Defendants' Disclosure of Expert Witnesses

    NO. Cv-89-0360977 S 

SUPERIOR COURT MILO SHEFF, ET AL. 

Plaintiffs 

JUDICIAL DISTRICT OF 
HARTFORD/NEW BRITAIN 
AT HARTFORD 

V. 

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WILLIAM A. O'NEILL, ET AL. JANUARY 15, 1992 

Defendants 

DEFENDANTS ' DISCLOSURE OF EXPERT WITNESSES 
  

Pursuant to the order of the court establishing a schedule 

for disclosure of expert witnesses, employees and consultants 

expected to present testimony at trial, whie defendants offer the 

following amended list and disclosure. The defendants wish to 

emphasize that the particular facts and opinions which will be 

offered by the witnesses listed below are not the only facts and 

opinions which the witnesses may offer at trial. The defendants 

expect to supplement their disclosure after the plaintiffs have 

fully and finally answered the defendants' first set of 

interrogatories and requests for production and the defendants 

have had an opportunity to consider and prepare whatever response 

may be appropriate to claims made by the plaintiffs in response 

to that discovery. Defendants also expect to supplement this 

  
 



    

list with additional names and additional information as work now 

in progress and work to be undertaken after the plaintiffs fully 

and finally answer the defendants' interrogatories and requests 

for production is completed. 

1. Christine Rossell, Ph.D. (Expert Witness) Boston 
  

University, 232 Bay State Road, Boston, Massachusetts 02215: 

Dr. Rossell is a Professor of Political Science at Boston 

University. 

Professor Rossell is expected to testify that the State of 

Connecticut is responding appropriately to the educational 

conditions in the Hartford area by encouraging voluntary 

integration and compensating poor school districts for their 

poverty. 

Professor Rossell will base her testimony on her scholarly 

research of the following at least: 

1. the evolution of school desegregation; 

2. national school desegregation trends; 

3. measuring the effectiveness of school desegregation; 

4. the relative merit of voluntary and mandatory school 

desegregation plans;    



      

5. white flight as a function of desegregation; 

6. the effectiveness of specific approaches to 

desegregation; i.e., freedom of choice, majority-to-minority 

transfer, controlled choice, magnet schools, etc.; 

7. metropolitan-based desegregation plans; 

8. State of Connecticut policies and programs to encourage 

voluntary desegregation and to aid poor districts through 

compensatory funding, general and categorical. 

Among other things, Dr. Rossell will rely on her work 

entitled The Carrot or the Stick for School Desegregation Policy, 
  

Temple University Press, 1990. Dr. Rossell's resume has been 

provided to plaintiffs as Exhibit 19(a) of defendants' response 

to plaintiffs' fourth request for production. 

2. David Armor, Ph.D. (Expert Witness) 5006 Klingle Street, 
  

N.W., Washington, D.C. 20011: 

Dr. Armor is currently Visiting Professor, Rutgers 

University; Consultant, American Institutes for Research; and 

President, National Policy Analysts. 

Dr. Armor is principal investigator for a grant to write a 

treatise on race, education and the courts; coprincipal 

  
 



      

investigator on a national study of magnet schools; and an 

associate investigator on a project that is conducting case 

studies of school districts with school choice policies. 

While Dr. Armor may testify on more than one topic, at this 

time he is expected to testify that research has demonstrated "no 

significant and consistent effects of desegregation on Black 

achievement. " Dr. Armor may also offer opinions regarding 

reasons for the differences in performance on the CMT between 

Hartford and suburban children; however, his work in this area is 

not yet complete. 

Dr. Armor will base his testimony on his own original 

studies as well as his scholarly analysis of the research 

concerning the effects of desegregation on Black student 

achievement. Dr. Armor's resume has been provided to the 

plaintiffs as Exhibit 19(b) to defendants’ response to 

plaintiffs’ fourth request for production. 

3. Dr. G. Donald Ferree (Expert Witness) Institute for 
  

Social Inquiry, Roper Center for Public Opinion, P. O. Box 440, 

Storrs, Connecticut 06268: 

  
 



      

Dr. Ferree is the Associate Director of the Institute for 

Social Inquiry, University of Connecticut. Dr. Ferree's resume 

will be provided as Exhibit 19(d) to defendants' response to 

plaintiffs' fourth request for production as soon as it is 

available. 

