Correspondence from Asst. AG Whelan to Tegeler; Notices of Deposition and Deposition Subpoenas (Redacted)

     [||0c11f40f-b1ce-4486-ad1f-b6278c6b6427||] MacKenzie Hall 

110 Sherman Street 

Hartford, CT 06105 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

  

FAX (203) 523-5536 

Office of The Attorney General Tel: "BEE=7173 

State of Connecticut 
Aprll-le6, 1992 

Philip Tegeler, Esqg. 
Connecticut Civil Liberties Union 

32 Grand Street 

Hartford, CP 06106 

  

RZ: ‘Sheff v., O'Neill 

Dear Phil: 

Enclosed please find notices of deposition and subpoenae 
duces tecum for the plaintiffs' expert witnesses, Although I am 
presently available on the dates indicated in the deposition 
notices I recognize that some, if not all, of the depositions 
will need to be rescheduled in order to accommodate practical 
considerations. My thinking is that the issuance of these 
notices will force both sides to immediately address the 
practical scheduling problems. 

I would ask that you send me a letter confirming deposition 
dates which are acceptable to you and offering alternate dates 
for those which are not. If you exercise the option to insist 
that the deposition of any expert be taken in their home state we 
will, of course, have to make special arrangements. In these 

instances my plan is to arrive the night before the deposition 
and leave the day after so we will have ample time to complete 

the deposition. 

At. the moment 1 can say for Certain that 1 will not be able 
to conduct any depositions between May 18 and May 28, 1992 
because of a three day hearing I have scheduled during that time 
period. I plan to take a week's vacation in June or July but 
these plans are not yet final. This leaves me fairly flexible 
throughout the months of June and July —-- at least at the moment. 

The sooner I hear from you regarding firm dates the more 
likely it is that we will avoid scheduling conflicts that might 
prolong the taking of the depositions. 

 



  

: y 
a 

April 16, 1992 

Page 2 

We look forward to hearing from you. 

Very truly yours, 

RICHARD BLUMENTHAL 
ATTORNEY/ G 

    

    BY: / ohn R. Whelan 
Assigtant Attorney General 

JRW/mu of 

CC Counsel of Record 

 



      

Cv. 89-03609778 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

V. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL/¢, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Jamills 

Henry Braddock, III, Center for Social Inquiry, 3505 North 

Charles Street, Baltimore, MD 21218. Said deposition will begin 

at 9:30 a.m. on the 6th day of May, 1992 and continue on such 

additional days as may be necessary to complete the deposition. 

The deposition will be conducted before an appropriate officer in 

the conference room of the Office of the Attorney General, 110 

Sherman Street, Hartford, CT. The deposition will be conducted 

in accordance with the laws and rules of practice of the State of 

Connecticut. 

  
 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 
aki gr 

By: V% 4H Ae 
  

John R. Whelan 
Asgistant Attorney General 
1Y0 Sherman Street 
Hartford, Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April-d, 1992: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 
Hartford, CT 06106 

  
 



      

Wesley W. Horton, Esq. 

Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 

  

  

John R. whelan 
Assistant Attorney General 

  
 



      

SUBPOENA DUCES TECUM 
  

TO: Jamills Henry Braddock, III 
Center for Social Inquiry 
3505 North Charles Street 
Balitmore, MD 21218 

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 9:30 a.m. on the 
6th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 

Hartford, Connecticut. : 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this 4 # any of? April, 1992: 

eh onl jel! 
John R. Whelan 
Commissioner of the Superior Court 

  

4 

v/ CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
April 4 , 1992: 

ZY 

Jel 
   

  

John R. Lf 
Assistant Attorney General 

if 

  

 



      

Cv 89-0360977S 

MILO SHEFP, et al SUPERIOR COURT 

J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL //, 1982 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of 

Christopher Collier, 876 Orange Center Road, Orange, CT 06477. 

Said deposition will begin at 9:30 a.m. on the 8th day of May, 

1992 and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  

 



  

  

    

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 
ATTORNEY ENERAL 

(0 

  

By: 
  

Joh R. gn 
Asgistant Attorney General 
110 Sherman Street 

fiartford, Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
Aprid= l/l. , 1992: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 
Hartford, CT 06106 

  

 



  

  

    

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CTP 06105 

Ruben: Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A, Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, ,NY 10036 

   
  

John R. Whelan 
AsSistant Attorney General 

  
 



      

SUBPOENA DUCES TECUM 
  

TO: Christopher Collier 

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 9:30 a.m. on the 
8th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this [EC day of April, 1992 

ite J) Miz. 
John R. Whelan 
Commissioner of the Superior Court 

  

/ CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
April 1992: 

iY Aa 
  

JohA”R. Whelan 
AsSistant Attorney General 
vd 

  

 



    

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A, O'NEILL, et al 

Defendants APRIL/(, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Robert 

L. Crain, Professor of Sociology and Education, Teachers College, 

Columbia University, 525 West 120th Street, New York, NY. Said 

deposition will begin at 9:30 a.m. on the 7th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

   



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

Ge a tr 

By: i A J PA 
  

John R. Whelan 
Assistant Attorney General 

7/110 Sherman Street 
/ Haritord Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April / ; 19923 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 
Hartford, CT 06106 

  

 



        

      

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036 

I) Ai 
Johd R. WHelan 
Assistant Attorney General 

    

  

  

7 

  

 



      

SUBPOENA DUCES TECUM 
  

TO: Robert L. Crain 
Professor of Sociology and Education 
Teacher's College 
Columbia University 
525 West 120th Street 
New York, NY 

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 9:30 a.m. on the 
7th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this (44 aay of April, 1992 

A J 
John /R. Whelan 
Commissioner of the Superior Court 

/ 4 

  

  

Vi 

’ CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
Aprils i, 1992: 

Lif 

  

  

John R. Whelan 
Assistant Attorney General i: 

  
 



  

  

    

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A, O'NEILL, et al 

Defendants APRIL , 1992 

  

NOTICE OF DEPOSITION 

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Marvin 

Dawkins, 17627 N.W. 62nd Place, North Hialeah, Florida. Said 

deposition will begin at 9:30 a.m. on the 12th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  

 



    

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICH: BLUMENTHAL 

ATTOR] 74 GENERAL 

By: [24 Vii 
Jon R. Whelan 
ASsistant Attorney General 
/110 Sherman Street 
Hartford, Connecticut 06105 
Telephone: 566-7173 

    CERTIFICATION 
  

This 1s to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April. 1992:   

| John Brittain, Esq. 
H University of Connecticut 

School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 

Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106       
 



  

  

    

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 1003 

    

  

  

LL Le 

John R. Whelan 
Assistant Attorney General 

   



      

SUBPOENA DUCES TECUM 
  

TO: Marvin Dawkins 

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 9:30 a.m. on the 
12th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER Pag OF THE LAW. 

   Dated at Hartford, this I day of gE 1992 

or Wy, 
John R. ‘Whelan 
fommissioner of the Superior Court 

  

// CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postag prepaid to all counsel of record on 
April 

  

  

JoRn R. Whelan 
Assistant Attorney General 

/ 

Vv 

  

 



      

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Va 

WILLIAM A, O'NEILL, et al 

Defendants APRIL, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Mary 

Kennedy, Director, National Center for Research on Teacher 

Evaluation, 513 Ardson Road, East Lansing, Michigan . Said 

deposition will begin at 9:30 a.m. on the 13th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  

 



    

You are invited to attend and cross-examine. 

By: 

FOR THE DEFENDANTS 

ATTORNEY BLUMENTHAL 

ATTORN So 

i A ln 
  

  

   

Ns 
Asgistant Attorney General 
140 Sherman Street 
artford, Connecticut 06105 

Telephone: 566-7173 

CERTIFICATION 
  

This 1s to certify that a copy of the foregoing was mailed 
postage, prepaid to the following counsel of record on 
April I 1992: 

    
John Brittain, Esq. 
University of Connecticut 
School of Law 

65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

  

 



  

  

    

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
14th Floor 
New York, NY-10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 We 43rd Street 
New Yor pd Soy A     
  

JGR’ R. Whklan 
Assistant Attorney General 

  

 



      

SUBPOENA DUCES TECUM 
  

TO: Mary Kennedy, Director 
National Center for Research on Teacher Evaluation 
513 Ardson Road 
East Lansing, Michigan 

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 9:30 a.m. on the 
13th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this i of April, 1992 

27 i 
John R. wi 
ommissioner of the Superior Court y: 

  

  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
bestaqge prepaid to all counsel of record on 
April ny 1992: 

Cif Nhl 
  

Joh R. Whelan 
Assistant Attorney General 

  

 



      

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A. O'NEILL, et al 

Defendants APRIL //, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of William 

Trent, EPS, 368 Education Building, 1310 South Sixth Street, 

Champagne, Illinois. Said deposition will begin at 9:30 a.m. on 

the 14th day of May, 1992 and continue on such additional days as 

may be necessary to complete the deposition. The deposition will 

be conducted before an appropriate officer in the conference room 

of the Office of the Attorney General, 110 Sherman Street, 

Hartford, CT. The deposition will be conducted in accordance 

with the laws and rules of practice of the State of Connecticut.     
 



