to aggressive outreach and recruitment. Only some of the plans are even minimally responsive to these concerns. The Paterson, Newark and Jersey City plans provide for some expenditures, but do not describe any definite plans, and the West New York plan provides for minimal expenditures and for the provision of literature to be distributed at several identified forums, but also does not describe aconcrete strategy. Ms. Ponessa observes that after the Court issued Abbott VI , the DOE did not offer the districts any guidance as to how to comply with its mandate regarding assessment and, where indicated, recruitment. While Abbott-district superintendents wrote a letter to the Department seeking clarification and assistance regarding outreach, no guidelines were issued even after that request. Paterson did list some additional outreach activities on its revised application, but neither Newark, Jersey City nor West New York offered any revision in this area. The DOE's responses approving these plans did not require that any of these districts make any further revisions. Ponessa's comments regarding the lack of any post-Abbott VI guidelines or standards for the development and implementation of plans for aggressive outreach are echoed in the certification offered by Thomas G. Dunn, Jr., superintendent of the Elizabeth School District. Dr. Barnett reports in his certification that a CEER door-to-door survey conducted in Newark in spring 2000 found that "most parents" were unaware of the availability of an early childhood program from the district.

As for Head Start, the petitioners claim that those Head Start programs that did not meet Abbott standards were not offered sufficient funding to allow them to achieve the necessary standards. The failure of the DOE to provide such funding violates the Court's mandate. Ms. Ponessa's analysis of the four districts' applications both pre- and post-Abbott VI indicates that in January 2000, Paterson identified 492 three- and four-year-olds in federally funded Head Start and had no plan or budget to serve these children in a way that would assure that they received an Abbott-compliant education in their Head Start programs. Newark had included funding to serve 345, but had no plan to serve them in accordance with Abbott standards. In addition, it identified 1430 additional three- and four-year-olds in federally funded Head Start programs, but requested no funding to serve these children in Abbott-compliant programs. Jersey City