Correspondence from Lado to Tegeler and Stone Re: List of Expert Witnesses with Draft

    -— a . a" — 

To: Phil Tegeler, Martha Stone 

From: Marianne Engelman Lado #4 

Date: January 14, 1991 

Re: List of Expert Witnesses in Sheff v. O'Neill 
  

Attached please find a partial response to Defendants’ 
Interrogatory #18. 

I have written paragraphs on Jomills Braddock, Bob Crain, 
Marvin Dawkins, and Bill Trent. Please feel free to make comments 
or suggestions as to how they can be improved, or to conform their 
form to that of the other paragraphs. I have discussed the answers 
with Bob Crain and Marvin Dawkins and feel that we now have fairly 
good descriptions of their expected testimony, even though the 
descriptions are still a bit sketchy. (I tried to reach Adam Cohen 
today to discuss the Crain outline and hope he will be back in the 
office tomorrow.) I expect to confirm the other two descriptions 
with Jomills Braddock and Bill Trent tomorrow morning. 

As you will see, there are still a number of paragraphs to be 
completed. In addition, the following questions and issues remain: 
(1) Jenny Rivera suggested that, given the current state of the 
remedial work, it might be appropriate to add Cathy Walsh's name 
at a later date. (Would that be possible?) The same might be said 
of the other remedial experts. (2) What kind of qualifying 
language is appropriate under Practice Book Section 220(D)? (3) 
On what dates do we expect analyses and reviews to be completed? 
What dates are appropriate, given the current, tentative schedule 
agreed upon with Whalen? 

I will be in a meeting between 9:30 and 11:30 a.m., but can 
be reached in the office after that time. I apologize to Martha 
for not having reached her, but hope that we will be able to talk 
tomorrow. Hope all is well. 

4 
es. fm Ellis 

/ Adam Cohen 

 



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Expert Witnesses 
  

18. Please specify the name and address of each and every 
person the plaintiffs expect to call as an expert witness at trial. 
For each such person please provide the following: 

a) The date on which that person is expected to complete the 
review, analysis, or consideration necessary to formulate the 
opinions which that person will be called upon to offer at trial; 

b) The subject matter upon which that person is expected to 
testify; and 

C) The substance of the facts and opinions to which that person 
is expected to testify and a summary of the grounds for each 
opinion. 

RESPONSE: Experts whom the plaintiffs expect to call at trial are 
listed below, pursuant to Practice Book Section 220(D): 
  

Dr. Jomills Henry Braddock, II, Center for Social 
Organization of Schools, Johns Hopkins University, 3505 
North Charles Street, Baltimore, Maryland, 21218. Dr. 
Braddock is expected to testify to (1) the adverse 
educational and long-term effects of racial, ethnic, and 
economic segregation; (2) the adverse effects of racial, 
ethnic, and economic segregation on the educational 
process within schools. Specifically, Dr. Braddock is 
expected to testify that school segregation tends to 
perpetuate segregation in adult 1life, that school 
desegregation helps to transcend systemic reinforcement 
of inequality of opportunity, and that segregation 
affects the educational process within schools. In his 
testimony, the materials on which Dr. Braddock is 
expected to rely include his published works, as well as 
research currently being conducted on the educational and 
long-term effects of racial, ethnic, and economic 
segregation by Dr. Marvin P. Dawkins and Dr. William 
Trent. (See descriptions, below) Dr. Braddock is 
expected to base his testimony on (1) Braddock, "The 
Perpetuation of Segregation Across Levels of Education: 
A Behavioral Assessment of the Contact-Hypothesis," 53 
Sociology of Eduction 178-186 (1980); (2) Braddock, 
Crain, McPartland, "A Long-Term View of School 
Desegregation: Some REcent Studies of Graduates as 
Adults," Phi Delta Kappan 259-264 (1984); (3) Braddock, 
"Segregated High School Experiences and Black Students’ 
College and Major Field Choices," Paper Presented at the 
National Conference on School Desegregation, University 
of Chicago (1987); (4) Braddock, McPartland, "How 
Minorities Continue to be Excluded From Equal Employment 
Opportunities: Research ' on Labor Market and 
Institutional Barriers," 43 Journal of Social Issues 5- 

  

  

  

   



  

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39 (1987); and (5) Braddock, McPartland, "Social- 
Psychological Processes That Perpetuate Racial 
Segregation: The Relationship Between School and 
Employment Desegregation, 19 Journal of Black Studies 
267-289 (1989). Dr. Braddock is expected to complete his 
review on April 1, 1991. 

