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What is this case about? Reed v. LAUSD and UTLA is a class action lawsuit in which the named plaintiffs sued the Los Angeles Unified School District and others because budget-based teacher layoffs at their schools deprived them of their constitutional right to equal educational opportunity. An impending second round of layoffs threatened to make matters worse. The trial court issued a preliminary injunction, finding that further layoffs at plaintiffs schools would appreciably impair the students fundamental right to an equal education opportunity. LAUSD and the students then negotiated a settlement agreement. The agreement expanded the preliminary injunction to other academically struggling schools in the District. Now, the settlement agreement not only continues the preliminary injunctions protections for the plaintiffs three schools, but also prevents layoffs at up to 42 equally vulnerable schools and ensures the layoffs diverted from those schools are not redirected to other endangered schools. The United Teachers of Los Angeles (UTLA) objected to the settlement. However, the judge approved it, finding that it would remedy constitutional violations. The UTLA has appealed that decision, and is asking the California Court of Appeal to reverse it. Why is the Union supporting seniority-based layoffs? The UTLA is arguing that the settlement agreement violates its Collective Bargaining Agreement, which provides for seniority-based layoffs. The UTLA is also raising certain procedural arguments in an effort to overturn the settlement agreement. Why are seniority-based layoffs not working? Students and LAUSD agree that seniority-based RIFs have been devastating for the most vulnerable schools in the District. Its hard to recruit teachers who are interested in teaching at those schoolsit takes an especially dedicated and energetic teaching force to make a difference. But because the newest teachers overwhelmingly tend to start out at the poorest and lowest-performing schools in the District, each time the District lays off teachers, those schools can lose most or all of their teachers. Because of the seniority-based RIFs, the schools must constantly rebuild their teaching staff, starting over again at square one with each new round of layoffs. That in turn disrupts those students educations because they must be taught by substitute teachers and misassigned teachers until the positions can be refilled. As the judge in this case has found, there is overwhelming, heartbreaking evidence that

because of the seniority-based RIFs, the students at the most vulnerable schools are not getting equal access to education. Why do many teachers disagree with the Unions position in this case? A growing group of teachers, parents, educational organizations, and policymakers support the Reed settlement. Since the settlement agreement has been implemented, many of the schools targeted by the settlement have shown a marked improvement. They are finally getting a chance to provide a stable education environment and give their students a chance at succeeding. As teachers know, improving education in California is a process. But above all else, they know that students must come first. That is why so many teachers disagree with the position that the UTLA is taking in this litigation, which puts contracts before students. What role is our firm playing in this litigation? Our firm will be filing an amici curiae (friends of the court) brief in the Court of Appeal on behalf of teachers, parents, educational organizations, and policymakers who want to support the settlement and make their voices heard on this important issue. What do I have to do to become an amicus curiae (friend of the court)? If you are interested in joining the group of amici curiae supporting the settlement, we would be excited to speak with you. We are representing the amici curiae in this case on a pro bono basis, which means you would not be responsible for any of our costs or attorneys fees. If you act as an amicus curiae, we would add your name to the list of amici curiae joining the brief, and submit a brief statement of your interest in the case along with the amici curiae brief. Any other involvement in the matter would be up to you. Because we must file the brief by February 29, 2012, we are trying to finalize our list of amici and their statements of interest by Friday, February 24 at the latest. If you are interested, please contact Jeremy Rosen, the lead attorney for the amici curiae: Jeremy Rosen, Horvitz & Levy, LLP (818) 995-5828 jrosen@horvitzlevy.com Thank you for your dedication to improving education for California students! We look forward to the opportunity to speak with you.