Letter to All Counsel RE: Enclosed Letter to Plaintiff's Counsel Relating to Deposition Schedule

Public Court Documents
September 4, 1992

Letter to All Counsel RE: Enclosed Letter to Plaintiff's Counsel Relating to Deposition Schedule preview

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  • Connecticut, Case Files, Sheff v. O'Neill Hardbacks. Letter to All Counsel RE: Enclosed Letter to Plaintiff's Counsel Relating to Deposition Schedule, 1992. a55a00d4-a546-f011-8779-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/12b3f8b0-5863-4f9e-8715-8033634fb40b/letter-to-all-counsel-re-enclosed-letter-to-plaintiffs-counsel-relating-to-deposition-schedule. Accessed September 18, 2025.

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    MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06105 

RICHARD BLUMENTHAL 
\TTORNEY GENERAL 

FAX (203) 523-5536 

  

Office of The Attorney General Tel: 5656-7173 

State of Connecticut 
September 4, 1992 

Honorable Harry Hammer 
Judges' Chambers 
Superior Court 
Pe OO. BOX:325 
Rockville, Connecticut 06066 

RE: Sheff yv. O'Neill 
£V39-03609775 
  

Dear Judge Hammer: 

Enclosed please find a letter which we recently sent to the 
plaintiff's counsel outlining matters relating to the deposition 
schedule in the above-captioned case. We thought you should be 
aware of this matter in light of the date which has been set for 

      

   

trial. 

Very truly yours, 

RICH BLUMENTHAL 

ATTORN gi : 
Li 7 

( vA 
74 / ( 

BY:/ John R. Whelan 
Ksdistant Attorney General 

JRW: jm 7 
enc. 

CC: All Counsel of Record 

W/Enc. 

 



" 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

  

MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06103 

  

FAX (203) 523-5536 

Office of The Attorney (General Tel: 566-7173 

State of Connecticut 

September 4, 1992 

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

Hartford, CT 06105 

RE: SHEFF v. O'NEILL/DEPOSITIONS 
  

Dear Phil: 

Due to the time constraints under which the defendants are 
now forced to operate, we must abandon our plans to take the 
depositions of the following individuals who have been listed by 
the plaintiffs as expert witnesses or witnesses with experience 
and background in education who are expected to testify regarding 
their background and experiences: 

Donald Carso 

Eddie Davis 

Richard Montanez Pietri 

Edna Negron 
Freddie Morris 

Joshia Haig 
Katherine Kennelly 
Alice Dixon 

Robert Nearine 

10. John Hubert 

ll. Antres Buford 

12. Charles Senteio 

13. John Shea 

14, Jeffrey Foreman 
15. Adnelly Maricheal 
16. Gladys Hernandez 
17. Thomas O'Connor 
18. Brad Noel 

19. Diane Cloud 

20. Winzola Perry 

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Please advise the individuals whose depositions have been 
scheduled that their depositions are cancelled. 

The following list represents my understanding of the 
deposition schedule as it now stands along with the dates we have 
chosen for the depositions of the three new "outside" expert 

 



Philip Tegeler, Esdq. 
September 4, 1992 

Page 2 

witnesses which the plaintiffs have recently identified and a 

date for continuation of the Trent and Allison depositions. 

September 3, 1992 9430 p.m. Steahr {plaintiffs’ deposition) 

September 8, 1992 9:30 a.m, Calvert (plaintiffs' deposition) 

September 9, 1992 9:30 a.m. Braddock (defendants' deposition) 

September 10, 1992 9:30 a.m. LaFontaine (defendants' deposition) 

September 11, 1992 :30 a.m. Prowda (plaintiffs' deposition) 9 

September 11, 1992 3:00 p.m. Breen (plaintiffs' deposition) 

September 14, 1992 9:00 a.m. Ferree (plaintiffs' deposition) 

September 14, 1992 12:00 p.m. Armor (plaintiffs' deposition) 

September 15, 1992 9:30 a.m. Rossell (plaintiffs' deposition) 

September 18, 1992 2:00 p.m. Tirozzi (plaintiffs' deposition) 

September 1992 :30 a.m. Natriello (defendants' deposition) 

September 24, 1992 :30 a.m. Gordon (defendants' deposition) 

September 29, 1992 30 a.m. Orfield (defendants' deposition) 

September 30, 1992 9:30 a.m, Kennedy (defendants' deposition) 

October 1, 1992 2:00 p.m. Ferandino (plaintiffs' deposition) 

October 2, 1992 10:00 am Levine (plaintiffs; deposition) 

october 5, 1992 10:00 a.m. Walsh (defendants' depositon) 

October 7, 1992 9:30 a.m. Willie (defendants' deposition) 

October 8, 1992 10:00 a.m. Slavin (defendants' deposition) 

Qotober 13, 1992 9:30 a.m. Morales (defendants' deposition) 

October 15, 1992 9:30 a.m. Allison (defendants'cont. deposition) 

October 15, 1992 1:00 p.m. Trent (defendants' cont. deposition) 

October 20, 1992 :30 a.m. Sergi {(plaintiffs' deposition) 

October 22, 1992 :30 a.m. Behuniak (plaintiffs' deposition) 

October 22, 1992 :00 p.m. Congero (plaintiffs' deposition)  



  

~ 
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Philip Tegeler, Esd. 
September 4, 1992 

Page 3 

At your request, we are continuing our effort to identify a 

date for the depositions your wish to take of SBE members Mannix, 

Wright and Cuevas. Mr. Mannix has recently been released from 

the hospital so we are in a better position to choose a date, 1 

have asked the department of education to work with these three 

individuals to identify a date or dates between October 15, 1992 

and October 31, 1992 on which all three depositions can be taken 

in two hour increments as previously scheduled. Since these 

individuals are not paid for their work on the Board and must 

attend to their own work we hope you will make every effort to 

accommodate the schedule we will be proposing. 

We will make a decision as to whether we wish to take Dr. 

Margolin's deposition on September 21st, as you have suggested, 

after we receive the description of his expected testimony from 

you. 

Very truly yours, 

RICHARD BLUMENTHAL 

7 te     BYA4/ 

*efistant Attorney General 

JRW:ac \ / 

cc: Hon. Harry Hammer 7 

Mark Stapleton, Esq. / 

 



State of Connecticut 
ATTORNEY GENERAL 

MacKENZIE HALL 

110 SHERMAN STREET 

HARTFORD, CONNECTICUT 06105 

JULIUS L CHAMBERS ESQ 

MARIANNE LADO ESQ 

RONALD ELLIS ESQ 

NAACP LEGAL DEFENSE & ED FUND 

99 HUDSON ST 

NEW YORK NY 10013

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