Correspondence from Whelan to Tegeler with Notices of Deposition and Deposition Subpoenas

    FANIEIIANN - MacKenzie Hall 

RICHARD BLUMENTHAL i : 110 Sherman Street 

ATTORNEY GENERAL CA Hartford, CT 06105 

FAX (203) 523-5536 

Office of The Attorney General Tel: 566-7173 

State of Connecticut 
April 16, 1992 

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

Hartford, CT 06106 

RE: Sheff v. O'Neill 
  

Dear Phil: 

Enclosed please find notices of deposition and subpoenae 

duces tecum for the plaintiffs' expert witnesses. Although I am 

presently available on the dates indicated in the deposition 

notices I recognize that some, if not all, of the depositions 

will need to be rescheduled in order to accommodate practical 

considerations. My thinking is that the issuance of these 

notices will force both sides to immediately address the 

practical scheduling problems. 

I would ask that you send me a letter confirming deposition 

dates which are acceptable to you and offering alternate dates 

for those which are not. If you exercise the option to insist 

that the deposition of any expert be taken in their home state 

will, of course, have to make special arrangements. In these 

instances my plan is to arrive the night before the deposition 

and leave the day after so we will have ample time to complete 

the deposition. 

At the moment I can say for certain that I will not be able 

to conduct any depositions between May 18 and May 28, 1992 

because of a three day hearing I have scheduled during that time 

period. I plan to take a week's vacation in June or July but 

these plans are not yet final. This leaves me fairly flexible 

throughout the months of June and July -- at least at the moment. 

The sooner I hear from you regarding firm dates the more 

likely it is that we will avoid scheduling conflicts that might 

prolong the taking of the depositions.  



  

April 16, 1992 

Page 2 

We look forward to hearing from you. 

Very truly yours, 

RICHARD BLUMENTHAL 

ATTORNEY) GENE | 

V2 
BY: n R. Whelan 
Assigtant Attorney General 

JRW/mu 

cc: Counsel of Record 

 



      

CV 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 

J.D. HARTFORD/NEW 

Plaintiffs 
NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al 

Defendants apriL/¢, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Jamills 

Henry Braddock, III, Center for Social Inquiry, 3505 North 

Charles Street, Baltimore, MD 21218. Said deposition will begin 

at 9:30 a.m. on the 6th day of May, 1992 and continue on such 

additional days as may be necessary to complete the deposition. 

The deposition will be conducted before an appropriate officer in 

the conference room of the Office of the Attorney General, 110 

Sherman Street, Hartford, CT. The deposition will be conducted 

in accordance with the laws and rules of practice of the State ofl 

Connecticut. 

  
 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD VP 
Rs fn 

By: ya 
  

Joh R. Whelan 
Asgistant Attorney General 
1Y0 Sherman Street 
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 
April I{ , 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 

New York, NY 10036 ° 

hs, A 
WJ 

John R. WI 

   
  

whelan 

Assistant Attorney General 

7 

      
 



      

SUBPOENA DUCES TECUM 
  

TO: Jamills Henry Braddock, III . 

Center for Social Inquiry 

3505 North Charles Street 

Balitmore, MD 21218 

GREETING: -—- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 

deposition which will take place beginning at 9:30 a.m. on the 

6th day of May, 1992, or to such day thereafter and within 60 

days hereof to testify what you know in regard to a certain 

civil action pending before the Superior Court for the Judicial 

District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 

CV 89-0360977S. Said deposition shall be conducted at the Office 

of the Attorney General (Conference Room), 110 Sherman Street, 

Hartford, Connecticut. 
. 

  

pursuant to Practice Book § 245(c) you are further directed 

to produce and permit inspection and copying of the following 

material on or before the date of your deposition: All 

materials in your possession Or control relating to studies of 

Hartford and/or its suburban cities or towns which you have 

conducted or which you have relied on for the purpose of 

formulating or confirming the opinions which you are expected to 

offer at trial; and all materials in your possession or control 

relating to other studies which you have conducted the results 

of which you intend to rely on to support the opinions which you 

are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this 16 ¢ aay of April, 1992 

John R. Whelan 
Commissioner of the Superior Court 

if 
iy 

/ CERTIFICATION 

   
  

  

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

postage prepaid to all counsel of record on 

april {yd ,,199 
AN 

2 
Fal /) ot 

  

    

John R. Whelan 
Assistant Attorney General 

/ 

  

 



        

CV 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 

J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL//, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of 

Christopher Collier, 876 Orange Center Road, Orange, CT 06477. 

