Correspondence to and from co-counsel; from Blumenthal to Judge Hammer

    | 

1 
National Office 

A A 
Suite 1600 

NAACP LEGAL DEFENSE 99 Hudson Street 

| AND EDUCATIONAL FUND, INC. New York, N.Y. 10013-2897 (212) 219-1900 Fax: (212) 226-759: 

August 31, 1992 

William Trent 
EPS, 368 Education Bldg. 
University of Illinois 
1310 South Sixth Street 
Champagne, Ill. 61820 

Dear Bill: 

I hope that you have recovered from last week’s trials and 

tribulations, and that you are feeling well. 

As you know, during the course of last Tuesday’s deposition we 

promised to send a number of unpublished reports to John Whelan. 

These included the following items: 

1. An unpublished study coauthored with McPartland using the 

High School and Beyond data to examine Black and White 

sense of "well-being;" 

2. If it exists, an unpublished study coauthored with 

Braddock using the NLS Employer data examining the 

relationship between high school racial composition and 

employers; 

3. The citation to your work in Hawley’s 15 vol. collection; 

and 

4. A better copy of the variables used in your study in 

connection with Sheff v. O'Neill. 

It would also be helpful if we could obtain a copy of the Chicago- 

based study regarding the use of formative and summative data at 

the school level. 

Please let me know whether these materials are readily 

available and approximately how long it might take to send them to 

LDF. I would like to be able to respond to John Whelan’s requests 

in a timely manner. 

In addition, we had discussed convening a conference call with 

Bob Crain. I hope that at least one of the following times is 

convenient: (1) Wednesday, September 2, at 4:00 p.m. (EST): (2) 

Friday, September 4, at 9:00 a.m.; (3) Friday, September 6, at 4:30 

Regional Offices 

Suite 208 
Contributions are The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part Suite 301 

315 West Ninth Street 
deductible for U.S. of the National Association for the Advancement of Colored People 1275 K Street, NW 

income tax purposes. (NAACP) although LDF was founded by the NAACP and shares its Washington, DC 20005 Los Angeles, CA 90015 

commitment to equal rights. LDF has had for over 30 years a separate (202) 682-1300 

Board, program, staff, office and budget. 

(213) 624-2405 

Fax: (202) 682-1312 Fax: (213) 624-0075 

 



  

| I J 

p.m. Please let me know which times fit into your schedule. I 
will call Bob Crain and Sandy DelValle to confirm arrangements. 

Thank you for your continuing enthusiasm. Your participation 
in this case is much appreciated. 

Sincerely, 

Marianne Engelman Lado 

cc. Robert Crain 

Sandy DelValle 
Ron Ellis 

 



 
 

 
 

 
 
 
 

 
 
 
 

  
  

 
   
 
 

  

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National Office 

A A 
Suite 1600 

NAACP LEGAL DEFENSE 99 Hudson Street 

AND EDUCATIONAL FUND, INC. New York, N.Y. 10013-2897 (212) 219-1900 Fax: (212) 226-7592 

August 20, 1992 

Martha Stone, Esq. 

Connecticut Civil Liberties 

Union 
32 Grand Street 

Hartford, CT 06106 

Dear Martha: 

Below please find a list of materials by or relating to David 

Armor. Please let me know if you want these reproduced. 

1. Armor Deposition, U.S v. Charleston County, S.C. , (1987): 

Direct by Santos (U.S. Dept. of Justice), Cross by Henderson 

(Pittsburg) ; 

  

  2. Armor Testimony, Charleston County: Direct by Lindseth, Cross 

by Glassman, Henderson; 

  

3. Armor’s Testimony on behalf of Woodland Hills School District, 

Hoots: Direct and Redirect by Rutter, Cross by Henderson; 

4. Armor Testimony, Nichols v. Natchez (1989): Direct by Adams, 

Cross by Byrd (LDF), Beber, Redirect by Adams, Recross by 

Beber; 

5. Armor Deposition, Nichols v. Natchez: Examination by Chachkin 
  

(LDF), Beber; 

6. Armor Testimony, Riddick v. Norfolk (1984): Cross by Williams 

(LDF), Redirect by Stalnaker with catalogue of complete 

testimony and abstract of deposition; 

  

  7. Armor Testimony, Stell v. Chatham County (1988): Direct by 

Lindseth, Cross by Johnston (LDF), Marks; 

  8. Armor Deposition, Stell v. Chatham County (1988): Examination 

by Marshall (U.S. Dept. of Justice), Johnston (LDF); 

9, Armor Interview, "Profiles in Education," Education Update 

(Heritage Foundation: 1990); 
  

Regional Offices 

Suite 208 

1275 K Street, NW 315 West Ninth Street 

Washington, DC 20005 Los Angeles, CA 90015 

(202) 682-1300 (213) 624-2405 

Fax: (202) 682-1312 Fax: (213) 624-0075 

Contributions are The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part Suite 301 

deductible for U.S. of the National Association for the Advancement of Colored People 

income tax purposes. (NAACP) although LDF was founded by the NAACP and shares its 

commitment to equal rights. LDF has had for over 30 years a separate 

Board, program, staff, office and budget. 

