Defendants' Second Set of Interrogatories and Second Request for Production of Documents with Certification

    CV 89-03609778 

MILO SHEFF, et al., : SUPERIOR COURT 

Plaintiffs, JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

AT HARTFORD v. 

WILLIAM &, O'NEILL, et al., 

Defendants. : SEPTEMBER 2, 1992 

DEFENDANTS' SECOND SET OF INTERROGATORIES AND 

SECOND REQUEST FOR PRODUCTION OF DOCUMENTS 
  

  

Pursuant. to sections 216 and 227 of the Practice Book, the 

defendants hereby present the plaintiffs with the following 

second set of interrogatories and second request for production. 

1. INTERROGATORY 

1. In regard to the studies conducted by the plaintiffs’ 

expert Robert L. Crain which are reported in the articles 

"Finding Niches: Desegregated Students Sixteen Years Later" 

(June, 1992) and "School Desegregation and Black Occupational 

Attainments: Results of a Long Term Experiment" please provide 

all formulas, equations, intermediate calculations, and 

instructions necessary to allow the defendants or someone acting 

  

 



  

on their behalf to produce all charts and tables included in   
the articles. The information being requested includes, but is 

not limited to, information about conditions for deletion or 

retention of subjects in each table, full regression equations 

for all tables in both articles that show results "controlling 

for family background”, and complete documentation of variables 

in those regression equations along with any special recoding 

instructions for dummy variables. 

11. REQUEST FOR PRODUCTION 

1. In regard to the studies conducted by the plaintiffs’ 

expert witness Robert L. Crain which are reported in the articles 

entitled "Finding Niches: Desegregated students Sixteen Years           
 



  

  

    

Later" (June, 1992) and "School Desegregation and Black 

Occupational Attainments: Results of a Long Term Experiment" 

please provide all written or computerized documents, materials, 

formulas, equations, intermediate calculations, and instructioas 

necessary to allow the defendants or someone acting on their 

behalf to produce all charts and tables included in these 

articles, including, but not limited to, information about 

conditions for deletion or retention of subjects in each table, 

full regression equations for all tables in both reports that 

show results "controlling for family background", and complete 

documentation of variables in those regression equations along 

with any special recoding instructions for dummy variables. The 

material being requested includes, but is not limited to, coples 

of the SPSS computer runs that produced each chart or table, 

along with clear definitions of each variable in the run, 

    

  
 



      

WHEREFORE, the defendants seek a complete response to the 

above-captioned 1interrogatory and request for production in 

accordance with the rules of practice. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

ATTORNEY GENERAL 
i /) "id 

iS y 2 
   
    

BY: 
  

    

/[Jd¥n R. Whelan 

/Adsistant Attorney General 

bris No. 085112 

10 Sherman Street 

Hartford, CT 06105 

Telephone: 566-7173 

  

Martha M. Watts 
Assistant Attorney General 

Juris No. 406172 

110 Sherman Street 

Hartford, CT 06105 

Telephone: 566-7173 

Wind i fp Yet, Gos 

  

  

 



      

CERTIFICATION 
  

This is to certify that a copy of the foregoing was mailed, 

postage prepaid on September 2, 1992 to the following counsel of 

record: 

John Brittain 

University of Connecticut 
School of Law 

65 Elizabeth Street 
Hartford, CT 06105 

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

Philip Tegeler, Esq. 
Martha Stone, Esq. 

Connecticut Civil Liberties Union 

32 Grand Street 

Hartford, CT 06106 

Wesley W. Horton 
Mollier, Horton & Fineberg, P.C. 

90 Gillett Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 

Puerto Rican Legal Defense and 

Education Fund 
99 Hudson Street 
l4th Floor 
New York, NY 10013 

  

  

 



      

Julius L. Chambers, 

Marianne Lado, Esq. 

Ronald Ellis, Esq. 
NAACP Legal Defense and 
Education Fund 

99 Hudson Street 

New York, NY. 10013 

Esq. 

John A. Powell 

Helen Hershkoff 

American Civil Liberties Union 
132 West 43rd Street 

New York, NY 10036 

2 
  

JoHn/ R. Whelan 
Agsistant Attorney General