Plaintiffs' Amended Responses to Defendants' First Set of Interrogatories

    Cv89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

Vv. JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

WILLIAM A. O'NEILL, et al. AT HARTFORD 

Defendants FEBRUARY 12, 1991 

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PLAINTIFFS’ AMENDED RESPONSES TO DEFENDANTS' 
FIRST SET OF INTERROGATORIES 
  

  

PAST VIOLATIONS: AFFIRMATIVE ACTS 
  

1. Please identify each and every affirmative act by the 
defendants, their predecessors, or any other state officer, 
agency or other body which the plaintiffs will claim at trial 
violated the State Constitution. For each such act provide the 
date the act occurred, the person, agency or other body 
responsible for the act, and any and all information the 
plaintiffs will claim that person, agency or other body had or 
should have had at that time which would have apprised them of 
the consequences of that act. 

  

RESPONSE TO INTERROGATORIES 1, 2, 3, 4: 
  

Plaintiffs have not brought this case to challenge the 

constitutionality of specific historical actions of the state. 

Rather, as plaintiffs have repeatedly maintained, it is the 

present condition of racial segregation in the region's schools 
  

that violates the Connecticut Constitution as a matter of law, 

   



  

and the harms that flow from the present condition of racial and 

economic segregation that in fact deprive Hartford area school 

children of their right to equality of educational opportunity. 

Defendants have claimed that the requisite “state action” is 

not present here, because, as they argue, the state has taken no 

affirmative steps to cause segregation. As plaintiffs have tried 

to impress upon the court, the state's argument has no basis in 

law. The state controls public education, and the state has an 

affirmative duty to guarantee equal educational opportunity. The 

extensive involvement of the state satisfies every standard of 

state action of which plaintiffs are aware. As in Horton v. 
  

Meskill, the Sheff case claims that the present system of public 

education is unconstitutional. Defendants’ state action argument 

in the present case would be equivalent to arguing in the Horton 

case that the state did not "cause" differences in wealth, tax 

burden, and educational need among different school districts! 

Nonetheless, if defendants persist in this line of argument, 

and if the court does not eliminate this issue prior to trial, 

plaintiffs are prepared to rebut defendants’ claims that the 

state did nothing to cause or contribute to school segregation or 

that the state is not "responsible for" existing school 

boundaries that exacerbate segregation. In fact, defendants have 

taken numerous actions that have “caused” or "contributed to” 

segregation. Taken together, in whole or in part, these actions 

 



by the state can be said to be unconstitutional to the extent 

that they have led to or have contributed to the unconstitutional 

system of racial and economic segregation and the concomitant — 

harm that flows from that system. A summary of plaintiffs’ proof 

on these points is set out below, as best as can be determined at 

this stage of the case. Plaintiffs reserve the right to amend or - 

supplement their responses. 

Defendants are legally responsible for the 

creation, maintenance, approval, funding, 

supervision and control of public education. 

  

  

  

Defendants discharge a broad range of statutory 

obligations that demonstrate their control over and 

responsibility for Connecticut's system of public education. 

Defendants provide substantial financial support to schools 

throughout the State to finance school operations. See §§10-262, 

et seq. They also approve, fund, and oversee local school 

building projects, see §§10-282, et seq., and reimburse towns for 

student transportation expenses. See §10-273a. 

Defendant State Board of Education has "general 

supervision and control [over] the educational interests of the 

state,” §10-4, and exercises broad supervision over schools 

throughout the State. It prepares courses of study and curricula 

for the schools, develops evaluation and assessment programs, and  



conducts annual-assessments of public schools. See id. The — 

Board also prepares a comprehensive plan of long-term goals and 

short-term objectives for the Connecticut public school system 

every five years. See id. 

Defendants exert -broad control over school attendance 

and school calendar requirements. They establish the ages at 

which school attendance is mandatory throughout the State. See 

§10-184. They determine the minimum number of school days that 

public schools must be in session each year, and have the 

authority to authorize exceptions to this requirement. See §10- 

15. They also set the minimum number of hours of actual school 

work per school day. See §10-16. In addition, defendants 

promulgate a list of holidays and special days that must be 

suitably observed-in the public schools. See §10-29a. 

Defendants are directly involved in the planning and 

implementation of required curricula for the State's public 

schools. They promulgate a list of courses that must be part of 

the program of instruction in all public schools, see §10-16Db, 

and they make available curriculum materials to assist local 

schools in providing course offerings in these areas. See id. 

Defendants impose minimum graduation requirements on high schools 

throughout the State. See §10-22la. And they exercise 

supervisory authority over textbook selection in all of the 

State's public schools. See §10-221. In addition, defendants  



  

require that all public schools teach students at every grade — 

level about the effects of alcohol, tobacco, and drugs, see §10- 

19, and that they provide students and teachers: with-an—_ — 

opportunity for silent meditation at the start of every school 

day. See §10-16a.—- ~~ 

| Defendants exert broad authority over the hiring, 

retention, and retirement, of teachers and other school 

personnel. They set minimum teacher standards, see §10-145a, and 

administer a system of testing prospective teachers before they 

are certified by the State. See §10-145f. Certification by 

defendants is a condition of employment for all teachers in the 

Connecticut public school system. See §10-145. All school 

business administrators, see §10-145d, and intramural and 

tnterscholastic coaches hired must also be certified by 

defendants. See §10-149. Defendants also prescribe statewide 

rules governing teacher tenure, see §10-151, and teacher 

unionization, see §10-153a, and maintain a statewide teachers!’ 

retirement program. See §10-183c. 

Defendants supervise a system of proficiency 

examinations for students throughout the State. See §10-14n. 

These examinations, provided and administered by the State Board 

of Education, test all students enrolled in public schools. See 

id. Defendants require students who do not meet State standards 

to continue to take the examinations until they meet or exceed 

 



  

expected performance levels. See id. Defendants also promulgate 

procedures for the discipline-and expulsion of public school 

students throughout the State. See §10-233a et seq. 

Defendants also exert broad authority over language of 

instruction in public schools throughout the State. They mandate 

that English must be the medium of instruction and administration 

in all public schools in the State. See §10-17. But they also 

require local school districts to classify all students according 

to their dominant language, and to meet the language needs of 

bilingual students. See §10-17f. Defendants require each school 

implementing a program of bilingual education for the first time 

to prepare and submit a plan for implementing such a program to 

the State Commissioner of Education. See id. 

The Connecticut Supreme Court has repeatedly stated that 

public education is, in every respect, a responsibility of the 

state. See Plaintiffs’ Memorandum of Law in Opposition to 

Respondents’ Motion to Strike (November 9, 1989) (pp. 7-15). 

While certain aspects of administration are delegated to local 

districts, such delegation is only at the pleasure of the state, 

and in no way diminishes the state’s ultimate duty to provide 

public education. See, e.qg., Waterbury Teachers Association v. 
    

Furlong, 162 Conn. 390, 294 A.2d 546 (1972). Plaintiffs will 

present evidence of the history of state control over local 

 



  

education in Connecticut through their expert historical witness, 

Professor Christopher Collier. 

b. The state requires, pursuant to C.G.S. §10-240, that 
school district boundaries be coterminous with municipal 

boundaries. 

  

  

  

The requirement that town and school district-boundaries 

be coterminous was imposed by the state in 1909.1 Prior to 

1909, there was no state requirement that town and school 

district lines be the same, and many school districts crossed 

town lines.2 Since 1909, there has been no change in school 

district boundaries in the Hartford region, even as those school 

districts became increasingly segregated. Thus, the state- 

imposed system of coterminous town and school district boundaries 

served as a legal template on which the pattern of school 

segregation was laid out. 

  

1 In prior legislation, the state had authorized towns to 
consolidate school districts within their borders (1854), and had 
prohibited the establishment of any additional school districts 
(1866). 

d See, e.q., 2nd Annual Report of the Board of Commissioners of 
the Common Schools, (Hartford, 1840); Annual Report of the 
Superintendent of the Common Schools for 1847 (Seth Beers); 
Annual Report of the Superintendent of the Common Schools, 1955; 
Stiles, History of Ancient Wethersfield, V.I. (1904, reprinted 
1974) p. 370; Litchfield and Hoyt, History of the Town of Oxford, 
(1960); See Also F. W. Beers, Atlas of New York and Vicinity 
Including Fairfield County, Connecticut (1867); F. W. Beers and 
Ellis and G.G. Soule, Atlas of New Haven County (1868); Atlas of 
New London County (1868) ; County Atlas of Litchfield (1874); 
County Atlas of Middlesex, Connecticut (1974); Backer and 
Tilden, Atlas of Hartford City and County (Hartford, 1896); 

  

  

  

  

  

  

    

  

    

    

  

  

  

School Districts of the Town of Hartford (1902). 

 



  

Even iA 1909, although Connecticut's black population 

was very small, the pattern of black migration and racially 

identifiable housing was already established. By 1909, roughly 

92% of Connecticut blacks were living in the cities. Thus, 

restriction of school districts to city boundaries had the 

foreseeable impact of limiting black access to suburban schools: 

Professor Collier will testify that two to three segregated black 

schools were established in Hartford between 1811 and 1859; that 

until after the civil war, black students were permitted to 

attend no public high school in Connecticut; and that there is 

evidence that there is evidence that black students in the 19th 

century were often held up to scorn and ridicule in those 

instances in which they attended white schools. It was not until 

1867 that state law abolished "official” segregation of public 

schools. 

The only exception to the requirement of coterminous 

town and school district boundaries is where two or more 

districts voluntarily enter into a regional school district with 

state approval, pursuant to C.G.S. §10-39 et seq. However, this 

option was denied to the City of Hartford for fifteen years, from 

1969 to 1985, during the most rapid period of growth in school 

 



minority concentration, by operation of a state statute, C.G.S. 

§10-39.3 

There is AB ERE tutional basis for the legal 

requirement that town and school district boundaries be 

coterminous. Nor is there any practical basis for the 

requirement. School districts throughout the United States are 

organized on other than a town-by-town basis. In Connecticut, 

intertown arrangements have been approved, encouraged, or 

mandated by the state, in the areas of sewer, water, 

transportation, and education. In the area of education, the 

state has established regional vocational-educational schools, 

and has encouraged interdistrict cooperative arrangements among 

suburban communities in special education programs. However, 

since 1954, with the exception of Project Concern, which the 

state has failed to adequately fund (see response to 

Interrogatory 5), the state provided no funding for 

urban/suburban interdistrict programs in regular education until 

after the present lawsuit was announced. 

  

3 See Memorandum from Commissioner 
dated ‘ 

  
  

   



The state requires, pursuant to-C.G.S.- §10-184, 
that school-age children attend public school 1 
within the school district wherein the child 
resides. 

  

  

  

Pursuant to C.G.S. 10-184, parents are required to send - 

their children seven and over and under sixteen to a school 1in 

the district wherein such child resides.” | ‘Defendants have 

enforced this statute to 0 prevent children living in the city of 

Hartford from attending school in suburban districts. For 

example, in 1985, four parents living in Hartford sent their 

children across town lines to the Bloomfield school system in 

order to secure an integrated and minimally adequate education 

for their children. Defendants, with the knowledge that the 

system of education these children were receiving was better in 

Bloomfield, employed the criminal process and had the parents 

arrested for larceny pursuant to C.G.S. 53a-119. See State Vv. 
  

Saundra Foster (spring 1985). 
  

Plaintiffs will also present historical evidence that 

prior to the adoption of C.G.S. §10-184, school children in 

Connecticut often crossed district lines to obtain education 

[ INSERT--find Sebok document]. 

 



  

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d. From approximately 1954 to the present, the State 
  

Department of Education and the State Board cf... --... .   

Education have engaged in a massive program of new 
school ‘construction and school additions or 
renovations in Hartford and the surrounding 
communities, with direct knowledge of the 
increasing segregation in Hartford area schools. 

  

  

  

  

  

By 1954, defendants were well aware of the growing 

pattern of racial segregation in education and its alleged harm 

to black children. Between 1954 and the present, defendants 

approved and funded the construction of over fifty new schools in 

virtually all-white communities, representing over ____% of the 

total school capacity in the region.4 Through stipulation or 

testimony, plaintiffs will provide the court with a list or map 

of schools built, by year, grade level and number of students, 

along with a table, map or other graphic representation of the 

increasing racial segregation of Hartford area schools over time. 

e. The state has further contributed to segregation by 
authorizing and/or requiring payment of transportation 
costs by local districts for students attending private 
schools, and by reimbursing local districts for said 
costs. 

  

  

  

  

[MARIANNE LADO] 

  

4 

Discovery Exhibit ( 

Source: DOE reports and H.C. Planning Associates Survey -- 
Set of Document Production). 

   



  

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f. The state’s adoption and implementation of the-"Racial 
Imbalance” law and requlations has contributed to and 
authorized racial segregation in Hartford schools. 

  

  

  

(MARIANNE LADO] 

g. The state contributed to racial and economic 
segregation, and unequal, inadequate educational 
conditions by establishing and maintaining an 
unequal and unconstitutional system of educational 
financing, up to 1986.° 

  

  

  

  

  

Until 1979 the principal source of school funding came 

from local property taxes, which depended on the wealth of the 

town. This principal source was supplemented by the state by a 

$250 flat grant principal, which applied to the poorest and the 

wealthiest towns. There was great wealth disparity which was 

reflected in widely varying funds available for local education 

and consequently widely varying quality of education among towns. 

The property-rich towns through higher per pupil expenditures 

  

5 Sources for this section include Horton v. Meskill, 31 Conn. 
Sup. 377, 332 A.2d 113 (1974); I1d., 172 Conn. 615, 376 A.2d 359 
(1977); Supreme Court Record in previous case, (No. 8127); Horton v. Meskill, 195 Conn. 24, 486 A.2d 1099 (13985); Supreme Court 

  

  

Record in previous case, Nos. 12499-12502. 

 



were able to provide a substantially wider range and high qualify. 

of education services than property-poor towns even as taxpayers 

in those towns were paying higher taxes than taxpayers in 

property-rich towns. All this was happening even though the 

state had the non-delegable responsibility to insure the students 

throughout the state received a substantially equal educational- 

opportunity. Thus prior to 1979, the system of funding public 

education in the state violated the state constitution. 

In 1979, the state adopted a guaranteed tax base to 

rectify in part the financing inequities. This system was to be 

phased in over five years from 56% funding in 1979-80 to 100% 

funding in 1983-84. In 1980, the state amended the 1979 act to 

postpone current year funding for special education for one year, 

saving the state $9,000,000. This had ar Adverse impact on 

property-poor towns. In 1981, the state reduced the 1981-82 

phase-in from 78% to 72%, saving the state $63,000,000. In 1982, 

the state reduced the 1982-83 phase-in from 89% to 81% and again 

postponed special education reimbursement for one year, saving 

the state $44,900,000. In 1983, the state reduced the 1983-84 

phase-in from 100% to 90% and again postponed special education 

reimbursement for one year, saving the state $83,000,000. The 

state also mandated the use of 3-year-old rather than 2-year-old 

data. This change made the data more obsolete but saved the  



state $23,000.000. In 1984; the state reduced the 1984-85 phase- 

in from 100% to 95%, saving $21,000,000. 

The delays between 1980 and 1985 in implementing the 

1979 act and the unjustified use of obsolete data made the 

formula more disequalizing and exacerbated disparities in per 

pupil expenditures. These conditions denied students their 

rights to substantially equal educational opportunities under the 

state constitution. - A. a 

The state has contributed to racial and economic 

segregation in housing. 
  

  

Residential segregation is 2 complex process that is 

strongly influenced by the actions of federal, state, and local 

government in the areas of housing policy, transportation, land 

use regulation and educational policy. Residential segregation 

is also influenced by the actions and policies of private 

realtors and landlords who are subject to regulation by the 

state. Individual choices also play a role in the process. The 

process of residential segregation can also be influenced and 

attenuated by effective actions at all levels of government. 

Plaintiffs are not claiming in this lawsuit that any of 

the state's housing actions are unconstitutional. Any such 

claims are expressly reserved. However, it cannot be denied that 

the state has played an important causal role in the process of 

residential segregation in the Hartford region. Plaintiffs will  



  

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describe, through expert testimony, some of the ways that the 

state of Connecticut has contributed to residential segregation. 

(Plaintiffs’ investigation is ongoing and is subject to amendment 

in a timely fashion.) 

Plaintiffs testimony on these issues may include but 

will not be limited to the following areas: 

Location of Assisted Housing: Approximately 73% of 
  

Hartford-area assisted family housing units are located in the 

City of Hartford. The state has played a direct role in the 

creation, funding, approval, siting, or administration of many of 

these units over the past 40 years. On information and belief, 

these units were racially segregated by town when initially 

occupied and have remained segregated to the present. In 

contrast, elderly assisted housing is located predominantly in 

the suburbs. 

Transportation: During the same time period, the 
  

state has engaged in a series of transportation decisions that 

have increased "white flight” from Hartford, limited minority 

access to employment opportunities, and exacerbated racial and 

economic residential segregation in the Hartford region. These 

actions have included the construction and expansion of I-91, the 

construction and/or expansion of Route I-84, Route 2, and Route 

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44, the reduction in light rail/commuter rail capacity, and the. - _ 

rejection of various mass transit proposals by the state DOT. 

These patterns are consistent with well documented historical 

patterns in metropolitan areas throughout the Northeast. 

  

Affirmative Marketing: In its administration of 

state housing programs, the state has failed to monitor and. .- 

enforce affirmative marketing plans for state-funded suburban 

housing developments, including, on information and belief, 

failure to require affirmative marketing during initial 

occupancy, failure to provide adequate numbers of staff to 

monitor and enforcement affirmative marketing requirements, 

failure to conduct surveys of racial occupancy, and failure to 

require affirmative marketing plans until 1988. 

Statutory Barriers: The state has provided 
  

suburban towns with veto power over state-subsidized projects 

through C.G.S. §8-120, which prohibits the Connecticut Housing 

Authority from developing new housing, including Section 8 

developments, in any municipality without a finding of need or 

approval by the local governing body of the municipality,’ and 

through C.G.S. §§8-39(a) and 8-40, which prohibit local housing 

  

7 In the pending case of East Hartford v. Papandrea, this 
  

statute is being used by a suburban Public Housing Authority to 
exclude out-of-town federal rental certificates. 

 



  

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authorities from constructing, rehabilitating or -financing.a - 

housing development in a neighboring municipality without that 

municipality’s permission. 

Rental Assistance: Another way in which the state 
  

has conte ibited. to residential segregation through its 

administration of state housing programs is through its 

administration and oversight of state and federal rental 

assistance programs, and its failure to permit or encourage such 

certificates to be used in a portable manner to permit 

certificate holders to cross municipal lines. For example, in 

1980, the office of the attorney general interpreted C.G.S §§8- 

39(a) and 8-40 to limit the use of federal rental subsidies to 

the municipality where the certificates were issued. Also, in 

its own administration of the state-subsidized rental assistance 

program (RAP), the state has placed a large share of Hartford- 

area RAP certificates in the City of Hartford.8 Finally, on 

information and belief, in its own administration of the 

federally-funded Section 8 certificate and voucher programs, the 

state has failed to take sufficient steps to seek out suburban 

housing opportunities, and has placed an increasing share of 

  

8 [list data] 

 



Hartford area rental Section 8 certificates and vouchers “in the=— 

City of Hartford.’ 

Residency Preferences: The state has officially 
  

permitted the use of residency preferences by suburban public 

housing authorities, including certain PHAs in the Hartford area, 

residency preferences have a discriminatory impact in white 

suburban communities, limiting the access of low income minority 

residents to suburban housing opportunities and suburban schools. 

Exclusionary Zoning: The state has been repeatedly 
  

advised of the discriminatory and exclusionary effects of its 

scheme of planning, zoning and land use laws and regulations, 

which have permitted local governments to erect zoning and other 

land use barriers to the construction of multifamily housing, 

rental housing, manufactured housing, assisted low and moderate 

income housing. As a matter of law, zoning and land use 

regulation is solely a state power, which Connecticut delegates 

to municipalities. As a matter of practice, until very recently, 

the state of Connecticut has essentially “looked the other way” 

as exclusionary local ordinances forseeably multiplied throughout 

the state. Up until 1988, the legislature consistently resisted 

efforts to reform exclusionary zoning, in spite of frequent calls 

  

9 [list data]  



for reform. In addition, various state agencies promoted the . .. - 

status quo in zoning and land use through the planning process, 

and the state may have also encouraged exclusionary land use—- 

patterns through its system of funding local sewer construction. 

Plaintiffs will present evidence of the state’s failure to act to 

remedy -the exclusionary zoning practices for which it was 

directly responsible. 

& * =o | * * * 

At the present time, plaintiffs are continuing to 

investigate actions taken by defendants that have contributed to 

the constitutional violations set out in the Complaint. At this 

time, except as set out above, plaintiffs have not completed 

investigation as to what specific "information [defendants]...had 

or should have had” at particular times which would have 

"apprised defendants of the consequences of particular actions.” 

Plaintiffs’ position is that although proof of such “notice” is 

not necessary for plaintiffs to prevail, nonetheless the 

increasing racial and economic segregation in area schools was 

obvious, and numerous reports and studies put the state on notice 

of the problems and possible causes and solutions. See response 

to Interrogatory 5. Further details in response to this 

interrogatory will be provided in a timely fashion, in advance of 

trial.  



  

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each such act provide the date the act occurred, the person, 

agency or other body responsible for the act, and any and all 

information the plaintiffs will claim that person, agency or _ 

other body had or should have had at that time which would have 

apprised them of the consequences of that act. : : 

RESPONSE: [Please see response to Interrogatory 1] 

3. Please identify each and every affirmative act by the 

defendants, their predecessors or any other state officer, agency 

or other body which the plaintiffs will claim at trial caused the 

condition of socio-economic isolation in the Hartford Public 

Schools and/or the identified suburban school districts. For 

each such act provide the date the act occurred, the person, 

agency or other body responsible for the act, and any and all 

information the plaintiffs will claim that person, agency or 

other body had or should have had at that time which would have 

apprised them of the consequences of the act. 

  

RESPONSE: [Please see response to Interrogatory 1] 

4. Please identify each and every affirmative act by the 

defendants, their predecessors or any other state officer, agency 

or other body which the plaintiffs will claim at trial cause the 

concentration of "at risk” children in the Hartford Public 

Schools. For each such act provide the date the act occurred, 

the person, agency or other body responsible for that act, and 

any and all information the plaintiffs will claim that person, 

agency or other body had or should have had at that time which 

would have apprised them of the consequences of that act. 

  

RESPONSE: [Please see response to Interrogatory 1] 

PAST VIOLATIONS: OMISSIONS 
  

5. Please identify each and every affirmative act, step, or 

plan which the plaintiffs will claim at trial the defendants, 

their predecessors, or any other state officer, agency or other 

body were required by the State Constitution to take or implement 

to address the condition of racial and ethnic isolation in the 

Hartford Public Schools and the identified suburban school 

 



  

A 

districts, but which was not in fact taken or implemented. For 

each such act, step, or plan provide the following: 

a) The last possible date upon which that act, step or 

plan would necessarily have been taken or 

implemented in order to have avoided a violation 

that the Constitution; 

b) The specific details of how such act, step or plan 

should have been carried out, including (1) the 

specific methods of accomplishing the objectives. of -. : 

the act, step or plan, (2) an estimate of how long 

it would have taken to carry out the act, step, or 

plan, and (3) an estimate of the cost of carrying 

out the act, step or plan; 

c) For Hartford and each of the identified suburban 

school districts, the specific number and percentage 

of black, Hispanic and white students who would, of 

necessity, have attended school outside of the then 

existing school district in which they resided in 

order for that act, step or plan to successfully 
address the requirements of the Constitution. 

RESPONSE: As set out in the Complaint, defendants’ failure to 
  

act in the face of defendants’ awareness of the educational 

necessity for racial, ethnic, and economic integration in the 

public schools, defendants’ recognition of the lasting harm 

inflicted on poor and minority students concentrated in urban 

school districts, and defendants’ knowledge of the array of legal 

tools available to defendants to remedy the problem, is violative 

of the State Constitution. Plaintiffs challenge defendants’ 

failure to provide plaintiffs with the equal educational 

opportunities to which the defendants were obligated to ensure. 

 



  

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Since at least-1965, when the United States Civil Rights 

Commission reported to Connecticut's ‘Commissioner of Education, 

defendants have had uonledge of the increasing racial, ethnic, 

and economic segregation in the ‘Hartford metropolitan area and 

the power and authority to remedy this school segregation. Not 

only did defendants EI to. _take- comprehensive or Ey wR steps 

to ameliorate the increasing segregation in and among the 

region's schools, but defendants also failed to provide equal 

access to educational resources to students in the schools in the 

Hartford metropolitan area. Such resources include, but are not 

limited to, number and qualification of staff; facilities; 

materials, books, and supplies; and curriculum offerings. 

Specifically, plaintiffs may present evidence at trial of 

the many reports and recommendations presented to Defendants 

which documented the widespread existence of racial, ethnic, and 

economic segregation and isolation among the school districts and 

which proposed or endorsed remedial efforts to eliminate such 

segregation. Plaintiffs will not necessarily claim that if 

implemented, the specific programs and policies offered in such 

reports and recommendations would have been sufficient to address 

the constitutional violation. Neither will plaintiffs 

necessarily claim that any one particular recommendations was 

required by the State Constitution. These reports and 

recommendations may include but are not limited to the following: 

 



  

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a. United States-Civil-Rights Commission, Report to-- -.. 
Connecticut’s Commissioner of Education (1965); 

b. Center for Field Studies, Harvard Graduate School 
of Education; Schools for Hartford {Cambridge,—— ———~=—=== 
Mass.: Harvard University, 1965); 
  

c. "Equality and Quality in the Public Schools,” 
Report of a Conference Sponsored Jointly by the 
Connecticut Commission on Civil Rights and the 
Connecticut State Board of Education,” (1966). 

d. Request by the Connecticut Civil Rights Commission 
to the Governor (request that the Governor take a 
stand against de facto segregation and publish a 
statement on the drawbacks of de facto segregation 
in the schools) (1966). 

e. Committee of Greater Hartford School 
Superintendents, Proposal to Establish a 
Metropolitan Effort Toward Regional Opportunity 
(METRO) (1966); 

f. Legislative Commission on Human Rights and 
Opportunities, Plan for the Creation and Funding of 
Educational Parks (Hartford, December, 1968); 

g. Task Force, Regional Advisory Committee for ths 
Capitol Region, "The Suburbs and the Poverty 
Problems of Greater Hartford,” (Hartford, September 

30, 1968); 

h. Irving L. Allen and J. David Colfax, Urban Problems 
and Public Opinion in Four Cities (Urban Research 
Report No. 14, Community Structure Series No. 3; 
Storrs, Conn.: University of Connecticut, 1968); 

  

  

i. Walter R. Boland, et al., De Facto School 
Segregation and The Student: A Study of the 
Schools in Connecticut's Five Major Cities (Urban 
Research Report No. 15, Community Structure Series 
No. 4; Storrs, Conn.: University of Connecticut, 
1968); 

  

  

  

k. Educational Resources and Development Center, The 
School of Education and Continuing Education 
Service, University of Connecticut, A Study of 
Urban School Needs in the Five Largest Cities of 

  

  

 



Connecticut (Storrs, Conn.: University of 
Connecticut, 1963); 
  

Edward A. Lehan, Executive Secretary to the 
Hartford City Manager, Report on Racial CHRPOBTELOR 
of Hartford Schools to the State Board of Education 
(Hartford, 1969); 

Joint Committee of the Hartford Board of Education 
and the Human Relations Commission, Rartford, 

Report, (July, 1969); == grins Rant 

City of Hartford, "Community Development Action 
Plan: Education 1971-1975," (Sept. Y, 1579); ; 

Hartford Board of Education, "Reconisnded Revision 
in School Building Program,” (May 18, 1970); 

Local Government: Schools and Property, “The 
Report of the Governor's Commission on Tax Reforms, 
Submitted to Governor Thomas J. Meskill Pursuant to 
Executive Order 13 of 1972," (Hartford, 
Connecticut, December 18, 1972); 

  

Commission to Study School Finance and Equal 
Educational Opportunity, Financing Connecticut 
Schools: Final Report of the Commission (Hartford, 
Conn., January, 1975); 

  

  

"State Board of Education Policy Statement on Equal 
Educational Opportunity,” Connecticut State Board 
of Education, (Hartford, October 27, 1986); 

"Report on Racial/Ethnic Equity and Desegregation 
in Connecticut's Public Schools,” Connecticut 
State Department of Education (1988); and 

"Quality and Integrated Education: Options for 
Connecticut,” Connecticut State Department of 
Education (1989). 

In addition to the recommendations and reports set out 

above, the State failed to adequately supplement the funding of a 

known successful integration program, Project Concern, beginning 

in 1980 when federal funding cutbacks and Hartford Board of  



Education cutbacks forced a reduction in the numbers of children 

participating in the program and in the numbers of staff hired to. 

service these CHTIAYER (0 DE rapIOTSEETOPaTE; Lesourts 

teachers, bus stop aides). The State has also failed to take ap- 

propriate steps to increase the numbers of children PETELITIPACING 

over and above the approximately 750+ students now enrolled in 

the program, despite knowledge that receiving school districts 

would increase their participation if the State provided funding. 

The following studies and documents, among others, have repeated- 

ly demonstrated to the Defendants that Project Concern is one of 

a number of programs to successfully provide an equal educational 

opportunity and a meaningful integrated experience for some urban 

and suburban children: 

a. Mahan, Thomas W. The Impact of Schools on Learning: 
Inner-City Children in Suburban Schools. 
  

  

Mahan, Thomas W. Project Concern 1966-1968, A Report on 
the Effectiveness of Suburban School Placement for 

Inner-City Children. 

  

  

  

Ninety-First Congress, Second Session on Equal Education 
Opportunity. “Hearing Before the Select Committee on 
Equal Educational Opportunity of the United States 
Senate.” 1970. 

Connecticut State Department of Education, “Reaction to 
Racial Imbalance Guidelines for Hartford Public 
Schools.” April 20, 1970. 

State Board of Education Minutes (Capital Region 
Planning Agency Endorses the Expansion of Project 
Concern) January 7, 1970. 

Gable, R. and Iwanicki, E., A Synthesis of the 
Evaluation Findings from 1976-1980 (May 1981)  



  

- 0 

g. Gable, Thompson, Iwanicki,The Effects of Voluntary : 

~ Desegregation on Occupational Outcomes, The Vocation 
al Guidance Quarterly, 230-239 (1983) 
  

h. Gable, R.and Iwanicki, E. The Longitudinal Effects of a 

Voluntary School Desegregation Program on the Basic 

Skill Progress of Participants. 1 Metropolitan Educa- 
tion 65. Spring, 1986. 

  

  

  
igh Gable, R.; Iwanicki, E. Project Concern Evaluation. - 

October, 1986. - : : 

j. Gable, R. and Iwanicki, E.; Final Evaluation Report 

1986-87 Hartford Project Concern Program (December 

1987) 
  

k. Gable, R. and Iwanicki, E. Final Evaluation Report 1988- 
89 Hartford Project Concern Program (Nov. 1989) 
  

1. Crain, R., et al., Finding Niches:Desegregated Students 
Sixteen Years Later, Rand Reports, (1985) ; revised 1990 
  

  

m. Crain, R., et al., School Desegregation_ and Black 
Occupational Attainment. 1985 
  

  

n. Table 5 Project Concern 1973-1989 Number of Project 
Concern Students from Sending Districts, (Defs’. Answer 
to Plaintiffs Motion for Production 1l3(a)) 

In addition, Plaintiffs’ evidence at trial may include 

but will not be limited to defendants’ failure to eliminate 

exclusionary zoning and housing policies; defendants’ failure to 

promote integrated housing in the Hartford region; and 

defendants’ failure to establish a constitutional system of 

educational financing up to and including 1986 (see response to 

Interrogatory 1). 

 



  

“3%. - 

In regard to questions 5 a, b, and c, as set out in 

Defendants’ Interrogatory 5, Plaintiffs have not determined and" 

are, at least at this time, unable to estimate the "last possible 

date’ upon which individual actions, steps, or plans would ~ — — 

necessarily have had to have been implemented in order to have 

avoided violation of the State Constitution, nor do plaintiffs 

concede the relevance of such an inquiry. ~Likewise, plaintiffs 

are not required to specify which methods would have cured the _ 

constitutional violation at particular moments in time, how long 

such methods would have taken to implement, or the cost of 

implementation. Such questions, including the number and 

percentage of African American, Latino, and white students who 

may seek to attend school outside of the boundaries of the city 

of Hartford, are issues which plaintiffs expect would be 

addressed by plaintiffs’ expert witnesses on desegregation 

remedies after a determination is made by the court as to the 

state's liability. 

6. Please identify each and every affirmative act, step or 
plan which the plaintiffs will claim at trial the defendants, 
their predecessors, or any other state officer, agency or other 
body were required by the State Constitution to take or implement 
to address the condition of socio-economic isolation in the 
Hartford Public Schools and the identified suburban school 
districts, but which was not in fact taken or implemented. For 
each such act, step or plan provide the following: 

a) The last possible date upon which that act, step or 
plan would necessarily have been taken or 
implemented in order to have avoided a violation of 
the Constitution; 

 



  

- 38 iw 

b) The specific details of how such act, step or plan =~" ~~ 
~~ should have been carried out including, (1) the 

- specific methods of accomplishing the objectives of 
the act, step or plan, (2) an estimate of how long 
it would have taken to carry out the act, step or — = 
plan, and (3) an estimate of the cost of carrying 
out the act, step or plan; 

c) For Hartford and each of the identified suburban 
school districts, the specific number and percentage- 
of poor, middle, and/or upper class students who 
would, of necessity, have attended school outside of 
the then existing school district in which they 
resided in order for that act, step, or plan to 
successfully address the requirements of the — 
Constitution; 

d) The specific criteria which should have been used to 
identify those students who would, of necessity, 
have attended school outside the then existing 
school district in which they resided, so that the 
concentration of students from poor families in 
Hartford Public Schools would be low enough to 
satisfy the requirements of the Constitution. 

  

RESPONSE: Please see response to Interrogatory 5. Plaintiffs 

have not, at this point, alleged that one specific criterion or 

indicator must be used to identify students who "would, of 

necessity” be transferred to another school district. As stated 

in the Complaint, rates of family participation in the federal 

Aid to Families with Dependent Children program is widely 

accepted as a measure closely correlated with family poverty. 

Participation in the federal school lunch program is also an 

index of poverty status. 

7. Please identify each and every affirmative act, step or 
plan which the plaintiffs will claim at trial the defendants, 
their predecessors, or any other state officer, agency or other 
body were required by the State Constitution to take or implement 
to address the conditions created by the concentration of "at 

 



. risk” children in .the Hartford Public Schools but which were not 
in fact taken or implemented. For each such act, step, or plan 
provide the following: 

a) The last possible date upon which that act, step or. 
~ plan would necessarily have been taken or 

implemented in order to have avoided a violation of 
the constitution; 

The specific details of how such act, step or plan 
should have been carried out including (1) the 
specific methods of accomplishing the objective of 
the act, step or plan, (2) an estimate as to how 
long it would have taken to carry out the act, step 
or plan, and (3) an estimate of the cost of carrying 
out the act, step or plan; 

The specific number and percentage of “at risk” 
Hartford students who would, of necessity, have 
attended school outside of the existing school 
district in which they resided in order for that 
act, step or plan to successfully address the 
requirements of the Constitution. 

The specific criteria which should have been used to 
identify those students who would, of necessity, 
have attended school outside the then existing 
school district in which they resided so that the 
concentration of "at risk” students in Hartford 
Public Schools would be low enough to satisfy the 
requirements of the Constitution. 

RESPONSE: Please see response to Interrogatory 5. As set out in   

the Complaint in this action, all children, including those 

deemed at risk of lower educational achievement, have the 

capacity to learn if given a suitable education. Yet, the 

Hartford public schools operate at a severe educational 

disadvantage in addressing the educational needs of all students, 

due in part to the sheer proportion of students who bear the 

burdens and challenges of living in poverty. The increased need  



  

- 30 = 

for special programs, such as compensatory education, stretches — 

Hartford school resources . even further. As also stated in the 

Complaint, the demographic characteristics of the students in the 

Hartford pibite selene. differ sharply from students in the 

suburban schools by. a umber of relevant measures, such as 

and whether a child is from a single-parent family. Plaintiffs 

have not, at this point, alleged that one specific criterion or 

indicator Aust be used to identify students who "would, of 

necessity” be transferred to another school district. 

CURRENT OR ONGOING VIOLATIONS 
  

8. Using the 1987-88 data as a base, for Hartford and each 
of the identified suburban school districts please specify the 
number and percentage of black, Hispanic and white students who 
must, of a necessity, attend school in a location outside of the 
existing school district in which they reside in order to address 
the condition of racial and ethnic isolation which now exists in 
accordance with the requirements of the Constitution. 

  

RESPONSE: Objection [Please see plaintiffs’ objection to 

Interrogatory 8, Plaintiffs’ Objections To Interrogatories, Filed 

September 20, 1990, attached hereto.] 

9. Using the 1987-88 data as a base, for Hartford and each 
of the identified suburban school districts please specify the 
number and percentage of poor, middle and/or upper class students 
who must, of necessity, attend school outside of the existing 
school district in which they reside in order to address the 
condition of socio-economic isolation which exists in Hartford 
and the identified suburban school districts in accordance with 
the requirements of the Constitution. Also identify the specific 
criteria which must be used to identify the pool of poor Hartford 
students from which those students who would be required to 

 



  

-3Y'u 

attend schools outside of the existing district in which they 

reside must be chosen so as to address the condition of socio- 

economic isolation in accordance with the requirements of the 

Constitution. 

RESPONSE: Objection [Please see plaintiffs’ objection to 
  

Interrogatory 9, Plaintiffs’ Objections To Interrogatories, Filed 

September 20, 1990, attached hereto.] 

10. Using the 1987-88 data as a base, identify the number 

and percentage of “at risk” children in the Hartford Public 

Schools who must, of necessity, attend school at a location 

outside the existing Hartford School District lines in order to 

address the concentration of "at risk” children in the Hartford 

Public Schools in accordance with the requirements of the 

Constitution. Also identify the specific criteria which must be 

used to identify the pool of Hartford students from which those 

who would be required to attend schools in the suburban school 

districts must be chosen so as to address the concentration of 

"at risk” children in the Hartford Public Schools. 

  

RESPONSE: Objection [Please see plaintiffs’ objection to 

Interrogatory 10, Plaintiffs’ Objections To Interrogatories, 

Filed September 20, 1990, attached hereto.] 

MINIMALLY ADEQUATE EDUCATION 

11. Please identify each and every statistic the 
plaintiffs’ will rely on at trial to support any claim they 

intend to make that the educational "inputs” (i.e. resources, 
staff, facilities, curriculum, etc.) in the Hartford Public 

Schools are so deficient that the children in Hartford are being 

denied a "minimally adequate education.” For each such fact 

specify the source(s) and/or name and address of the person(s) 

that will be called upon to attest to that statistic at trial. 