 



  

10. 

11. 

12. 

1s. 

14. 

15. 

16. 

1;. 

18. 

19. 

20. 

E 

Armor, "Unwillingly to School," Policy Review (Heritage 

Foundation: 1981); 
  

Armor Report to U.S. Commission on Civil Rights, "The Racial 

Composition of Schools and College Aspirations of Negro 

Students"; 

Articles with reference to Armor: 

a. Pear, "Advisor to U.S. Desegregation Study 

Quits, Saying It’s Biased" New York Times 

(October 30, 1985); 

ba Hiatt, "Norfolk Shelves Its Plan to Kill 

Crosstown Busing" Washington Post (June 10, 1982); 

C. Feinberg, "Busing Orders Said to Widen 

Isolation" Washington Post (May 15, 1981); 

qd. Seligman, "The Busing Religion" Fortune (October 

9, 1978); 

e. Fields, "Choosing Education Excellence" 

Washington Times (July 11, 1989); 

Armor, "After Busing: Education and Choice" (1989); 

Armor, "The Double Double Standard: A Reply" The Public Interest ; 

Armor, "School and Family Effects on Black and White 

Achievement: A Re-examination of the USOE Data"; 

Armor, "School Busing: A Time for Change" (1988); 

Armor, "White Flight Demographic Transition and the Future of 

School Desegregation"; 

Armor, "Why Is Black Educational Achievement Rising?" Public 

Interest (1992); 

Armor C.V; and 

Memo by Jenkins (LDF) Regarding Approaches to Expert Testimony 

by Armor (May 20, 1992). 

 



® a » 

Please let me know if I can be of assistance with preparations 

for Armor’s deposition. At this point, I plan to be in Hartford on 

September 3 for the deposition. 

Cheers, 

Marianne Engelman Lado 

MEL: ja 

cc: Ron Ellisv 

 



   
      

National Office 

A A Suite 1600 

NAACP LEGAL DEFENSE 99 Hudson Street 
AND EDUCATIONAL FUND, INC. New York, N.Y. 10013-2897 (212) 219-1900 Fax: (212) 226-75¢ 

August 20, 1992 

John R. Whalen 
Assistant Attorney General 
Office of the Attorney General 
State of Connecticut 
MacKenzie Hall 
110 Sherman Street 
Bartford, CT 06105 

Re: Sheff v. O'Neill: Lost Diskette 

Dear John: 

Enclosed please find a second diskette containing the 
requested data used by Dr. Robert Crain. I am sending 
by overnight mail in order to ensure speedy delivery. 

the diskette 

Please let me know if any additional problems arise regarding 
this diskette. 

Sincerely, 

LET. 
Marianne ‘Engelman Lado 

cc. Philip Tegeler, Esq. 
Martha Stone, Esq. 
Martha M. Watts, Asst. Atty. Gen. 

Contributions are The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part 

deductible for U.S. of the National Association for the Advancement of Colored People 
income tax purposes. (NAACP) although LDF was founded by the NAACP and shares its 

commitment to equal rights. LDF has had for over 30 years a separate 

  

Regional Offices 

Suite 301 Suite 208 

1275 K Street, NW 315 West Ninth Street 

Washington, DC 20005 Los Angeles, CA 9015 

(202) 682-1300 (213) 624-2405 

  

    



   
Mackenzie flail 

110 Sherman Strect 

Hartord. CT 061035 

RiCTLARDY BLUMENTHAL 
ATTORNEY GENERAL 

  

FAX (203) d2:3-33:36 

Ottice of The Attorney General 

State of Connecticut 
Tel: 566-7173 

August 17, 1992 

The Honorable Harry Hammer 
Judicial District at Hartford 

95 Washington Street .. Ted i 
P.O. Drawer D, Station A 

Hartford, CT 06106 

The Honorable Harry Hammer 
Judicial District at Rockville 

l Court Street 

P.O. Box 424 

Rockville, CT 06066 

RE: SHEFF v. O'NEILL   

Dear Judge Hammer: 

On August 26, 1992, counsel for the parties in the 

above-captioned case are scheduled to appear before Your Honor 

for a. status conference. At the conference, the defendants will 

be requesting that certain matters be considered on the record. 

Consequently, we request that a court reporter be present at the 

status conference in order to make a formal record of the 

proceedings. 

Thank you for your consideration. 

Very truly yours, 

    :  M&r thay. 
Assistant Attorney General 

MMW: ac 

ce: "John ‘Brittain, Fsq. Ruben Franco, Esq. 
Wilfred Rodriguez, Esg. Jenny Rivera, Esq. 

Philip Tegeler, Esg. Julius Chambers, Esq. 

Martha Stone, Esq. Marianne Lado, Esq. 

Wessley W. Horton, Esg. John A. Powell, Esq. 

Helen Hershkoff Esqg. «Helen Hershkoff, Esq.’ 

Adam S. Cohen, Esq. John R. Whelan, Asst. Atty. Gen.