Letter to All Counsel RE: Documents Requested with Deposition Subpoena and Certificate of Service

    FL COLIEN DA TON 
Thirty Two Grand Street. Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX October 7, 1992 

Mr. John Whelan 
Assistant Attorney General 
110 Sherman Street : 
Hartford, CT 06105 

RE: Sheff v. O'Neill 
  

Dear John, 

Pursuant to paragraph 4 of the Pretrial Order of September 2, 
1992, we are giving notice as to the documents requested for the 
deposition of Dr. Theodore Sergi scheduled for October 20, 1992. 
If any of the documents you have previously submitted to us are 
responsive to this request, please indicate the number of the 
document. In order to save time at the deposition, we would 
appreciate receiving these documents at least two days in advance. 

Thank you for your cooperation. 

Sincerely, 

Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

 



SUBPOENA DUCES TECUM 
  

Dr. Theodore Sergi 
Department of Education 
165 Capitol Avenue 
Hartford, CT 06106 

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 20th of October, 
1992, or to such day thereafter and within sixty days hereof to 
testify what you know in regard to a certain civil action pending 
before the Superior Court for the Judicial District of Hartford/New 
Britain entitled Sheff v. O'Neill, No. CV 89-0360977s. Said 
deposition shall be conducted at the offices of the Connecticut Civil 
Liberties Union Foundation, 32 Grand Street, Hartford, Connecticut 
{Conference Room). 

  

Pursuant to Practice Book §245(c) you are further directed to 
produce and permit inspection and copying of the following: 

A copy of your current resume. 

Any evaluations of the Priority School District program not 
previously produced. 

All reports, memoranda, correspondence, or other document 
relating to the Priority School District program, January 
1991 to the present (not including any documents previously 
produced). 

Any applications regarding the Priority School District 
program in the Hartford area, not previously produced. 

A copy of the volume of Connecticut Town and School District 
Profiles referenced in defendants’ response to request #43, 
Plaintiffs’ Fifth Request for Production of Documents. 

All trial exhibits or reports you have prepared in Sheff v. 

O'Neill. 
  

Any proposals specifically regarding racial integration of 
vocational education programs, 1985 to the present.  



HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Dated at Hartford, Connecticut this 7th day of October, 1992. 

A Zz 
Philip D. Tegeler/Martha Stone 
Commissioner of the Superior Court 

  

CERTIFICATE OF SERVICE 
  

This is to certify that a copy of the foregoing has been faxed 
and mailed postage prepaid to John R. Whelan, Assistant Attorney 
General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 06105 this 
7th day of October, 1992. 

PF 
Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs