Notice of Disclosure of Expert Witnesses; Plaintiffs' Fourth Identification of Expert Witnesses Pursuant to Practice Book 220 (D)

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

July 15, 1992 

Honorable Harry Hammer 
P.O. Box 325 
Rockville, CT 06066 

RE: Sheff v. O'Neill, CV89-0360977S 
  

Dear Judge Hammer, 

Enclosed is a copy of Plaintiffs’ Fourth Identification of 
Expert Witnesses, served on defendants today. 

Sincerely, 

Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

The Connecticut Civil Liberties Union Foundation 
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Cv89-0360977s 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

Ve JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

WILLIAM A. O'NEILL, et al. AT HARTFORD 

Defendants JULY. 15, 1992 

  

NOTICE OF DISCLOSURE OF EXPERT WITNESSES 
  

Plaintiffs hereby give notice that they have disclosed their 

fourth list of expert witnesses anticipated to testify at trial, 

pursuant to Practice Book §220(D), by service upon defendants’ 

counsel on this day, July 15, 1992, 

Respectfully Submitted, 

VA 77 ia 
Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 

Union Foundation 
32 Grand Street 
Hartford, C7 

  

  

06106 

    
Wesley W. Horton 
Moller, Horton, & Rice 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers 
Marianne Engelman Lado 
Ronald L. Ellis 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

John Brittain 
University of Connecticut 

School of Law 
65 Elizabeth Street 

Bartford, CT 06105 

  

   



  

Helen Hershkoff Jenny Rivera 
John A. Powell Ruben Franco 
Adam S. Cohen Puerto Rican Legal Defense 
American Civil Liberties and Education Fund 

Union Foundation 99 Hudson Street 
132 West 43rd Street New York, NY 10013 
New York, NY 10036 

CERTIFICATE OF SERVICE 
    

This is to certify that one copy of the foregoing has been 

mailed postage prepaid by certified mail to John R. Whelan, 

Assistant Attorney General, MacKenzie Hall, 110 Sherman Street, 

mm 
Hartford, CT 06105 this /b5' day of July, 1992. 

  

  

Philip D. Tegeler 

    
 



      

€v89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

Vv. JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

WILLIAM A. O'NEILL, et al. AT HARTFORD 

Defendants July 15, 1592 

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PLAINTIFFS’ FOURTH IDENTIFICATION OF EXPERT WITNESSES 
PURSUANT TO PRACTICE BOOK §220 (D) 
  

  

Pursuant to Practice Book §220(D), as modified by the Pretrial 

Order entered by the Court on April 10, 19%2, the plaintiffs herein 

disclose their fourth list of expert witnesses anticipated to 

testify at trial, in response to Defendants’ First Set of 

Interrogatories. Any additional expert witnesses shall be 

identified pursuant to the Pretrial Order. 

Interrogatory 18. Please specify the name and address of each 
and every person the plaintiffs expect to call as an expert witness 
at trial. For each such person please provide the following: 

  

a. The date on which that person is expected to complete the 
review, analysis, or consideration necessary to formulate the 
opinions which that person will be called upon to offer at trial; 

b. The subject matter upon which that person is expected to 
testify; and 

c. The substance of the facts and opinions to which that 
person is expected to testify and a summary of the grounds for each 
opinion. 

RESPONSE: Experts whom the plaintiffs expect to call at trial are   

listed below, pursuant to Practice Book Section 220(D): 

  

  
  

 



      

  

William M. Gordon, 148 Greenmount Boulevard, Dayton, OH 45419. 
Dr. Gordon is expected to testify regarding the options for school 
desegregation presented to the state but not acted upon, 1954 to 
the present, and the historical context of those decisions, 
including the state’s awareness of increasing levels of school 
segregation in the Hartford region. Dr. Gordon may also testify, 
at the appropriate time, regarding options available to address the 
system of segregated education in the Hartford region. Dr. Gordon 
will rely, in part, on the documents listed in response to 
defendants’ interrogatory 5, in Plaintiffs’ Amended Responses to 
Defendants’ First Set of Interrogatories (February 19, 1991). 