Dr. Ferree is expected to testify regarding proper methods 

and procedures for conducting a public opinion poll to ascertain 

the attitudes of Connecticut residents and/or groups of 

Connecticut residents. He is expected to present and explain the 

results of a survey conducted by Institute for Social Inquiry at 

the request of the Governor's Commission on Quality and 

Integrated Education. The results to that survey are summarized 

in the attachment to Exhibit 6 in support of the defendants’ 

motion for summary judgment. 

4. Dr. Pasquale Forgione (former DOE Consultant) c/o State 
  

Department of Education, 165 Capitol Avenue, Hartford, 

Connecticut 06106: 

Dr. Forgione is not expected to offer opinion testimony as 

an expert witness. Instead he will provide testimony regarding 

the development, implementation and analysis of the CMT and CMT 

results. The specific analysis of CMT results which will be 

  
 



      

described by this witness have been provided to the plaintiffs in 

Exhibit 16(f) of defendants' response to plaintiffs' first 

request for production, Exhibit 18(d) of defendants' response to 

plaintiffs' second request for production, and Exhibit 10(c) of 

defendants' response to plaintiffs' third request for production. 

5 Dr. Douglas Rindone (DOE Consultant) c/o State 
  

Department of Education, 165 Capitol Avenue, Hartford, 

Connecticut 06106: 

Dr. Rindone is not expected to offer opinion testimony as an 

expert witness. Instead he may provide testimony regarding the 

development, implementation and analysis of the CMT and CMT 

results. The specific analysis of CMT results which will be 

described by this witness have been provided to the plaintiffs in 

Exhibit 16(f) of defendants' response to plaintiffs' first 

request for production, Exhibit 18(d) of defendants' response to 

plaintiffs' second request for production, and Exhibit 10(c) of 

defendants' response to plaintiffs' third request for production. 

6. Dr. William Congero (DOE Consultant) c/o State 
  

Department of Education, 165 Capitol Avenue, Hartford, 

Connecticut 06106: 

  
 



      

Dr. Congero is not expected to offer opinion testimony as an 

expert witness. Instead he may provide testimony regarding the 

development, implementation and analysis of the CMT and CMT 

results. The specific analysis of CMT results which will be 

described by this witness have been Bevided to the plaintiffs in 

Exhibit 16(f) of defendants’ response to plaintiffs' first 

request for production, Exhibit 18(d) of defendants’ response to 

plaintiffs' second request for production, and Exhibit 10(c) of 

defendants' response to plaintiffs’ third request for production. 

7. Dr. Peter Behuniak (DOE Consultant) c/o State Department   

of Education, 165 Capitol Avenue, Hartford, Connecticut 06106: 

Dr. Behuniak is not expected to offer opinion testimony as 

an expert witness. Instead he may provide testimony regarding 

the development, implementation and analysis of the CMT and CMT 

results. The specific analysis of CMT results which will be 

described by this witness have been provided to the plaintiffs in 

Exhibit 16(f) of defendants’ response to plaintiffs' first 

request for production, Exhibit 18(d) of defendants’ response to 

plaintiffs' second request for production, and Exhibit 10(c) of 

defendants' response to plaintiffs' third request for production. 

  
 



      

8. Dr. Elliot Williams (DOE Consultant) c/o State 
  

Department of Education, 165 Capitol Avenue, Hartford, 

Connecticut 06106: 

Dr. Williams is not expected to offer opinion testimony as 

an expert witness. Instead Dr. Williams will provide information 

regarding existing and plann ed programs promoting interdistrict 

cooperation and improving integration. Specifically Dr. Williams 

will describe and verify the accuracy of the information found in 

Exhibits 3(x-z) to the defendants' response to plaintiffs' second 

request for production. 

9. Dr. Robert Brewer (DOE Consultant) c/o State Department 
  

of Education, 165 Capitol Avenue, Hartford, Connecticut 06106: 

Dr. Brewer is not expected to offer opinion testimony as an 

expert witness. Instead Dr. Brewer will offer testimony 

regarding state grants to local school districts generally and 

the state's financial contribution to the school districts in 

what the plaintiffs have described as the Hartford area in 

particular. Dr. Brewer will attest to the accuracy of the 

information found in Exhibits 4(ee) and 7 of defendants response 

to plaintiffs' second request for production. 

  
 



      

10. Dr. Peter Prowda (DOE Consultant) c/o State Department   

of Education, 165 Capitol Avenue, Hartford, Connecticut 06106: 

Dr. Prowda is not expected to offer opinion testimony as an 

expert witness. Instead Dr. Prowda will offer testimony 

regarding the analysis of comparative rates of absenteeism 

provided to the plaintiffs as Exhibit 7(a) of the defenants’ 

response to plaintiffs' first request for production. 

11. Dr. Theodore Sergi (DOE Consultant) c/o State   

Department of Education, 165 Capitol Avenue, Hartford, 

Connecticut 06106: 

Dr. Sergi is not Fo AIA) to offer opinion testimony as an 

expert witness. Instead Dr. Sergi will offer testimony regarding 

the background, implementation and effectiveness of the state's 

priority school district grant program. Dr. Sergi's testimony 

will include an explanation of the analysis found in Exhibit 

4(ff) of defendants' response to plaintiffs’ second request for 

production. 

12. Dr. Thomas Breen (DOE Consultant) c/o State Department   

of Education, 165 Captitol Avenue, Hartford, Connecticut 06106. 

  
 



      

Dr. Breen is not expected to offer opinion testimony as an 

expert witness. Instead Dr. Breen will offer testimony regarding 

the racial and ethnic composition of schools and school districts 

throughout the state. He is also expected to focus on the racial 

and ethnic composition of the schools in Hartford and those towns 

which plaintiffs have identified as "suburban" communities for 

the purpose of this suit. Among other things Dr. Breen is 

expected to verify the accuracy of the information contained in 

Exhibits 4(a) and 18(a-x) of defendants response to plaintiffs’ 

fourth request for production. He will also verify the accuracy 

of certain other analysis of the racial and ethnic composition of 

the school in Hartford and the "suburban" communities which will 

be disclosed to the plaintiffs in the near future. 

13. Mr. Lloyd Calvert (Expert Witness) c/o Office of the 
  

Attorney General, 110 Sherman Street, Hartford, Connecticut 

06105: 

Mr. Calvert is the former Superintendent of Schools in West 

Hartford, Trumbull and Windsor and former Assistant 

Superintendent of Schools in Hartford. He is now serving as 

educational consultant to the Office of the Attorney General in 

regard to the Sheff v. O'Neill case. Mr. Calvert's resume is 
  

«10% 

  
 



      

being provided to the plaintiffs as Exhibit 19(c) to defendants’ 

response to plaintiffs' fourth request for production. 

Mr. Calvert is expected to testify regarding the racial and 

ethnic composition of the Hartford public schools and certain 

trends regarding the racial and ethnic composition of the 

Hartford public schools in comparison to the 21 school districts 

which plaintiffs have chosen to designate as suburban school 

districts. Tables and data which Mr. Calvert will rely on will 

be disclosed in response to the plaintiffs' earlier production 

requests as soon as they are in final forn. 

Mr. Calvert will also testify regarding the state's efforts 

to address the needs of disadvantaged and urban children since 

the 1920's as evidenced in records of the State Board of 

Education and his own work and experience. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

rid) 
R. Whelan - Juris 085112 

sgistant Attorney General 
110 Sherman Street 
artford, Connecticut 06105 

Tel: 566-7173 

  

      

   

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Dacre ill Ludi 
  Diane W. Whitney - Juris 
Assistant Attorney Gener 
110 Sherman Street 
Hartford, Connecticut 06105 
Tel. 566-7173 

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CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed 

this 16th day of January, 1992 to the following: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, Connecticut 06105 

Wilfred Rodriguez, Esq. 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, Connecticut 06112 

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 

32 Grand Street 
Hartford, Connecticut 06106 

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, Connecticut 06105 

Jenny Rivera, Esq. 
Ruben Franco, Esq. 

Puerto Rican Legal Defense Fund, Inc. 
99 Hudson Street 
14th Floor 

New York, New York 10013 

-13- 

  

    
 



      

Julius L. Chambers 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, New York 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, New York 10036 

  

  
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