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EXHIBIT A
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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Student Doe 1 by and through his :

Parents/Guardians Does 1 and 2, :
et al. :
:
Plaintiffs, :
:
: CIVIL ACTION NO. 09-12095
v. :
:
:
Lower Merion School District, :
:
Defendant. :

SUPPLEMENTAL DECLARATION OF MICHAEL ANDRE

I, Michael Andre, hereby declare as follows:

1. My name is Michael Andre. I am over the age of twenty-one (21) years. I

am authorized by the Lower Merion School District (“District”) to make this Declaration.

2. Each statement contained in this Declaration is within my personal

knowledge or knowledge I obtained in the course of my employment with the District

and is true and correct.

3. I have no personal financial stake in the above-styled and numbered

lawsuit.

4. I submit this Declaration in support of the District’s Supplemental

Memorandum of Law in Further Support of Motion for Summary Judgment.

5. I am the Supervisor of Transportation for the District. I have held this

position with the District since August 1983.

6. In this role I oversee pupil transportation for the District, which transports

approximately 8,000 students to approximately 130 different schools (10 of which are

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Lower Merion School District public schools, and the balance of which are private,

parochial, and independent schools) each day.

7. As Supervisor of Transportation I am responsible for, among other things,

supervising drivers, bus aides, and mechanics; purchasing vehicles; constructing bus

routes; and completing required reports.

8. On January 12, 2009, the Board of School Directors adopted a

Redistricting Plan known as Plan 3R.

9. Under Plan 3R, all students attending Gladwyne, Belmont Hills, and Penn

Valley Elementary Schools are zoned to attend Welsh Valley Middle School and then

Harriton High School (with those students living in the official, historic Lower Merion

High School walk zone having the option to choose between Harriton High School or

walking to Lower Merion High School).

10. There were 44 ninth grade students redistricted to Harriton High School

for the 2009-2010 school year. This includes:

 23 students from the Narberth/Penn Valley area:

 19 white; 3 Asian, 1 Indian

 21 students from South Ardmore:

 12 African-American; 6 white; 3 Hispanic

11. For the 2009-2010 school year, there are 30 African-American ninth

graders attending Harriton High School.

12. Of these 30 students, only 12 are from the South Ardmore area; the

remaining 18 are African-American students who live outside the areas affected by Plan

3R, i.e., they live in areas districted to Harriton High School even prior to Plan 3R, or

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