Rackley v. Board of Trustees of Orangeburg Regional Hospital Brief and Appendix for Appellants

Public Court Documents
January 1, 1962

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Date is approximate.

Topic
- Economic Justice
Notable Person
- Jack Greenberg
Organization
- NAACP Legal and Educational Defense Fund, Inc.
Collection
- Brief Collection
Taxonomy
Identifier
- 9b3725c4-c19a-ee11-be36-6045bdeb8873

Cite this item

Case Files, Sheff v. O'Neill Hardbacks. Letter from Horton to court, 1995. 9be6d947-a446-f011-8779-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/666e0984-04a4-446d-9e8e-12dac3d9c77a/letter-from-horton-to-court. Accessed August 19, 2025.

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    MOLLER, HORTON & SHIELDS, P.C. 
ATTORNEYS AT LAW 

90 GILLETT STREET 

HARTFORD, CONNECTICUT 06105 

SUSAN M. CORMIER TELEPHONE 

WESLEY W. HORTON (203) 522-8338 
KIMBERLY A. KNOX TELECOPIER 

WILLIAM R. MOLLER* (203) 728-0401 
KAREN L. MURDOCH 

CHRISTY SCOTT 
ROBERT M. SHIELDS, JR. 1995 

*ALSO ADMITTED IN DISTRICT OF COLUMBIA 

Michéle Angers, Deputy Chief Clerk 
SUPREME and APPELLATE COURTS 

Drawer Z, Station A 
Hartford, CT 06106 

Re: Sheff, et al. v. O’Neill, et al. 
S.C. 15255 

Dear Ms. Angers: 

The plaintiffs request permission to file a 65-page brief in 
support of their appeal. The plaintiffs have already reduced the 
size of their draft, but the voluminous nature of the record and 
the complexity of the legal issues requires a 65-page brief. 

The plaintiffs filed a 551-page revised proposed findings of 
fact but the trial court found only a small percentage of them. 
Therefore a part of the brief must be devoted to a discussion of 
demonstrating the undisputed nature of many of the proposed 
findings. In addition, the issues on the merits require an 
extensive analysis of the Geisler factors, especially 
sociological and economic considerations. 

Among the issues discussed are the meaning of "segregation" 
and "discrimination" in Article First, §20, the meaning of state 
action as it pertains to education, the relevance of Horton Vv. 
Meskill I and III to this case and other matters of great public 
importance. A 65-page brief is warranted in this unusual case. 

  

  

Very truly yours, 

OPPOSING COUNSEL CONSENTS 
TO THE GRANTING OF THIS REQUEST 

Wesley W# Horton 

WWH: jt  



  

  
  

    

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 
following counsel of record on July 25, 1995: 

John C. Brittain, Esq. 
UCONN LAW SCHOOL 

65 Elizabeth Street 
Hartford, CT 06105 
(203) 241-4664 

Martha Stone, Esq. 
Philip D. Tegeler, Esq. 
CCLU 

32 Grand Street 

Hartford, CT 06106 

(203) 247-9823 

Christopher Hansen, Esq. 
ACLU 

132 West 43rd Street 

New York, NY 10036 
(212) 944-9800 

Marianne Engelman Lado, Esq. 
Dennis D. Parker, Esq. 
NAACP LEGAL DEFENSE FUND 
99 Hudson Street 

New York, NY 10013 

(212) 219-1900 

Sandra Del Valle, Esq. 
PUERTO RICAN LEGAL DEFENSE & 

EDUCATION FUND 
99 Hudson Street 
New York, NY 10013 

(212) 219-3360 

Wilfred Rodriguez, Esq. 
NEIGHBORHOOD LEGAL SERVICES 

1229 Albany Avenue 
Hartford, CT 106102 

(203) :297-0760 

Bernard McGovern, Esq. 
Martha Watts Prestley, Esq. 
OFFICE OF THE ATTORNEY GENERAL 
110 Sherman Street 
Hartford, CT. 056105 
(203) 566-7173 

Gregory D’Auria, Esq. 
OFFICE OF THE ATTORNEY GENERAL 
55 Elm Street 

Hartford, CT 06106 

(203) 566-4990 

Wes . rton 

  
 



      

S.C. 15255 

MILO SHEFF, ET Al. $ SUPREME COURT 

VS. 3 

WILLIAM A. O’NEILL, ET AL. s JULY 25, 1995 

MOTION FOR EXTENSION OF TIME 
  

The plaintiffs move for a 5-day extension of time in which the 

parties will file their briefs. 

i. Brief History 
  

This case involves the constitutional right of students in the 

Hartford area to equal educational opportunity. 

2a Specific Facts 
  

The Supreme Court issued an order sua sponte on May 11, 1995 that 

the trial court file a finding of facts by June 15, 1995, the 

plaintiffs file their brief by July 27, .19295, the defendants file 

their brief by August: 24, 1995, and the plaintiffs file their reply 

brief by September 7, 1995. Thereafter the time for the trial court 

to file its finding was extended 12 days until June 27, 1995. 

The record in this case is voluminous and the issues are of great 

importance. The plaintiffs have been working diligently on their 

brief but need 5 more days to put it in final form for filing. 
———— 

rn ——— I~ ~~, Jr —~— 

Fad si >, 4 

OPPOSING COUNSEL CONSENTS TQ 

THE GRANTING OF THIS MOT ION 

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MOLLER, HORTON & SHIELDS, P.C. 

ATTORNEYS AT Law 

90 GILLETT STREET 

HARTFORD, CONNECTICUT 06105 

  

SUSAN M. CORMIER TELEPHONE 
WESLEY W. HORTON (203) 522-8338 
KIMBERLY A. KNOX TELECOPIER 
WILLIAM R. MOLLER* (203) 728-0401 
KAREN L. MURDOCH 

CHRISTY SCOTT 
ROBERT M. SHIELDS, JR. 

July 25, 1995 ’ 

*ALSO ADMITTED IN DISTRICT OF COLUMBIA 

Michéle Angers, Deputy Chief Clerk 
SUPREME and APPELLATE COURTS 

Drawer Z, Station A 
Hartford, CT 06106 

Re: Sheff, et al. v. O’Neill, et al. 

S.C. 15255 

Dear Ms. Angers: 

The plaintiffs request permission to file a 65-page brief in 
support of their appeal. The plaintiffs have already reduced the 
size of their draft, but the voluminous nature of the record and 
the complexity of the legal issues requires a 65-page brief. 

The plaintiffs filed a 551-page revised proposed findings of 
fact but the trial court found only a small percentage of them. 

Therefore a part of the brief must be devoted to a discussion of 
demonstrating the undisputed nature of many of the proposed 
findings. In addition, the issues on the merits require an 
extensive analysis of the Geisler factors, especially 
sociological and economic considerations. 

Among the issues discussed are the meaning of "segregation" 
and "discrimination" in Article First, §20, the meaning of state 

action as it pertains to education, the relevance of Horton Vv. 
Meskill T and III to this case and other matters of great public 
importance. A 65-page brief is warranted in this unusual case. 

  

  

Very truly yours, 
OPPOSING COUNSEL CONSENTS 
TO THE GRANTING OF THIS REQUEST m—— 

Wesley W# Horton 

WWH: jt 

 



  

  

  

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 
following counsel of record on July 25, 1995: 

John C. Brittain, Esq. 
UCONN LAW SCHOOL 

65 Elizabeth Street 
Hartford, CT 06105 

(203) 241-4664 

Martha Stone, Esq. 
Philip D. Tegeler, Esq. 
CCLU 

32 Grand Street 
Hartford, CT 06106 
(203) 247-9823 

Christopher Hansen, Esq. 
ACLU 

132 West 43rd Street 
New York, NY 10036 

(212) 944-9800 

Marianne Engelman Lado, Esq. 
Dennis D. Parker, Esq. 
NAACP LEGAL DEFENSE FUND 
99 Hudson Street 
New York, NY 10013 
(212) 219-1900 

Sandra Del Valle, Esq. 
PUERTO RICAN LEGAL DEFENSE & 

EDUCATION FUND 

99 Hudson Street 
New York, NY 10013 
(212) 219-3360 

Wilfred Rodriguez, Esq. 
NEIGHBORHOOD LEGAL SERVICES 
1229 Albany Avenue 
Hartford, 'CT 06102 
(203) 297-0760 

Bernard McGovern, Esq. 
Martha Watts Prestley, Esq. 
OFFICE OF THE ATTORNEY GENERAL 
110 Sherman Street 
Hartford, CT 06105 
(203) 566-7173 

Gregory D’Auria, Esq. 
OFFICE OF THE ATTORNEY GENERAL 

55 Elm Street 
Bartford, CT 06106 
(203) 566-4990 

Wes. : rton

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Rackley v. Board of Trustees of Orangeburg Regional Hospital Brief and Appendix for Appellants

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