RESPONSE: [Please see response to Interrogatory 13.] 
  

12. Please identify each and every statistic, other than the 

results of the Mastery Test, which the plaintiffs will rely on at 

trial to support any claim they intend to make that children in 
Hartford are being denied a "minimally adequate education’ 

 



  

-iD 

because of the educational "outputs" for Hartford. For each such 
fact specify the source(s) and/or name and address of-the 
person(s) that will be called upon to attest to-that statistic at- 
trial. 

  

RESPONSE: [Please see response to Interrogatory 14.) 

EQUAL, EDUCATION 
  

13. Please identify each and every category of educational 
“inputs” which the plaintiffs will rely on at trial in their 
effort to establish that the educational “inputs” in Hartford are 
not equal to the educational "inputs” of the suburban school 
districts. For each such category identify each and every 
statistical comparison between Hartford and any or all of the 
suburban school districts which the plaintiffs will rely on to 
show the alleged inequality. For each such comparison identify 
the source(s) and/or name and address of the person(s) that will 
be called upon to attest to the accuracy of that statistical 
comparison at trial. 

RESPONSE: As of the date of this response, plaintiffs are 
  

compiling data and information on disparities and inequities in 

"educational inputs” and resources among Hartford and the 

surrounding districts. This data may include, but may not be 

limited to comparisons in the following areas: 

a. Facilities -- data may include, but may not be 
limited to comparisons of the condition and size of 
school buildings, the condition and size of school 
grounds, overcrowding and school capacity, 
maintenance, the availability of specific 
instructional facilities and physical education 
facilities, and special function areas (e.g. types 
of counselling, libraries); 

b. Equipment and Supplies; 

c. Personnel -- data may include, but may not be 
limited to comparisons of student teacher ratios, 
teaching staff characteristics, and non-teacher 
staff number and characteristics; 

 



  

-: 33 

d. Curriculum -- data may include, but may not be 
limited to comparisons of course offerings, 
textbooks and course--levels, and special programs; 

e. Extracurricular Opportunities; and 

f. School experience -- data may include, but may not 
be limited to comparisons of counselling services, 
disciplinary rates, absentee rates, retention 
rates, tardy rates, and the concentration of 
poverty. TTT = : : : 

At the present time, plaintiffs’ investigation and analysis 

of these categories has not been completed. The data and 

information concerning disparity in “inputs” upon which 

plaintiffs rely is equally available to defendants. 

Nevertheless, plaintiffs will disclose such information in a 

timely manner prior to trial. 

14. Please identify each and every category of educational 
"outputs” other than the Mastery Test, which the plaintiffs will 
rely on at trial in their effort to establish that the 
educational “outputs” in Hartford are not equal to the 
educational “outputs” of the suburban school districts. For each 
such category identify each and every statistical comparison 
between Hartford and any one or all of the suburban school 
districts which the plaintiffs will rely on to show the alleged 
inequality. For each such comparison identify the source(s) 
and/or name and address of the person(s) that will be called upon 
to attest to the accuracy of that statistical comparison at 
trial. 

RESPONSE: As of the date of this response, plaintiffs are 
  

compiling data and information on disparities and inequities in 

"educational outputs” and other measures of achievement or 

educational quality among Hartford and the surrounding districts, 

including but not limited to the following areas of comparison: 

dropout rates and percentage of students receiving a diploma; 

 



PSAT and SAT scores; college attendance; employment outcomes; and 

career and life outcomes. 

At the present time, plaintiffs’ investigation and analysis 

of these categories has not been completed. Plaintiffs are also 

exploring other social, economic and psychological measures. 

Plaintiffs have not yet identified who will present analyses of _ 

such data at trial, other than those experts listed in 

plaintiffs’ response to Interrogatories 18 and 19. Plaintiffs 

will disclose such information in a timely manner prior to trial. 

OTHER 

15. Please identify each and every study, other document, 
or information or person the plaintiffs will rely upon or call 
upon at trial to support the claim that better integration will 
improve the performance of urban black, Hispanic and/or socio- 
economically disadvantaged children on standardized tests such as 
the Mastery Test. 

RESPONSE: As set out in the complaint, racial and economic   

isolation in the schools adversely affects both educational 

attainment and the life chances of children. The studies, 

documents, information, and persons upon whom the plaintiffs will 

rely at trial may include, but are not limited to information 

listed in the response to Interrogatory 19 and the following: 

Crain, R.L., and Braddock, J.H., McPartland, J.M., “A 
Long Term View of School Desegregation: Some Recent 
Studies of Graduates as Adults,” 66 Phi Delta Kappan 
259-264 (1984); 

   



  

--35- 

Crain, R.L., and Hawes, J.A., Miller, R.L., Peichert, 
J.R., "Finding Niches: Desegregated Students Sixteen 
Years Later,” R-3243-NIE, Rand (January,-1985); - 

Crain, R.L., and Strauss, J., “School Desegregation and 
Black Occupational Attainments: Results from a Long- 
term Experiment,” Reprinted from CSOS Report No. 359 
(1985); 

Levine, D.U., Keeny, J., Kukuk, C+;-O/Hara Fort, —-B., 
Mares, K.R., Stephenson, R.S., "Concentrated Poverty 
and Reading Achievement in Seven Big Cities,” 11 Urban 
Review 63 (1979). — a RT GS RE i a Se 

"Poverty, Achievement and the Distribution of 
Compensatory Education Services,” National Assessment 
of Chapter 1, Office of Educational Research and 
Improvement, U.S. Dept. of Ed. (1986); 

"Report on Negative Factors Affecting the Learning 
Process,” Hartford Board of Education (1987); 

Connecticut State Department of Education (various 
reports, past and present, including but not limited to 
reports on racial, ethnic, and economic segregation, 
racial balance, school resources, and educational 
outcomes). 

See also reports listed in Plaintiffs’ Identification of Expert Witnesses Pursuant to Practice Book §220 (D) (January 15, 1991), attached hereto. 

  

  

  

16. Please identify each and every study, other document, or information or person the plaintiffs will rely upon or call upon at trial to support the claim that better integration will improve the performance of urban black, Hispanic and/or socio- economically disadvantaged children on any basis other than 
standardized tests. 

RESPONSE: [Please see response to Interrogatory 15.)   

17. Please describe the precise mathematical formula used by the plaintiffs to compute the ratios set forth in paragraph 42 of the complaint. 

  

RESPONSE: Plaintiffs recognize that the computation set out in 

142 of the Complaint may be inaccurate. Plaintiffs have 

 



  

-'36 = 

indicated their willingness “to ‘discuss stipulation as to 

aggregate city vs. suburban mastery test scores. 

