Correspondence from Tegeler to Swaminathan Re: Assessment of Tapes

    connecticut civil 

AN CCEUK 

  

  

liberties union foundation 
32 grand street 

hartford, connecticut 06106 

telephone: 247-9823 

January 28, 1991 

Professor H. Swaminathan 
School of Education 
University of Massachusetts 

at Amherst 
Hills House 
Amherst, MA 01003 

RE: Sheff v. O'Neill 

Dear Professor Swaminathan, 

With this letter I am shipping you the computer tapes 
provided by the Department of Education in response to the our 
recent discovery requests (items 4, 5, 6, 7 -- see attached 
"Third Request for Production of Documents"), along with 
printouts of the explanatory materials we requested (items 8, 9). 

We would like you to begin your assessment of these tapes by 
addressing the following questions: 

1. Has DOE provided everything we asked for? 

2. What specific kinds of interdistrict disparity data can 
we obtain from the ED-001 tapes and the School Staff 
Report tapes that is not already reported? Is it 
possible to make an initial assessment as to which 
disparities among districts appear to be the most 

" extreme? 

3. See the 1984-85 Curriculum Survey tapes and accompanying 
memos. What is your assessment of the value of these 
materials? Which interdistrict comparisons would be 
most reliable from the curriculum survey? Which 
disparities among districts initially appear to be the 
most extreme?  



  

4. Do you think the mastery test tapes can be used to 

replicate or "check" the Mary Kennedy/David Myers 
analysis we sent to you? 

Of course, as we have discussed, we have many other 

questions, but it would be helpful to have the answers to these 

first, and to discuss how long you think further research will 

take, 

I am enclosing under separate cover the final signed 

Protective Order governing use of these tapes. Please be sure 

you have reviewed this Order before using the tapes. If you need 

further clarification, please give us a call. 

We really appreciate all the help you are giving to us. 

Thank you. 
Sincerely, 

Wy Fev 
Philip Tegeler 
Martha Stone 
Attorneys for Plaintiffs 

PDT/dmt 

Enclosure 

  

 



    

connecticut civil 

    

CCIVFK 
  

liberties union foundation 
32 grand street 

hartford, connecticut 06106 

telephone: 247-9823 

January 28, 1991 

Professor H. Swaminathan 
School of Education 
University of Massachusetts 

at Amherst : 
Hills House 

Amherst, MA 01003 

RE: Sheff v. O'Neill 
  

Dear Professor Swaminathan, 

With this letter I am shipping you the computer tapes 
provided by the Department of Education in response to the our 
recent discovery requests (items 4, 5, 6, 7 -- see attached 
"Third Request for Production of Documents"), along with 
printouts of the explanatory materials we requested (items 8, 9). 

We would like you to begin your assessment of these tapes by 
addressing the following questions: 

l. 

2. 

Has DOE provided everything we asked for? 

What specific kinds of interdistrict disparity data can 
we obtain from the ED-001 tapes and the School Staff 
Report tapes that is not already reported? Is it 
possible to make an initial assessment as to which 
disparities among districts appear to be the most 
extreme? 

See the 1984-85 Curriculum Survey tapes and accompanying 
memos. What is your assessment of the value of these 
materials? Which interdistrict comparisons would be 
most reliable from the curriculum survey? Which 
disparities among districts initially appear to be the 
most extreme? / 

 



  

4. Do you think the mastery test tapes can be used to 

replicate or "check" the Mary Kennedy/David Myers 

analysis we sent to you? 

Of course, as we have discussed, we have many other 
questions, but it would be helpful to have the answers to these 

first, and to discuss how long you think further research will 

take. 

I am enclosing under separate cover the final signed 

Protective Order governing use of these tapes. Please be sure 

you have reviewed this Order before using the tapes. If you need 

further clarification, please give us a call. 

We really appreciate all the help you are giving to us. 

