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 October 19, 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