Plaintiffs' Objection to Interrogatories

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CV8d-0360977S 

SUPERIOR COURT MILO SHEFF, ET AL 

VS. : JUDICIAL DISTRICT OF HARTFORD/ 
NEW BRITAIN AT HARTFORD 

WILLIAM A. O/NEILL, ET AL : SEPTEMBER 20, 1990 

PLAINTIFFS’ OBJECTION TO INTERROGATORIES 
  

Pursuant to §228 of the Connecticut Practice Book, the Plaintiffs 

herewith object to the following interrogatories dated July 13, 1990: 

8. Using the 1987-1988 data as a base, for Hartford and each of the identified suburban school districts Please specify the number and 
percentage of black, Hispanic and white students who must, of a 
necessity, attend school in a location outside of the existing school district in which they reside in order to address the condition of 
racial and ethnic isolation which now exists in accordance with the requirements of the Constitution. 

  

OBJECTION: Defendants’ interrogatory seeks information from 
plaintiffs in regard to the specific remedy that plaintiffs seek if they 
prevail in this lawsuit. To that extent, defendants do not seek 
information relating to the liability phase but the remedial phase of 
this lawsuit. Plaintiffs object on the grounds that such information is premature, and beyond the scope of the lawsuit at this present time. 

9. Using the 1987-88 data as a base, for Hartford and each of the 
identified suburban school districts please specify the number and 
percentage of poor, middle and/or upper class students who must, of 
necessity, attend school outside of the existing school district in 
which they reside in order to address the condition of socio-economic 
isolation which exists in Hartford and the identified suburban school 
districts in accordance with requirements of the Constitution. Also 
identify the specific criteria which must be used to identify the pool 
of poor Hartford students from which those students who would be 
reguired to attend schools outside of the existing district in which 
they reside must be chose so as to address the condition of 
sccio-economic isolation in accordance with the requirements of the 
Constitution. 

OBJECTION: See objection to Interrogatory 8.   
  

  

  
 



  

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9. Using the 1987-88 data as a base, identify the number and 
percentage of "at risk! children in the Hartford Public Schools who 
must, of necessity, attend school at a location outside the existing 
Hartford School District lines in order to address the concentration of 
"at risk" children in the Hartford Public Schools in accordance with the 
requirements of the Constitution. Also identify the specific criteria 
which must be used to identify the pool of Hartford students from which 
those who would be required to attend schools in the suburban school 
districts must be chosen so as to address the concentration of "at risk" 
children in the Hartford Public School.s 

OBJECTION: See objection to Interrogatory 8. 

20. For each of the above listed interrogatories please provide 
the name and address of each person who assisted in the preparation of 
the answer to that interrogatory and describe the nature of the 
assistance which that person provided. 

OBJECTION: To the extent it requires the disclosure concerning 
experts who will not testify at trial, it is not provided for under P.B. 
§220 (A) (1). 

PLAINTIFFS, MILO SHEFF, ET AL 

  Wh NLS 

| Hartford, CT   
MARTHA STONE 

CONNECTICUT CIVIL LIBERTIES UNION 

FOUNDATION 

32 Grand Street 

Hartford, CT 06106 

(203)247-9823 

Juris No. 61506 

PHILIP D. TEGELER 
CONNECTICUT CIVIL LIBERTIES UNION 

FOUNDATION 

32 Grand Street 

06106 
(203)247-9823 
Juris No. 102537 

LJ 

WESLEY W. HORTON 
MOLLER, HORTON & 

FINEBERG, P.C. 

90 Gillett Street 
Hartford, CT 06105 

(203) 522-8338 

Juris No. 38478 

WILFRED RODRIGUEZ 
HISPANIC ADVOCACY PROJECT 

Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 
(203)278-6850 

Juris No. 302827 

06102     
 



  

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MARIANNE LADO 
RONALD ELLIS 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 

New York, NY 10013 

(212)219-1900 
Pro Hac Vice 

HELEN HERSHKOFF 

ADAM S. COHEN 

JOHN A. POWELL 

AMERICAN CIVIL LIBERTIES UNION 

FOUNDATION 

132 West 43rd Street 

New York, NY 10036 
(212)944-9800 

Pro Hac Vice 

JOHN BRITTAIN 

UNIVERSITY OF CONNECTICUT 

SCHOOL OF LAW 

65 Elizabeth Street 
Hartford, CT 06105 

(203) 241-4664 

Juris No. 101153 

JENNY RIVERA 

PUERTO RICAN LEGAL DEFENSE 

AND EDUCATION FUND 

99 Hudson Street 

New York, NY 10013 

  
 



  

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CERTIFICATION 

I hereby certify that a copy of the foregoing was mailed to all 

counsel of record on September 20, 1990. 

  

Wes . Horton