Preliminary Disclosure of Non-Expert Witnesses

Public Court Documents
August 5, 1992

Preliminary Disclosure of Non-Expert Witnesses preview

5 pages

Includes Envelope to Chambers, Lado, and Ellis.

Cite this item

  • Case Files, Sheff v. O'Neill Hardbacks. Preliminary Disclosure of Non-Expert Witnesses, 1992. f1267019-a546-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/6309dac1-fbc9-4bdf-affe-1c95e95338e3/preliminary-disclosure-of-non-expert-witnesses. Accessed July 29, 2025.

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    CV B89-0360977S 

MILO SHEPF, et al SUPERIOR COURT 

J.D. HARTFORD/NEW BRITAIN 

Plaintiffs AT HARTFORD 

V. 

WILLIAM A. O'NEILL, et al 

Defendants : August 5,"1992 

PRELIMINARY DISCLOSURE OF NON-EXPERT WITNESSES 
  

The defendants hereby give notice to the plaintiffs that, in 

light of the plaintiffs failure to provide necessary answers to 

the defendants' interrogatories in a timely fashion and in light 

of the fact that the depositions of most of the plaintiffs’ 

witnesses have yet to be taken due to scheduling problems, the 

defendants are unable to identify particular non-expert witnesses 

the defendants may call a trial at this time. 

The defendants would note that thousands of documents have 

been turned over to the plaintiffs in pretrial discovery and the 

plaintiffs will find the names of various employees of the 

defendants who have knowledge regarding the contents of the 

documents in the documents themselves. The defendants consider 

all of the individuals whose names appear in those documents as    



  

  
potential non-expert witnesses. These individuals are avallable 

for depositions assuming that the plaintiffs apply for the   
necessary extension of time to conduct further depositions. 

FOR THE DEFENDANTS 

BLUMENTHAL 

ry A | 
n 2 “Whelan 

ssistant Attorney General 
10 Sherman Street | 

Hartford, CT 06105 

Telephone: 566-7173 

| BY: Woih I Vist yop 

BY: 
  

  

Martha M. Watts 

Assistant Attorney General 
110 Sherman Street 
Hartford, CT 06105 
Telephone: 566-7173 

    
 



  

  CERTIFICATION 
  

| This 1s to certify that a copy of the foregoing was mailed, 

postage prepared on August 5, 1992 to the following counsel of   record: 

John Brittain 
| University of Connecticut | 

School of Law 

65 Elizabeth Street 
‘Hartford, CT 06105 | 

Wilfred Rodriguez | 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

Philip Tegeler 
Martha Stone 

Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106   
] Wesley W. Horton, Esq. 

Moller, Horton & Fineberg P.C. 
90 Gillett Street | 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and 
Education Fund 
99 Hudson Street 
14th Floor 
New York, NY 10013 

    
 



  

  

Julius L. Chambers, Esq. 

Marianne Lado, Esq. 

Ronald Ellis, Esq. 
NAACP Legal Defense and 

| Education Fund 
| 99 Hudson Street 
| New York, NY 10013 

John A. Powell 
Helen Hershkoff 
American Civil Liberties Union | 
132 West 43rd Street 

ll New York, NY 10036 

     

   

  

/ 

0, 

| 
Jon R. Whelan | 
/Agsistant Attorney General   

    
 



State of Connecticut 
ATTORNEY GENERAL 

MacKENZIE HALL 

110 SHERMAN STREET 

HARTFORD, CONNECTICUT 06105 

JULIUS L CHAMBERS ESQ 

MARIANNE LADO ESQ 
RONALD ELLIS ESQ 

NAACP LEGAL DEFENSE & ED FUND 

99 HUDSON STREET 
NEW YORK NY 10013 

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