Said deposition will begin at 9:30 a.m. on the 8th day of May, 

1992 and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



  

    
  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

  

Jobs’ R. Whelan 
Asgistant Attorney General 

1270 Sherman Street 

artford, Connecticut 06105 

Telephone: 566-7173 

  

CERTIFICATION 
  

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

postage repaid to the following counsel of record on 

April i. 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 , 

a NY 10036 
; 50. 1 

/ Vy Nop, 
oi 

a7 R. Whelan 
AS istant Attorney General 

  

  

’ 
‘4 

4 

  

 



      

  

. SUBPOENA DUCES TECUM 
 ) 

TO: Christopher Collier 
876 Orange Center Road 
Orange, CT 06477 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
8th day of May, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the office 
of the Attorney General (Conference Room), 110 Sherman Street, 

Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this [C day of April, 1992 

Ui Jf Mt 
John R. Whelan 
Commissioner of the Superior Court 

  

/ CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage TE to all counsel of record on 

  

  

Lit Whelan 
Assistant Attorney General 
¥ 

  
 



      

Cv 89-0360977S 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

v. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL/C, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Robert 

L. Crain, Professor of Sociology and Education, Teachers College, 

Columbia University, 525 West 120th Street, New York, NY. Said 

deposition will begin at 9:30 a.m. on the 7th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  

 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

   
  

John E ila 
Assistant Attorney General 

4/110 Sherman Street 
/ 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 
April j/ , 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 
l4th 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 
New York,    

  

Joi “a WHelan 
Assistant Attorney General 

7 

  
 



      

~ SUBPOENA DUCES TECUM 
  

TO: Robert L. Crain 
Professor of Sociology and Education 
Teacher's College 
Columbia University 
525 West 120th Street 
New York, NY 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
7th day of May, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this felony of April, 1992 
/) 
WAT Ae 

John /R. Whelan 
Eptassiuns: of the Superior Court 

y 

CERTIFICATION 

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
Hatt cd 1992: 

Med 

  

  

   
     
  

John R. Whelan 
Assistant Attorney General 

/ 

  
 



      

Cv 89-0360977s 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A, O'NEILL, et al 

Defendants APRIL , 1992 

  

NOTICE OF DEPOSITION 

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Marvin 

Dawkins, 17627 N.W. 62nd Place, North Hialeah, Florida. Said 

deposition will begin at 9:30 a.m. on the 12th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICH BLUMENTHAL 

we LOA Jul 
  

Join R. Whelan > 
KSsistant Attorney General 
10 Sherman Street 

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 
April 1 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 
l4th 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 
New York, NY 1003 

      
  

\ JL 
John R. Whelan 
Assistant Attorney General 

/ 

/ 

  
 



      

. SUBPOENA DUCES TECUM 
  

TO: Marvin Dawkins 
17627 N.W. 62nd Place 
North Hialeah, Florida 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
12th day of May, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, Cah PENALTY OF THE LAW. 

Dated at Hartford, this 5 pe of April, 1992 

Lf Ho 
John R. ‘Whelan 
commissioner of the Superior Court 

7 

4 CERTIFICATION 

  

  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
April 9923 

{ J] 
   

   

  

lL? 

  

JoRn"R. niet 
Assistant Attorney General 
p 

  
 



      

Cv 89-0360977S 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A. O'NEILL, et al 

Defendants APRIL, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Mary 

Kennedy, Director, National Center for Research on Teacher 

Evaluation, 513 Ardson Road, East Lansing, Michigan . Said 

deposition will begin at 9:30 a.m. on the 13th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

  

RICHA my 

AT70 de A 

By: : Zz 

Tok . Whelan 

  

   
Asglistant Attorney General 

0 Sherman Street 
artford, 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 
April V/A rv. 19823 

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 

43rd Street 
New Yor + NY 1003 9 

wh J § 

   
  

