Correspondence from Tegeler to Whelan with Deposition Subpoena for Thomas Steahr

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX August 20, 1992 

Mr. John Whelan 
Assistant Attorney General 
110 Sherman Street 
Hartford, CT 06105 

RE: Sheff v. O'Neill 
  

Dear John, 

In light of plaintiffs’ recent proposed amendment to the 
Complaint and plaintiffs’ amended list of expert witnesses, we 
would appreciate prompt notification as to whether the state plans 
to call or withdraw Patricia Downs and Thomas Steahr as witnesses 
in this case. 

However, if you still plan to call Mr. Steahr as a witness, 
pursuant to paragraph 4 of the Pretrial Order of April 10, 1992, we 
are giving notice as to the documents requested for his deposition 
scheduled for September 3, 1992. If any of the documents you have 
previously submitted to us are responsive to this request, please 
indicate the number of the document. In order to save time at the 
deposition, we would appreciate receiving these documents at least 
two days in advance. 

In addition, as we have discussed in relation to other expert 
witnesses, we are requesting that a more detailed description of 
Mr. Steahr’s anticipated testimony be provided to us prior to the 
deposition. 

Thank you for your cooperation. 

Sincerely, 

Ww Zee 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: "All Counsel 

The Connecticut Civil Liberties Union Foundation 

“es 

 



  

SUBPOENA DUCES TECUM 
  

TO: Thomas Steahr 
College of Agriculture and Natural Resources 

University of Connecticut 
Box U-22 
Room 318 
1376 Storrs Road 
Storrs, CT 06269-4021 

GREETING: 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 

commanded to appear before an appropriate officer at a deposition 
which will take place beginning at 2:00 p.m. on the 3rd of September, 
1992, or to such day thereafter and within sixty days hereof to 
testify what you know in regard to a certain civil action pending 
before the Superior Court for the Judicial District of Hartford/New 
Britain entitled Sheff v. O'Neill, No. CV 89-0360977S. Said 
deposition shall be conducted at the offices of the Connecticut Civil 
Liberties Union Foundation, 32 Grand Street, Hartford, Connecticut 
(Conference Room). 

  

Pursuant to Practice Book §245(c) you are further directed to 
produce and permit inspection and copying of the following: 

l1. Raw data underlying the conclusions set out 1in the 
description of your testimony in “"Defendants’ Amended 
Disclosure of Expert Witnesses" attached hereto. 

2. Any studies or reports you have prepared in this case. 

3. Any tables, charts, or other trial exhibits you have 
prepared in this case. 

4. Copies of any research, papers, or articles you have 
prepared that discuss the role of government actions in 
promoting racial or economic segregation in housing, or the 
relative role of private choice vs. government action. 

5. Copies of previous studies you have conducted regarding 
demographics in the Hartford area. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

Nt 
Dated at Hartford, Connecticut this 20 day of August, 1992. 

WY J Fez 
  

Philip D. Tegeler/Martha Stone 
Commissioner of the Superior Court 

 



  

CERTIFICATE OF SERVICE 
  

This is to certify that a copy of the foregoing has been faxed 
and mailed postage prepaid to John R. Whelan and Martha M. Watts, 
Assistant Attorneys General, MacKenzie Hall, 110 Sherman Street, 
Hartford, CT 06105 this 20th day of August, 1992. 

y i ad 
  

Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs