Correspondence from Tegeler to Whelan with Rossell Deposition Subpoena

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ThirtyTwo Grand Street, Hartford. CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX July 14, 1992 

Mr. John Whelan 
Assistant Attorney General 
110 Sherman Street 
Rartford, C7 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 Christine Rossell scheduled for July 28; 1992. «. Xf 

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. 

If you have any questions regarding the attached subpoena, please 

contact attorney Ron Ellis at 212-219-1900. 

In addition, if there are any anticipated changes in the 

description of Ms. Rossell’s anticipated testimony, please provide 

the description to us prior to the deposition. 

, Thank you for your cooperation. 

Sincerely, 

7 oft pics 
SS ol 

A EEA 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 

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SUBPOENA DUCES TECUM 
  

TO: Christine Rossell 
Boston University 
232 Bay State Road 
Boston, MA 02215 

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 10:00 a.m. on the 28th of July, 

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. All studies, surveys, reports, polls, or statistical data 

prepared, requested or commissioned by or in the possession 

of the deponent or the State of Connecticut or any of its 

officers, employees or agencies which have been, or will be 

relied on, in whole or in part, for the deponent’s expected 

testimony at the trial of this action. This request 

includes but is not limited to documents relating to 

attitudes, preferences or objections of parents, school 

administrators, community representatives, elected officials 

or other public leaders in Hartford, the surrounding 

communities, or the State of Connecticut on: (1) school 

; desegregation; (2) transportation or reassignment of 

students; (3) mandatory and/or voluntary remedial school 

desegregation plans; (4) school curricula; (5) bilingual 

education. 

2. As to any and all surveys or polls, which have been or will 

be relied on, in whole or in part, for the deponent’s 

expected testimony at the trial of this action: 

a. any written questionnaire or survey Or poll 

instrument that includes the verbatim text of 

written or oral survey or poll questions; 

b. any written instructions or verbatim text utilized for 

conducting a telephone survey or poll; 

v 

c. any written documents describing how the survey or poll 

was conducted; 

 



  

d. any written description of the survey or polling process 

or instructions intended to be used to prepare or train 

the individual(s) who would conduct the survey or poll; 

e. documents describing or relating to the sampling plan, 

if any, for the survey or poll, including all 

statistical analyses in connection with sampling; 

f. code books for responses or a complete description of 

the manner in which responses to oral or written survey 

questions were coded or categorized for purposes of 

analysis or evaluation; 

g. tabulations of responses to the instrument upon which 

the expert may rely; 

h. written documentation necessary to read and analyze (on 

commonly available personal computers) any information 

or data provided on computer disks or tape; and 

i. computer magnetic tapes or disks containing information 

or data relating to the poll or survey. 

All reports, studies, data compilations or calculations, and 

all underlying raw data relating to the sample of twenty 

school districts used in the book The Carrot or the Stick 

for School Desegregation Policy. 
  

  

Copies of all documents, reports, memoranda or 

correspondence relating to the decision to use or not to use 

school districts for the analyses performed in The Carrot or 

the Stick for School Desegregation Policy. 
  

  

Any follow-up studies conducted subsequent to The Carrot or 

the Stick for School Desegregation Policy including any 

studies pertaining to items 1-8 listed in the description of 

your testimony in Defendants’ Amended Disclosure of Expert 

Witnesses (May 15, 1992). 

  

  

All critiques or articles relating to The Carrot or the 

Stick for School Desegregation Policy and other studies you 

have published. 

  

  

A list and copies of all documents, reports, memoranda, 

studies, polls or correspondence referred to and/or relied 

on by the deponent for the proposed testimony in this 

action. 

Any Connecticut specific analyses you have prepared, 

including but not limited to analyses of State of 

 



  

Connecticut policies and programs to encourage voluntary 

desegregation; comparison of such programs and policies to 

programs and policies in other states; and other topics 

listed in Defendants’ Amended Disclosure of Expert Witnesses 

(May 15, 1992). 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

™ 
Dated at Hartford, Connecticut this }¥ day of July, 1992. 

EL Pearl 
Philip D. Tegeler /Aartha—Stome 
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, Assistant Attorney 

General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 06105 this 

157 day of July, 1592. 

  

Philip D. Tegeler /AMax=tha—Stome [||2dfbf8f3-a160-46ed-b32c-64b7791253a3||]