STATE OF LOUISIANA DIVISION OF ADMINISTRATIVE LAW P.O. Box 44033, Baton Rouge, LA 70804-4033 Main Phone (225) 342-1800 * Fax (225) 342-1812 www.adminlaw.state.la.us Located at 1020 Florida Street, Baton Rouge, LA 70802 JOHN BEL EDWARDS Governor EMALIE A. BOYCE Director March 15, 2018 Marta Jewson The Lens 4344 Earhart Boulevard, Suite B New Orleans, LA 70125 VIA E-MAIL to mjewson@thelensnola.org RE: Response to Public Records Request Dear Ms. Jewson, On March 5, 2018, we received the attached public records request for a copy of the complaint and final decision in DAL Docket No. 2016-2727-DOE-IDEA. We have provided the complaint only as this matter is ongoing and no final decision has been rendered. Attached, please find our response, which has been redacted for privacy reasons, and is being sent electronically to the e-mail address above in an attachment consisting of consisting of 16 pages. Should you have any questions, please contact the Division of Administrative Law at (225) 342-1800. Very truly yours, C Christine Dabney Clerk of Court Providing Impartial Hearings for Government and Citizens An Equal Opportunity Employer Division of Administrative Law (DAL) Public Records Request Form Use this form to request a copy of a public record in the custody and control of the Division of Administra ve Law. (If you want to request records from an administra ve case and you are a party to the case, do not use this form. Instead, contact the Clerk's Office to obtain a copy of the records.) There may be costs associated with this request depending on the delivery format you choose for the response. All costs must be paid in advance. You may submit the form online by filling it out completely and clicking on the “Submit” bu on at the end of the form. To print and send this form to DAL by postal mail or fax, click here to download the form. ................................................................................................................................................................................................................................................................................ First Name * Marta Last Name * Jewson Organization The Lens If Applicable Mailing Address * Street Address 4344 Earhart Blvd. Address Line 2 Suite B Email Address * City State / Province / Region New Orleans LA Postal / Zip Code Country 70125 Orleans mjewson@thelensnola.org Telephone Number * 612-802-3063 Fax Number Description of Information Requested DAL Docket Number 2017-9863-DOE-IDEA If applicable Please be as specific as possible to ensure your request is accurately answered. If you need additional space, you may add an additional page to this request by attaching a document below. * I'd like to view a copy of the complaint and the final decision in this case. Attach Document Delivery Format Options The response can be provided to you in one of four delivery formats: in person inspection, email, hard copies, and download to CD. Records requested to be viewed in person or emailed to you are available at no cost. There are costs for hard copies of the records or if you want the records downloaded to a CD. Select One * No cost delivery format options Costs delivery format options * E-mail Select your preferred delivery format option. Date of Request 3/5/2018 Signature * Type your name or use your mouse to sign. LOUISIANA DEPARTMENT OF EDUCAT ION FILED STATE OF LOUI S IANA To: From: Date: Re: Division of Administrative Law Parris A. Taylor December 1, 2017 Request for Due Process Hearing ~~ REQUESTOR obo STUDENT v. SCHOOL Log Number: 78-H-11 DEC 01 2017 DIVISION OF ADMINSTRATIVE LAW The Louisiana Department of Ed ucation ("Department") received a due process hearing request in the above-referenced matter on December 1, 2017, from Debra Weinberg, 0/B/0 - v. ool Board. Based on the December 1, 2017, receipt date, the deadline for Ms. Weinberg and the school district to convene a resolution meeting is December 16. 2017. Unless one of the three events described in Louisiana Bulletin 1706 §S10.C occurs, the resolution period will expire on December 31. 2017. 