Fax to All Counsel RE: Documents Requested for Deposition and Testimony of Peter Prowda with Attached Subpoena and Certificate of Service

    FPOUNMNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX August 28, 1992 

Mr. John Whelan 
Assistant Attorney General 
110 Sherman Street 
Hartford, CT 06105 

RE: Sheff v. O'Neill 
  

Dear John, 

Pursuant to paragraph 4 of the Pretrial Order of April 10, 
1992, we are giving notice as to the documents requested for the 
deposition of Peter Prowda scheduled for September 11, 1992. If 
any of the documents you have previously submitted to us are 
responsive to this request, please indicate the number of the 
document. In order to save time at the deposition, we would 
appreciate receiving these documents at least two days in advance. 

In addition, as we have discussed in relation to other expert 
witnesses, we are requesting that a more detailed description of 
Mr. Prowda’s anticipated testimony be provided to us prior to the 
deposition. 

Thank you for your cooperation. 

Sincerely, 

Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 
Ro 5 

 



  

SUBPOENA DUCES TECUM 
  

TO: Peter Prowda 
Department of Education 
165 Capitol Avenue 
Bartford, CT 06106 

GREETING: 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a deposition 
which will take place beginning at 9:00 a.m. on the 11th of September, 
1992, or to such day thereafter and within sixty days hereof to 
testify what you know in regard to a certain civil action pending 
before the Superior Court for the Judicial District of Hartford/New 
Britain entitled Sheff v. O'Neill, No. CV 189-0360977S. Said 
deposition shall be conducted at the offices of the Connecticut Civil 
Liberties Union Foundation, 32 Grand Street, Hartford, Connecticut 
(Conference Room). 

  

Pursuant to Practice Book §245(c) you are further directed to 
produce and permit inspection and copying of the following: 

1. A copy of your current resume. 

2. Raw data underlying Exhibit 7(a) as set out in the 
description of your testimony in "Defendants’ Amended 
Disclosure of Expert Witnesses" (July 23, 1992). 

3. Any other studies, tables, reports, data analyses, or trial 
exhibits you have prepared in this case (not including 
documents produced at deposition of Doug Rindone). 

4. Any data or summary of data for Hartford and each of the 
surrounding communities on the proportion of ninth graders 
who complete high school within four years, as referenced in 
the publication "Indicators of Success." 

5. Any studies or reports on the impact of the exclusion 
provisions on the CMT programs for Special Education and 
bilingual students. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 
Tor 

Dated at Hartford, Connecticut this v) day of August, 1992. 

WW 7 Epix 
  

Philip D. Tegeler/Martha Stone 
Commissioner of the Superior Court 

 



  

CERTIFICATE OF SERVICE 
  

This is to certify that a copy of the foregoing has been faxed 
and mailed postage prepaid to John R. Whelan and Martha M. Watts, 
Assistant Attorneys General, acKenzie Hall, 110 Sherman Street, 
Hartford, CT 06105 this day of August, 1992, 

J7 Za 
  

Philip D. Tegeler/Martha Stole 
Attorneys for Plaintiffs