Correspondence from Tegeler to Whelan Re: Scheduling of Additional Depositions

Correspondence
July 22, 1992

Correspondence from Tegeler to Whelan Re: Scheduling of Additional Depositions preview

2 pages

Cite this item

  • 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 October 19, 2025.

    Copied!

    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

Copyright notice

© NAACP Legal Defense and Educational Fund, Inc.

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.


Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.