Plaintiffs' Objection to Defendants' Motions for Extension of Time; Plaintiffs' Final Identification of Expert Witnesses

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

August 17, 1992 

Honorable Harry Hammer 
P.O. Box 325 
Rockville, CT 06066 

RE: Sheff v. O'Neill, CV89-0360977S 
  

Dear Judge Hammer, 

Enclosed please find copies of "Plaintiffs’ Objection to 
Defendants’ Motions for Extension of Time to Take Depositions"” 
and "Plaintiffs’ Final Identification of Expert Witnesses 
Pursuant to Practice Book §220(D)," both submitted today. 

We look forward to seeing you at the status conference 
scheduled for August 26 at 9:30 a.m. 

Sincerely, 

WW zs 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosures 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 

SF 3405 

 



      

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Cv89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

vv. JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

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

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Defendants AUGUST 17, 1992 

  

PLAINTIFFS’ OBJECTION TO DEFENDANTS’ MOTIONS FOR 
EXTENSION OF TIME TO TAKE DEPOSITIONS 
  

  

Plaintiffs object to defendants’ recent motions dated July 28 and 

August 10, 1992, which seek to significantly alter the Court’s 

Pretrial Order by extending the time to take depositions from 

September 15 to November 15. Plaintiffs object for the following 

reasons: 

1. Plaintiffs’ first and primary concern is that the trial in 

this action not be delayed. While plaintiffs do not object, per se, 

to the scheduling of 2-3 additional weeks of depositions, they are 

concerned that defendants may use any extension of time as a basis to 

seek a delay in the start of trial. This action was filed more than 

three years ago. The harms alleged in the complaint have not abated, 

and if anything are becoming more urgent. Plaintiffs submit that it 

is now time for trial to be scheduled, pursuant to paragtapl 14 of the 

Pretrial Order. The parties are fondy to prepare a final pretrial 

memorandum and list of exhibits, as set out in the Pretrial Order. 

While this process takes place, and in the final weeks before trial, 

  

 



  

defendants may conclude the depositions of various teachers and school 

administrators identified by plaintiffs. However, there is no reason 

to delay the scheduling and commencement of trial in this action. 

2. Second, the amount of additional time requested by defendants 

is clearly excessive. The parties should be able to conclude the 

remaining depositions by the end of the first week in October. There 

are many free days available, and there is no reason that multiple 

depositions cannot be scheduled on the same day, as the case gets 

closer to trial. This court should note that defendants have four 

assistant attorney generals with appearances in this case, as well as 

a full time educational consultant, and the resources of the entire 

State Department of Education at their disposal. 

3. Third, plaintiffs’ recently submitted proposed amendment to 

the complaint, which has not been opposed by the defendants, should, 

if accepted by the Court, eliminate the need for depositions of 

plaintiffs’ previously listed housing experts Rabin and Price, whose 

testimony has now been removed from plaintiffs’ expert list!, and 

could also, plaintiffs hope, lead to the removal of defendants’ 

corresponding housing experts from this case. 

For all of the foregoing reasons, plaintiffs urge the Court not 

to grant any modifications of the Pretrial order without at the same 

  

1 Yale Rabin is still listed as an expert, but for the 
purpose of presenting demographic and aggregate school construction 
lata to the Court.       
 



  

time scheduling a firm trial date. Plaintiffs also object to the 

excessive amount of additional time requested by defendants, but are 

not opposed to the scheduling of an additional two to three weeks of 

depositions, for both sides, in the context of a final scheduled trial 

    

date. 

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 

Adam S. Cohen 
Helen Hershkoff 
John A. Powell 
American Civil Liberties 

Union Foundation 

132 West 43rd Street 
New York, NY 10036 

BY: 

Respectfully Submitted, 

HL Tac 
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 
Hartford, CT 06105 

Ruben Franco 

Ken Kimerling 
Sandra Del Valle 
Puerto Rican Legal Defnese 

and Educational Fund 
99 Hudson Street 
New York, NY 10013 

  

 



      

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 

+H 
Street, Hartford, CT 06105 this /7 day of August, 1992. 

