Letter to All Counsel RE: Enclosed Letter to Plaintiff's Counsel Relating to Deposition Schedule
Public Court Documents
September 4, 1992
5 pages
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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 December 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 :
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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)
~
pl
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