Correspondence from Tegeler to Whelan Re: Scheduling of Additional Depositions
Correspondence
July 22, 1992
2 pages
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Case Files, Sheff v. O'Neill Hardbacks. Correspondence from Tegeler to Whelan Re: Scheduling of Additional Depositions, 1992. 68efc25f-a246-f011-877a-0022482c18b0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/19a0c8fe-5471-4acf-babc-330cc012ac6c/correspondence-from-tegeler-to-whelan-re-scheduling-of-additional-depositions. Accessed December 06, 2025.
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FOUNDATION
ThirtyTwo Grand Street, Hartford. CT 06106
203/247-9823 Fax 203/728-0287
TRANSMITTED BY FAX July 22, 1992
Mr. John Whelan
Assistant Attorney General
MacKenzie Hall
110 Sherman Street
Hartford, CT 06105
RE: Sheff v. O'Neill; Scheduling of Additional Depositions
Dear John,
I am writing to arrange scheduling for the remaining expert
depositions in the Sheff case.
The current schedule, based on our recent conversations, is
as follows:
Current Schedule
July 23 John Allison
August 4 Douglas Rindone
[August 6] [Armor Exhibits Due]
August 25 William Trent
August 27 Robert Crain
August 28 Mary Kennedy
September 1 Patricia Downs
September 2 Ruth Price
September 3 David Armor
September 3 Thomas Steahr
September 4 Yale Rabin
September 8 Lloyd Calvert
September 9 Jomills Braddock
September 10 Hernan LaFontaine
September 14 Donald Feree
September 15 Christine Rossell
Additional Witnesses
The remaining identified plaintiffs’ experts to be deposed
by you include plaintiff experts Charles Willie, Gary Natriello,
and William Gordon. You have indicated that you do not intend to
depose Mary Carroll and we likewise assume you would not be
deposing school principals. Please let us know if this is
incorrect.
The Connecticut Civil Liberties Union Foundation
5
Remaining witnesses to be deposed by plaintiffs include
former commissioner Tirozzi, 3-4 State Board of Education members
(who could be deposed on one day), the expert you indicated you
would identify this week, and the new commissioner. We also
should schedule deposition dates for your listed experts Thomas
Breen, Peter Prowda, William Congero, and Peter Behuniak, unless
you inform us that any of these witnesses will not be called at
trial. Plaintiffs may also seek to depose other witnesses,
including any defendants’ experts not yet named, but at the
present time this is the schedule as we anticipate it.
Based on the foregoing, an additional ten (10) days will
need to be scheduled between now and September 15. We are
available on the following days to complete these depositions.
Available Deposition Dates
July 30 (defendants’ witnesses)
August 5 (defendants’ witnesses)
August 7 (defendants’ witnesses)
August 13-21 (during your vacation, if other counsel are
available).
August 24
August 26 (afternoon)
August 31
September 7
September 11
We are also available to attend these depositions from
September 16-30 if this is the only time you have available. By
doing so we would not wish to further amend the scheduling order
or delay the trial in any way. We have ample time to complete
these depositions prior to September 15, and we hope you will
fully explore your own availability and availability of other
counsel with appearances in this case in order to expedite the
completion of discovery.
Please give me a call to work out the scheduling for these
upcoming depositions.
Sincerely,
Philip D. Tegeler
Attorney for Plaintiffs
PDT/dmt