Wp Ta 
  

Philip D. Tegeler       

 



      

Cv89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

Ve JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

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

Defendants AUGUST 17, 1992 

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

  

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

Order entered by the Court on April 10, 1992, the plaintiffs herein 

disclose their final list of expert witnesses anticipated to testify 

at trial, in response to Defendants’ First Set of Interrogatories. 

Plaintiffs have not included in this list any potential rebuttal 

witnesses. Also, plaintiffs have not listed any present or former 

state employees, appointees, or any defendants’ experts, who may be 

called upon to present expert testimony as adverse witnesses. 

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): 

Dr. Jomills Henry Braddock, 314 Center for .@ Social 
Organization of Schools, Johns Hopkins University, 3505 
North Charles Street, Baltimore, Maryland, 21218. Dy. 
Braddock is expected to testify to (1) the adverse 
educational and long-term effects of racial, ethnic, and 
economic segregation; (2) the adverse effects of racial, 
ethnic, and economic segregation on the educational process 
within schools. Specifically, Dr. Braddock is expected to 
testify that school segregation tends to perpetuate 
segregation in adult life, that school desegregation helps 
to transcend systemic reinforcement of inequality of 
opportunity, and that segregation affects the educational 
process within schools. In his testimony, the materials on 
which Dr. Braddock is expected to rely include his 
published works, as well as research currently being 
conducted on the educational and long-term effects of 
racial, ethnic, and economic segregation by Dr. Marvin P. 
Dawkins and Dr. William Trent. (See description below and 
in January 15, 1991 Identification of Expert Witnesses.) 
Dr. Braddock is expected to base his testimony on (1) 
Braddock, "The Perpetuation of Segregation Across Levels of 
Education: A Behavioral Assessment of the Contact- 
Hypothesis," 53 Sociology of Education 178-186 (1980); (2) 
Braddock, Crain, McPartland, "A Long-Term View of School 
Desegregation: Some Recent Studies of Graduates as 
Adults." Phi Delta Kappan 259-264 (1984); (3) Braddock, 
"Segregated High School Experiences and Black Students’ 
College and Major Field Choices," Paper Presented at the 
National Conference on School Desegregation, University of 
Chicago (1987); (4) Braddock, McPartland, "How Minorities 
Continue to be Excluded from Equal Employment 
Opportunities: Research on Labor Market and Institutional | 
Barriers," 43 Journal of Social Issues 5-39 (1987); and (5) | 
Braddock, McPartland, "Social-Psychological Processes that | 
Perpetuate Racial Segregation: The Relationship Between | 
School and Employment Desegregation," 19 Journal of Black | 

Studies 267-289 (1989). | 

  

    
  

  

  
  

  

Christopher Collier, Connecticut State Historian, 876 
  

Orange Center Road, Orange, Connecticut, 06477. Professor 
Collier is expected to testify regarding (1) the historical 
and constitutional lack of autonomy of Connecticut towns 
and school districts and the history of state control over     
 



      

local education; (2) the historical development of the 
system of local school districts; (3) the existence and 
prevalence of school districts and student attendance 
patterns crossing town lines; (4) the origins and 
historical interpretation of the equal protection and 
education clauses of the 1965 Constitution. Professor 
Collier’s testimony may also address certain issues set out 
in responses l(a-e) in Plaintiffs’ Amended Responses to 
Defendants’ First Set of Interrogatories (February 19, 
1991), and other matters discussed in his deposition taken 
on. June 23, 1992. In his testimony, the materials upon 
which Professor Collier may rely will include numerous 
historical sources, including primarily but not limited to 
Helen Martin Walker, Development of State Support and 
Control of Fducation in Connecticut (State Board of 
Education, Connecticut Bulletin #4, Series 1925-16); Keith 
W. Atkinson, The Legal Pattern of Public Education in 
Connecticut (Unpublished Doctoral Dissertation, University 
of Connecticut, 1950); Annual Reports of the Superintendent 
of the Common Schools, 1838-1955; Jodziewicz, Dual Localism 
in 17th Century Connecticut, Relations Between the General 
Court and the Towns, (Unpublished Doctoral Dissertation, 
William & Mary, 1974); Bruce C. Daniels, The Connecticut 
Town : Growth and Development, 1635-1790, Middletown 
Connecticut, Wesleyan University; Trumbull, Public Records 
of the Colony of Connecticut; Public Records of the State 
of Connecticut; Proceedings of the Constitutional 
Convention of 1965; the map collection at Sterling Memorial 
Library, including Beers’ Atlas of Connecticut (1868); 
Annual Reports of various local boards of education, and 
other documents referenced in Professor Collier’s deposi- 
tion. 

  

  

  

  

  

    

  

  

  

  

  

  

  
  

  

  

  

Dr. Robert L. Crain, Professor of Sociology and Education, 
Teachers College, Columbia University, 525 West 120th 
Street, Box 211, New York, New York, 10027. Dr. Crain is 
expected to testify to the adverse educational and long- 
term effects of racial, ethnic, and economic segregation in 
the Hartford metropolitan area. Specifically, Dr. Crain is 
expected to testify that the effects of Project Concern 
participation for students in the Hartford metropolitan 
area have been to reduce the likelihood of (1) dropping out 
of high school, (2) early teenage pregnancy, and (3) 
unfavorable interactions with the police. Dr. Crain is 
expected to testify, further, that the effects of Project 
Concern participation for students in the Hartford 
metropolitan area have been to increase (1) college 
retention, (2) the probability of working in private sector 

  

  

  
  

 



      

professional and managerial jobs, (3) the probability of 
interracial contact, and (4) favorable attitudes toward 
whites. In his testimony, Dr. Crain is expected to base 
his testimony on his published works and his analyses of 
Project Concern. Specifically, Dr. Crain is expected to 
rely on (1) Crain, Strauss, "School Desegregation and Black 
Occupational Attainments: Results from a Long-Term 
Experiment," Center for Social Organization of Schools, 
Report No. 359 (1985); (2) Crain, Hawes, Miller, and 
Peichert, "Finding Niches: Desegregated Students Sixteen 
Years Later," Unpublished Manuscript, Institute for Urban 
and Minority Education, Teachers College (revised 1990); 
and (3) Gable, Thompson, Iwanicki, "The Effects of 
Voluntary Desegregation on Occupational Outcomes," The 
Vocational Guidance Quarterly 230-239 (1983) and other 
reports. 
  

Dr. Mary Kennedy, Director, National Center for Research on 
Teacher Evaluation, Michigan State University, 513 Ardson 
Road, East Lansing, Michigan, 48823. Dr. Kennedy will 
testify about the relationship of family poverty and high 
concentrations of poverty to educational outcomes. 
Specifically, Dr. Kennedy will testify that two of the most 
important measures of poverty which have a strong relation- 
ship to educational outcomes are intensity of family 
poverty (measured by number of years of sustained poverty 
of the child and his family), and attendance at a school 
with a high concentration of poor «children. Her 
conclusions show that: (1) Students are increasingly likely 
to fall behind grade levels as their families experience 
longer spells of poverty; (2) Achievement scores of all 
students -~ not just poor students - decline as the 
proportion of poor students in a school increases; (3) The 
relationship between school poverty concentration and 
school achievement averages is even stronger than the 
relationship between family poverty status and student 
achievement. In fact, non-poor students who attend schools 
with a high concentration of poor students are more likely 
to fall behind than are poor students who attend a school 
with a small proportion of poor students; and (4) Increases 
in the proportion of poor children in a school are 
associated with decreases in average starting achievement 
and even occasionally with decreases in learning rates over 
time. Dr. Kennedy's opinions are based on her research and 
that of others as contained in reports, including, but not 
limited to Rennedy, M.M., Jung, R.K., and Orland, M.E. 
(1986), Poverty, Achievement and the Distribution of 

  

  

  

  

 



      

Compensatory Education Services, U.S. Department of Education, 
19865. 
  

Dr. William Trent, EPS, 368 Education Building, University 
of Illinois, 1310 South Sixth Street, Champagne, Illinois, 
61820. Dr. Trent is expected to testify to the adverse 
educational and long-term effects of racial, ethnic, and 
economic segregation on Latinos, African Americans, and 
white Americans. Specifically Dr. Trent is expected to 
testify that economic school segregation has adverse long- 
term outcomes for Latinos, African Americans, and white 
Americans, that desegregation has beneficial results on the 
aspirations and expectations of Latino students and on 
their likelihood of working in interracial environments, 
and that white Americans who have experienced desegregated 
schools are more likely to work with and to have positive 
attitudes toward African American co-workers. Dr. Trent is 
expected to base his testimony on his published work and 
his analysis of data from (1) the National Longitudinal 
Survey of Labor Force Behavior -- Youth Cohort, an annual 
survey sponsored by the United States Departments of Labor 
and Defense of 12,686 young persons throughout the United 
States, with data available for 1979-1987; (2) the High 
School and. Beyond Study, a national longitudinal 
probability sample of more than 58,000 1980 high school 
sophomores and seniors, conducted in 1980, 1982, 1984, and 
19867 and (3) the National Longitudinal A Survey of 
Employers, a national probability sample of 4,087 
employers, conducted in the 1970's. 

  

Charles V. Willie, Ph.D., Harvard University, Graduate School of 
Education, Monroe C. Gutman Library, Cambridge, MA 02138. Dr. 
Willie is expected to testify regarding the effects of 
segregated education on white and black children; the lack of 
equal educational opportunity in Hartford area schools; the 
educational benefits of diversity and racial integration; the 
need to restructure educational attendance patterns and/or 
districts to eliminate racial isolation and to enhance the 
quality of education, especially for nonwhite school children 
concentrated in racially and economically impacted areas; and 
the general options available to promote integration and racial 
equity. Dr. Willie is also expected to participate in testimony 
regarding a proposed remedy at the appropriate stage in the 
proceedings. 

  

Dr. Catherine E. Walsh, University of Massachusetts, 250 Stuart 
  

Street, Boston, MA 02116. Dr. Walsh is expected to testify at 

  

  

  

  
 



  

the appropriate stage of the proceedings, regarding a proposed 
remedy in this case. Such testimony may address the structure, 
instructional orientation, content and physical location of 
bilingual education; school-based management; curriculum 

restructuring; educational grouping of Latino students to 
promote integration while providing for the students’ needs; the 
relationship between language and literacy development and 
academic achievement for Latino students; and other remedial 
issues. Dr. Walsh’s testimony will be based upon her review of 
the available surveys and theoretical works regarding the 
functioning of bilingual programs and segregated and 
desegregated school systems, and on her own experience and her 
investigations into the functioning of the schools, school 
systems and bilingual programs of the Greater Hartford Area and 
other places, and on the results of investigations made by other 
expert witnesses in this case. 

Yale Rabin, 9 Farrar Street, Cambridge, MA 02138. Mr. 
Rabin will describe patterns of population growth by race 
and ethnicity and poverty status in the Hartford region in 
comparison with rates of growth of new school capacity in 
Hartford and the surrounding communities, 1954 to the 
present.! 

  

John Allison, Capitol Region Education Council, 3599 
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; the inadequacy of purely voluntary 

  

  

    ! This final identification of expert witnesses is based on 
plaintiffs’ Proposed Amendment to Complaint, dated July 21, 1992, and 
anticipates that plaintiffs’ Proposed Amendment will be granted. iE 
plaintiffs’ Proposed Amendment to the Complaint is not granted, 
plaintiffs’ Final Identification of Expert Witnesses should also 
include descriptions of the testimony of Ruth Price and Yale Rabin, 
as set out in Plaintiffs’ Second Identification of Expert Witnesses 
dated March 18, 1991; Professor Terry Tondro, University of 
Connecticut School of Law, who would testify as to the state’s role 
in exclusionary zoning and local land use regulation; and other 
witnesses. 

