Correspondence from Whelan to Tegeler and Stone Re: Further Responses to Discovery Requests

    AN @& MacKenzie Hall 
RICHARD BLUMENTHAL 13 110 Sherman Street 

ATTORNEY GENERAL 1 Hartford, CT 06105 

FAX (203) 523-5536 

Office of The Attorney General 

State of Connecticut Tel: 566-7173 

November 9, 1992 

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

Hartford, CT 086106 

RE: SHEFF v. O'NEILL/FURTHER RESPONSES TO PLAINTIFFS’ 
DISCOVERY REQUESTS 
  

  

Dear Phil & Martha: 

Over the last couple of weeks, some of our witnesses have 
refined and added to the exhibits which we intend to present at 
trial. We expected to provide you with this material along with 
our other exhibits last week. Because the date for exchange of 
exhibits has been postponed, we feel obliged by the discovery 
rules to provide you with the refined and additional material at 
this time. 

The first twenty-five items on the following list 
represent the most current set of exhibits which we expect Dr. 
David Armor to present at trial. Since his work is continuing, 
we may provide you with additional exhibits before he testifies. 
The next fourteen items on the list were prepared by Robert 
Brewer. As you can see this material is largely responsive to 
material you recently provided us in response to our discovery 
requests. The second to the last item is an item we previously 
provided to you in response to one of your discovery requests. 
We call this item to your attention only because it is being 
added to the exhibits we expect Douglas Rindone to present. The 
final item on the list is a population analysis done by Dr. 
Thomas Steahr. 

Except with regard to the analysis of the SSPs being 
conducted by Dr. Gary Natriello, we are operating on the belief 
that you have fully answered our discovery requests and provided 
us with all of the exhibits and data summaries your witnesses 
expect to present at trial. Our discovery requests are at least 
as comprehensive as yours, thus you operate under the same 
obligation of continuing disclosure as we do. Any effort on your 
part to introduce exhibits which have not been provided to us in 
a timely fashion or exhibits which have been revised in any  



  

Philip Tegeler, Esq. 
Martha Stone, Esq. 
November 9, 1992 
Page 2 

substantive way will be opposed. We hope and expect that this 
problem will not come up. 

1. Chart 1: Achievement Study: Black Poverty Rates. 

2. Chart 2: Achievement Study: White Povery Rates. 

3. Chart 3: Achievement Study: Education, Income and 

Family Status: Total Population: Hartford and 21 
Suburbs. 

4, Chart 4: Achievement Study: Black Sixth Grade Reading: 
Hartford and 21 Suburbs. 

5 Chart 5: Achievement Study: White Sixth Grade Reading: 
Hartford and 21 Suburbs. 

6. Chart 6: Achievement Study: Black Sixth Grade Math: 
Hartford and 21 Suburbs. 

Fg Chart 7: Achievement Study: White Sixth Grade Math: 
Hartford and 21 Suburbs. 

8. Chart 8: Achievement Study: Education, Income, and 
Family Status: Blacks Only: Hartford and Five Suburbs. 

9. Chart 9: Achievement Study: Black Sixth Grade Reading: 
Hartford and Five Suburbs. 

10. Chart 10: Achievement Study: Black Sixth Grade Reading: 
Hartford and Five Suburbs. 

11. Chart 11: Achlevement Study: Black Sixth Grade Reading; 
Six Individual Districts in Hartford Area. 

12. Chart 12: Achievement Study: Black Fourth Grade 
Reading: Six Individual Districts in Hartford Area. 

13. Chart 13: Achievement Study: Hispanic Poverty and 
Bilingual Rates: Hartford and 21 Suburbs. 

14. Chart 14: Achievement Study: Hispanic Sixth Grade 
Reading: Hartford and 21 Suburbs. 

15. Chart 15: Achievement Study: Hispanic Sixth Grade Math: 
Hartford and 21 Suburbs. 

16. Chart 16: Achievement Study: Separating the Effects of 
Racial Isolation from SES Factors. 

 



  

Philip Tegeler, Esq. 
Martha Stone, Esq. 
November 9, 1992 
Page 3 

127. 