Dr. Gary Natriello, Professor of Sociology and Education, Teachers 
College, Columbia University, 525 West 120th St., Box 211, New 
York, NY 10027. Dr. Natriello is expected to testify regarding 
(1) demographic and social conditions in the Hartford community in 
relation to educational challenges faced by Hartford schools and 
students; (2) educational resources and programs currently 
available in the Hartford district to meet the educational needs of 
Hartford students; (3) comparison between resources and programs 
available in Hartford and in the surrounding districts; (4) 
examination of levels of educational achievement and attainment in 
Hartford and the surrounding districts; and (5) assessment of 
Hartford and the surrounding districts in relation to state 
educational standards and mandates, including the Connecticut 
Mastery Test. Specifically, Dr. Natriello is expected to testify 
that (1) the concentration of poor children and children who are 
otherwise educationally disadvantaged poses extreme challenges to 
performance of students and schools in the Hartford district; (2) 
the available resources and programs in the Hartford schools are 
not sufficient to meet the educational needs of Hartford students; 
(3) a significant disparity in educational programs and resources 
exists among Hartford and the surrounding districts, which is 
enhanced by the special demands placed on educational resources in 
the Hartford districts and by the level of student need that exists 
in the Hartford district; (4) there are significant disparities in 
achievement and attainment among students in Hartford and the 
surrounding communities; and (5) these disparities are inconsistent 
with state educational standards and mandates. Dr. Natriello is 
expected to base his testimony on his review of documents provided 
to plaintiffs in discovery; public documents obtained from 
Hartford, the Hartford public schools, and other local towns and 
school districts; and his own research on the education of 
disadvantaged students in urban settings. Dr. Natriello is 
expected to complete his review by August 15, 1992. 

  

Mary Carroll, director, Project Concern, 128 Westland, Hartford, 
  

CPT, Ms. Carroll will testify about the history of the Project 

  

  

  
  

  

 



    

Concern program, the levels of school district participation, state 
and local funding sources, and the level of student and parent 
participation. She will further testify about the space needs of 
the program, transportation issues, composition and selection 
issues, and criteria for exclusion of students from the program. 
In addition, she is expected to testify about the extent of 
staffing, parent involvement, and in-service training. In her 
testimony, Ms. Carroll may rely on the following documents: budget 
documents outlining levels of funding for the program, including 
grant applications; Mahan, Thomas, Project Concern 1966-68: A 
Report on the Effectiveness of Suburban School Placement for Inner- 
City Youth (1968), documents furnished by Defendants to Plaintiffs’ 
First Request for Production, nos. 12 and 13 and Plaintiffs’ Second 
Request for Production, no. 3. 

  

  

  

School Principals. Plaintiffs expect to call several Hartford 
school principals at trial to give both expert testimony and fact 
testimony based on their experience and observations in the 
schools. Expert testimony is anticipated to include opinions and 
observations regarding the impact of racial, ethnic and economic 
isolation of students in the Hartford public schools; the 
educational and social needs of elementary and secondary students 
attending Hartford public schools; the effects of student turnover; 
the effects of lack of educational resources on instruction; and 
the institutional and educational impacts of a student body that 
includes a high percentage of poor and educationally disadvantaged 
children. Principals identified as expert witnesses include Donald 
Carso, principal, McDonough School, 100 Wilson Street, Hartford, 
CT; Eddie Davis, principal, Weaver High School, 415 Granby, 
Hartford, CT; Richard Montanez; principal, Hooker School, 200 
Sherbrooke Avenue, Hartford, CT; and Edna Negron, principal, 
Betances School, 42 Charter Oak Avenue, Hartford, CT. 

  

  

  

  

In addition to the areas of testimony set out above, 

plaintiffs’ experts are also expected to interpret and comment on 

the testimony and research of other experts, including both 

plaintiffs’ and defendants’ experts. With respect to documents 

listed herein, plaintiffs have included some of the primary sources 

upon which these experts will base their opinions, but have not 

provided a comprehensive list of all documents reviewed or relied 

on. If any other additional areas of testimony are identified for   

  

  

  

 



      

the foregoing experts or other documents upon which they primarily 

rely are identified, plaintiffs will identify such testimony and 

documents in a timely fashion. 

Wesley W. Horton 
Moller, Horton, & Rice 
90 Gillett Street 
Hartford, C7 06105 

Julius L. Chambers 
Marianne Engelman Lado 
Ronald L. Ellis 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 

New York, NY 10013 

Helen Hershkoff 

John A. Powell 

Adam S. Cohen 
American Civil Liberties 

Union Foundation 

132 West 43rd Street 

New York, NY 10036 

BY: 

Respectfully Submitted, 

WL Ferre 
Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 
Union Foundation 

32 Grand Street 
Bartford, CT 06106 

  

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Bartford, CT 06112 

John Brittain 

University of Connecticut 
School of Law 

65 Elizabeth Street 
Hartford, CT 06105 

Ruben Franco 
Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
New York, NY 10013 

  

  
 



      

CERTIFICATE OF SERVICE 
  

This is to certify that one copy of the foregoing has been 

mailed postage prepaid by certified mail to John R. Whelan, 

Assistant Attorney General, MacKenzie Hall, 110 Sherman Street, 

V/ 
Hartford, CT 06105 this /b “day of July, 1992. 

VA   
Philip D. Tegeler