30 days after the hearing request was filed. Please document and record when the parties were informed that an administrative law j udge has been assigned because that date triggers the three day period for either party to chall enge the assignment. According to State Regulations, a final decision must be reached and a copy of the decision mailed to the parties within forty-five days after the resolution period expires. Once the hearing timeline begins to run, the administrative law judge may grant "specific extensions of time ... at the request of either party" but not their own initiative. Louisiana Bu lletin 1706 §515(B). " When an extension is granted, the hearing officer sha ll, on the day the decision is made to grant the extension, notify all parties and the Department in writing, stating the date, time, and location of the resched uled hearing." Bu ll etin 1706 §515.B.2. The Department and all parties should also be notified of what, if any, im pact the extension wi ll have on when the final decision and order will be issued. Please inform the Department of: 1. The initial dead line for the hearing as requ ired by Section 515 of Bulletin 1706; 2. The date(s) of any pre-hearing conference(s); 3 . When the resolution meeting was scheduled, held, or waived; 4. The hearing date(s); and 5 . Any extended dead line(s). During the course of the hearing, ONLY send the Department correspondence setting dates incl uding dead lines and hearing dates. Please submit the entire administrative record, including the origina l signed decision, once the rehearing and appea l delays have lapsed. Lou.t.st77.4 53 .272 1 I WWW.LOU ISIANABELIEVES .COM Please send all final decisions (including dismissals): 1. To the Department by email toDisputeResolution.DOE@la.gov AND madavis@la.gov (send the signed original by mail with the rest of the file); 2. To the Special Education Director - or the attorney who represents the school district electronically with delivery confirmation and by first class mail with a certificate of mailing; 3. To the parent - or the attorney who represents the parent - electronically with delivery confirmation and by first class mail with a certificate of mailing; 4. To the parent - or the attorney who represents the parent - electronically with delivery confirmation and by first class mail with a certificate of mailing; (two copies must be sent to the parent or the parent’s attorney); and, 5. to the superintendent of the school district by first class mail. Please send the (originals or copies) of the certificates of mailing and the electronic delivery verifications with the file. Please put the log number (Log Number: 78-H-11) on the certificates of mailing and e-verifications. The Department has continued its contract with Associated Reporters, Inc., to provide court reporting services for due process hearings. Contact Katrina Morgan at (504) 529-3355 or (800) 355-7245 for any in-person hearing date(s) to arrange for a court reporter for the due process hearing. Be sure to inform her that you are calling for the Department of Education in order to avoid billing problems. Please contact Margie Golmon at (225) 342-3572 with any questions you have regarding the court reporting services contract. If you have any additional questions or concerns, please feel free to contact me or call Marshall Ann Davis at (225) 342-6971. PAT/mad Attachment Request for due process hearing PRR, Page 2 of 16 LOUISIANA DEPARTMENT OF EDUCAT ION TO: Debra Weinberg, Managing Attorney, The Advocacy Center Superintendent of Schools, Executive Director, Exceptiona FROM : Parris A. or, Louisiana Department of Education ~ DATE: December 1, 2017 LOG NUMBER: 78-H-11 School Board s Services The Louisiana Department of Education ("Department") received the enclosed due process hearing request on December 11 2017. I have forwarded the hea ri ng req uest to the Division of Administrative Law (" DAL"). Someone from DAL will contact you soon about pa rticipating in a pre-hearing conference and confirming the due process hearing request timelines. The school distr ict must convene a resolution meeting within fifteen days after receiving notice of a due process hearing request (Louisiana Bulletin 1706 §510), and the requestor ~ attend, unless both parties agree in writing to waive the resol ution process or to pa rticipate in mediation. The Department recom mends that parties participate in resolution meetings and attempt to resolve th is matter during the 30 day resolution period. Please note that an attorney for the school district may not participate in the resolution meeting unless the parent is accompanied by an attorney. The school district must inform the Department when the resolution meeting date is held or, if a resolution meeting is not held, a send a copy of