  

Collier: MS 

Dr. Robert IL. Crain, Professor of Sociology and 
Education, Teachers College, Columbia University, 525 
West 120th Street, Box 211, New York, New York, 10027. 
Dr. Crain is expected to testify to the adverse 
educational and long-term effects of racial, ethnic, and 
economic segregation in the Hartford metropolitan area. 
Specifically, Dr. Crain is expected to testify that the 
effects of Project Concern participation for students in 
the Hartford metropolitan area have been to reduce the 
likelihood of (1) dropping out of high school, (2) early 
teenage pregnancy, and (3) unfavorable interactions with 
the policy. Dr. Crain is expected to testify, further, 
that the effects of Project Concern participation for 
students in the Hartford metropolitan area have been to 
increase (1) college retention, (2) the probability of 
working in private sector professional and managerial 
jobs, (3) the probability of interracial contact, and 
(4) favorable attitudes toward whites. In his testimony, 
Dr. Crain is expected to base his testimony on his 
published works and his analyses of Project Concern. 
Specifically, Dr. Crain is expected to rely on (1) Crain, 
Strauss, "School Desegregation and Black Occupational 
Attainments: Results from a Long-Term Experiment," 
Center for Social Organization of Schools, Report No. 359 
(1985); (2) Crain, Hawes, Miller, and Peichert, "Finding 
Niches: Desegregated Students Sixteen Years Later," 
Unpublished Manuscript, Institute for Urban and Minority 
Education, Teachers College (revised 1990); and (3) 
Gable, Thompson, Iwanicki, "The Effects of Voluntary 
Desegregation on occupational Outcomes," The Vocational 
Guidance Quarterly 230-239 (1983). Dr. Crain is expected 
to complete his review on April 1, 1991. 

  

  

  

Dr. Marvin P. Dawkins, 17627 N.W. 62nd Place, North, 
Hialeah, Florida, 33015. Dr. Dawkins is expected to 
testify to the adverse educational and long-term effects 
of racial, ethnic, and economic segregation on African 
Americans. Specifically, Dr. Dawkins is expected to 
testify that African Americans who have attended 
segregated schools have a lower probability of attending 
predominantly white colleges and universities, 
maintaining interracial contacts, and working in 
desegregated settings. Dr. Dawkins is expected to base 
his testimony on (a) his analysis of data from the 
National Survey of Black Americans, a nationally 

  

 



  

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representative survey of African Americans conducted over 
a period of seven months between 1979 and 1980 at the 
Survey Research Center, Institute for Social Research, 
University of Michigan, and funded by the Center for the 
Study of Minority Group Mental Health, at the National 
Institute of Mental Health; (b) Dawkins, "Black Students! 
Occupational Expectations: A National Study of the 
Impact of School Desegregation,"™ 18 Urban Education 98- 
113 (1983); (c) Braddock, Dawkins, "Predicting Black 
Academic Achievement in Higher Education," 50 Journal of 
Negro Education 319-327 (1981); (d) Braddock, Dawkins, 
"Long-Term Effects of School Desegregation on Southern 
Blacks," 4 Sociological Spectrum 365-381 (1984); and (e) 
Dawkins, "Persistence of Plans for Professional Careers 
Among Blacks in Early Adulthood," 58 Journal of Negro 
Education 220-231 (1989). Dr. Dawkins is expected to 
complete his analysis on March 15, 1991. 

  

  

  

  

  

  

Dr. Mary Kennedy: MS 

Yale Rabin: PT 

Swaminathan: 2? 

  

Dr. William Trent, EPS, 368 Education Building, 
University of Illinois, 1310 South Sixth Street, 
Champagne, Illinois, 61820. Dr. Trent is expected to 
testify to the adverse educational and long-term effects 
of racial, ethnic, and economic segregation on Latinos, 
African Americans, and white Americans. Specifically Dr. 
Trent is expected to testify that the economic school 
segregation has adverse long-term outcomes for Latinos, 
African Americans, and white Americans, that 
desegregation has beneficial results on the aspirations 
and expectations of Latino students and on their 
likelihood of working in interracial environments, and 
that white Americans who have experienced desegregated 
schools are more likely to work with and to have positive 
attitudes toward African American co-workers. Dr. Trent 
is expected to base his testimony on his published work 
and his analysis of data from (a) the National 
Longitudinal Survey of Labor Force Behavior =-- Youth 
Cohort, an annual survey sponsored by the U.S. 
Departments of Labor and Defense of 12,686 young persons 
throughout the United States, with data available for 
1979-1987; (b) the High School and Beyond Study, a 
national longitudinal probability sample of more than 
58,000 1980 high school sophomores and seniors, conducted 
in 1980, 1982, 1984, and 1986; and (c) the National 
Longitudinal Survey of Employers, a national probability 
sample of 4,087 employers, conducted in the 1970's. Dr. 
Trent is expected to complete his analysis on April 1, 
19921. : i 

 



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Willie/Alves/Walsh/Castellanos: Omit, for now? 

To add: qualifying language that will apply to all of the above.