  
 



      

measures to effectuate desegregation; and the other issues 
discussed in his deposition. The documents upon which Mr. 
Allison is expected to rely include those documents listed 
in Plaintiffs’ Amended Responses to Defendants’ First Set 
of Interrogatories (February 19, 1991), #5 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 is also expected to testify regarding the extent 
and effects of racial and economic isolation on Latino 
students; the special needs of Spanish-dominant students 
and families; and the role of bilingual education. Mr. 
LaFontaine may also participate in testimony regarding a 
proposed remedy in this case at the appropriate stage in 
the proceedings. 

William M. Gordon, 148 Greenmount Boulevard, Dayton, OH 
45419. Dr. Gordon is expected to testify regarding the 
options for school desegregation presented to the state but 
not acted upon, 1954 to the present, and the historical 
context of those decisions, including the state’s awareness 
of increasing levels of school segregation in the Hartford 
region. Dr. Gordon may also testify, at the appropriate 
time, regarding options available to address the system of 
segregated education in the Hartford region. Dr. Gordon 
will rely, in part, on the documents listed in response to 
defendants’ interrogatory 5, in Plaintiffs’ Amended 
Responses to Defendants’ First Set of Interrogatories. 

  

Dr. Gary Natriello, Professor of Sociology and Education, 
  

Teachers College, Columbia University, 525 West 120th St., 
Box 211, New York, NY 10027. Dr. Natriello is expected to 
testify regarding (1) demographic and social conditions in 

  
 



      

the Hartford community in relation to educational 
challenges faced by Hartford schools and students; (2) 
educational resources and programs currently available in 
the Hartford district to meet the educational needs of 
Hartford students; (3) comparison between resources and 
programs available in Hartford and in the surrounding 
districts; (4) examination of levels of educational 
achievement and attainment in Hartford and the surrounding 
districts; and (5) assessment of Hartford and the 
surrounding districts in relation to state educational 
standards and mandates, including the Connecticut Mastery 
Test. Specifically, Dr. Natriello is expected to testify 
that (1) the concentration of poor children and children 
who are otherwise educationally disadvantaged poses extreme 
challenges to performance of students and schools in the 
Hartford district; (2) the available resources and programs 
in the Hartford schools are not sufficient to meet the 
educational needs of Hartford students; (3) a significant 
disparity in educational programs and resources exists 
among Hartford and the surrounding districts, which is 
enhanced by the special demands placed on educational 
resources in the Hartford districts and by the level of 
student need that exists in the Hartford district; (4) 
there are significant disparities in achievement and 
attainment among students in Hartford and the surrounding 
communities; and (5) these disparities are inconsistent 
with state educational standards and mandates. Dr. 
Natriello is expected to base his testimony on his review 
of documents provided to plaintiffs in discovery; public 
documents obtained from Hartford, the Hartford public 
schools, and other local towns and school districts; and 
his own research on the education of disadvantaged students 
in urban settings. 

Mary Carroll, director, Project Concern, 128 Westland, 
Hartford, CT. Ms. Carroll will testify about the history 
of the Project Concern program, the levels of school 
district participation, state and local funding sources, 
and the level of student and parent participation. She 
will further testify about the space needs of the program, 
transportation issues, composition and selection issues, 
and criteria for exclusion of students from the program. 
In addition, she is expected to testify about the extent of 
staffing, parent involvement, and in-service training. In 
her testimony, Ms. Carroll may rely on the following 
documents: budget documents outlining levels of funding for 
the program, including grant applications; Mahan, Thomas, 
Project Concern 1966-68: A Report on the Effectiveness of 

  

  

  
  

  

  
 



      

Suburban School Placement for Inner-City Youth (1968), 
documents furnished by Defendants to Plaintiffs’ First 
Request for Production, nos. 12 and 13 and Plaintiffs’ 
Second Request for Production, no. 3. 