EXPERT WITNESSES 
  

18. Please specify the name and address of each and every 
person the plaintiffs expect to call as an expert witness at 
trial. For each such person please provide the following: 

a) The date on which that person is expected to 
complete the review, analysis, or consideration 
necessary to formulate the opinions which that 
person will be called upon to offer at trial; 

b) The subject matter upon which that person is 
expected to testify; and 

c) The substance of the facts and opinions to which 
that person is expected to testify and a summary of 
the grounds for each opinion. 

  

RESPONSE: On January 15, 1991, the plaintiffs disclosed their 

initial list of expert witnesses anticipated to testify at trial, 

pursuant to Practice Book §220 (D), as modified by this Court's 

Order of October 31, 1990 and the parties’ Joint Motion for 

Extension of Time to Disclose Expert Witnesses filed December 3, 

1990. See Plaintiffs’ Tdentification of xpert Wi tne      8S8E§    

Pursuant to Practice Book, §220 (D) (January 15, 1991); athe] fuels : 

incorporated herein by reference. In addition, plaintiffs have 

identified other possible witnesses who may testify at the trial 

in this action, but whose analyses are not sufficiently complete 

to respond to defendants’ interrogatory or to confirm whether 

plaintiffs expect to call such witnesses. Additiondexpert 

 



  

witnesses will be identified as set out in the parties* December --——-:d= 

- 37 « 

3, 1990 Joint Motion, as they become available. 

DATA COMPILATIONS 
  

19. In the event the plaintiffs intend to offer into 

evidence at trial any data compilations or analyses which have 

been produced by the plaintiffs or on the plaintiffs’ behalf by - 

any mechanical or electronic means please describe the nature and 

results of each such compilation and/or analysis and provide the 

following additional information. 

a) 

b) 

c) 

d) 

The specific kind of hardware used to produce each 
compilation and/or analysis; 

The specific software package or programming 

language which was used to produce each compilation 

and/or analysis; 

A complete list of all specific data elements used 
to produce each compilation and/or analysis; 

The specific methods of analyses and/or questions 
used to create the data base-for each compilation 
and/or analysis; 

A complete list of the specific questions, tests, 
measures, or other means of analysis applied to the 
data base to produce each compilation and/or 
analysis; 

Any and all other information the defendants would 
need to duplicate the compilation or analysis; 

The name, address, educational background and role 
of each and every person who participated in the 
development of the data base and/or program used to 
analyze the data for each compilation and/or 
analysis; and 

The name and address of each and every person 
expected to testify at trial who examined the 
results of the compilation or analysis and who 
reached any conclusions in whole or in part from 
those results regarding the defendants’ compliance 

 



  

- 38 = 

with thé Yaw, and, for each such person, provide a 
complete list of the conclusions that person 

reached. 

RESPONSE: Plaintiffs may offer into evidence compilations and 
  

analyses including but not limited to analyses of data on the 

educational and long-term effects of racial, ethnic, and economic 

segregation. In addition, plaintiffs may offer into evidence 

compilations and analyses on other elements of plaintiffs’ case, 

including the disparity in resources between Hartford and the 

suburban schools. Plaintiffs are still planning research and 

compiling and analyzing data drawn from the following sources and 

will provide more detailed information in such research when it 

is available. Such information will be provided in a timely 

fashion, in advance of trial. 

The data sets which form the basis for the analyses of the 

educational and long-term effects of racial, ethnic, and economic 

segregation include, but will not be limited to the following: 

(1) The National Longitudinal Survey of Labor Force 
Behavior -- Youth Cohort, an annual survey 
sponsored by the U.S. Departments of Labor and 
Defense of 12,686 young persons throughout the 
United States. Data available and used in this 
research begins in 1979 and extends through 1987. 

(2) The National Survey of Black Americans, a national 
survey of 2,107 African Americans who are 18 years 
of age or older. The survey was designed and 
conducted by the survey Research Center, Institute 
for Social Research at the University of Michigan. 
Data was collected between 1979 and 1980. 

(3) The High School and Beyond Study, a national 
longitudinal probability sample of more than 58,000 

 



1980 high school sophomores and seniors. Surveys __ 
were conducted in 1980, 1982, 1984, and 1986. 

(4) The National Longitudinal Survey of Employers, a 
national probability sample of 4,087 employers. 
Surveys were conducted in the 1970's. 

Further sources of data are set out in Plaintiffs'’ 

Identification of Expert Witnesses Pursuant to Practice Book §220 

(D), served on January 15,1991, and incorporated herein by 

reference. gt 

Plaintiffs are currently unable to specify the kind of 

hardware used to produce each analysis, the specific software 

package used, the complete list of specific data elements used; 

and specific methods of analysis. Plaintiffs will provide such 

information in a timely fashion as it becomes available to the 

plaintiffs, in advance of trial. 

PLAINTIFFS, MILO SHEFF, ET AL 

  

MARIANNE ENGELMAN LADO PHILIP D. TEGELER 

RONALD ELLIS CONNECTICUT CIVIL LIBERTIES 

NAACP Legal Defense & UNION FOUNDATION 
Educational Fund, Inc. 32 Grand Street 

99 Hudson Street Hartford, CT 06106 
New York, NY 10013 (203) 247-9823 
(212) 219-1900 Juris No. 102537 
Pro Hac Vice  



MARTHA STONE WESLEY W. HORTON 

CONNECTICUT CIVIL LIBERTIES MOLLER, HORTON & 

UNION FOUNDATION FINEBERG, P.C. 

32 Grand Street 90 Gillett Street 

Hartford, CT 06106 Hartford, CT 06105 
(203) 247-9823 (203) 522-8338 
Juris No. 61506 Juris No. 38478 

WILFRED RODRIGUEZ JOHN BRITTAIN 

HISPANIC ADVOCACY PROJECT UNIVERSITY OF CONNECTICUT 

Neighborhood Legal Services SCHOOL OF LAW 

1229 Albany Avenue 65 Elizabeth Street 
Hartford, CT 06102 Hartford, CT 06105 
(203) 278-6850 (203) 241-4664 
Juris No. 302827 Juris No. 101153 

ADAM S. COHEN JENNY RIVERA 

HELEN HERSHKOFF PUERTO RICAN LEGAL 

JOHN A. POWELL DEFENSE AND EDUCATIONAL FUND 

AMERICAN CIVIL LIBERTIES 99 Hudson Street 

UNION FOUNDATION New York, NY 10013 
132 West 43rd Street (212) 219-3360 
New York, NY 10036 Pro Hac Vice 

(212) 944-9800 
Pro Hac Vice