Letter from Moller, Horton & Shields, P.C. to court RE: Preparation of Record

    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. 29 ; 1995 

*ALSO ADMITTED IN DISTRICT OF COLUMBIA 

Michele Angers, Deputy Chief Clerk 
SUPREME and APPELLATE COURTS 

Drawer D, Station A 
Hartford, CT #06106 

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

Dear Ms. Angers: 

To confirm our telephone conversation yesterday, the 
plaintiffs would appreciate it if you could prepare the record as 
soon as possible. The plaintiffs are in full agreement with 
Attorney D’Auria’s attached letter. 

Very truly yours, 

Wesley W. Horto 

vr yr 

WH: jt 
cc: All Counsel of Record 

 



  

55 Elm Street 

P.O. Box 120 

Hartford, CT 06141-0120 

(203) 566-2026 

Office of The Attorney General Tel. (203) 566-4990 

State of Connecticut 
June 20, 1995 

RICHARD BLUMENTHAL 
ATTORNEY GENERAL 

  

Attorney Wesley Horton 
Moller, Horton and Shields 
90 Gillette Street 
Hartford, CT 06106 

RE: Sheff v. 0’Neill (S.C. 15255) 
  

Dear Wes: 

As we discussed the other day, I propose that you ask the Supreme Court 
Clerk to prepare the printed record as early as possible in this case. Given 
the various memoranda of decision, the stipulation and whatever else Judge 
Hammer renders, I think the Court would benefit from accurate cites in our 
brief to the printed record (rather than the usual "R.  ") even more in this 
case than in others. Also, in a case in which the briefs and appendices will 
probably be voluminous, we both should probably know what won’t make it into 
the printed record so we won’t be guessing when preparing our respective 
briefs and end up putting duplicative matter in the Appendix. 

Specifically, I think that the following ought to go in the printed 
record: the most recent complaint, defendants’ motion to strike, defendants’ 
latest amended answer, defendants’ motions to strike and for summary judgment, 
the Judge’s two pre-trial memoranda of decision, his post-trial memorandum of 
decision (with corrections), the Supreme Court’s various orders regarding 
further findings, the Joint Stipulation, the parties’ respective revised 
proposed findings of fact, anything new that the Judge rules on regarding 
these proposals, the plaintiffs’ appeal, any motion(s) for review and rulings 
thereon, and any relevant to Section 4013 papers. 

I’d agree to forgo putting in our respective statements of the issues 
(or going with what we’ve both already filed for purposes of the printed 
record) as long as we agree that both parties can amend their statement of the 
issues up until the time of the filing of each party’s respective brief. 

Please call me when you have given this some thought. 

Very truly yours, 

Gregory T. D’Auria 
Assistant Attorney General 

GRD/as