Letter to All Counsel RE: Enclosed Letter to Plaintiff's Counsel Relating to Deposition Schedule
Public Court Documents
September 4, 1992

5 pages
Cite this item
-
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.
Copied!
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 O C o O J O o u l d w n HH 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