THE COMPLAINT ALLEGES IN 40 COUNTS THAT, WITH RESPECT TO 9 SCHOOLS, LEA, EAST CHICAGO SCHOOL DIST., FILED DEFICIENT MAN AGEMENT PLANS, FAILED TO MAINTAIN COPY OF PLAN IN SCHOOL, AND FAILED TO GIVE NOTICE; THAT IT FAILED TO IDENTIFY ACBM IN 8 SCHOOLS; THAT IT FAILED TO INSPECT ONE SCHOOL; AND IT FAILED TO OBTAIN A WRITTEN ASSESSMENT IN ONE SCHOOL.