18. 

18. 

20. 

23. 

22. 

23. 

24. 

25. 

26. 

27. 

28. 

29. 

Chart 17: Achievement Study: Percent Entering Four Year 
College (Graphic): Individual Districts in Hartford 
Area (22). 

Chart 18: Achievement Study: Percent Entering Four Year 
College (Graphic): Individual Districts in Hartford 
Area (22). 

Table 1: Achievement Study: Percent Entering Four Year 
College (Numerical): Individual Districts in Hartford 
Area (22). 

Chart 1: Community Choice Study: Percent Choosing 
Neighborhoods of Varying Racial Composition. 

Chart 2: Community Choice Study: Percent of Hartford 
Whites Choosing 21 Suburbs Versus Staying in Hartford. 

Chart 3: Community Choice Study: Percent of Hartford 
Blacks Choosing 21 Suburbs Versus Staying in Hartford. 

Chart 4% Community Choice Study: Percent of Hartford = 
Hispanics Choosing 21 Suburbs Versus Staying in 
Hartford. 

Chart 5: Community Choice Study: Community Percent 
Minority, Actual Versus After Community of Choice 
(Graphic): Hartford Area. 

Table 1: Community Choice Study: Community Percent 
Minority Actual Versus After Community of Choice 
(Numerical): Hartford Area. 

Analysis of Public Transportation Expenditures in 
Hartford Area, 1988-89, 1989-90, 1990-91. 

Public Transportation Expenditures Per Pupil (Excludes 
Special Education) in Hartford Area, 1983-84 through 
1990-91. 

Special Education Transportation Expenditures Per Pupil 
in Hartford Area, 1983-84 through 1990-91. 

Total Transportation Expenditures as a Percentage of 
Net Current Expenditures in Hartford Area, 1983-84 
through 1990-31. 

 



  

Philip Tegeler, Esq. 
Martha Stone, Esq. 
November 9, 1992 
Page 4 

30. Percentage of Pupils Transported in Hartford Area, 
1989-90, 1930-91. 

31. Analysis of Special Education Expenditures in Hartford 
Area, 1988-389, 1989-90, 1990-91. 

32. Per Pupil and Percentage Analysis of Expenditures in 
Hartford Area, 1979-80 through 1990-91 and Twelve Year 
Cumulative Per Pupil Expenditures. 

33. Replication of Plaintiffs’ Selected District Three Year 
Expenditure Summary. 

34. Five Year Composite Analysis of Library Books 
Expenditure Per Pupil and Per School in Hartford Area, 
1986-87 through 1990-91. 

35. Analysis of Library Books Expenditures Per Pupil and 
Per School in Hartford Area, 1986-87 through 1990-91. 

36. Textbooks, Library Books, Instructional Supplies and 
Equipment, Statewide Combined Total Expenditures Per 
Pupil for 1986-87 through 1990-91 Sorted by Ascending 
Rank. 

37. Number of Public Schools in Hartford Area in 1980 and 
15892, 

38. Public Schools in Hartford Area Closed 1981 to 1991. 

39... Public School sin Hartford Area Closed 1971 to 1991. 

40. Construction of Additional Space in Hartford Area 1985 
to Present. 

41. Mentors, Assessors, and Cooperating Teachers in the 
Hartford Area: 1991-92. 

 



8 

  

Philip Tegeler, Esq. 
Martha Stone, Esq. 

November 9, 1992 
Page 5 

42. Major Population Patterns: Total and Black Population 
Size, Connecticut, 1900 toi 1990. 

Very truly yours, 

RICHARD BLUMENTHAL 

Mnppesy GENERAL 

BY “John R. Whelan 
Assistant Attorney General 

Vv’ 

   
JRW: ac 

cc: Martha M. Watts, Asst. Atty. General 
Alfred A. Lindseth, Esq. 