John’ R. Whelan 
Assistant Attorney General 

Foy 
F 4 7 

i 

! 
i 

  
 



      

- SUBPOENA DUCES TECUM 
  

TO: Mary Kennedy, Director 
National Center for Research on Teacher Evaluation 

513 Ardson Road 
East Lansing, Michigan 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
13th day of May, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Vj 

Dated at Hartford, this {day of April, 1992 

[2 Z va y 4 
John R. Whelan 
ommissioner of the Superior Court 

/ 

  

  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
horily/ prepaid to all counsel of record on 

1992: 

yy. 
TST % Whelan 
Assistant Attorney General 

  

  

vf 

  
 



      

Cv 89-0360977S 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

v. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL //, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of William 

Trent, EPS, 368 Education Building, 1310 South Sixth Street, 

Champagne, Illinois. Said deposition will begin at 9:30 a.m. on 

the 14th day of May, 1992 and continue on such additional days as 

may be necessary to complete the deposition. The deposition will 

be conducted before an appropriate officer in the conference room 

of the Office of the Attorney General, 110 Sherman Street, 

Hartford, CT. The deposition will be conducted in accordance 

with the laws and rules of practice of the State of Connecticut. 

  

 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 
ATTORNEY GENE z 

we A AAA 
  

JoBn R. Whelan 
sistant Attorney General 

110 Sherman Street 
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 

April // , 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 

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 Srreat 

ig 

  

  

Jefirf R. Whelan 
‘Assistant Attorney General 

Education Fund 

  

 



    

SUBPOENA DUCES TECUM 
B 

  

William Trent, EPS 
368 Education Building 
1310 South Sixth Street 
Champagne, Illinois 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 

deposition which will take place beginning at 9:30 a.m. on the 

14th day of May, 1992, or to such day thereafter and within 60 

days hereof to testify what you know in regard to a certain 

civil action pending before the Superior Court for the Judicial 

District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 

CV 89-0360977S. Said deposition shall be conducted at the Office 

of the Attorney General (Conference Room), 110 Sherman Street, 

Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 

to produce and permit inspection and copying of the following 

material on or before the date of your deposition: All 

materials in your possession or control relating to studies of 

Hartford and/or its suburban cities or towns which you have 

conducted or which you have relied on for the purpose of 

formulating or confirming the opinions which you are expected to 

offer at trial; and all materials in your possession or control 

relating to other studies which you have conducted the results 

of which you intend to rely on to support the opinions which you 

are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this /A4faay of April, 1992 

NIA Sc 
  

Whelan 
“‘ommissioner of the Superior Court 

4 CERTIFICATI
ON 

  

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

postage prepaid to all counsel of record on 

April // | 1992; 

oF 
Joh" R. Whelan 
a Attorney General 

/ 

     



      

Cv 89-03609778 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL /, 1992 

  

NOTICE OF DEPOSITION 

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of 

Catherine E. Walsh, University of Massachusetts, 250 Stuart 

Street, Boston, MA. Said deposition will begin at 9:30 a.m. on 

the 2nd day of June, 1992 and continue on such additional days as 

may be necessary to complete the deposition. The deposition will 

be conducted before an appropriate officer in the conference room 

of the Office of the Attorney General, 110 Sherman Street, 

Hartford, CT. The deposition will be conducted in accordance 

with the laws and rules of practice of the State of Connecticut. 

  
 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICAD UMENTHAL 
ATTORNE Jeo Th 

By: AN 
    
  

ohn R. Whelan 
ssistant Attorney General 
10 Sherman Street 

Hartford, Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
  

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

postag repaid to the following counsel of record on 

April yi 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, Pp.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 

New York, py) 

JohA R. Whelan 
Assistant Attorney General 

    
  

Ae 

$f 
v 

      
 



      

SUBPOENA DUCES TECUM 
  

TO: Catherine E. Walsh 
University of Massachusetts 
250 Stuart Street 
Boston, MA 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
2nd day of June, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

  

Dated at Hartford, sie fe: of April, 1 

pe 744 
A"R. Whelan 
nissioner of the Superior Court 

       

  

  

/ 
7 CERTIFICATION 

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
Apri +. 19923 

LUI 
Joh” R. Whelan 
Assistant Attorney General 

   

  

/ 
4 / 

f 

Ps 

  
 



      

Cv 89-0360977S 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

v. 

WILLIAM A. O'NEILL, et al 

Defendants APRILZ , 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Hernan 

LaFontaine, 181 North Beacon Street, Hartford, CT. Said 

deposition will bedin at 9:30 a.m. on the 29th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  

 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

BLUMENTHAL 

  

  

Jghh R. Whelan 
AsSistant Attorney General 
10 Sherman Street 
artford, 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 

April 7 19923 

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 

  

John R. Whelan 
‘Assistant Attorney General 

  
 



      

SUBPOENA DULL BR TECUM 
  

TO: Hernan LaFontaine 
181 North Beacon Street 

Hartford, CT 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
29th day of May, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, Ty PENALTY OF THE LAW.    

  

Dated at Hartford, this J, > of April, 1992 

UL for 
Joh /R. Whelén 
Commissioner of the Superior Court 

  

CERTIFICATION 
  

/ 

This is to certify that a copy of the foregoing was mailed 
Vii ig) prepaid to all counsel of record on 
gi. 1992; 

5   
2) Ahélan 
Assistant Attorney General 
¥ 

  
 



    

Cv 89-0360977s 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A, O'NEILL, et al 

Defendants APRIL(C, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Yale 

Rabin, 9 Farrar Street, Cambridge, MA. Said deposition will 

begin at 9:30 a.m. on the 3rd day of June, 1992 and continue on 

such additional days as may be necessary to complete the 

deposition. The deposition will be conducted before an 

appropriate officer in the conference room of the office of the 

Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

   



  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

/ "JAA By: J 
JOWh R. Whelan 
Agsistant Attorney General 

10 Sherman Street 
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 

april jf, 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 

New York, 
7 

    

    
  

John R. Whelan 
Assistant Attorney General 

  
 



      

SUBPOENA DUCES TECUM 
kb 

  

TO: Yale Rabin 
9 Farrar Street 

Cambridge, CT 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
3rd day of June, 1992, or to such day thereafter and within 60 

days hereof to testify what you know in regard to a certain 

civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 

CV 89-0360977S. Said deposition shall be conducted at the Office 

of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 

to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 

Hartford and/or its suburban cities or towns which you have 

conducted or which you have relied on for the purpose of 

formulating or confirming the opinions which you are expected to 

offer at trial; and all materials in your possession or control 

relating to other studies which you have conducted the results 

of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this lf Posy of April, 1992 

J Hn 
Johri’R. Whelan 
Commissioner of the Superior Court 

  

CERTIFICATION 
  

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

postage prepaid to all counsel of record on 

April// , 1992: 

IW — 
  

Joh# Rv Whelan 
Asgistant Attorney General 

/ 

Vv 

  
 



      

Cv 89-0360977S 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A, O'NEILL, et al 

Defendants aparLl 1992 

  

NOTICE OF DEPOSITION 

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of John 

Allison, Capital Region Education Council, 599 Matianuck Avenue, 

Windsor, CT. Said deposition will begin at 9:30 a.m. on the 15th 

day of May, 1992 and continue on such additional days as may be 

necessary to complete the deposition. The deposition will be 

conducted before an appropriate officer in the conference room of 

the office of the Attorney General, 110 Sherman Street, Hartford, 

CT. The deposition will be conducted in accordance with the laws 

and rules of practice of the State of Connecticut. 

  
 



    

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHX BLUMENTHAL 

TL) Lt. 
  

Joh R. Whelan 
Sean: Attorney General 
¥10 Sherman Street 
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 

April iL 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 
l4th 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 Rest 43rd Street 
Nev PLY 7) 7, 

  

24 Jb 
2d Zi os 
  

Assistant Attorney General 

  
 



      

SUBPOENA a TECUM 
  

TO: John Allison 
Capital Region Education Council 
599 Matianuck Avenue 
Windsor, CT 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 
15th day of May, 1992, or to such day thereafter and within 60 
days hereof to testify what you know in regard to a certain 
civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this l/ {Lday of April, 1992 

KY Min 
Joh# R. Whelan 
‘Commissioner of the Superior Court 

7 CERTIFICATION 

  

