Plaintiffs' Third Identification of Expert Witnesses Pursuant to Practice Book 220 (D)

    Cv89-0360977S 

  

MILO SHEFF, et al. : SUPERIOR COURT 

Plaintiffs 3 

x. : JUDICIAL DISTRICT OF 

: HARTFORD/NEW BRITAIN 

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

Defendants : April 1, 1992 

  

PLAINTIFFS’ THIRD IDENTIFICATION OF EXPERT WITNESSES 
PURSUANT TO PRACTICE BOOK §220 (D) 
  

  

Pursuant to Practice Book §220(D), as modified by the 

Proposed Pretrial Order submitted to the Court on March 13, 1992, 

the plaintiffs herein disclose their third list of expert 

witnesses anticipated to testify at trial, in response to 

Defendants’ First Set of Interrogatories. Any additional expert 

witnesses shall be identified pursuant to the Pretrial Order. 

Interrogatory 18. Please specify the name and address of 
each and every person the plaintiffs expect to call as an expert 
witness at trial. For each such person please provide the 
following: 

  

a. The date on which that person is expected to complete 
the review, analysis, or consideration necessary to formulate the 
opinions which that person will be called upon to offer at trial; 

b. The subject matter upon which that person is expected to 
testify; and 

  
  

  
 



      

c. The substance of the facts and opinions to which that 
person is expected to testify and a summary of the grounds for 
each opinion. 

RESPONSE: Experts whom the plaintiffs expect to call at trial 
  

are listed below, pursuant to Practice Book Section 220(D): 

John Allison, Capitol Region Education Council, 599 Matianuck 
Avenue, Windsor, CT 06095. Mr. Allison is expected to testify 
in detail regarding the matters set out in his affidavit dated 
September 19, 1991, attached as Exhibit A to Plaintiffs’ 
Memorandum in Opposition to Defendants’ Motion for Summary 
Judgment (September 20, 1991). In general, Mr. Allison will 
testify regarding the state’s failure to act effectively to 
remedy the increasing racial and economic isolation of the 
Hartford schools; the limited scope of the state’s past and 
current efforts to promote integration; and the inadequacy of 
purely voluntary measures to effectuate desegregation. The 
documents upon which Mr. Allison is expected to rely include 
those documents listed in Plaintiffs’ Amended Responses to 
Defendants’ Pirst Set of Interrogatories (February 19, 1991), 45 
as well as more recent documents relating to interdistrict school 
plans and desegregation proposals. Mr. Allison is also expected 
to participate in testimony regarding a proposed remedy in this 
case at the appropriate stage in the proceedings. 

  

Hernan LaFontaine, 181 N. Beacon St., Hartford, CT 06105. Mr. 
LaFontaine is expected to testify in detail regarding the matters 
set out in his affidavit dated September 19, 1991, attached as 
Exhibit B to Plaintiffs’ Memorandum in Opposition to Defendants’ 
Motion for Summary Judgment (September 20, 1991). In general, 
Mr. LaFontaine is expected to testify, based in part on his own 
observations as former Hartford superintendent, regarding the 
detrimental effects of racial and economic isolation of students 
in the Hartford Public Schools, the inadequacy of current state 
funding to address the special needs of the Hartford schools, and 
the need for greater racial and economic integration in the 
Hartford schools. Mr. LaFontaine may also participate in 
testimony regarding a proposed remedy in this case at the 
appropriate stage in the proceedings. 

  

In addition to the areas of testimony set out above, 

plaintiffs’ experts are also expected to interpret and comment on 

  
 



  

the testimony and research of other experts, including both 

plaintiffs’ and defendants’ experts. With respect to documents 

listed herein, plaintiffs have included some of the primary 

sources upon which these experts will base their opinions, but 

have not provided a comprehensive list of all documents reviewed 

or relied on. If any other additional areas of testimony are 

identified for the foregoing experts or other documents upon 

which they primarily rely are identified, plaintiffs will 

identify such testimony and documents in a timely fashion. 

    
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 

Respectfully Submitted, 

we WL Tr 
Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 

Union Foundation 

32 Grand Street 
Bartford, 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 

  

  
 



      

- li 

Helen Hershkoff Ruben Franco 
John A. Powell Jenny Rivera 
Adam S. Cohen Puerto Rican Legal Defense 
American Civil Liberties and Education Fund 

Union Foundation 99 Hudson Street 
132 West 43rd Street New York, NY 10013 
New York, NY 10036 

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, 

Assistant Attorney General, MacKenzie Hall, 110 Sherman Street, 

> 
Hartford, CT 06105 this / day of April, 1992. 

VA - 
  

Philip D. Tegeler