Joint Motion for Extension of Time to Disclose Expert Witnesses Pursuant to Practice Book Section 220 (D)

    Cv89-0360977S 

  

MILO SHEFF, et al. - SUPERIOR COURT 

Plaintiffs : 

Vv. : JUDICIAL DISTRICT OF 
: HARTFORD/NEW BRITAIN 

WILLIAM A. O'NEILL, et al. : AT HARTFORD 

Defendants : Maych 18,1991 

  

PLAINTIFFS’ SECOND IDENTIFICATION OF EXPERT WITNESSES 
PURSUANT TO PRACTICE BOOK §220 (D) 
  

  

Pursuant to Practice Book §220(D), as modified by this 

Court's Order of October 31, 1990 and the parties’ Joint Motion 

for Extension of Time to Disclose Expert Witnesses filed December 

3, 1990, the plaintiffs herein disclose their second list of 

expert witnesses anticipated to testify at trial, in response to 

Defendants’ First Set of Interrogatories. In addition, 

plaintiffs have identified other possible witnesses who may 

testify at the trial in this action, but whose analyses are not 

sufficiently complete to respond to defendants’ interrogatory or 

to confirm whether plaintiffs expect to call such witnesses. As 

set out in the parties’ Joint Motion for Extension of Time to 

Disclose Expert Witnesses filed December 3, 1990, such additional 

expert witnesses may be identified in sixty days or thereafter. 

  

  
 



  

  

    

Interrogatory 18. Please specify the name and address of 
each and every person the plaintiffs expect to call as an expert 
witness at trial. For each such person please provide the 
following: 

  

a. The date on which that person is expected to complete 
the review, analysis, or consideration necessary to formulate the 
opinions which that person will be called upon to offer at trial; 

b. The subject matter upon which that person is expected to 
testify; and 

c. The substance of the facts and opinions to which that 
person is expected to testify and a summary of the grounds for 
each opinion. 

RESPONSE: Experts whom the plaintiffs expect to call at trial   

are listed below, pursuant to Practice Book Section 220(D), as 

modified by the Court: 

Charles V. Willie, Ph.D., Harvard University, Graduate 
School of Education, Monroe C. Gutman Library, Cambridge, MA 
02138. Dr. Willie is expected to testify about the 
restructuring of educational attendance patterns and/or 
districts to eliminate racial isolation and to enhance the 
quality of education, especially for nonwhite school 
children concentrated in racially and economically impacted 
areas. Dr. Willie is expected to analyze the effects of 
segregated education upon the learning ability of white and 
nonwhite school children. He is also expected to propose 
educational plans to insure educational and racial equity. 

  

Dr. Catherine E. Walsh, University of Massachusetts, 250 
Stuart Street, Boston, MA 02116. Dr. Walsh is expected to 
testify regarding the linguistic and sociocultural issues 
involved in the racial and economic isolation of Puerto 
Rican and other Latino students. Dr. Walsh is expected to 
testify about the structure, instructional orientation, 
content and physical location of bilingual education. She 
is expected to generally testify regarding curriculum 
restructuring, school-based management, educational grouping 
of Puerto Rican students to promote integration while 
providing for the students’ needs, and the relationship 
between language and literacy development and academic 

  

  

  

  

 



  

      

    

achievement for Puerto Rican students. Dr. Walsh is also 
expected to testify as to remedial plans in the remedial 
portion of this case. Dr. Walsh's testimony will be based 
upon her review of the available surveys and theoretical 
works regarding the functioning of bilingual programs and 
segregated and desegregated school systems, and on her own 
experience and her investigations into the functioning of 
the schools, school systems and bilingual programs of the 
Greater Hartford Area and other places and on the results of 
investigations made by other expert witnesses in this case. 

