Memo from Tegeler to Correspondence Re: Meeting with Andrew Gold, College

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ATTORNEY WORK PRODUCT 
PRIVILEGED AND CONFIDENTIAL 

TO: Sheff lawyers; experts 
FROM: Philip Tegeler 
RE: Meeting with Andrew Gold, Trinity College 
DATE: 11-25-91 

I met last week with Andy Gold, an economics professor at 
Trinity College, who is on sabbatical this year, and would like 
to offer his free assistance to us in his spare time while he is 
working on an unrelated writing project. He is most interested 
in doing “number crunching” on small, discrete projects, and he 
has a strong interest in our case. In addition to his general 
qualifications, Andy prepared an expert report on educational 
finance and municipal overburden for the City of Hartford ten 
years ago in Horton v. Meskill, he has taught in the area of 
school and housing desegregation, and has been active for a 
number of years in the joint Trinity-UConn Law MPA program. I 
believe he has testified as an expert witness in several 
employment discrimination cases. He also testified on the 
racial imbalance act/regs when they were initially proposed. 

We discussed four possible areas of work: 

1. Analysis of how special education needs in Hartford draw 
funds away from regular education; analysis of special education 
spending in relation to need (Gold did similar analysis in his 
Horton v. Meskill study). 

2. Staff turnover: analysis of state reports and Hartford 
BOE data to show pattern of teacher turnover in Hartford system, 
especially movement of young teachers with experience out of 
system, and out of high poverty schools. [In addition, if we do 
not engage Professor Natriello to do an analysis of disparities 
among teaching staffs, Professor Gold might be persuaded to do 
it.) 

3. Assistance in preparation of depositions/cross 
examination of Rossell and Armor. Gold is very interested in 
reviewing recent writings (and, possibly, testimony) of Rossell 
and Armor to identify themes, passages, etc., helpful to us. 
Gold notes that both have primarily looked at intradistrict 
desegregation, and would support our argument that the racial 
imbalance law was a contributing factor in the increased 
segregation of the Hartford schools. 

4. Municipal overburden: in partial response to the 
state's financial arguments, as recently presented in their 
summary judgment brief, Gold would update portions of his 1980 
report and summarize the ways in which Hartford is limited in 
its ability to spend as much money on education as suburban 
towns. 

 



  

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If there are any objections or modifications to these proposals, 
or if you can think of other areas of similar scope (i.e., small 
projects in the nature of rebuttal testimony), please let me 
know. It may also be possible to coordinate Professor Gold's 
offer of assistance with Professor Natriello's proposed study.