Thank you. ; 
Sincerely, 

Wy Fev 
Philip Tegeler 
Martha Stone 
Attorneys for Plaintiffs 

PDT/dmt 

Enclosure 

  

 



  

List of documents (1-28-91) 
  

1. 

11. 

12. 

13. 

Blue Ribbon Commission on Housing; Report and 
Recommendations to the Governor and General Assembly (March 
1, 1988) 

  

  

Cataloque of Publicly Assisted Rental Housing In Connecticut 
[undated - 1988] 
  

Capitol Region Council of Governments, An Assessment of 
Housing Needs in the Capitol Region, December, 1987. 

  

  

Office of Policy and Management, Housing 2000, Part TI: 
Renters in Need; Who - Why - Where (October, 1987) 

  

  

Office of Policy and Management, State Policies Plan for the 
Conservation and Development of Connecticut 1987-1992 
(adopted by the General Assembly, June 3, 1987 

  

    

CHRO, Task Force on Housing in Connecticut: First Summary 
Report (October 8, 1987) 
  

Capitol Region Council of Governments, letter to CRCOG 
Housing Committee from Community Development Staff regarding 
recommendations on the establishment of numerical housing 
goals for the Capitol Region and its municipalities, 
September 29, 1986. 

CHRO, Housing Discrimination and Opportunities in the State 
of Connecticut (April, 1986) 
  

[1986] State of Connecticut Five Year Housing Advisory Plan, 
1987-1992 
  

"Regional Housing Needs Assessment: Summary of Format and 
Methodology” (Circa 1986) 

Department of Housing, 1983 Three Year Housing Advisory 
Plan, (October 31, 1983) 
  

Task Force Finance Committee, Three Year Housing Advisory 
Plan, Task Force Recommendations, Circa 1983. 

  

  

Central Naugatuck Valley Regional Planning Agency, A _ Back 
Door to Least Cost Housing: Expanding Housing Opportunities 
Inside the Single Family Dwelling, September, 1982 
  
  

    

 



State of Connecticut, Conservation and Development Policies 
Plan, 1982-1985, April 14, 1982. 
  

  

A Model Ordinance and Model Procedures for “One-Stop” 
Applications for the Development of Land, State of 
Connecticut Department of Housing, February, 1982. 

  

  

State of Connecticut Department of Housing, Housing and Land 
Use: Community Options for Lowering Housing Costs, November 
1981. 
  

Fair Housing/Housing Services Staff, Capitol Region Council 
of Governments, How to Develop An Affirmative Fair Housing 
Marketing Plan, May, 1981. 
  

  

Commissioner of the Department of Housing, Three Year 
Housing Advisory Plan, October 31, 1980 

  

  

Department of Housing, Task Force for the Three Year Housing 
Plan, Working Papers (November 1980) 

ABT Associates, New Directions for Municipal Regulation in 
the Capitol Region in Connecticut,; a Technical Assistance 
Project; Task 3 Report; Volume II: Appendix of Local 
Inclusionary Zoning Models (July 28, 1980) 

William McEachern, Large-Lot Zoning in Connecticut: 
Incentives and Effects, U.Conn. Center for Real Estate and 
Urban Economic Studies, May, 1979. 

  

CHRO, The Status of Equal Housing Opportunity (May, 1978) 
  

  

Suburban Action Institute, Developing Inclusionary Zoning 
Ordinances, prepared for Commission on Human Rights and 
Opportunities (May, 1978) 
  

Suburban Action Institute, A Study of Zoning in Connecticut, 
prepared for Commission on Human Rights and Opportunities 
(April, 1978) 

  

CHRO in cooperation with U.S. DOT, Federal Highway 
Administration and the Connecticut DOT, Human Rights Impact 
Statement for Proposed Widening of Interstate 91 and 
Interstate 291, Final Draft, June 1976. 

  

  

  

26. Education/Instruccion Reports (1974) 

27. Other reports (see bibliography prepared by Lisa Galipo)