Letter to All Counsel RE: Documents Requested for Deposition of Thomas Breen with Attached Subpoena and Certificate of Service

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX August 28, 1992 

Mr. John Whelan 
Assistant Attorney General 
110 Sherman Street 
Hartford, C7 06105 

RE: Sheff v. O'Neil) 
  

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 Thomas Breen scheduled for September 11, 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. Prowda’s anticipated testimony be provided to us prior to the 
deposition. 

Thank you for your cooperation. 

Sincerely, 

Wp Teer 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 

ols  



  

SUBPOENA DUCES TECUM 
  

TO: Thomas Breen 
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 3:00 p.m. on the 11th of September, 
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 89-0360977S. 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. Any studies, reports, tables, charts, or other trial 
exhibits you have prepared in this case, that have not 
already been provided to plaintiffs. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, Connecticut this DE ny of August, 1992. 

PL Sezz< 
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 AF day of August, 1992. 

WV LF FEzze 
  

Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs