Correspondence from Whelan to Tegeler Re: Expert List

Correspondence
December 12, 1991

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Correspondence from Whelan to Tegeler Re: Expert List preview

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  • Case Files, Sheff v. O'Neill Hardbacks. Correspondence from Whelan to Tegeler Re: Expert List, 1991. 13d23bcb-a946-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1e5f0de3-f8cb-40e1-82aa-f0e8fbcdeed7/correspondence-from-whelan-to-tegeler-re-expert-list. Accessed October 10, 2025.

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    MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06105 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

ll 

  

FAX (203) 5323-5536 

Office of The Attorney General Pel: 566-7173 

State of Connegticut 

Philip Tegeler, Esq. 
Connecticut Civil Liberties Union 

32 Grand Street 

Hartford, CT 06106 

R 3)
 Sheff v. O'Neill   

Dear Phil: 

In order to establish a basis for beginning the depositions 
of the individuals who you have identified as plaintiffs' expert 
witnesses, we would appreciate it if you would provide us with an 
up-to-date list identifying those of your witnesses who have 
completed all of the work they intend to do to prepare and speak 
about the opinions they intend to offer at trial. My point in 
making this request is to be sure that we do not find out during 
the course of the deposition that the expert plans to do 
additional work which would make it necessary for us to continue 
the deposition until that work is completed, and that we do not 
find out at trial that your expert relied on new or different 
facts and information to substantiate his or her opinions. 

We are especially concerned that at least some of your 
expert witnesses may be relying on information, including 
information about Hartford and the suburban school districts, 
which we asked ycu to identify in response to the defendants’ 
first set of interrogatories, but which you have not yet provided 
to us. To the extent that any of your expert witnesses will rely 
on the information sought by way of our interrogatories which you 
have not yet compiled and/or provided to us, it would be a waste 
of time and effort to take their depositions before your experts 
have that information and you provide us with full and final 
responses to our interrogatories. 

It seems to me that the depositions of at least some of your 
expert witnesses will have to be put off until you provide us 
with complete and up-to-date answers to our interrogatories. The 
depositions of witnesses who have no further work to do and who 
will not be relying on information which you will be supplying to 

 



  

Philip Tegeler, Esq. 

December 11, 1991 

Page 2 

us in supplemental responses to our interrogatories should be 
able to move forward in the near future. 

We look forward to hearing from you on this matter. 

Very truly yours, 

RICHARD UMENTHAL 

ATTORNEY GENERAL 

  

JRW/mu / / 
cc: All Counsel of Record A

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