  

School Principals. Plaintiffs expect to call several 
Hartford school principals at trial to give both expert 
testimony and fact testimony based on their experience and 
observations in the schools. Expert testimony is 
anticipated to include opinions and observations regarding 
the impact of racial, ethnic and economic isolation of 
students in the Hartford public schools; the educational 
and social needs of elementary and secondary students 
attending Hartford public schools; the effects of student 
turnover; the effects of lack of educational resources on 
instruction; and the institutional and educational impacts 
of a student body that includes a high percentage of poor 
and educationally disadvantaged children. Principals 
identified as expert witnesses include Donald Carso, 
principal, McDonough School, 100 Wilson Street, Hartford, 
CT; Eddie Davis, principal, Weaver High School, 415 Granby, 
Hartford, CT; Richard Montanez; principal, Hooker School, 
200 Sherbrooke Avenue, Hartford, CT; and Edna Negron, 
principal, Betances School, 42 Charter Oak Avenue, 
Hartford, CT; Freddie Morris, principal, Wish School, 350 
Barbour Street, Hartford, CT. 

  

  

  

  

  

  

Experts not Previously Disclosed 
  

Robert Slavin, Johns Hopkins University, Baltimore, MD; 
Director of the Early and Elementary School Program at the 
Center for . Research on Effective Schooling for 
Disadvantaged Students at Johns Hopkins University. Dx. 
Slavin may be called to testify about effective educational 
programs for public school children, and about educational 
programs that could be implemented in the Hartford-area 
public schools to facilitate student achievement. If 
called as a witness, Dr. Slavin will base his opinions on 
his own research and his review of literature on successful 
educational programs for children. Among the books and 
articles that Dr. Slavin has authored or co-authored are: 
Effective Programs for Students at Risk (Allyn & Bacon, 
1989); and Preventing Early School Failure (Allyn & Bacon, 
forthcoming.) 

  

  

  

Julio Morales, Professor and Dean, University of 
  

Connecticut School of Social Work. Professor Morales is 
expected to testify in regard to drop out rates and drop 

  

  

  

  
 



  

out studies conducted by him (Dropout Prevention Program 
Final Evaluation Report, 1988-1990). 

Hartford Public Schools Administrators: Plaintiffs expect 
to call administrators of the Hartford Public Schools to 
discuss the effects of racial segregation and high poverty | 
concentration on Hartford students, teachers, and schools. 
These witnesses will also address the needs of Hartford | 
students and inequities in educational resources and 
educational outcomes. Administrators who may be called at 
trial include Josiha Haig, Superintendent, Hartford Public 
Schools; Catherine Kennelly, Director of Financial 
Management; Alice Dickens, Assistant Superintendent for 
Support Programs and Services; Robert Nearine, Special 
Assistant for Evaluation, Research and Testing; John 
Hubert, researcher and evaluator; Antres Buford, former 
coordinator, Dropout Prevention Program; Charles Senteio, 
Deputy Superintendent; John Shea, Assistant Superintendent 
for School Sites; Jeffrey Forman, Special Assistant to the | 
Superintendent for Planning and Development; Adnelly | 
Marichal, Coordinator, Bilingual Department. 

    
  

  

      

  

  

  

  

  

Plaintiffs may also seek to add an additional expert witness to 

this list in the near future, who could not be contacted at the time 

this list was due. 

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. 

      
 



      

BY: 

Wesley W. Horton 
Moller, Horton, & Rice 
90 Gillett Street 

Hartford, C7 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. 

Adam S. 

Powell 

Cohen 

American Civil Liberties 
Union Foundation 

132 West 43rd Street 

New York, NY 10036 

Respectfully Submitted, 

Wy Sse 
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 
Hartford, CT 06105 

Ruben Franco 
Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
New York, NY 10013 

  

 



      

il 

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 

bg 4 
Street, Hartford, CT 06105 this [7 day of August, 1992. 

Hp a 
  

Philip D. Tegeler 

  

  
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