Plaintiffs' Sixth Request for Production of Documents with Notice of Service and Certificate of Service

    Cv89-0360977s 

  

MILO SHEFF, et al. 

Plaintiffs SUPERIOR COURT 

JUDICIAL DISTRICT OF 
HARTFORD/NEW BRITAIN 
AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al. 

Defendants SEPTEMBER 15, 1992 

  

PLAINTIFFS’ SIXTH REQUEST FOR PRODUCTION OF DOCUMENTS 
  

You are requested pursuant to §227 of the Connecticut Practice 

Book to produce the following documents for inspection and copying 

within thirty days of service of this Request. Said production shall 

be made at the office of plaintiffs’ counsel, Connecticut Civil 

Liberties Union Foundation, 32 Grand Street, Hartford, Connecticut 

06106. 

bi INSTRUCTIONS AND DEFINITIONS 

Plaintiffs incorporate herein the instructions and definitions 

set out in Plaintiffs’ Fifth Request for Production of Documents by 

reference. 

II. DOCUMENTS REQUESTED 

1. All documents and reports created for the two year "pilot 

program" conducted by Katherine Oleksiw regarding dropout rates, 

retention rates, etc. for priority school districts. 

2 All documents and reports and data collected for the 

"statewide survey" regarding dropout rates, retention rates, etc., as 

referred to by Peter Prowda in his deposition. 

  

  
 



A copy of the paper or study conducted by Barbara Beaudin on 3s 

teacher turnover, as described by Peter Prowda in his deposition. 

4. Any enrollment projections done for Hartford and surrounding 

districts, 1985 to present. 

5. A complete set of district-level strategic school profiles 

for each school district in Connecticut. 

6. A copy of the computer disk or tape containing the entire 

database for the strategic school profiles. 

7. A complete set of strategic school profiles for each school 

in Hartford, Farmington, West Hartford and Glastonbury. 

8. ED 165 reports for each school and district in Hartford and 

the surrounding communities (if not included in strategic school 

profiles). 

9. "Budget Briefs" (Commissioner’s Recommendations to the State 

Board of Education), 1987 to the present. 

10. State Board of Education " Budget Proposals," 1987 to the 

present. 

11. Chellenge for Excellence: cnnacticut’s Comprehensive Plan 

Career and Adult Education: for Elementary, Secondary, Vocational, 

A Policy Plan 1991-1995. 

"A Guide to Curriculum Development in Foreign Languages." 12. 

in Condition of Education 13. "Meeting the Challenge -- 

Connecticut 1986" (reprint -- December 1987).      



      

JA. Vocational-technical 

(Commissioner’s Recommendations to the State Board of Education 

June 1990 and August 90). 

15. "Unacceptable Trends in Kindergarten" (1988). 

Wesley W. Horton 
Moller, Horton, & Rice 
90 Gillett Street 
Hartford, ‘CT 06105 

Julius L. Chambers 
Marianne Engelman Lado 
Ronald L. Ellis 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

Respectfully Submitted, 

  

Y: yy 4 [JE 
Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 
Union Foundation 

32 Grand Street 

Hartford, CT 06106 

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

John Brittain 
University of Connecticut 

School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

schools budget request 1991-1992 

  

  

 



      

-idl 

Adam S. Cohen Ruben Franco 
Helen Hershkoff Ken Kimerling 
John A. Powell Sandra Del Valle 
American Civil Liberties Puerto Rican Legal Defnese 

Union Foundation and Educational Fund 
132 West 43rd Street 99 Hudson Street 
New York, NY 10036 New York, NY 10013 

CERTIFICATE OF SERVICE 
  

This is to certify that one copy of the foregoing has been mailed 

postage prepaid to John R. Whelan and Martha M. Watts, Assistant 

Attorneys General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 

~ 77 
06105 this /2 day of September, 1992. 

Wp ze 
  

Philip D. Tegeler 

  

  
 



  

Cv89-0360977S 

  

MILO SHEFF, et al. 

Plaintiffs SUPERIOR COURT 

JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al. 

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Defendants SEPTEMBER 15, 1992 

  

NOTICE OF SERVICE OF SIXTH REQUEST 
FOR PRODUCTION OF DOCUMENTS 
  

  

Plaintiffs give notice that on September 15, 1992, they served 

Plaintiffs’ Sixth Request for Production of Documents on the 

defendants by service upon their counsel. 

Respectfully Submitted, 

Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 
Union Foundation 

32 Grand Street 

  

    
Wesley W. Horton 
Moller, Horton, & Rice 
90 Gillett Street 
Bartford, CT 06105 

Julius L. Chambers 
Marianne Engelman Lado 
Ronald L. Ellis 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

Hartford, CT 06106 

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

John Brittain 
University of Connecticut 

School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

  

 



      

i Bing 

Adam S. Cohen Ruben Franco 

Helen Hershkoff Ken Kimerling 
John A. Powell Sandra Del Valle 

American Civil Liberties Puerto Rican Legal Defnese 
Union Foundation and Educational Fund 

132 West 43rd Street 99 Hudson Street 

New York, NY 10036 New York, NY 10013 

CERTIFICATE OF SERVICE 
  

This is to certify that one copy of the foregoing has been mailed 

postage prepaid to John R. Whelan and Martha M. Watts, Assistant 

Attorneys General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 

Kd 
06105 this // day of September, 1992. 

   
I< 
  

Philip D. Tegeler