the written statement confirming that both parties agreed to waive the resolution meeting. Please provide this information to the Department - by e-mail to DisputeReso lution.DOE@Ia.gov and madavis@ la.gov - as soon as possible and no later than January 2, 2018. We are attaching a Resolution Verification Form for your convenience. If you wish to participate in mediation, please send a written request by email to one of the addresses in the previous paragraph, to the address below, or by fax to (225) 342-1197. The primary difference between a resolution meeting and mediation is the resolution meeting includes only the parties to the hearing, but mediation is conducted by a neutral, objective, and trained mediator contracted by the Department to help both sides to resolve the dispute. The Department encourages parties to consider mediation, and there is a mediation request form with additional information on our website www.louisianabelieves.com. The assigned ad ministrative law j udge wi ll hold a pre-hearing conference, probably by phone, to discuss issues, witnesses, exhibits, and other matters that wi ll make the hearing process easier. During the pre-hearing conference, t he administrative law judge will schedu le the actua l hearing date(s), address any pre-hea ri ng issues, and will set dead lines to exchange documents, exhibits, witness lists, etc. The pre-hearing conference is not your due process Lou.t.st77.453 .272 1 I WWW.LOU ISIANABELIEVES .COM hearing; you will have a formal due process hearing unless the parties are able to settle this matter before the scheduled hearing date. The administrative law judge will not form an opinion about this due process hearing request until both parties have had an opportunity to present arguments and evidence and to respond to the opposing party’s arguments and evidence. Again, someone from the DAL will contact both of you separately to set up dates and times for the pre-hearing conference, but neither party should attempt to talk about the specific facts and issues of this case with the administrative law judge unless the other party is also part of the conversation. Any and all correspondence about this case must include the Log Number (78-H-11) and should be sent directly to the administrative law judge, with a copy sent to the opposing party. If you wish to challenge the appointment of your administrative law judge because you have reason to doubt the particular administrative law judge’s impartiality, you must submit written information supporting your challenge to the Department within three business days of receiving notice that DAL has appointed an administrative law judge. Enclosures Hearing Request To the parent or parent’s attorney (via email only): Free and Low-Cost Legal and Other Relevant Services, Louisiana’s Educational Rights of Children with Disabilities, Louisiana Department of Education Dispute Resolution Comparison Chart, CADRE’s Special Education Resolution Meetings: A Guide for Parent of Children & Youth, Louisiana State Department of Education’s Special Populations Complaint Brochure, Due Process Brochure and Mediation Brochure, United States Department of Education’s Balancing Student Privacy and Safety: A Guide to the Family Educational Rights and Privacy Act for Elementary and Secondary Schools Brochure, and Parents’ Guide to the Family Educational Rights and Privacy Act: Rights Regarding Children’s Education Records PRR, Page 4 of 16 F I L ED STATE OF LOU I S IA N A • • ( l( )() DEC 01 2017 DIVISION OF ADt.AINSTRATIVE LAW ILDE LoQ No. 78-H-11 I ADVOCACY CENTER December I, 20 17 SENT VIA ELECTRONIC MAIL ONLY TO: DisputeResolution.OOE@la.gov Louisiana Department of Educatjon Attention Lega l Division Post Office Box 94064 Baton Rouge, Louisiana 70804-9064 Re: Due Process Complaint against School Board To Whom it May Concem: We are filing the attached Due Process ) by and through . aint on behalf of - (DOB: Debra J. Weinberg, Bar No.: 32760 Advocacy Center of Louisiana 8325 Oak Street New Orleans, LA 70118 -2043 504-522-2337, extension 128 504-522-5507 (Facsi mile) dwcinbcrg@ndvocacy ln.org Kenneth Kolb, Bar No.: 18290 Advocacy Center of Louisiana 8325 Oak Street New Orleans, LA 701 18 -2043 504- 522-2337. extension 121 504-522-5507 (Facsimile) kkolb@auvocacY.Ia.org _ _ _ _501-522-2:137 (Voice) • 1-1100-960-7705 (Voice) • 5111-n2-5507 (Fax) • W\\l'ov.advocacyla.org • New Orleans, Loui~;i;tna 70 II U PRR, Page 5 of.S:v16 Tlte P,·otectiou cuul Advocacy ...