Yale Rabin, 9 Farrar Street, Cambridge, MA 02138. 
Professor Rabin is expected to testify regarding 
actions of state and local officials that have 
contributed to the development of segregated housing 
patterns in the Hartford region. Specifically, 
Professor Rabin is expected to testify as to the 
state's role in the location of subsidized low income 
family housing in the Hartford area; the current and 
historical racial consequences of those decisions; the 
effects of state transportation policies, including 
highway construction, on residential segregation; the 
effects of the state’s failure to adequately monitor 
and enforce affirmative marketing requirements; the 
effects of state administration and regulation of 
rental assistance programs; and the state's en- 
couragement of local barriers to the development of 
affordable housing, including municipal veto laws, 
residency preferences, and exclusionary zoning. 
Professor Rabin is also expected to present historical 
analysis of the development of racial and economic 
segregation in the Hartford region, and to summarize 
the studies and reports presented to the state during 
the past 40 years indicating the growth of racial and 
economic segregation, the role of government action in 
contributing to segregation, and the opportunities open 
to the state to remedy the problem. In his testimony, 
the materials upon which Professor Rabin is expected to 
rely include his published work, U.S. Census data; 
published and unpublished reports by state agencies, 
including but not limited to the Department of Housing 
and its predecessors, the Office of Policy and 
Management, the Commission on Human Rights and 
Opportunities, the Department of Transportation, the 
Connecticut General Assembly, and reports or testimony 
regarding housing, land use and transportation 
submitted to the state by private organizations. 

  

  

  
 



  

    

    

Professor Rabin is expected to complete his review by 
June 1, 1991. 

Ruth Price, 196 Glengarry Road, Fairfield, CT 06430. 
Ms. Price 1s expected to testify regarding actions of 
state and local officials that have contributed to the 
development of segregated housing patterns in the 
Hartford region. Specifically, Ms. Price is expected . 
to testify as to the state's role in the location of 
subsidized low income family housing in the Hartford 
area and the types of subsidized housing located in 
each town; the income and racial characteristics of 
residents in such housing; the history of state 
transportation policies, including highway 
construction, as they affect the residential 
segregation; the state's failure to adequately monitor 
and enforce affirmative marketing requirements; the 
state’s administration and regulation of rental assis- 
tance programs; and the state’s encouragement of local 
barriers to the development of affordable housing, 
including municipal veto laws, residency preferences, 
and exclusionary zoning. Ms. Price will also review 
and summarize the studies and reports prepared by or 
presented to the state during the past 40 years 
indicating the growth of racial and economic 
segregation, the role of government action in 
contributing to segregation, and the opportunities open 
to the state to remedy the problem. In her testimony, 
Ms. Price is expected to rely on United States census 
data and published and unpublished reports by state 
agencies, including but not limited to the Department 
of Housing and its predecessors, the Office of Policy 
and Management, the Commission on Human Rights and 
Opportunities, the Department of Transportation, the 
Connecticut General Assembly, and reports or testimony 
regarding housing, land use and transportation sub- 

  

mitted to the state by private organizations. Ms. 
Price is expected to complete her review by June 1, 
1991. 

In addition to the areas of testimony set out above, 

plaintiffs’ experts are also expected to interpret and comment on 

the testimony and research of other experts, including both 

  

    

  
 



  
plaintiffs’ and defendants’ experts. With respect to documents 

listed herein, plaintiffs have included some of the primary 

sources upon which these experts base their opinions, but have 

not provided a comprehensive list of all documents reviewed or 

relied on. If any other additional areas of testimony are 

identified for the foregoing experts or other documents upon 

which they primarily rely are identified, plaintiffs will 

identify such testimony and documents in a timely fashion, 

pursuant to the parties’ Joint Motion for Extension of Time to 

    
Disclose Expert Witnesses filed December 3, 1990. 

Wesley W. Horton 
Moller, Horton, & Fineberg 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers 

Marianne Lado 

Ron Ellis 

NAACP Legal Defense & 
Educational Fund, Inc. 

99 Hudson Street 
New York, NY 10013 

Respectfully Submitted, 

ww. JPY TER 
  

Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 

Union Foundation 

32 Grand Street 
Hartford, C7 06106 

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

John Brittain 

University of Connecticut 
School of Law 

65 Elizabeth Street 
Hartford, C7 06105   

  

 



  

- Bi 

Helen Hershkoff Jenny Rivera 
John A. Powell Puerto Rican Legal Defense 
Adam Cohen and Education Fund 
American Civil Liberties 99 Hudson Street 

Union Foundation New York, NY 10013 
132 West 43rd Street 

New York, NY 10036 

CERTIFICATE OF SERVICE 
  

This is to certify that one copy of the foregoing has been 

mailed postage prepaid by certified mail to John R. Whelan and 

Diane W. Whitney, Assistant Attorney Generals, MacKenzie Hall, 

110 Sherman Street, Hartford, CT 06105 this yr day of March, 

a a 
1991.   

  

Philip D. Tegeler