  

  

This is to certify that a copy of the foregoing was mailed 
postag 7/7 1502; to all counsel of record on 

s 19923 

Ya    
  

~ JO6Kh R/ Whelan 
Assistant Attorney General 

  
 



      

Cv 89-0360977s 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A, O'NEILL, et al 

Defendants APRIL{, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Ruth 

Price, 196 Glengarry Road, Fairfield, CT. Said deposition will 

begin at 9:30 a.m. on the 11th day of May, 1992 and continue on 

such additional days as may be necessary to complete the 

deposition. The deposition will be conducted before an 

appropriate officer in the conference room of the Office of the 

Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

yy    By: 
  

Jopn R. ‘Whelan 
sistant Attorney General 

10 Sherman Street 
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 

April J/ , 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 
l4th 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 
New rk, NY 10036 

PNY A 
  

Sy Whelan 
Assistant Attorney General 

  
 



      

- SUBPOENA 81404: TECUM 
  

TO: Ruth Price 
196 Glengarry Road 
Fairfield, CT 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a 
deposition which will take place beginning at 9:30 a.m. on the 

11th day of May, 1992, or to such day thereafter and within 60 

days hereof to testify what you know in regard to a certain 

civil action pending before the Superior Court for the Judicial 
District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 
CV 89-0360977S. Said deposition shall be conducted at the Office 

of the Attorney General (Conference Room), 110 Sherman Street, 

Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 

material on or before the date of your deposition: All 

materials in your possession or control relating to studies of 

Hartford and/or its suburban cities or towns which you have 

conducted or which you have relied on for the purpose of 

formulating or confirming the opinions which you are expected to 

offer at trial; and all materials in your possession or control 

relating to other studies which you have conducted the results 

of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 
- A 

fay of April, 1992 

LJ Ns 
John” R./Whelan 
/Commissioner of the Superior Court 
i/ 
/ CERTIFICATION 

     

  

   

Dated at Hartford, this 

/ 
J 
  

  

This is to certify that a copy of the foregoing was mailed 
postagy prepaid to all counsel of record on 
April 7/ , 1992: 

  

Johari R. Whelan 
Assistant Attorney General 

vd 
v 

  
 



      

SUBPOENA DUCES TECUM 

2 

  

TO: Charles V. Willie, Ph.D. 
Harvard University 
Graduate School of Education 
Monroe C. Gutman Library 
Cambridge, MA 

GREETING: -- 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a 

deposition which will take place beginning at 9:30 a.m. on the 

1st day of June, 1992, or to such day thereafter and within 60 

days hereof to testify what you know in regard to a certain 

civil action pending before the Superior Court for the Judicial 

District of Hartford/ New Britain entitled Sheff v. O'Neill, No. 

CV 89-0360977S. Said deposition shall be conducted at the Office 

of the Attorney General (Conference Room), 110 Sherman Street, 

Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 

to produce and permit inspection and copying of the following 

material on or before the date of your deposition: All 

materials in your possession or control relating to studies of 

Hartford and/or its suburban cities or towns which you have 

conducted or which you have relied on for the purpose of 

formulating or confirming the opinions which you are expected to 

offer at trial; and all materials in your possession or control 

relating to other studies which you have conducted the results 

of which you intend to rely on to support the opinions which you 

are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this i aay of April, 1992 
~ ; / 

JohniR. Whelan 
issioner of the Superior Court i 

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

post sds repaid to all counsel of record on 

April 

iY 
Joh®’ R. Whelan 
Assistant Attorney General 
If 

    
  

CERTIFICATION 
  

  

; ? 

137 

Y 

  
 



      

Cv 89-0360977S 

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

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A. O'NEILL, et al 

Defendants APRIL//, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Charles 

V. Willie, Ph.D., Harvard University, Graduate School of 

Education, Monroe C. Gutman Library, Cambridge, MA. Said 

deposition will begin at 9:30 a.m. on the lst day of June, 1932 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 
AT a 

7/8 
  

    

  

Jolin R. Whelan 
A sistant Attorney General 

10 Sherman Street 
// 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 

April vi 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 
l4th 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 
New 7 10036 

Gl) INA 
   
  

york Whelan 
Agsistant Attorney General 

J