…information sufficient to form a belief as to the truth of the allegation that “none of the eliminated grant programs were reinstated.” Such allegations are therefore deemed denied and strict…

…belief about the truth of the remaining allegations in this paragraph and therefore denies them. 46 174. After reasonable investigation, Respondent lacks knowledge or information sufficient to form a belief…

…reform efforts did not eliminate the problem but rather, lulled us into a false sense of security. We therefore need to heighten our efforts to address the lead in paint,…

…participate in or benefit from an aid, benefit or service or provide an aid, benefit or service that is not as effective or not equal to others. 34 C.F.R. §…

…relief with respect to the Education, Special Education, Suspected-To-Be- Eligible Special Education and Disability Subclass members. By failing to provide an appropriate, legally compliant education Defendants have acted or refused…

…contains a definition that is for convenience of reference only and, therefore, no response is necessary. 3. The Petitioner Entities 75. Admitted, upon information and belief. 76. – 77. The…

in the Petition. For instance, Petitioners’ Brief claims that “Petitioners are not asking the Court to interfere with the budgeting process…” [Petitioners’ Brief at 31]. However, such statement is a…

……. 119 PRAYER FOR RELIEF …………………………………………………………………………… 120 1 PETITION FOR REVIEW IN THE NATURE OF AN ACTION FOR DECLARATORY AND INJUNCTIVE RELIEF Petitioners, by and through their counsel, for their…

…at: http://www.education.pa.gov/Teachers%20- %20Administrators/School%20Finances/Education%20Budget/Pages/default.aspx (showing the BEF appropriations distributed per the formula in 2017-18 and the total BEF appropriation). See also Pa. Dep’t. of Educ., 2016-17 Summary Level State Revenue Annual…

…filed a joint supplemental brief (“Exec. Supp. Br.”), except for the Board of Education, which broke from the other Executive Respondents and filed its own brief (“Bd. of Educ. Supp….

what other programs should be defunded”). The Supreme Court, rejecting the Commonwealth’s argument, refused to abdicate all matters of budget appropriations to the legislature—particularly when appropriations and budget allotments affect…

…Lead Surveillance, Annual Report 2014 available at http://www.health.pa.gov/My%20Health/Infant%20and%20Childrens%20Health/Lead%20Poisoning%20 Prevention%20and%20Control/Documents/2014%20Lead%20Surveillance%20Annual%20Report%20r2.p df 3 Pediatric Lead Exposure Flint Water Results, Mona Hanna-Attisha, available at http://www.scribd.com/doc/282806501/Pediatric-Lead-Exposure-Flint-Water-Results http://www.dsf.health.state.pa.us/health/lib/health/familyhealth/lead_elimination_plan_for_2010.pdf http://www.nchh.org/Portals/0/Contents/PA%20-%20Impact%20Stmt.pdf http://www.health.pa.gov/My%20Health/Infant%20and%20Childrens%20Health/Lead%20Poisoning%20Prevention%20and%20Control/Documents/2014%20Lead%20Surveillance%20Annual%20Report%20r2.pdf http://www.health.pa.gov/My%20Health/Infant%20and%20Childrens%20Health/Lead%20Poisoning%20Prevention%20and%20Control/Documents/2014%20Lead%20Surveillance%20Annual%20Report%20r2.pdf http://www.health.pa.gov/My%20Health/Infant%20and%20Childrens%20Health/Lead%20Poisoning%20Prevention%20and%20Control/Documents/2014%20Lead%20Surveillance%20Annual%20Report%20r2.pdf http://www.scribd.com/doc/282806501/Pediatric-Lead-Exposure-Flint-Water-Results 2 There…

…note that this definition is included only in the definitions relating to the Annual State Report Card. We believe that it is important that a definition of a child in…

…main categories: 1. Benefits to school districts and the state; 2. Benefits to teachers and staff; “In 2008, the General Assembly and the Governor reformed state funding for basic education,…

(Ohio 1979) ………………………………………………………… 30, 35, 38 Bd. of Educ. of Cty. of Kanawha v. W. Virginia Bd. of Educ., 639 S.E.2d 893 (W. Va. 2006) (Starcher, J., dissenting) ………………………………32 Bd….

…2017 National School Climate Survey (2018), https://www.glsen.org/ sites/default/files/GLSEN-2017-National-School-Climate-Survey-NSCS- Full-Report.pdf ……………………………………………………………………………. 10, 13 GLSEN, School Climate in Pennsylvania (2019), https://www.glsen.org/sites/ default/files/Pennsylvania%20State%20Snapshot%20-%202017%20 NSCS_0.pdf ……………………………………………………………………………………. 5, 9 Angela Irvine & Aisha Canfield, Reflections…

provides substantial benefits to individuals and, as individual benefits are aggregated throughout a community, creates broad social and economic benefits. Investing in public education is thus far more cost-effective for…

…challenge to Pennsylvania’s now-defunct 2014 school funding arrangement with a challenge to Act 35, Petitioners, on July 6, 2018, filed a brief in opposition to the Application (“Petitioners’ Brief”), along…

…OF AUTHORITIES -vii- Urban Institute, The Negative Effects of Instability on Child Development (2013), https://www.urban.org/sites/default/files/publication/32721/412908 -The-Negative-Effects-of-Instability-on-Child-Development-Fact- Sheet.pdf; ……………………………………………………………………………………………….. 7 Ý¿­»æ ïéóîèèê ܱ½«³»²¬æ ððíïïîèêíêðï п¹»æ ç Ü¿¬» Ú·´»¼æ ðîñîèñîðïè 1 STATEMENT…

defendant must be an educational agency, (2) the plaintiff must face language barriers impeding her equal participation in the defendant’s instructional programs, (3) the defendant must have failed to take…