-ti'IH for L ouis iartn 8325 Oak Strt:cl STATE OF LOUISIANA DIVISION OF ADMINISTRATIVE LAW DEPARTMENT OF EDUCATION • • • • • • IN THE MATTER OF - B Y AND THOUGH HER,- ILDE LoQ No. 78-H-11 DOCKET NO• TRACKING N O . - - - - - ****************************************************************************** DUE PROCESS COMPLAINT I. INTRODUCTION 1. -s student with-who resides in an Individualized Education Program (IEP). Because School Board's actions and inactions- is receiving educational services at home, must be present for all of and 2. has no interaction with peers, educational services. ~ significant intellectual delays, communication deficits, social deficits, IIIII has substantial difficulties with transitions. New individuals and situations can trigger- negative behaviors. IIIII has a history of running away when is disabilities, IIIII is not able to reliably detennine if behavior may upset at school. Due to and aggressive behaviors. be dangerous to 3. . Upon returning to school in August 2017 after the summer break, without transition planning or notice of a new paraprofessional, IIIII immediately began having behavioral issues, was refusing work, ran from the school, and had to regularly be sent home early from already shortened day. PRR, Page 6 of 16 I 4. In August 2017, as a result o.SB's staff being unable to manage- behavior, the took unpaid leave, the 5. lost IIIII in the classroom. Because job. Starting in October 2017, even with the school. Since November 2017, 6. job to be with took unpaid leave from present, IIIII refused to go to the IIIII has received educational services at home. By failing to provide any related services, by providing an unsafe educational placement, and by providing insufficient staffing toiiiii. •B is violating right to a free appropriate education under the IDEA, 20 U.S.C. §§ 1400-1482; the federal regulations promulgated pursuant to the IDEA, 34 C.F.R. §§ 300.1-300.818.; Louisiana's Educational Opportunities for Students with Exceptional hies Act, La. R.S. §§ 17: 1941-1990; Louisiana's regulations implementing the IDEA found in Bulletins 1508 and 1706. 7. By failing to provide any related services, a safe educational environment, or consistent academic instruction,.SB violated~ght to a free appropriate education under §504 of the Rehabilitation Act of 1973,29 U.S.C. §794. 8. .SB violated the 2016 settlement agreement, which is enforceable under federal and state law, by not providing: 1. A properly trained and certified paraprofessional; 2. Case management team meetings; 3. Professional development performed by a BCBA; 4. Prior notice of staffing changes; and 5. Related services. II. PARTIES 9. ~as born in resides with at was attending a public school program at directly administered by .SB in-arish, Louisiana, from January 2017 until October 2017 and has attended direct run schools administered by .SB since at least 2015. Page 2 of 11 PRR, Page 7 of 16 10. - is the o f - a minor child. 11. .SB is a local educational agency responsible for providing • . with a free appropriate public education and the procedural protections required under the IDEA, 20 U.S.C. §§ 1400-1482, Louisiana's Educational Opportunities for Students with Exceptionalities Ac~ La. R.S. §§ 17:1941-1990, and Section 504 of the Rehabilitation Act of 1973. DI. STATEMENTOFFACTS A. Through both personnel and architectural failures, .SB denied- an appropriate education in the least restrictive environment. 12, . .. a w i t h - has an IEP through.SB to address significant inteJJectuaJ delays, communication deficits, social deficits, and aggressive behaviors. New individuals and situations can trigger- negative behaviors, such as running away when is upset at school. Due to disabilities, IIIII is not able to reliably determine if behavior may be dangerous to 13. From Fall2016 until October 2017,111111 attended a public school program at directly administered by .SB i n - Parish, Louisiana. 14. .SB constructed ~lassroom at to meet the requirements of the July 28,2016 Settlement Agreement that resolved the 2016 Due Process Complaint against.SB. At this address-has a primary room, individual bathroom, a "cool-down" room, and access to a shared gym. 15. During the winter and spring of2017llll was doing well at school, having extended the length of shortened school day up to three hours a day and fewer negative behaviors. Page 3 of 11 PRR, Page 8 of 16 was exhibiting 16. Upon returning to school in August 2017, without any transition planning or notice of a new paraprofessional, -mmediately began having behavioral issues, was refusing work, and had to be regularly sent home early. 