Correspondence between Gordon and Ellis Re: Deposition

    ® » 
National Office 

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 

Mr. William M. Gordon 

148 Greenmount Blvd. 

Dayton, Ohio 4541 

Re: Sheff v. O'Neill 
  

Dear Mr. Gordon: 

Enclosed please find the certificate of service which was 

inadvertently omitted from your October 6 letter. Please accept my 

apology. 

Sincerely yours, 

Marcella G. Williams 
Secretary to 

Ronald L. Ellis 

Encl. 

oy Regional Offices 

ontributions are The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not i cte . 3 part i 

deductible for U.S. of the National Association for the Advancement of Colored People ater NW — inth 
income tax purposes. (NAACP) although LDF was founded by the NAACP and shares its Washington DC 20005 Los A [EA 

commitment to equal rights. LDF has had for over 30 years a separate (202) 682.1300 (1) 24.2405 : 
Board, program, staff, office and budget. Fax: (202) 682-1312 Fax: (213) 624-0075 

 



      

CERTIFICATION 
  

This is to certify that on this 7th day of October, 1992 a 

copy of the foregoing was mailed to the following counsel of 

record: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

Philip Tegeler, Esq. 
Martha Stone, Esq. 

Connecticut Civil 
Liberties Union 
32 Grand Street 
Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense 
and Education Fund 
99 Hudson Street 
14th Floor 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036 

Wilfred Rodriguez, Esq. 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

Wesley W. Horton, Esq. 
Moller, Horton & 

Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers, Esq. 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Education Fund, Inc. 
99 Hudson Street 

New York, NY 10013 

Ar 
  

go R. Whelan 
istant Attorney General 

  

  
 



    

William M. Gordon 

148 Greenmount Blvd. Office: (513) 299 9098 

Dayton, Ohio 45419 (513) 873 3006 

Home: (513) 299 6065 
Fax: (513) 299 9786 

October 11, 1992 

Mr. Ronald L. Ellis 
NAACP Legal Defense 
Suite 1600 
99 Hudson Street 
New York, New York 10013-2897 

Sheff v. O'Neill 

Dear Ron: 

I received your note and business cards but, the "recent 
certificate of service" was not included. You might want to drop 
a copy in the mail if you have some time, I think it would be 

helpful to me. 

Very truly yours, 
\ 

3 

. \ 

: 2A \ \ 
\ \ 

William M. Gordon 

 



   
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 

October 6, 1992 

Mr. William M. Gordon 

148 Greenmount Blvd. 

Dayton, Ohio 45419 

Re: Sheff v. 0’Neill 
  

Dear Bill: 

Enclosed please find three (3) of my business cards for your 
coffee cups. Also enclosed is a recent certificate of service 
showing plaintiffs’ counsel and their affiliations. Sandra 
DelValle has replaced Jenny Rivera of the Puerto Rican Legal 
Defense and Education Fund. Julius Chambers, Ruben Franco and John 

Powell are listed for organization purposes and play no active role 
in the litigation. 

The defendants are represented by John Whelan and, more 
recently, Martha Watts. 

Very truly yours, 

Ronald L. Ellis 
Encls. 

Regional Offices 

Contributions are The NAACP Legal Defense & Educational Fund, Inc. (LDF) is not part Suite 301 Suite 208 
deductible for U.S. of the National Association for the Advancement of Colored People 1275 K Street, NW 315 West Ninth Street 
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 (213) 624-2405 
Board, program, staff, office and budget. : Fax: (202) 682-1312 Fax: (213) 624-0075 

 



  

William M. Gordon 

148 Greenmount Blvd. Office: (513) 299 9098 
Dayton, Ohio 45419 (513) 873 3006 
Li Home: (513) 299 6065 

Fax: (513) 299 9786 

September 29, 1992 

Mr. Ronald L. Ellis 
NAACP Legal Defense Fund 
99 Hudson Street 
New York, New York 10013 

RE: Sheff v. O'Neill 
  

Dear Ron: 

Though a bit concerned at the onset of my preparation for last 
week’s deposition, I felt Thursday went well and that we were 
able to establish our positions without giving very much ground. 
upon reflection, the time spent in New York was really quite 
helpful as was the opportunity on Thursday to meet with the 

clients/lawyers and on Friday to take a complete tour of the city 
and see each school. I feel as a result of this last visit that I 
have a much stronger understanding of the litigation and thus a 
higher comfort level. 

Enclosed is my invoice for the trip and time spent reviewing the 
documents and preparing for the deposition. As agreed, I have 
deferred $15/hour of my consulting fee which will be settled at 
the close of the litigation. 

I also want you to know that I thoroughly enjoyed the opportunity 
to work with you and to spend some fee time together. It is 
always more comforting to know ones colleagues as a trial date 

approaches and with the substantial number of attorneys involved 
in this case working closely with you and Phil reduces my 
anxieties. It would be helpful if I had a roster of attorneys. I 
keep trying to sort out the various litigants but have met with 
some confusion of names. Also, I need from you a replacement 
business card for the coffee stained one I had to give up at the 
deposition. 

As directed, I am submitting a separate invoice to Phil for my 
deposition time. I am enclosing a copy for your files so you will 

 



remain fully informed concerning my activities. 

Take care, I look forward to our next meeting, be it the trial or 

sooner. Phil has indicated he is thinking of scheduling me during 
the Thanksgiving week. I have gone ahead and made reservations, 
just in case. 

Very truly yours, 

vn ny 
William M. Gordon 

Enclosures: