Correspondence from Carraway to Neyhart, Markham, and McGee Re: Joint Appendix; Enclosed Weber Testimony Excerpts and Exhibits

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

August 26, 1992 

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

RE: Sheff v. O'Neill 
  

Dear John, 

Pursuant to paragraph 4 of the Pretrial Order of April 10, 
1992, we are giving notice as to the documents requested for the 
deposition of Lloyd Calvert scheduled for September 8, 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. Calvert’s anticipated testimony be provided to us prior to the 
deposition. 

Thank you for your cooperation. 

Sincerely, 

/5/ 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 

ws 

 



  

SUBPOENA DUCES TECUM 
  

TO: Lloyd Calvert 

c\o Office of the Attorney General 
MacKenzie Hall 
110 Sherman Street 
Bartford, CT 06105 

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 9:30 a.m. on the 8th 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 wv. 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: 

1. Notes of any interviews conducted with any staff of the 
Hartford public schools. 

2. Copies of any reports, memoranda, proposals, or articles you 
have written on the subject of racial integration prior to 
your employment by the Office of the Attorney General. 

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

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

5. Copies of all "Records of the State Board of Education" 
referred to at p. 17 of Defendants’ Amended Disclosure of 
Expert Witnesses (July 23, 19%2). 

6. Summaries of all data you rely on in your testimony, 
including data on demographics and current enrollment in 
Hartford area schools. 

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

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

[Ss] 
  

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 hand- 
delivered to John R. Whelan and Martha M. Watts, Assistant Attorneys 
General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 06105 this 

day of August, 1992. 

  

Philip D. Tegeler/Martha Stone 
Attorneys for Plaintiffs