Defendants' Response to Plaintiffs' Sixth Request for Production of Documents with Certification

    Cv 89-0360977S 

MILO SHEFF, et al., : SUPERIOR COURT 

JUDICIAL DISTRICT OF 
HARTFORD/NEW BRITAIN 

Vv. : AT HARTFORD 

Plaintiffs, 

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WILLIAM A. O'NEILL, et al., 

Defendants. OCTOBER 26, 1992 

DEFENDANTS' RESPONSE TO PLAINTIFFS' SIXTH REQUEST 

FOR PRODUCTION OF DOCUMENTS 
  

  

Defendants offer the following answers and objections to the 

plaintiffs’ Sixth Request for Production of Documents. 

1. All documents and reports created for the two year 

"pilot program" conducted by Katherine Oleksiw regarding dropout 

rates, retention rates, etc. for priority school districts. 

ANSWER: See Defendants' Response to Plaintiffs' First 

Request for Production, Exhibits 4(a),(b),(c), and (4d) and 

Defendants' Response to Plaintiffs' Fifth Request for Production, 

item 19. 

  

  
 



  

  

2 All documents and reports and data collected for the 

"statewide survey" regarding dropout rates, retention rates, 

etc., as referred to by Peter Prowda in his deposition. 

ANSWER: See response to 1, above. 

3. A copy of the paper or study conducted by Barbara 

Beaudin on teacher turnover, as described by Peter Prowda in his 

deposition. 

ANSWER: Defendants' Response to Plaintiffs' Fifth Request 

for Production, exhibits 5(a) and 20 (a), (b). 

4, Any enrollment projections done for Hartford and 

surrounding districts, 1985 to present. 

ANSWER: See Exhibits 4(a) - (o). 

5. A complete set of district-level strategic school 

profiles for each school district in Connecticut.       
 



      

ANSWER: See responses to 8, below. With respect to 

districts not encompassed by the phrase "Hartford and the 

surrounding districts," the files and records of the State 

Department of Education's Division of Teaching and Learning 

relating to district-level strategic school profiles, not 

otherwise privileged, will be open for inspection at a mutually 

convenient date and time. During that inspection, plaintiffs’ 

representative may identify documents which the plaintiffs would 

like to have copied. Depending on the number of documents 

identified, the defendants will either provide plaintiffs with a 

copy of those documents or make those documents available for 

copying by the plaintiffs. All arrangements must be made through 

counsel for the defendants. 

6. A copy of the computer disk or tape containing the 

entire database for the strategic school profiles. 

ANSWER: The requested item is not available at this time. 

In any event, the defendants object to this request as it is 

inconsistent with the Protective Order dated January 23, 1991. 

According to that order, 

No print out or hard copy of any 
material taken or derived from any computer 

-3-   
 



      

tapes, discs, diskettes, or other computer 

records turned over to the plaintiffs or 
their attorneys during the course of this 
litigation may be admitted into evidence 
unless plaintiffs' attorneys provide 

defendants with all information necessary to 

allow the defendants to duplicate the 

analysis, search, sort, etc. by which the 

material was generated and this information 

is provided within sufficient time before 
trial to allow the defendants to duplicate, 

examine, and analyze the procedures used to 

generate the print out or hard copy. 

There is no way that the plaintiffs can comply with this aspect 

of the Protective Order if they were provided with the requested 

disk or tape at this late stage. 

7. A complete set of strategic school profiles for each 

school in Hartford, Farmington, West Hartford and Glastonbury. 

ANSWER: See response to 8, below. 

B. ED 165 reports for each school and district in Hartford 

and the surrounding communities (if not included in strategic 

school profiles). 

ANSWER: See exhibits 8(a) - 8(kkkkkkk). Responsive 

documents relating to the East Windsor Public Schools are not yet 

  

  
 



  

  

available from the Department of Education. The defendants will 

provide those documents to the plaintiffs as soon as they become 

available. 

9, "Budget Briefs" (Commissioner's Recommendations to the 

State Board of Education), 1987 to present. 

ANSWER: The files and records of the State Department of 

Education's Division of Finance and Administrative Services 

relating to "Budget Briefs" and "Budget Proposals" not otherwise 

privileged, will be open for inspection at a mutually convenient 

date and time. During that inspection, plaintiffs’ 

representative may identify documents which the plaintiffs would 

like to have copied. Depending on the number of documents 

identified the defendants will either provide plaintiffs with a 

copy of those documents or make those documents available for 

copying by the plaintiffs. All arrangements to inspect files and 

records must be made through counsel for the defendants. 

10. State Board of Education "Budget Proposals," 1987 to 

the present.       
 



      

ANSWER: See response to 9, above. 

11. Challenge for Excellence: Connecticut's Comprehensive 

Plan for Elementary, Secondary, Vocational, Career and Adult 

Education: A Policy Plan 1991-1998, 

ANSWER: See Exhibit 11. 

12. "A Guide To Curriculum Development in Foreign 

Languages." 

ANSWER: See Exhibit 12. 

13. "Meeting the Challenge -- Condition of Education in 

Connecticut 1986" (reprint -- December 1987). 

ANSWER: See Defendants' Response to Plaintiffs' First Set 

of Interrogatories, exhibit 27(a) and Defendants' Response to 

Plaintiffs' Fifth Request for Production, items 59 and 63. 

  

  

 



  

  

14. Vocational-technical schools budget request 1991-1992 | 

(Commissioner's Recommendations to the State Board of Education | 

—— June 1990 and August 90). | 

ANSWER: See response to 9 and 10, above. 

15. "Unacceptable Trends in Kindergarten" (1988). 

ANSWER: See Exhibit 15. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

or il, V/A rs 
John R. Whelan 
Assistant Attorney General 
110 Sherman Street / 
Hartford, CT 06105 
Tain 566-7173 p 

  

  

  

“Marthd M. Wat i 4A 
Assistant Attorney General 
‘110 Sherman Street 
Hartford, CT 06105 
Telephone: 566-7173       
 



  

  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed, 

postage prepaid on October 26, 1992 to the following counsel of 

record: 

John Brittain, Esq. Wilfred Rodriguez, Esq. 

University of Connecticut Hispanic Advocacy Project 

School of Law Neighborhood Legal Services 

65 Elizabeth Street 1229 Albany Avenue 

Hartford, CT 06105 Hartford, CT 06112 

Philip Tegeler, Esq. Wesley W. Horton, Esq. 

Martha Stone, Esq. Moller, Horton & Fineberg P. Ce 

Connecticut Civil Liberties Union 90 Gillett Street 
32 Grand Street Hartford, CT 06106 

Hartford, CT 06106 

Ruben Franco, Esq. Julius L. Chamberes, Esq. 
Jenny Rivera, Esq. Marianne Lado, Esq. 
Puerto Rican Legal Defense Fund Ronald Ellis, Esq. 
and Education Fund NAACP Legal Defense Fund and 

14th Floor Educational Fund 

99 Hudson Street 99 Hudson Street 

New York, NY 10013 New York, NY 10013 

John A. Powell, Esq. 

Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036 

  

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