17. Due to a significant decline in behavior from the previous year, there was an IEP meeting on August 23, 2017. At the August 23,2017, the parent addressed significant concerns regarding personnel, related services, the lack of air conditioning in the school building, and -ability to flee the school building. At that meeting.SB agreed to fmd a solution to prevent IIIII from fleeing the school building. 18. to ~ses a side entrance with a door next To enter and exit classroom. This door cannot be locked or barred from the inside. Twice during August 2017, - r a n out the door toward the street. On the second occasion, August 28, 2017 after the August 23, 2017 IEP meeting, ran across the street. As of the date of this complaint,.SB has failed to take the necessary steps to protect~ and develop a plan and a behavioral program that adequately addresses 19. propensity to run from the school and into the street. In August 2017, as the staff was unable to manage- behavior, the took unpaid leave from leave, the 20. lost - job to be with IIIII in the classroom. Because job. paraprofessional ignorin,_, trying to trigger observed behaviors, and being openly oppositional to disclosed and teacher. The paraprofessional also name, diagnoses, and behavioral details to other staff at both school, which do not have contact with information. When the took unpaid and have no need to know school and another disability related reported this conduct to the school district, it was directly provided to the paraprofessional, leading to further confrontations and negative behavior toward the student. Page4 of 11 PRR, Page 9 of 16 21. Starting in October 2017, even with the school building. Since November 2017, 22. The present, IIIII refused to go to the IIIII has received educational services at home. has repeatedly offered to be hired as the paraprofessional for . . . as meets the hiring criteria. Despite this, .SB refuses to hire , but nonetheless relies on constant availability during instruction. 23. Despite .SB and the parent agreeing to have related services provided virtually and the inclusion of related services on the IEP, . . has not received any related services, virtually or in person, during the 2017-2018 school year. 24. In November 2017, Metropolitan Human Services District, the Office for Citizens with Developmental Disabilities, and Quality called the to an urgent meeting. School or school board personnel contacted these Medicaid subcontractors and told them that the wanted to immediately institutionalize dedicates to keeping 1111· This is both untrue and defamatory. The IIIII in the community. Despite the requests, they would not disclose who provided this false infonnation. 25. As IIIII cannot safely remain in an educational program at a school or be educated without the presence, .SB has failed and continues to fail to provide IIIII with a free appropriate public education in the least restrictive environment. B. By failing to adbere to tbe settlement agreement, .SB denied- access to the necessary consistency, planning, and personnel needed f o r - to receive an appropriate education. 26. On March 15, 2016 the filed a Due Process Complaint against.SB (DAL Docket No. 2016-2727-DOE-IDEA, LDE Docket No. 56-H-09) alleging that.SB violated the IDEA by: I. Not providing any educational services for four and a half months; 2. Page Sofll PRR, Page 10 of 16 By allowing a teacher to punch IIIII in the ; 3. by not following the behavior intervention plan and crisis plan; and 4. by failing to appropriately report restraints and seclusions. 27. On July 28, 2016, after participating in the resolution meeting and continuing to draft the settlement document, .Band the settled the 2016 Due Process by executing a settlement agreement (2016 Settlement). 28. The 2016 Settlement included among it provisions thatllll would have "a one- on-one paraprofessional ... [who is] certified/licensed under Louisiana law as a behavior technician." (Settlement ,3). Additionally, it required that "a behavior analyst, licensed/certified under Louisiana law and with certification from a nationally recognized behavior analytic certification organization .. . provide professional supervision for the paraprofessional, including in-person supervision approximately 1 hour per work week." (Settlement ,4). 