CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS STATE OF LOUISIANA NO. 2017-11398 SECTION: J-S ORLEANS PARISH SCHOOL BOARD AND DR. HENDERSON LEWIS, R., IN HIS OFFICIAL CAPACITY AS ORLEANS PARISH SUPERINTENDANT OF SCHOOLS versus THE EINSTEIN GROUP, INC. FILED DEPUTY CLERK AFFIDAVIT STATE OF LOUISIANA PARISH OF ORLEANS BEFORE ME, the undersigned Notary Public, personally came and appeared Phong Tran who, upon being duly sworn, testi?es as follows: 1. My name is Phong Tran, and I am over the age of majority. 2. I am duly quali?ed, competent, and authorized to make this af?davit, the facts of which are within personal knowledge and are true and correct. 3. I am employed by The Einstein Group Inc. (?Einstein?) as its Deputy Chief Executive Officer and have served as Deputy CEO for 2 years. 4. In my capacity as the'Deputy Chief Executive Of?cer of Einstein, I am familiar with its ?nancial outlook, including revenues, expenses, assets and debts. 5. Einstein provides free transportation to any requesting student by providing fare for busas operated by the Regional Transit Authority With respect to Einstein students in grades 6 or below who live more than one mile from the school they attend, Einstein provides free transportation to any requesting student by providing fare for buses operated by the RTA, as well as for the student?s guardian to accompany the student to and from school on the RTA mode of transportation. XHIBIT 10. ll. 12. 13. 15. This year, Einstein has spent three thousand, four hundred and forty-eight dollars and twenty-seven cents on RTA fare for students enrolled at Einstein Charter School at Village de l?Est, ?ve thousand, ?ve hundred and one dollars and ninety?seven cents on RTA fare for students enrolled at Einstein Charter School at Sherwood Forrest, and nine thousand eight hundred and seventy-two dollars and ?fty- nine cents on RTA fare for students enrolled at Einstein Charter Middle School. The Middle School ?gure includes fare for students in grades 6-8 I have received a quote from Scholar?s First Transportation, a yellow bus company for transportation of Einstein students. Scholar?s First Transportation quotes the cost of a single bus running a pick-up loop in the morning and a drop-off loop in the evening at two?hundred and seventy??ve dollars per bus As of the signing of this af?davit, there are four hundred and five (405) students from grades K-6 enrolled in Einstein Charter School at Sherwood Forrest living more than a mile from the school. As of the signing of this af?davit, there are two-hundred and ?fty-four (254) students from grades K-6 enrolled in Einstein Charter School at Village de l?Est living more than a mile from the school. As of the signing of this af?davit, there are ninety (90) students from grades K-6 enrolled in Einstein Charter Middle School living more than a mile from the school. There are one-hundred and seventy?three days (173) in this school year. OPSB has never indicated to Einstein how many buses it believes that Einstein should employ to comply with law and policy. . To provide free transportation via yellow bus for all K-6 students residing more than one mile from their respective schools, Einstein estimates it would have to contract for hundreds ofthousands of dollars. The range of needed buses is anywhere from one bus to twenty-three buses. .Taking eleven as the median number of buses, this year, the total cost of providing yellow bus service for every student in K-6 residing more than a mile from his or her school would have been ?ve hundred and twenty-three thousand, three hundred and twenty ?ve dollars 17. By providing requesting students with RTA fare, rather than yellow bus service, Einstein will be able to spend roughly an additional $500,000 on'its educational programming this year. 18. Einstein is able to spend these funds on its highly successful English as a Second Language and Special Education Programs. 19. If Einstein were to contract for bus services for all of its students in K-6, it would have to make dramatic cuts including a loss of up to fourteen classroom teachers, one physical education teacher, two music teachers, one academic interventionist, and one blended learning, writing, and literacy interventionist. . Executed this day of December, 2017. Sworn to and Subscribed Before Me, Notary, this li?day of ecember, 2017. EMILIE LAUREN NOTARY ID NO. 37258 - STATE OF LOUISIANA PARISH OF My Commissmn is Ior LrIe