  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

ATTORNE GENE ; 

By: Hei K 
Joh gs R. Whelan 
Adsistant Attorney General 
10 Sherman Street 

Hartford, Connecticut 06105 
Telephone: 566-7173 

  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
Poster prepaid to the following counsel of record on 
April // 1992: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106       
 



  

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
14th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
Ney’ York, 

  

  

Joefif R. Whelan 
‘Assistant Attorney General 

      
 



      

SUBPOENA DUCES TECUM 
  

TO: William Trent, EPS 
368 Education Building 
1310 South Sixth Street 
Champagne, Illinois 

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 9:30 a.m. on the 
14th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, sis 2itfans of April, 1992 

DIA 
J . Whelan 

Lommissioner of the Superior Court 

  

  

CERTIFICATION 
  

Pd 4 

/ 
L} 

This is to certify that a copy of the foregoing was mailed 
postage ,prepaid to all counsel of record on 
April / : 19921 

ATE    all 
  

Whelan 
I Attorney General 

if 

1/ 

  

 



  

  

    

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL /, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of 

Catherine E. Walsh, University of Massachusetts, 250 Stuart 

Street, Boston, MA. Said deposition will begin at 9:30 a.m. on 

the 2nd day of June, 1992 and continue on such additional days as 

may be necessary to complete the deposition. The deposition will 

be conducted before an appropriate officer in the conference room 

of the Office of the Attorney General, 110 Sherman Street, 

Hartford, CT. The deposition will be conducted in accordance 

with the laws and rules of practice of the State of Connecticut. 

  

 



  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

  

By: 
  

fo R. %helan 
Assistant Attorney General 

10 Sherman Street 
23) Soe Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
    

This is to certify that a copy of the foregoing was mailed 
| postag repaid to the following counsel of record on 

April Se 1992; 

John Brittain, Esq. 
University of Connecticut | 
School of Law 
65 Elizabeth Street 
Hartford, Cr 06105 

Wilfred Rodriguez, Esq 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 

4 Hartford, CT 06112 

  
Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 
Hartford, CT 06106       
 



            

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 

American Civil Liberties Union 
132 West 43rd Street 

  

  

7 

Assistant Attorney General 
7 

V Vd 

  

 



        

SUBPOENA DUCES TECUM 
  

TO: Catherine E. Walsh 
University of Massachusetts 
250 Stuart Street 
Boston, MA 

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 9:30 a.m. on the 
2nd day of June, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, enis ff gay of April, 1 

LA 778 
John 'R. Whelan 
Commissioner of the Superior Court 

    

  

rf 

£ CERTIFICATION 

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
April, , 7 

  

   LLIN, 
Joh” R. Whelan’ 
  

Assistant Attorney General 

  
 



  

  

      

CV 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A. O'NEILL, et al 

Defendants APRILZ , 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned] 

case that the defendants intend to take the deposition of Hernan 

LaFontaine, 181 North Beacon Street, Hartford, CT. Said 

deposition will begin at 9:30 a.m. on the 29th day of May, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



  

    

    

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

  

ATTORNE Ee  / 

gE gl 

y 
By: TU 

Jghn R. Whelan 
AsSistant Attorney General 
10 Sherman Street 
artford, Connecticut 06105 

Telephone: 566-7173 

CERTIFICATION 
  

This 1s to certify that a copy of the foregoing was mailed 
postage ,prepaid to the following counsel of record on 
ARE Co 1992; 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

Wilfred Rodriquez, Esq 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, Cr 06112 

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

  

 



  

  
    

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
14th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 

Now Jock, BY 036 

L yy 

  

  

John R. Whelan 
‘Assistant Attorney General 

  
 



      

SUBPOENA DUCES TECUM 
  

TO: Hernan LaFontaine 

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 9:30 a.m. on the 
29th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, a, ZENRLTY OF THE LAW. 

Dated at Hartford, this / oe of April, 1992 

yA 
dh Whelan 
Commissioner of the Superior Court 

  

CERTIFICATION 
  : 

This is to certify that a copy of the foregoing was mailed 
a prepaid to all counsel of record on 
= y. 1992; / 

WIJ) 
  

yo Aindian 
Assistant Attorney General 

  

 



    

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve 

WILLIAM A, O'NEILL, et al 

Defendants APRIL(S, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Yale 

Rabin, 9 Farrar Street, Cambridge, MA. Said deposition will 

begin at 9:30 a.m. on the 3rd day of June, 1992 and continue on 

such additional days as may be necessary to complete the 

deposition. The deposition will be conducted before an 

appropriate officer in the conference room of the Office of the 

Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

   



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RISgpun, BLUMENTHAL 
ATTOR Ad A 

By: Uh dA 
  

{2 R. le 
Agsistant Attorney General 

/, 10 Sherman Street 
Hartford, Connecticut 06105 
Telephone: 566-7173 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April 4 y 3992 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

  

 



  

    
  

    

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A, Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, Y 10036 

‘J      
  

John R. Whelan 
Assistant Attorney General 

     



      

SUBPOENA DUCES TECUM 
  

TO: Yale Rabin 

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 9:30 a.m. on the 
3rd day of June, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this /{ Yaay of April, 1992 

x7 / 

J Hi 
Johr{’R. Whelan 
Commissioner of the Superior Court 

  

  

CERTIFICATION 
  

Ly 

This is to certify that a copy of the foregoing was mailed 
postage prepsia to all counsel of record on 

  

  
/} 

Jon# Re Whelan 
Asgistant Attorney General 

0h 4 

  

 



  

  

  

  

  

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

V. 

WILLIAM A, O'NEILL, et al 

Defendants HA 1992 

  

NOTICE OF DEPOSITION 

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of John 

Allison, Capital Region Education Council, 599 Matianuck Avenue, 

Windsor, CT. Said deposition will begin at 9:30 a.m. on the 15th 

day of May, 1992 and continue on such additional days as may be 

necessary to complete the deposition. The deposition will be 

conducted before an appropriate officer in the conference room of 

the Office of the Attorney General, 110 Sherman Street, Hartford, 

CT. The deposition will be conducted in accordance with the laws 

and rules of practice of the State of Connecticut. 

{ 

      
 



  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

wr By: LZ, J AL A 
Join R. Whelan 
Assistant Attorney General 
110 Sherman Street 
Hartford, Connecticut 06105 
Telephone: 566-7173 

  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April J/g» 1992: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105     Wilfred Rodriguez, Esq | 
Hispanic Advocacy Project 

i Neighborhood Legal Services 
1 1229 Albany Avenue 

Hartford, CT 06112 
  

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 
Hartford, CT 06106 

  

    
 



      

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 

Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 

Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 nest 43rd Street 
New rk/ NY 7) 

  

14 Jb 
D7 2 ans 
  

Assistant Attorney General 

  
  
 



      

SUBPOENA DUCES TECUM 
  

TO: John Allison 
Capital Region Education Council 
599 Matianuck Avenue 
Windsor, CT 

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 9:30 a.m. on the 
15th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this 7 of April, 1992 

LY Mn 
Toh& R. Whelan 
Commissioner of the Superior Court 

   
  

7 CERTIFICATION 
4 
  

This 1s to certify that a copy of the foregoing was mailed 
Rpriny)/, 1892; to all counsel of record on 

2M    
  

73 R,/ Whelan 
Assistant Attorney General 

  

 



      

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A, O'NEILL, et al 

Defendants APRIL{, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Ruth 

Price, 196 Glengarry Road, Fairfield, CT. Said deposition will 

begin at 9:30 a.m. on the 11th day of May, 1992 and continue on 

such additional days as may be necessary to complete the 

deposition. The deposition will be conducted before an 

appropriate officer in the conference room of the Office of the 

Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  
 



  

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

rrporis BLUMENTHAL 
AT Y NE 7 Vi 

By: il 

A R. YH 
Adsistant Attorney General 
/110 Sherman Street 
Hartford, Connecticut 06105 
Telephone: 566-7173 

    
  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April // 21092: 

John Brittain, Esq. 
| University of Connecticut 
| School of Law 

65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106       
 



      

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

Julius L. Chambers, Esq 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New, ork, NY 10036 

aA 

  

  

Johp ‘R. Whelan 
Assistant Attorney General 

    
 



      

SUBPOENA DUCES TECUM 
  

TO: Ruth Price 

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 9:30 a.m. on the 
llth day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, a PENALTY OF THE LAW. 

Dated at Hartford, this day of April, 1992 

A 
John  R. Whelan 
/Commissioner of the Superior Court 

/ CERTIFICATION 

  

  

This 1s to certify that a copy of the foregoing was mailed 
ER, prepaid to all counsel of record on 

April // , 1992: 

Vi 7A 

  

  

Fol Whelan 
Assistant Attorney General 

  

 



          

SUBPOENA DUCES TECUM 
  

TO: Charles V. Willie, Ph.D. 
Harvard University 
Graduate School of Education 
Monroe C. Gutman Library 
Cambridge, MA 

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 9:30 a.m. on the 
1st day of June, 1992, or to such day thereafter and within 60 
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 office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this «lf gay of or 1992 

Gd) 9) ( 
John R. Vc 
Compissioner of the Superior Court 
ir 

/ 

  

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
posta ° prepaid to all counsel of record on 

TA 
  

Joh®’R. Whelan 
Assistant Attorney General 

  

 



  

  
  

    

Cv 89-0360977S 

MILO SHEFF, et al SUPERIOR COURT 
J.D. HARTFORD/NEW 

Plaintiffs NEW BRITAIN AT HARTFORD 

Ve. 

WILLIAM A. O'NEILL, et al 

Defendants APRIL//, 1992 

NOTICE OF DEPOSITION 
  

Notice is hereby given to the parties in the above captioned 

case that the defendants intend to take the deposition of Charles 

V. Willie, Ph.D., Harvard University, Graduate School of 

Education, Monroe C. Gutman Library, Cambridge, MA. Said 

deposition will begin at 9:30 a.m. on the lst day of June, 1992 

and continue on such additional days as may be necessary to 

complete the deposition. The deposition will be conducted before 

an appropriate officer in the conference room of the Office of 

the Attorney General, 110 Sherman Street, Hartford, CT. The 

deposition will be conducted in accordance with the laws and 

rules of practice of the State of Connecticut. 

  

 



      

You are invited to attend and cross-examine. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

wi LAI 
  

G 

Join R. Whelan 
Adsistant Attorney General 

/A10 Sherman Street 
’/ Hartford, Connecticut 06105 

Telephone: 566-7173 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to the following counsel of record on 
April 7, 19923 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

  
 



  

    

      

Wesley W. Horton, Esq. 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense and Education Fund 
99 Hudson Street 
14th Floor 
New York, NY 10013 

Julius L. Chambers, Esg 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A, Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 

          
  

John AK. WHelan 
Agsistant Attorney General 

Wd 

  

 



  

—
—
 

    

SUBPOENA DUCES TECUM 
  

TO: Jamills Henry Braddock, III 
Center for Social Inquiry 
3505 North Charles Street 
Balitmore, MD 21218 

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 9:30 a.m. on the 
6th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed | 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this 64 aay of April, 1992 

UA Ll 
  

  

  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
April 4 , 1992: 

{ Hit!    
  

Jopn/R. Whelan 
Assistant Attorney General 

/ 

  
 



      

SUBPOENA DUCES TECUM 
  

TO: William Trent, EPS 
368 Education Building 
1310 South Sixth Street 
Champagne, Illinois 

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 9:30 a.m. on the 
14th day of May, 1992, or to such day thereafter and within 60 
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 Office | 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed | 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of | 
formulating or confirming the opinions which you are expected to | 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this (4 day of April, 1992 

      @R. Whelan 
J ommissioner of the Superior Court 

/ ri 

5 CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage ,prepaid to all counsel of record on 
april) 1992;        
     

“R. elan 
istant Attorney General 

  

  

 



    

    

SUBPOENA DUCES TECUM 
  

TO: Robert L. Crain 
Professor of Sociology and Education 
Teacher's College 
Columbia University 
525 West 120th Street 
New York, NY 

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 9:30 a.m. on the 
7th day of May, 1992, or to such day thereafter and within 60 
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 Office 
of the Attorney General (Conference Room), 110 Sherman Street, 
Hartford, Connecticut. 

  

Pursuant to Practice Book § 245(c) you are further directed | 
to produce and permit inspection and copying of the following 
material on or before the date of your deposition: All 
materials in your possession or control relating to studies of 
Hartford and/or its suburban cities or towns which you have 
conducted or which you have relied on for the purpose of 
formulating or confirming the opinions which you are expected to 
offer at trial; and all materials in your possession or control 
relating to other studies which you have conducted the results 
of which you intend to rely on to support the opinions which you | 
are expected to offer at trial. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, this Zod any of April, 1992 

UA Mi 
  

issioner of the Superior Court 

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed 
postage prepaid to all counsel of record on 
April ol 1992: 

i 
/ 7 
{ { 

! 

x Hh 

Joh R. Whelan 
Asgistant Attorney General 

/ 

    

  

 



FOUNDATION 
Thirty Two Grafd Street, Hartford, CT 06106 

A 

Ms. Marianne Lado 

NAACP Legal Defense Fund 

® 99 Hudson Street 
New York, NY 10013 

An affiliate of The American 

Civil Liberties Union Foundation LhollihdbeaBdhddiohdidd ded [||0c11f40f-b1ce-4486-ad1f-b6278c6b6427||]