Defendants' First Request for Production

    Cv 89-0360977sS 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A, O'NEILL, et al 

Defendants MARCH 31, 1992 

DEFENDANTS' FIRST REQUEST FOR PRODUCTION 
  

Pursuant to P.B. § 227, the defendants hereby request that 

the plaintiffs produce the following documents or records for 

inspection and copying by defendants' counsel: 

l. Documents, data tapes, discs or other means of data 

storage which contain all data gathered and/or used as part of 

the studies conducted by plaintiffs' expert witness, Dr. Robert 

Crain, which are summarized in the reports entitled "School 

Pessgredat ion and Black Occupational Attainments: Results from 

Long Term Experiment" and "Finding Niches: Desegregated Students 

Sixteen Year Later." 

Specifically the defendants seek the underlying data files 

and variables used for the analyses in these two reports. The 

files should consist of all coded and edited variables for all 

individual students and/or parents analyzed in the two studies,   

  

 



      

along with a description of the format and coding of each 

individual variable. The files should include specifications for 

any derived or transformed variables used in the two reports; 

inclusion of appropriate SPSS or SAS programming instructions and 

codebooks would be sufficient. 

In order to expedite the defendants' review of the requested 

material the defendants ask that the data be produced on standard 

floppy discs (using ASC II format) suitable for use on a standard 

MS-DOS PC. 

Pursuant to P.B. § 228 the above requested material should 

be produced within thirty (30) days of the certification below 

unless such time 1s extended by agreement of the parties or order 

of the court. 

WHEREFORE, the defendants seek production in accordance with 

the rules of practice. 

FOR THE DEFENDANTS 

RI BLUMEN halo 

ATT 
RD 

G =~ 

By: J / A 
Join R. Whelan A 

/ A sistant Attorney General 
" ¥10 Sherman Street 

  

    
  

   
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Hartford, Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 

postage prepaid to the following counsel of record on 

March 31, 1992: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 
Hartford, CT 06106 

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 

Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
14th Floor 

New York, NY 10013 

  

 



      

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street