Defendants' Second Set of Interrogatories and Second Request for Production of Documents and Notice of Filing

Public Court Documents
September 2, 1992

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Impact area
- Education
Topic
- School Desegregation
Matter
- Sheff v. O'Neill
Case
- Sheff v. O'Neill
U.S. state
- Connecticut
Collection
- Case Files
Taxonomy
Identifier
- 8ee5193e-a446-f011-877a-0022482c18b0

Cite this item

Case Files, Sheff v. O'Neill Hardbacks. Defendants' Second Set of Interrogatories and Second Request for Production of Documents and Notice of Filing, 1992. 8ee5193e-a446-f011-877a-0022482c18b0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/a0ea01de-cd99-4a5a-a254-953ecb91b9a0/defendants-second-set-of-interrogatories-and-second-request-for-production-of-documents-and-notice-of-filing. Accessed November 03, 2025.

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    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. : 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. 

I. 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 1n 

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. 

  

II. REQUEST FOR PRODUCTION 

1. ln 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 instructio.as 

necessary to allow the defendants or someone acting on their 

behalf to produce all charts ana 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 1s not limited to, COpies 

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 

BY: 
  

  

/Adsistant Attorney General 

| uris No. 085112 

/110 Sherman Street 

Hartford, CT 06105 

Telephone: 566-7173 

  
Win tl i yi oA Ge J 

Martha M. Watts 
Assistant Attorney General 

Juris No. 406172 
110 Sherman Street 

Hartford, CT 06105 

Telephone: 566-7173 

      

  
 



      

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. 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense and 
Education Fund 

99 Hudson Street 
New York, NY 10013 

Chambers, 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 

  

 



  

  

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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. 
: SEPTEMBER 2, 1992 

NOTICE OF FILING OF DEFENDANTS' SECOND SET OF 

INTERROGATORIES AND SECOND REQUEST FOR PRODUCTION   

  

    

The defendants hereby give notice that on September 2, 1992 

the defendants submitted their second set of interrogatories and 

second request for production to the plaintiffs. This discovery 

consists of one interrogatory and one request for production. 

 



        

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, Cr 06105 

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Lega! 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, Esq. 
Marianne Lado, Esq. 

Ronald Ellis, Esqg. 
NAACP Legal Defense and 
Education Fund 

99 Hudson Street 
New York, NY 10013 

John A. Powell 

Helen Hershkoff 

American Civil Liberties Union 

132 West 43rd Street 

New York, NY 10036 

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Johny R. Whelan 
AdsAistant Attorney General 

{

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Defendants' Second Set of Interrogatories and Second Request for Production of Documents and Notice of Filing

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