 



* Se 
MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06103 

FAX (203) 323-5536 

   
RICHARD BLUMENTHAL 

ATTORNEY GENERAL 

  

Office of The Attornev General 

State of Connecticut Tel: 566-7173 

November 9, 1992 

Philip Tegeler, Esq. 
Martha Stone, Esq. 

Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

RE: SHEFF v. O'NEILL/FURTHER RESPONSES TO PLAINTIFFS’ 
DISCOVERY REQUESTS 
  

  

Dear Phil & Martha: 

Over the last couple of weeks, some of our witnesses have 
refined and added to the exhibits which we intend to present at 
trial. We expected to provide you with this material along with 
our other exhibits last week. Because the date for exchange of 
exhibits has been postponed, we feel obliged by the discovery 
rules to provide you with the refined and additional material at 
this time. 

The first twenty-five items on the following list 
represent the most current set of exhibits which we expect Dr. 
David Armor to present at trial. Since his work is continuing, 
we may provide you with additional exhibits before he testifies. 
The next fourteen items on the list were prepared by Robert 
Brewer. As you can see this material is largely responsive to 
material you recently provided us in response to our discovery 
requests. The second to the last item is an item we previously 
provided to you in response to one of your discovery requests. 
We call this item to your attention only because it is being 
added to the exhibits we expect Douglas Rindone to present. The 
final item on the list is a population analysis done by. Dr. 
Thomas Steahr. 

Except with regard to the analysis of the SSPs being 
conducted by Dr. Gary Natriello, we are operating on the belief 
that you have fully answered our discovery requests and provided 
us with all of the exhibits and data summaries your witnesses 
expect to present at trial. Our discovery requests are at least 
as comprehensive as yours, thus you operate under the same 
obligation of continuing disclosure as we do. Any effort on your 
part to introduce exhibits which have not been provided to us in 
a timely fashion or exhibits which have been revised in any 

 



  

Philip Tegeler, Esq. 
Martha Stone, Esq. 

November 9, 1992 
Page 2 

substantive way will be opposed. We hope and expect that this 
problem will not come up. 

1. 

2. 

3. 

10, 

11. 

12. 

13. 

14. 

15. 

ls, 

Chart 1: Achievement Study: Black Poverty Rates. 

Chart 2: Achievement Study: White Povery Rates. 

Chart 3: Achievement Study: Education, Income and 
Family Status: Total Population: Hartford and 21 
Suburbs. 

Chart 4: Achievement Study: Black Sixth Grade Reading: 
Hartford and 21 Suburbs. 

Chart 5: Achievement Study: White Sixth Grade Reading: 
Hartford and 21 Suburbs. 

Chart 6: Achievement Study: Black Sixth Grade Math: 
Hartford and 21 Suburbs. 

Chart 7: Achievement Study: White Sixth Grade Math: . 
Hartford and 21 Suburbs. 

Chart 8: Achievement Study: Education, Income, and 
Family Status: Blacks Only: Hartford and Five Suburbs. 

Chart 9: Achievement Study: Black Sixth Grade Reading: 
Hartford and Five Suburbs. 

Chart 10: Achievement Study: Black Sixth Grade Reading: 
Hartford and Five Suburbs. 

Chart ll: Achievement Study: Black Sixth Grade Reading; 
Six Individual Districts in Hartford Area. 

Chart 12: Achievement Study: Black Fourth Grade 
Reading: Six Individual Districts in Hartford Area. 

Chart 13: Achievement Study: Hispanic Poverty and 
Bilingual Rates: Hartford and 21 Suburbs. 

Chart 14: Achievement Study: Hispanic Sixth Grade 
Reading: Hartford and 21 Suburbs. 

Chart 15: Achievement Study: Hispanic Sixth Grade Math: 
Hartford and 21 Suburbs. 

