Correspondence from Stone to Whelan

    i 

connecticut civil 
liberties union foundation 

32 grand street 

hartford, connecticut 06106 

telephone: 247-9823 

     
  

March 11, 1991 

Mr. John Whelan 
Assistant Attorney General 
MacKenzie Hall 
110 Sherman Street 
Hartford, OF 06105 

Dear John, 

We have carefully reviewed Defendants’ Response to 
Plaintiffs’ First Set of Interrogatories. We find them deficient 
in the following respects and would ask that you supplement your 
responses in an effort to avoid a motion to compel compliance, 
pursuant to Connecticut Practice Book §231. 

Interrogatory #2 
  

Although you furnished to us on January 15th, a list of 
expert witnesses you expect to call at trial, this list is 
partially non-responsive to Interrogatory #2 in that it does not 
"state 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.” 

Interrogatory #10 
  

This answer is not complete. Please indicate what 
"principal measures” in addition to the Connecticut Mastery Test 
the defendants believe measure student achievement. 

 



  

Interrogatory #14 
  

This answer is incomplete. Please clarify whether as a 
matter of fact, defendants believe Hartford school children are 
receiving a minimally adequate education. 

Interrogatory #16 
  

This answer is incomplete. Please list all causes known for 
the disparities. 

Interrogatory #19 
  

This answer is non-responsive. Each subsection calls for a 
two- part answer. First, do defendants agree with each 
subsection, and secondly, did each defendant have knowledge? 

Interrogatory #20 
  

This answer is non-responsive. Plaintiffs are entitled to 
know from defendants what actions were taken in response to the 
1965 report by the United States Civil Rights Commission. 

Interrogatory #21 
  

This answer is non-responsive. Defendants’ answer indicates 
that they “do not admit plaintiffs’ characterization of the 
contents” of the Harvard report. This interrogatory merely asks 
in what ways defendants believe such characterizations are 
inaccurate. 

Interrogatory #22 
  

This answer is incomplete. Please supplement the response. 

Interrogatory #25 
  

This answer is in part non-responsive and in part 
incomplete. Defendants do not specify exactly what steps were 
taken, nor do they address, for example, what actions they took 
to "reconfigure district lines.” 

Interrogatory #26 
  

This answer is non-responsive. To clarify, the actions 
referred to in this interrogatory are those of all defendants 
including defendant Governor. 

 



  

Interrogatory #27 
  

Plaintiffs only have Exhibit 18(a)(b)(c). Plaintiffs do not 
have Exhibit 18(d) referred to in defendants’ response. 

Interrogatory #29 
  

This answer is incomplete. The “school year each program is 
anticipated to commence and the number of students from each 
district to be participating in each” is unclear from the 
documents provided. 

Interrogatory #30 
  

This answer is non-responsive. 

We would appreciate your supplementary response no later 
than April 1, 1991. Thank you for your cooperation. If you have 
any further questions, please let us know. 

Sincerely, 

N CY : 

N loa Phe Shi 
Martha Stone 

Philip D. Tegeler 

Attorneys for Plaintiffs 

MS/amt