Defendants' Response to the Plaintiffs' Second Set of Interrogatories with Certification

    CV 89-0360977S 

MILO SHEFF, et al., : SUPERIOR COURT 

Plaintiffs, : JUDICIAL DISTRICT OF 

: HARTFORD/NEW BRITAIN 

Vv. : AT HARTFORD 

WILLIAM A. O'NEILL, et al., 

Defendants. 3 September 15, 1992 

DEFENDANTS' RESPONSE TO THE PLAINTIFFS' 

SECOND SET OF INTERROGATORIES 
  

  

& 
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The defendants hereby offer the following responses to ithe 

Plaintiffs' Second Set of Interrogatories dated July 15, 1992. 

l. Please list, by title, year, and number, all "Research 

Bulletins" issued by the Connecticut Department of Education, 1965 

to the present. 

ANSWER: See exhibit S(a) in response to the Plaintiffs’ 

Fifth Request for Production of Documents. 

2. Identify, by author, title, and date, each document Or 

document excerpt attached hereto at Exhibits A and B. (Plaintiffs 

also request full copies of each of these documents in their 

Fifth Request for Production.) 

  

  

 



      

ANSWER: The defendants are unable to provide the 

information requested by this interrogatory because they are 

unable to identify exhibits A and B or locate complete copies. 

3. State the total number of children receiving the free 

and reduced lunch program in Hartford and each of the surrounding 

districts. 

ANSWER: Information provided in response to letter from 

CCLU to defendants' counsel dated July 1, 1992. : 

4. State the total number of children living below the 

poverty level in Hartford and each of the surrounding districts. 

ANSWER: Objection: The information requested is equally 

available to the plaintiffs from the Census Bureau. 

5.4 State the total number of children receiving aid to 

dependent children (ADC) in Hartford and each of the surrounding 

districts. 

ANSWER: See defendants' response to request No. 55 of the 

Plaintiffs' Fifth Request for Production of Documents. 

6. State the total number of Spanish language dominant 

children in Hartford and each of the surrounding districts. 

  

  
 



  

  

    

ANSWER: See defendants' response to request No. 15 of the 

Plaintiffs' Fifth Request for Production of Documents. 

7. State the total number of children receiving special 

education services in Hartford and each of the surrounding 

districts. 

ANSWER: See exhibit 7(a)-(4d). 

8. State the total number of children on a full time 
[3 
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equivalent basis (FTE) receiving special education services iin 

Hartford and each of the surrounding districts. 

ANSWER: FTE is a mathematical computation which must be 

based on certain assumptions about special education. The 

assumptions which are used in computing the FTE could affect the 

validity of any use of the FTE to analyze special education 

expenditures, etc. The plaintiffs have been provided with the 

ISIS data base which contains all of the information available to 

the defendants upon which an FTE might be calculated. The 

defendants reserve the right to question the validity of any FTE 

computation the plaintiffs may derive from that data and the 

validity of the use of that computation for any purposes. 

  

  

 



      

9. State the total grant amount for special education 

reimbursement for Hartford and the surrounding districts for the 

years 1983-1990 (data missing from Exhibit 4, attached to 

defendants' July 8, 1991 Memorandum of Law in Support of 

Defendants' Motion for Summary Judgment). 

ANSWER: See exhibit 9(a) 

10. State the total grant amount for transportation 

reimbursement for Hartford and the surrounding districts for the 

years 1983-1990 (data missing from Exhibit 4, attached to 

defendants' July 8, 1991 Memorandum of Law in Support of 

Defendants' Motion for Summary Judgement). 

ANSWER: * See exhibit 10(a) 

11. State the total special education budget for Hartford 

and each of the surrounding districts for the years 1983-1990. 

ANSWER: See exhibit 11(a) 

  

  
 



  

  
Wherefore, the defendants offer the foregoing responses to. 

the plaintiffs' second set of interrogatories. 

FOR THE DEFENDANTS 

BY: 

  

  

Join R. Whelan 
Adsistant Attorney General 

10 Sherman Street . 
JHartford, CT: 06105 : 
Telephone: 566-7173 ; 

  
BY: Li 

  

we M. Watts’ 
ASsistant Attorney General 
110 Sherman Street 

Hartford, CT 06105 
Telephone: 566-7173 

      
 



    

CERTIFICATION 
  

This 

postage prepaid on September 15, 

record: 

John Brittain, Esq. 
University of Connecticut 
School of Law 

65 Elizabeth Street 

Hartford, CT 06105 

Philip Tegeler, Esq. 
Martha Stone, Esq. 

Connecticut Civil Liberties Union 
32 Grand Street 

Hartford, CT 06106 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense Fund 
and Education Fund 

l4th Floor 
99 Hudson Street 
New York, NY 10013 

John A. Powell, 

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

Esq. 

1s to certify that a copy of the foregoing was mailed, 

1992 to the following counsel of | 

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

Wesley W. Horton, Esq. : 
Moller, Horton & Fineberg, PC 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers, 

Marianne Lado, Esq. 

Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 

Education Fund 

99 Hudson Street 
New York, NY 10013 

i. 

Esq. 

  

  
Ld 

R. Whelan 
istant Attorney General