Pretrial Order

    ® 3:5] 26: 91 dul 

CCLU 
FOUNDATION 
Thirty Two Grand Street, Hartford, CT 06106 

203/247-9323 fax 203/728-0287 

as 

March 13, 1992 

Honorable Harry Hammer 

P.O. Box 325 
Rockville, CT 06066 

Re: Sheff v. O'Neill; Pretrial Order 
  

Dear Judge Hammer, 

Enclosed is the criginal of the Pretrial Order agreed to by 

the parties in this case, pursuant =o the discussion held at the 

status Conference last Friday. Attorney whelan has reviewed the 

enclosed Order and has no ob4ection to it being entered. 

We look forward to meeting with you again soon. 

Respectfully Submitted, 

V4 VARIN 27 4 

Philip D. Tegeler 
Martha Stone 

Attorneys for Plaintiffs 

cee: All Counsel 

 



      

*IbHA ® | 35:51 Z5. 91 

Cvg9-0360Q0977S 

  

MILO SHEFF, et al. 

Plaintiffs 2 SUPERIOR COURT 

V., : JUDICIAL DISTRICT OF 

: HARTFORD/NEW BRITAIN 

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

Defendants : MARCH 13, 1992 

  

PRETRIAL ORDER 

I. DISCOVERY 

The parties may continue to pursue discovery, with final 

discovery deadlines as set out herein: 

1. All further Interrcgatories and Requests for Production 

shall be served no later than July 13, 1982. 

2, All Requests for Admission shall be served and filed 

with the court no later than July 15, 1932. The Court may 

determine the appropriate scope of such requests. 

3. All Interrogatories, Requests for Production, and 

Requests for Admissior shall be responded to within a schedule to 

be agreed upon by the parties or by order of the Court if the 

parties cannot agree. 

4. Depositions may be conducted between April 15, 1982 and 

September 15, 1992. Such depositions may include reasonable 

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document requests releting to the subject matter of deponent's 

testimony, as long as two weeks notice is given to the deponent. 

Any depositions sought to be taken after September 15, 1992, must 

be permitted by order of the Court, or by stipulation, for goed 

cause shown. Good cause may include identification of witnesses 

after or near the deadline for taking of depositions. Plaintiffs 

shall also be permitted to conduct depositions up until September 

30, 1992 for any new expert witnesses identified pursuant to 910 

below. 

5. Depositions of any expert witness identified by either 

party shall be permitted pursuant to Practice Bock §220(A) (4). 

The terms and conditions under which these depositions will be 

taken ghall Te established by agreement of the parties, or by 

order of the Court if the parties cannoli agree. 

6. Depositions may be tape-recorded Or videotaped pursuant 

to a stipulation by the parties and upon approval by the Court, 

provided that nothing herein shall be construed to relieve the 

party taking the deposition from ary obligation they may have to 

produce a transcription of the deposition if that party expects 

to use that deposition or any part thereof at trial. The parties 

may agree to a transcription of less than the full deposition. 

7. All motions for orders compelling disccvery shall be 

filed no later than Saptember 1, 1992. Responses to gaid motions 

shall be filed within twenty-one days of receipt oi said motions. 

  
        

 



2@0 30H, 
304d ae 26. 91 Hu 

  

II. LIST OF WITNESEES 

8. The parties shall continue their practice, approved by 

the court, of mutual notification every 60 days of experts 

anticipated to testify at trial, along with a statement of the 

subject matter on which the expert is expected to testify, the 

substance of the facts and opinions tO which the expert is 

expected to testify, and a summary of the grounds for each 

opinion. Such continuing notification is scheduled for March 15, 

May 15, and July 15, 1332. 

9, The plaintiffs shall s=subnit a final list of expert 

witnesses on August 15, 19392, such list shall include each 

expert's name, title, and address, and shall state the subject 

matter on which the expert ls expected tO testify, the substance   
of the facte and opinions to which the expert is expected to 

testify, and a summary of tre grouncie for each opinion. 

10. The defendants shall submit a final list of expert 

witnesses on September 15, 1892. Such list ghall include each 

expert's name, title, and address, and shall state the subject 

matter on which the expert is expected to testify, the substance 

of the facts and op.nions to which the expert is expected to 

testify, and a summary cf the grounds for each opinion. 

11, The parties shall exchange a preliminary list of non- 

expert witnesses on August 1, 1992. Such list shall include each 

witness's name and acdress, and a brief statement of the subject         
 



      

BE" 35dd . # Bg:51l 26: 9l 

matter of each witness's anticipated testimony. The parties 

shall exchange a final list of non-expert witnesses on September 

2/:19%2. 

12. The parties shall each file and serve a pretrial 

memorandum, thirty day: prior te the commencement of trial, which 

shall include but not de limited to a list of stipulations on any 

jssues of fact and/or law as to which the parties have been able 

to agree and proposed findings of fact and conclusions of law. 

13. The parties shall each file and serve a final list of 

exhibits, thirty days prior to the commencement of trial, and the 

exhibits shall be made available to the other party fox 

inspection and copying. Unless within five business days, an 

objection on grounds of authenticity to the admissibility of any 

exhibit ig filed with a brief and citation of authority in 

support of the specif: c ground of objection, such exhibit may be 

admitted without further proof of authenticity. The right to 

object on all other grounds is reserved until the time of trial. 

The parties will make good faith efforts to stipulate to the 

admissibility of exhibits. All exhibits shall be premarked. 

Only exhibits listed pursuant to this Order will be offered at 

trial, except for gooc cause shown. 

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III. TRIAL 

14. 

of this 

congiderat 

IV. EXTEN 

15. 

applicatio 

Dated this 

The precise cate and location for commencement of trial 

casa shall be set by the Court after further 

ion. 

SION OF TIME 

Time deadlines se- by this Order may be extended upon 

n to the Court for good cause shown. 

  

HONORABLE HARRY HAMMER 

SUPERIOR COURT JUDGE 

day of March, 1992.