Correspondence from Tegeler to Whelan; Deposition Subpoenas of Levin and Ferrandino; Correspondence from Stone to Whelan

    FOUNDATION 
Thirty Two Grand Street. Hartford. CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX September 18, 1992 

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

RE: Sheff v. O'Neill 
  

Dear John, 

Pursuant £8 paragraph 4 of the Final Pretrial Order of 

September 2, 1992, we are giving notice as to the documents 

requested for the deposition of Michael Levin scheduled for October 

2, 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. Levin’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 

aFw5 

 



  

SUBPOENA DUCES TECUM 
  

TO: Michael B. Levin 

Vice President and Research Director 

Connecticut Policy and Economic Council, Inc. 

21 Lewls Street 

Hartford, CT 06103 

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 10:00 a.m. on the 2nd of October, 

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 89-036C977S. 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. Any studies, reports, tables, charts, or other trial 

exhibits you have prepared in this case. 

2. Copies of any research, papers, or articles you have 

prepared that discuss the state's fiscal treatment of 

Connecticut cities and towns, or fiscal treatment or 

condition of the city of Hartford and its school system. 

3. A copy of Municipal Expenditures in Connecticut, 1980-90 

(March 1992). 
  

4. A copy of the most recent annual report entitled Connecticut 

Municipal Budgets. 
  

  

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

a2! 
Dated at Hartford, Connecticut this 13 day of September, 1992. 

HY Sz 
  

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, MacKenzie Hall, 110 Sherman Street, 

Hartford, CT 06105 this [g7” day of September, 1992. 

wy Sz 
  

Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs 

 



    

FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX September 17, 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 Dr. Vincent L. Ferrandino scheduled for October 1, 
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. 

Thank you for your cooperation. 

Sincerely, 

May he Stowe 
Martha Stone 
Attorney for Plaintiffs 

MS/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 
> 5 

 



  

SUBPOENA DUCES TECUM 
  

TO: Dr. Vincent L. Ferrandino, Commissioner 
Connecticut Department of Education 
165 Capitol Avenue 
Hartford, 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 2:00 p.m. on the lst of October, 
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. O0O’Neill, No. CV 89-0360977S. 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. A copy of the 1991-95 "Comprehensive Plan for Elementary, 
Secondary, Vocational, Career, and Adult Education." 

3. A copy of January 7, 1989 State Board resolution adopting 
the Common Core of Learning. 

4. A complete set of Strategic School Profiles for each 
district and each school in Hartford and the surrounding 
communities and the computer tape containing such 
information. 

5. A copy of reduction options for 1993-94 and 1994-95. 

6. A copy of any correspondence between or among the Department 
of Education, the State Board of Education, or any state 
agencies, consultants, or officials, relating to integration 
and desegregation proposals which have been reviewed by you. 

7. Reports and plans issued by Office of Urban Agenda including 
staffing and list of planned activities. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, Connecticut this i 7 day of September, 1992. 

Man rhe dha 
  

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, MacKenzie Hall, 110 Sherman Street, 
Hartford, CT 06105 this /)] day of September, 1992. 

Martha Store 
Ea 
  

Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs