Defendants Response to Plaintiffs' First Set of Interrogatories

    Cv89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintifis 

Vv. JUDICIAL DISTRICT OF 
HARTFORD/NEW BRITAIN 

WILLIAM A. O'NEILL, et al. AT HARTFORD 

Defendants JANUARY 30, 1991 

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PLAINTIFFS’ SECOND MOTION FOR EXTENSION OF TIME TO RESPOND 
TO DEFENDANTS’ FIRST SET OF INTERROGATORIES 
  

  

Plaintiffs respectfully request an extension of time until 

February 19, 1991 in which to respond to Defendants’ First Set of 

Interrogatories. In support of this motion, plaintiffs state the 

following: 

1. Plaintiffs served their responses to Defendants’ First 

Set of Interrogatories on October 31, 1990. 

2. After consultation with defendants, and in an effort to 

resolve potential discovery disputes, plaintiffs agreed to 

respond in more detail to certain interrogatories or to amend 

certain interrogatory responses to clarify the issues in dispute. 

ORAL ARGUMENT NOT REQUESTED 
TESTIMONY NOT REQUIRED    



      

3. On December 3, 1990, the parties filed a Joint Motion 

for Extension of Time to Disclose Expert Witnesses Pursuant to 

Practice Book Section 220 (D), requiring initial identification 

of experts to take place on January 15, 1991. Without waiving 

any claims plaintiffs may have to seek a more complete response, 

both parties have complied with the deadline set out in said 

Joint Motion. 

4. On December 10, 1990, plaintiffs filed a Motion for 

Extension of Time to Respond to Defendants’ First Set of 

Interrogatories, requesting until January 30, 1991 to respond 

more fully to Defendants’ First Set of Interrogatories. The 

present motion would seek to extend the January 30 deadline for 

an additional 20 days. 

5. The plaintiffs have been working diligently to respond to 

Defendants’ First Set of Interrogatories, and need additional 

time to complete their response and to coordinate the work of 

several attorneys. The present motion is also needed, in part, 

to make an initial evaluation of discovery materials, including 

certain computer tapes, provided by defendants on January 24. 

6. This is plaintiffs’ second motion for extension of time 

to respond to Defendants’ First Set of Interrogatories. 

7. Defendants have been contacted and have no objection to 

the granting of this Motion. 

  

 



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

Julius L. Chambers 

Marianne Lado 

Ron Ellis 

NAACP Legal Defense & 
Educational Fund, Inc. 

99 Hudson Street 
New York, NY 10013 

Helen Hershkoff 
John A. Powell 
Adam Cohen 
American Civil Liberties 

Union Foundation 
132 West 43rd Street 
New York, NY 10036 

Respectfully Submitted, 

id 
  

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 

Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
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 Diane W. Whitney, 

Assistant Attorney Generals, MacKenzie Hall, 110 Sherman Street, 

Hartford, CT 06105 this 30th day of January, 1991. 

/</ 
  

Philip D. Tegeler