Chart 16: Achievement Study: Separating the Effects of 
Racial Isolation from SES Factors. “ 

 



  

Philip Tegeler, Esq. 
Martha Stone, Esq. 
November 9, 1992 
Page 3 

17. 

18. 

19, 

20, 

21, 

22. 

gi oi 

24. 

25. 

26, 

27. 

28, 

29. 

Chart 17: Achievement Study: Percent Entering Four Year 
College (Graphic): Individual Districts in Hartford 
Area (22). 

Chart 18: Achievement Study: Percent Entering Four Year 
College (Graphic): Individual Districts in Hartford 
Area (22). 

Table 1: Achievement Study: Percent Entering Four Year 
College (Numerical): Individual Districts in Hartford 
Area (22). 

Chart 1: Community Choice Study: Percent Choosing 
Neighborhoods of Varying Racial Composition. 

Chart 2: Community Choice Study: Percent of Hartford 
Whites Choosing 21 Suburbs Versus Staying in Hartford. 

Chart 3: Community Choice Study: Percent of Hartford 
Blacks Choosing 21 Suburbs Versus Staying in Hartford. 

Chart 4: Community Choice Study: Percent of Hartford 
Hispanics Choosing 21 Suburbs Versus Staying in 
Hartford. 

Chart 5: Community Choice Study: Community Percent 
Minority, Actual Versus After Community of Choice 
(Graphic): Hartford Area. 

Table 1: Community Choice Study: Community Percent 
Minority Actual Versus After Community of Choice 
(Numerical): Hartford Area. 

Analysis of Public Transportation Expenditures in 
Hartford Area, 1988-89, 1989-90, 1990-91. 

Public Transportation Expenditures Per Pupil (Excludes 
Special Education) in Hartford Area, 1983-84 through 
1950-91. 

Special Education Transportation Expenditures Per Pupil 
in Hartford Area, 1983-84 through 1990-91. 

Total Transportation Expenditures as a Percentage of 
Net Current Expenditures in Hartford Area, 1983-84 
through 1990-91. 

 



  

Philip Tegeler, Esq. 
Martha Stone, Esq. 
November 9, 1992 
Page 4 

30. Percentage of Pupils Transported in Hartford Area, 
1989-30, 1590-91. 

31. Analysis of Special Education Expenditures in Hartford 
Area, 1988-89, 1989-90, 1990-91. 

32. Per Pupil and Percentage Analysis of Expenditures in 
Hartford Area, 1979-80 through 1950-91 and Twelve Year 
Cumulative Per Pupil Expenditures. 

33. Replication of Plaintiffs' Selected District Three Year 
Expenditure Summary. 

34. Five Year Composite Analysis of Library Books 
Expenditure Per Pupil and Per School in Hartford Area, 
1986-87 through 1990-91. 

35. Analysis of Library Books Expenditures Per Pupil and 
Per School in Hartford Area, 1986-87 through 1990-91. 

36. Textbooks, Library Books, Instructional Supplies and 
~~ Equipment, Statewide Combined Total Expenditures Per 

Pupil for 1986-87 through 1990-91 Sorted by Ascending 
Rank. 

37. Number of Public Schools in Hartford Area in 1980 and 
1992. 

38. Public Schools in Hartford Area Closed 1981 to 1991. 

39. Public School sin Hartford Area Closed 1971 to 1991. 

40. Construction of Additional Space in Hartford Area 1985 
to Present. 

41. Mentors, Assessors, and Cooperating Teachers in the 
Hartford Area: 1991-92. 

 



Philip Tegeler, Esq. 
Martha Stone, Esq. 
November 9, 1992 
Page 5 

42. Major Population Patterns: Total and Black Population 
Size, Connecticut, 1900 toi 1990. 

Very truly yours, 

RICHARD BLUMENTHAL 

Bs vi Attorney General 

JRW:ac 

cc: Martha M. Watts, Asst. Atty. General 
Alfred A. Lindseth, Esq.