued in the form of a preliminary and ultimately permanent injunction; and c) For any and all other relief deemed necessary or equitable under the circumstances. RESPECTFULLY SUBMITTED: pecnsloney: Ronald S. Haley, Jr. (#30900) HALEY & ASSOCIATES ATTORNEYS AT LAW, LLC 8211 Goodwood Blvd Suite E Baton Rouge, LA 70806 225 663 8869 Office 888 900 9771 Facsimile thaley@ronaldhaleylawfirm.com‘Docusign Envelope 1D: DCSA7SF8-7679-4898-AUD-TE7102175727 STATE OF LOUISIANA CADDO PARISH VERIFICATION NOW before me, Ronald S. Haley, Jr., Notary Public duly commissioned herein appears: ROY CARY who hereby attests that the allegations in the Petition for Injunction are true and correct to the best of his knowledge. Signed on this the 10 day of September, 2024 in Caddo Parish, State of Louisiana. eeusamdy FOXY CARY ROY CARY = RONALD S. HALEY, JR. La Bar Roll 30900 Commission if for life‘Docusign Envelope ID: DCSA7SF8-7679-4898-A990-7E7102175727 ROY CARY, THE PEOPLES PROMISE * NO. DIV YOUTH DIVISION, INC., ALL STREETS * ALL PEOPLE, INC. * —_ ISTJUDICIAL DISTRICT COURT vs * CADDO PARISH LEISA G. WOOLFOLK IN HER * STATE OF LOUISIANA OFFICAL CAPACITY AS 7 SUPERINTENDENT OF CADDO PARISH * SCHOOL BOARD AND CADDO PARISH * SCHOOL BOARD . ARCO OREN IRR AO AA RDER Considering the Petition before this Court: IT IS HEREBY GRANTED, a temporary restraining order be immediately issued in accordance with La. Code of Civ. Pro. 3603 before this Honorable Court and show cause on the _ day of. » 2024 at why the relief requested herein should not be continued in the form of a preliminary and ultimately permanent injunction; IT IS DENIED JUDGE, 1S" JUDICIAL DISTRICT COURT Please Serve: ‘Caddo Parish School Board and Interim Superintendent Leisa G. Woolfork through the Attomey for the Caddo Parish School Board Reginald Abrams 330 Marshall St. Shreveport, LA 71101