Letter from Lado to Court RE: Plaintiffs’ Response to Defendant’s First Request for Production

    ® 

  

: . National Office fy 

  

A / Suite 1600 

NAACP LEGAL DEFENSE 99 Hudson Street 

AND EDUCATIONAL FUND, INC. New York, N.Y. 10013-2897 (212) 219-1900 Fax: (212) 226-7592 

June 4, 1992 

Honorable Harry Hammer 
P.O. BOX 325 

Rockville, CT 06066 

Re: Sheff v. 0’Neill 
  

Dear Judge Hammer: 

Enclosed please find a copy of the Plaintiffs’ Response to 
Defendants’ First Request for Production, which was served on the 
defendants today. 

Respectfully, 

TH Cpt Zi 
Marianne Engelman Lado 
Attorney for Plaintiffs 

cc. John R. Whelan, Esq. 
Diane Woodfield-Whitney, Esq. 
Wilfred Rodriguez, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
Ronald Ellis, Esq. 
Wesley W. Horton, Esq. 
Jenny Rivera, Esq. 
Philip Tegeler, Esq. 
Martha Stone, Esq. 
John R. Brittain, Esq. 

Regional Offices 

Contributions are The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part Suite 301 Suite 208 
deductible for U.S. of the National Association for the Advancement of Colored People 1275 K Street, NW 315 West Ninth Street 
income tax purposes. (NAACP) although LDF was founded by the NAACP and shares its Washington, DC 20005 Los Angeles, CA 90015 

commitment to equal rights. LDF has had for over 30 years a separate (202) 682-1300 (213) 624-2405 

Board, program, staff, office and budget. Fax: (202) 682-1312 Fax: (213) 624-0075 

 



   
dl 

Contributions are 

deductible for U.S. 

income tax purposes. 

* 
NAACP LEGAL DEFENSE 

AND EDUCATIONAL FUND, INC. 

Clerk of the Court 
Superior Court 
95 Washington Street 
Hartford, CT 06106 

Re: Sheff v. O’Neill 
  

Dear Sir or Madam, 

National Office WW 

Suite 1600 

99 Hudson Street 

New York, N.Y. 10013-2897 (212) 219-1900 Fax: (212) 226-7592 

June 4, 1992 

Please forward the attached Response to Defendants’ Request 
for Production to Judge Hammer, 
above-captioned case. 

attachment 

CC. All Counsel 

Board, program, staff, office and budget. 

The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part 
of the National Association for the Advancement of Colored People 
(NAACP) although LDF was founded by the NAACP and shares its 
commitment to equal rights. LDF has had for over 30 years a separate 

Marianne Engelman Lado 
Attorney for Plaintiffs 

Regional Offices 

Suite 301 

1275 K Street, NW 

Washington, DC 20005 

(202) 682-1300 
Fax: (202) 682-1312 

who has responsibility for the 

Suite 208 

315 West Ninth Street 

Los Angeles, CA 90015 

(213) 624-2405 
Fax: (213) 624-0075 

 



  

Cv 89-0360977S 

  

MI1O SHEFF, et al. : SUPERIOR COURT 

Plaintiffs : JUDICIAL DISTRICT OF 
Vv. : HARTFORD/NEW BRITAIN 

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

Defendants : JUNE 4, 1992 

  

PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FIRST REQUEST FOR 
PRODUCTION 
  

  

Pursuant to P.B. § 227, the defendants hereby request 

that the plaintiffs produce the following documents or records 

for inspection and copying by defendants’ counsel: 

1. Documents, data tapes, discs or other means of data 

storage which contain all data gathered and/or used as part of 

the studies conducted by plaintiffs’ expert witness, Dr. 

Robert Crain, which are summarized in the reports entitled 

"School Desegregation and Black Occupational Attainments: 

Results from Long Term Experiment" and "Finding Niches: 

Desegregated Students Sixteen Year later." 

Specifically the defendants seek the underlying data 

| files and variables used for the analyses in these two 

 



reports. The files should consist of all coded and edited 

variables for all individual students and/or parents analyzed 
  

in the two studies, along with a description of the format and 

coding of each individual variable. The files should include 

specifications for any derived or transformed variables used 

in the two reports; inclusion of appropriate SPSS or SAS 

programming instructions and codebooks would be sufficient. 

In order to expedite the defendants’ review of the 

requested material the defendants ask that the data be 

produced on standard floppy disks (using ASC II format) 

suitable for use on a standard MS-DOS PC. 

RESPONSE TO FIRST REQUEST FOR PRODUCTION: 
  

See the following documents and records, which plaintiffs 

append to this response, in accordance with P. B. §228: 

1. The data used in the studies that are the subject of the 

reports, "School Desegregation and Black Occupational 

Attainments: Results from Long Term Experiment" and "Finding 

Niches: Desegregated Students Sixteen Years Later," contained 

on floppy disk (using ASC II format) suitable for use on a 

standard MS-DOS PC; 

lz. The file "PKUNZIP," which will uncompress the data file  



  

and can be found on the same floppy disk; 

3. The codebook, which contains the variables used for 

analysis, a description of the format, and the coding of 

variables; 

4, "1982 Hartford Youth Employment Study: Student 

Questionnaire;" 

5 "1982 Hartford Youth Employment Study: Parent 

Supplement;" and 

6. "1982 Hartford Youth Employment Duty: Interviewer 

Training Manual." 

Respectfully Submitted, 

PLAINTIFFS, MILO SHEFF, ET AL. on Ze 

Julius L. Chambers 
Ronald L. Ellis 
Marianne Engelman Lado 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street, 16th Fl. 
New York, NY 10013 

(212) 219-1900 

  

 



  

Wesley W. Horton 
Moller, Horton & Fineberg 
90 Gillett Street 
Hartford, CT 06105 

John A. Powell 

Helen Hershkoff 

Adam Cohen 

American Civil Liberties 
Union Foundation 

132 West 43rd Street 

New York, NY 10036 

John Brittain 
University of Connecticut 

School of Law 

65 Elizabeth Street 
Hartford, CT 06105 

Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 
Union Foundation 

32 Grand Street 

Hartford, CT 06106 

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

Jenny Rivera 
Ruben Franco 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street, 12th Fl. 
New York, NY 10013