29. For the 2016-2017 school year and for the fall of2017- had two assigned paraprofessionals. Upon information and belief, the one of the paraprofessionals,-· who worked with IIIII from fall 2016 through November 2017 did not fully complete the necessary training and registration as a behavior technician as provided for under Louisiana law. Likewise Despite this, did not receive the dictated professional supervision since, at latest, winter 2017. has been purported to be a registered behavior technician as necessitated by the 2016 Settlement. Neither the second paraprofessional for the 2016-2017 school year, nor replacement for the 2017-2018 school year was trained as a registered behavior technician. 31 . The 2016 Settlement also provided for the creation of a "Case Management Team (CMT) ... consist[ing] of the Parent. .. and School Board experts who will collaborate at least monthly and who are charged with developing recommendations and plans for the IEP Team to consider." (Settlement 'd6). Page 6 ofll PRR, Page 11 of 16 32. Upon information and belief,.SB terminated the holding ofCMT meetings during fall 20 16 and despite persistent requests from the parent and attorney, none were held between fall 2016 and November 2017. The only meeting held in November 2017 did not meet . B ' s contractual obligation, as the district's expert was not present. 33. In the 2016 Senlement,.SB agreed to ..provide professional development to all o f - educational and related service providers, with the training conducted by a Board Certified Behavior Analyst (BCBA) regarding teaching strategies and behavior management techniques specific t o - areas ofneed and functional abilities .... " (Settlement ~8). 34. To the knowledge,.SB has not provided any BCBA formal or informal training t o - new personnel or to related service providers. The also is not aware of any formal professional development performed by the BCBA beyond some initial training for the paraprofessional during the beginning of the 2016-2017 school year. 35. Asllll has significant difficulties with new people, the 2016 settlement provided that the would be "informed of any and all changes to staffing (including teacher, paraprofessional, and/or related services providers) and/or educational location within one business day o.SB's knowledge of the change." (Settlement ~11). 36. During the summer of2017,.SB unilaterally changed the second ( paraprofessional to a new staff person. The ) was not notified, only becoming aware of the staffing change on the first day of the 2017-2018 school year. Also, despite the settlement requiring music therapy be provided at least 30 minutes per week during the 2016-2017 school year, IIIII has never received music therapy as a related service. 37. The settlement also mandates thatllll receive the related services in that during the 2016- 20 17 school year IEP and was to receive "related services in the areas of speech Page 7 of 11 PRR, Page 12 of 16 therapy (pragmatics), occupational therapy, adaptive physical education, and music therapy will be provided for a minimum of30 minutes each per week." (Settlement 120). 38. During the 2016-2017 school year, IIIII never received music therapy as a related service and access to speech therapy and occupational therapy was not provided according to the settlement IIIII has not received any related services during the 2017-2018 school year. 39. .SB failed to meet the standards it agreed to in the 2016 Settlement. IV. CAUSES OF ACTION A. Right to a free appropriate education in the least restrictive environment under the IDEA and Louisiana's law and regulations implementing the IDEA 40. Under the IDEA, all children with disabilities within the State must be provided with a free appropriate public education. 20 U.S.C. § 1412(a)(1); 34 C.F.R. § 300.101. 41. By failing to provide any related services, by providing an unsafe educational placement, and by providing insufficient staffing to IIIII SB violated right to a free appropriate education under the IDEA, 20 U.S.C. §§ 1400-1482; the federal regulations promulgated pursuant to the IDEA, 34 C.F.R. §§ 300.1-300.818.; Louisiana's Educational Opportunities for Students with Exceptionalities Act, La R.S. §§ 17:1941-1990; Louisiana's regulations implementing the IDEA found in Bulletins 1508 and 1706. B. Right to a free appropriate education in the least restrictive environment under §504 of the Rehabilitation act of 1973 42. Section 504 of the Rehabilitation Act of 1973,29 U.S.C. §794, prohibits programs or activities receiving federal financial assistance, such as .SB, from discriminating Page 8of11 PRR, Page 13 of 16 against, or utilizing criteria or methods of administration which subject, an otherwise qualified handicapped person to discrimination on the basis of handicap. 43. Under §504 and the regulations duly promulgated by the United States Department of Education, all students with disabilities within .SB must be provided with a free appropriate public education to meet their unique needs, and a panoply of procedural safeguards. 34 C.F.R. §§104.33-104.36. 44. By failing to provide any related services, a safe educational environment, or consistent academic instruction, .SB violated- right to a free appropriate education under §504 of the Rehabilitation Act of 1973,29 U.S.C. §794. C. Violation of Settlement Agreement Contract and Louisiana Law 45. .SB violated the 2016 settlement agreement, which is enforceable under federal and state law, by not providing: 1. A properly trained and certified paraprofessional; 2. Case management team meetings; 3. Professional development performed by a BCBA; 4. Prior notice of staffing changes; and 5. Related services. 46. Under LA R.S. 37:3705 "[n]o person shall hold himself out as a licensed behavior a registered line technician unless licensed, state certified, or registered ... " and under LA R.S. 37:3708, ..A line technician shall be registered by his supervising licensed behavior analyst with the board ... [and] shall be renewed annually by the supervising licensed behavior analyst." 47. By knowingly presenting the paraprofessional as a registered line technician when is not, .SB violated not only the settlement agreement but also Louisiana Law. V. REQUESTS FOR RELIEF Wherefore, by and through A. her,- requests that a hearing officer: Assume jurisdiction and set this matter down for a due process hearing; Page 9ofll PRR, Page 14 of 16 B. Issue an order requiring the.SB to immediately take the following steps: 1. Hire a new, Ph.D. level psychologist with at least 10 years experience working with teenagers with significant behavioral deficits due to autism to create a transition plan, make adaptations to the classroom to meet -needs; 2. Hire the after providing to serve as - one-on-one paraprofessional, the ABA training and registration necessary for certification as a line te~hnician; 3. Eliminate the use of a second paraprofessional working w i t h - 4. Provide a program for compensatory and related services of speech and music therapy virtually through online applications on the smart board at the school as well as through the iPad; 5. That the smart board in the classroom be connected to the Internet and properly calibrated, or if .SB is unable to do so that a new board be installed immediately that is properly calibrated and connected to the internet. 6. That a fully functional washer and dryer be returned to - classroom and connected for use in functional like skills training; 7. Provide IIIII with compensatory education for lost educational opportunities and services; 8. Provide all services agreed to in the 2016 settlement agreement; 9. Provide monetary compensation for lost wages incurred b y - (from August 28, 2017 through the start of and Page 10 of 11 PRR, Page 15 of 16 employment with .SB); 10. Provide ~ independent monitor, agreed upon by the Jarties. to ensure implementation of these orders and tbe 2016 Seulement who will report to this tribunal quarterly regarding the status of comp.liance. If this tribunal ftnds that . D. SB is unable or unwilling to provide IIIII with a free appropriate public education in a safe environment, that this tribunal order . SB to fund private or homeschool education and related services for IIIII in the manner of the E. choosing. Grant such other or further relief as may be deemed just and appropriate. Respectfully submitted this I s t day of December 2017. ON BEHALF OF By attorneys, 0~760 Advocacy Center of Louisiana 8325 Oak Street New Orleans. LA 70118 -2043 504-522-2337, extension 128 504-522-5507 (Facsimile) dv,,einberg@ advocac\·)a.org Ke1meth Kolb, Bar No.: 18290 Advocacy Center of louisiana 8325 Oak Street New Orleans, LA 701 18-2043 504-522-2337, extension 12 1 504-522-5507 (Facsimile) kkol b~ad vocacy la.org Page 11 of 11 PRR, Page 16 of 16 ,