Letter from AG Blumenthal to Tegeler RE Hourly Rates for Depositions

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MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06105 

FAX (203) 523-5536 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

  

Office of The Attornev General : Tel: 566-7173 
State of Connecticut 

June 2, 1992 

Philip Tegeler, Esq. 

Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

RE: Sheff v. O'Neill, Docket No. CV 89-0360977S 
  

Dear Phil: 

Pursuant to our recent conversations I am writing this 
letter to confirm our agreement regarding the hourly rates for 
the depositions of those individuals whose identity has been 
disclosed to date. This letter is being written pursuant to 
paragraph 3 of the order governing the depositions of expert 
witnesses which we have been discussing. 

Plaintiffs' Experts 
  

a. Dr. Jomills Henry Braddock, II -- $150 per hour; 
b. Dr. Christopher Collier -- $110 per hour; 
Cc. Dr, Robert L. Crain -- $150 per hour; 
d. Dr. Marvin F. Dawkins -- $130 per hour 
e. Dr. Mary Kennedy -- $150 per hour; 
f. Dr. William Trent =-- $130 per hour; 
d. Dr. Charles V. Willie -- $150 per hour; 
h. Dr. Catherine E. Walsh -- $130 per hour; 
i. Yale Rabin -- $130 per hour; 
J. Ruth Price =-- $110 per hour; 
k. John Allison -- $110 per hour; 
l. Hernan LaFontaine =-- $110 per hour. 

Defendants' Experts 
  

a. Christine Rossell, Ph.D. =-- $150 per hour; 
b. David Armor, Ph.D. =-- $150 per hour; 
C. G. Donald Ferree -- $90 per hour; 
d. Pasquale Forgione, Ph.D. -- $150 per hour; 
e. Lloyd Calvert -- $110 per hour; 
f. Thomas E. Steahr, Ph.D. -- $110 per hour; 

In addition I am writing to confirm that the following 
individuals are regular state employees who fall within the 
exception found in paragraph 7 of the order regarding the 

 



  

Philip Tegeler, Esq. 
May 20, 1992 
Page 2 

depositions of expert witnesses: Douglas Rindone, William 
Congero, Peter Behuniak, Elliot Williams, Robert Brewer, Peter 
Prowda, Theodore Sergi, Thomas Breen and Patricia Downs. 

If the defendants call these individuals as witnesses they 
will be called because of work they have done in the normal 
course of their employment and their testimony will be offered 
in the normal course of their employment. Since the defendants 
will incur no additional expense by reason of their testimony no 
fees for their time will be requested. 

Two of the individuals we have employed as expert witnesses 
are also state employees but they have been specially retained by 
this office for the purpose of this case. These individuals are 
Thomas Steahr and G. Donald Ferree. Pursuant to the agreement 
which we have reached it is understood that these two individuals 
do not fall within the provisions of paragraph 7 and that the 
rates set forth above will be paid by the plaintiffs. 

Please acknowledge the terms of the agreement which we have 
reached and which are set out above by signing the acknowledgment 
found below on behalf of the plaintiffs. 

Thank you for your cooperation. 

Very truly yours, 

RICHARD/B EN L 

ATTOE N 

BY: i 4 2 
Asgigtant Attorney General 

JRW/mu / 
ACKNOWLEDGMENT: 

V/A 
Philip Tegeler, Esgjg. fy, ° 
Counsel for the Plaintiffs 

  

    
  

  

 



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@ 

  

MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06105 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

  

FAX (203) 523-5536 

Office of The Attornev General Tel: 566-7173 

State of Connecticut 
June 2, 1992 

Philip Tegeler, Esq. 
Connecticut Civil Liberties Union 

32 Grand Street 

Hartford, CT 06106 

RE: Sheff v, O'Nelll, Docket No. CV 89-0360977S 
  

Dear Phil: 

Pursuant to our recent conversations I am writing this 
letter to confirm our agreement regarding the hourly rates for 
the depositions of those individuals whose identity has been 
disclosed to date. This letter is being written pursuant to 
paragraph 3 of the order governing the depositions of expert 
witnesses which we have been discussing. 

Plaintiffs' Experts 
  

a. Dr. Jomills Henry Braddock, 11 =-- $150 per hour; 
b. Dr. Christopher Collier -- $110 per hour; 
C. . Dr. Robert I. Crain -- 8150 per hour; 
d. Dr. Marvin F. Dawkins -- $130 per hour 
e. Dr. Mary Kennedy =-- $150 per hour; 
f. Dr. William Trent -- $130 per hour; 
ge. Dr. Charles Vv, Willie -- $150 per hour; 
h. Dr. Catherine E. Walsh -- $130 per hour; 
i. Yale Rabin -- $130 per hour; 
j. Ruth Price -- $110 per hour; 
k. John Allison -- $110 per hour; 
l. Hernan LaFontaine -- $110 per hour. 

Defendants' Experts 
  

a. Christine Rossell, Ph.D. -- $150 per hour; 
b. David Armor, Ph.D. -- $150 per hour; 
c. G. Donald Ferree -- $90 per hour; 
d. Pasquale Forgione, Ph.D. -- $150 per hour; 
e. Lloyd Calvert -- $110 per hour; 
f. Thomas E. Steahr, Ph.D. -- $110 per hour; 

In addition I am writing to confirm that the following 
individuals are regular state employees who fall within the 
exception found in paragraph 7 of the order regarding the 

 



  

Philip Tegeler, Esq. 
May 20, 1992 
Page 2 

depositions of expert witnesses: Douglas Rindone, William 
Congero, Peter Behuniak, Elliot Williams, Robert Brewer, Peter 
Prowda, Theodore Sergi, Thomas Breen and Patricia Downs. 

If the defendants call these individuals as witnesses they 
will be called because of work they have done in the normal 
course of their employment and their testimony will be offered 
in the normal course of their employment. Since the defendants 
will incur no additional expense by reason of their testimony no 
fees for their time will be requested. 

Two of the individuals we have employed as expert witnesses 
are also state employees but they have been specially retained by 
this office for the purpose of this case. These individuals are 
Thomas Steahr and G. Donald Ferree. Pursuant to the agreement 
which we have reached it is understood that these two individuals 
do not fall within the provisions of paragraph 7 and that the 
rates set forth above will be paid by the plaintiffs. 

Please acknowledge the terms of the agreement which we have 
reached and which are set out above by signing the acknowledgment 
found below on behalf of the plaintiffs. 

Thank you for your cooperation. 

Very truly yours, 

JRW/mu 
ACKNOWLEDGMENT: 

Vw 
  

  

  

Philip Tegeler, Esq. 
Counsel for the DY liEis