Request for Leave to Amend Complaint

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Impact area
- Education
Topic
- School Desegregation
Matter
- Sheff v. O'Neill
Case
- Sheff v. O'Neill
U.S. state
- Connecticut
Collection
- Case Files
Taxonomy
Identifier
- f5114e66-a246-f011-877a-002248226c06

Cite this item

Case Files, Sheff v. O'Neill Hardbacks. Request for Leave to Amend Complaint, 1992. f5114e66-a246-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/215cb99b-dadd-4670-8d21-42940444d6e7/request-for-leave-to-amend-complaint. Accessed November 02, 2025.

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    ’ 

Cv89-0360977S 

  

MILO SHEFF, et al. 

Plaintiffs SUPERIOR COURT 

JUDICIAL DISTRICT OF 
HARTFORD/NEW BRITAIN 
AT HARTFORD 

Vv. 

WILLIAM A. O'NEILL, et al. 

Defendants JULY 21, 1992 

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REQUEST FOR LEAVE TO AMEND COMPLAINT 
  

Pursuant to Practice Book §176, plaintiffs respectfully request 

leave to amend the complaint at paragraphs 47, 50, and 71. This 

amendment is necessary for the following reasons: 

1. Although plaintiffs have clearly indicated that the state’s 

role in segregated housing patterns is not a necessary part of their 

affirmative case, the presence of several passing references to defen- 

dants’ housing policies in the Complaint has apparently led to some 

confusion on the part of defendants regarding the scope of plaintiffs’ 

proof. It continues to be plaintiffs’ position that housing evidence 

is not part of their case, and they wish to eliminate any ambiguity 

in the pleadings that may be relied on by defendants to divert the 

Court’s attention from the important educational issues that are at 

the core of this case. 

2. The parties have discussed, unsuccessfully, the possible 

elimination of the "housing issue" by stipulation. The presence of 

  

   



      

certain statements regarding housing in the Complaint was one of the 

factors that made such a stipulation unworkable. 

3. This amendment is necessary to conform the complaint to the 

proof to be presented at trial. 

4. This amendment is necessary to reduce and focus the scope of 

issues to be tried to this Court. 

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

Julius L. Chambers 
Marianne Engelman Lado 
Ronald L. Ellis 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 

New York, NY 10013 

Helen Hershkoff 
John A. Powell 
Adam S. Cohen 

American Civil Liberties 
Union Foundation 

132 West 43rd Street 
New York, NY 10036 

BY: 

Respectfully Submitted, 

y AR 4 
  

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 
Bartford, CT 06105 

Ruben Franco 
Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
New York, NY 10013 

  

 



      

ORDER 

The foregoing request having been heard is hereby GRANTED/DENIED. 

  

Hammer, J. 

Dated this day of July, 1992 

  

  

  

  

 



      

CERTIFICATE OF SERVICE   

This is to certify that one copy of the foregoing has been mailed 

postage prepaid by certified mail to John R. Whelan and Martha M. 

Watts, Assistant Attorneys General, MacKenzie Hall, 110 Sherman 
py 

Street, Hartford, CT 06105 this J&? day of July, 1992. 

JF 7 Tee 
  

Philip D. Tegeler

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Request for Leave to Amend Complaint

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