Defendants-Appellees' Suggestion for Rehearing En Banc

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX August 14, 1992 

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

RE: Sheff v. O'Neill 
  

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 William Congero scheduled for August 26, 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. Congero’s anticipated testimony be provided to us prior to the 
deposition. 

Thank you for your cooperation. 

Sincerely, 

iy S7za?e 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 

Pe 5 

 



  

SUBPOENA DUCES TECUM 
  

TO: William Congero 
Department of Education 
165 Capitol Avenue 
Bartford, 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 26th of August, 
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: 

l. A copy of your current resume. 

2. A copy of the documents referenced on the attached list, 
previously requested at the deposition of Douglas Rindone. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, Connecticut this id day of August, 1292, 

WD zzmse 
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 14th day of August, 1992. 

IL Sn 
  

Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs 

 



List of Documents 
  

Resume of Douglas Rindone. 

Grade 4 CMT, Summary and Interpretations Booklet (1985-86). 

Common Core of Learning Progress Report submitted to NSF. 

Grade 6 CMT, Summary Data for Selected Districts (1990-91). 

College Board Report summarizing Connecticut results (1991). 

Verification of the meaning of "ENR" on request I.22.c. 
("Selecting a Sample for the Pilot Testing of the Connecticut 
Fourth Grade Mastery Test"). 

Priority School District Guidelines (request II.f6). 

Updated list of research projects (request III.1ll). 

Minutes of Education Equity Study Committee meetings (request 
IV.17). 

EERA field studies. 

Report on project and Hartford particpation in request IV.9.a. 

Check on Hartford participation in request IV.9.b. 

List of 43 school districts pursuant to request IV.11. 

The following 1990-91 State and Federal Research and 
Statistical Reports: 

Report DREA Contact 
  

Threats and Assaults W. Choquette 
School Staff Report Appendices J. Thompson 
Research Bulletins: J. Thompson 

Impact of Education Enhancement 
Fall Hiring 
Newly Hired Staff 
Demographics, Newly Hired Staff 
Suburban, Urban Teachers’ Paths to Classroom 

Special Ed in CT-Fiscal and Demographic S. Flavell 

Preliminary Strategic School Profile Data. 

Blank ED-165 form and completed ED-165’s for Hartford schools. 

Report on the effectiveness of the CMT (survey by DOE and 
Psychological Corporation). 

NAEP state by state comparison of Grade 8 mathematics.  



  

29) 

30) 

Statewide study of SAT scores by race. 

Standard deviations for test scores. 

Clarified version 1990, 1991 CMT summary data for selected 
districts (two previous versions had been contradictory). 

"Connecticut’s LEP Students: A Neglected Resource" (State 
Board Report, 1992). 

Socioeconomic indicators update using 1990 census data. 

Total Professional Staff per 1000 Students updated. 

Description of how Staff Cost per Pupil was calculated and who 
is included in "staff." 

Corrected copy of Classroom Teachers per 1000 Students chart. 

Staff certification list. 

Draft copies of survey forms to collect information from 
parents, students, and teachers. 

October 1 -- Strategic School Profiles. 

In the fall -- Bilingual education report update.