Correspondence from Tegeler to Whelan with Deposition Subpoena for Christine Rossell

    FOL NDATION 
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 
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 Christine Rossell scheduled for July 28, 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. 
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, 

7h 0. Ci Zip” 
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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 89-0360977sS. 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. 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; 

c. any written documents describing how the survey or poll 
was conducted; 

 



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; 

documents describing or relating to the sampling plan, 
if any,” for the survey or poll, including all 
statistical analyses in connection with sampling; 

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; 

tabulations of responses to the instrument upon which 
the expert may rely; 

written documentation necessary to read and analyze (on 
commonly available personal computers) any information 
or data provided on computer disks or tape; and 

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 3 i day of July, 1992. 

EL Fer 
Philip D. Tegeler Atartha—Steme 
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 

17 day of July, 1992. 

YA 
  

Philip D. Tegeler Atertha—Stomne 

 



Connecticut | Connecticut Civil Liberties Union | Liberties Union 
ThirtyTwo Grand Street, Hartford, CT 06106 

Gs 

Ron Ellis/Marianne Lado 
NAACP Legal Defense Fund 
99 Hudson Street 
New York, NY 10013 

An affiliate of The American 

: Civil Liberties Union  



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