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

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Cv89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

v. JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

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

Defendants NOVEMBER 28, 1990 

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JOINT MOTION FOR EXTENSION OF TIME TO DISCLOSE 
EXPERT WITNESSES PURSUANT TO PRACTICE BOOK SECTION 220(D) 
  

  

The parties respectfully request an extension of time to 

disclose the experts expected to testify at trial pursuant to 

Practice Book Section 220(D) as follows: 

a. On January 15, 1990, all parties shall simultaneously 

disclose the initial list of persons whom each party expects to 

call as an expert witness at trial (including any employees or 

consultants of defendants or plaintiffs), shall state the subject 

matter on which the expert is expected to testify, and shall 

state the substance of the facts and opinions to which the expert 

is expected to testify and a summary of the grounds for each 

opinion. 

b. Every sixty days thereafter, all parties shall exchange 

a list of any additional expert witnesses identified in the prior 

sixty-day period. 

NO ORAL ARGUMENT REQUESTED/NO TESTIMONY REQUIRED   
 



      

Cs Plaintiffs shall make final disclosure of such expert 

witnesses 120 days prior to the final trial date, and defendants 

shall make final disclosure of such expert witnesses sixty days 

thereafter. 

In support of this joint motion, the parties state the 

following: 

1. On: "July. 13, 1990, the defendants submitted 

interrogatories to the defendants which requested a list of 

expert witnesses which the plaintiffs intend to offer. 

2. On September 24, 1990, the plaintiffs submitted 

interrogatories to the defendants which requested a list of 

expert witnesses which the defendants intend to offer. 

3. On September 6, 1990, plaintiffs submitted a Joint 

Stipulation for Extension of Time to Respond to Defendant's First 

Set of Interrogatories, which included a stipulation that 

disclosure of experts be delayed until October 31, 1990. 

4. On October 9, 1990, defendants also submitted a Motion 

for Extension to Disclose Experts Pursuant to Practice Book 

Section 220(D). 

Ba On October 31, 1990, this Court granted a Joint Motion 

for Extension of Time to Respond to Interrogatories Regarding 

Disclosure of Expert Witnesses, pending formulation of the 

present motion. 

  

 



      

6. Because of the extremely complex and comprehensive 

nature of this case, at the present time, neither party has 

completed the process of identifying expert witnesses for trial, 

nor have the identified experts completed all of their research 

and analysis. 

7. The present case presents a broad challenge to the 

defendants’ practices in regard to the system of public education 

in the Hartford region. Because of the wide range of possible 

issues upon which the plaintiffs might want to offer expert 

testimony, the defendants will not know the entire scope of 

expert testimony they might need to seek until plaintiffs have 

identified their experts and the subject matter on which these 

experts will testify. 

8. The present motion would permit plaintiffs’ experts to 

substantially complete their research prior to being subjected to 

depositions by defendants. The present motion would also permit 

defendants to wait until such research is completed to conduct 

depositions, thus alleviating the need for duplicating 

depositions of the same witness. 

9. The parties, by this motion, do not waive any rights 

they may have to object to depositions or other discovery of 

experts, or to move for payment for such depositions or other 

discovery pursuant to Practice Book Section 220. 

  

 



      

WHEREFORE, the parties request an extension of time as set 

out above to disclose their experts pursuant to Practice Book 

Section 220(D). 

FOR THE PLAINTIFFS 

[PF   
Philip D. Tegeler 
Martha Stone 
Connecticut Civil Liberties 

Union Foundation 

32 Grand Street 

Hartford, CT 06106 

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 

Helen Hershkoff 

John A. Powell 
Adam Cohen 
American Civil Liberties 

Union Foundation 

132 West 43rd Street 

New York, NY 10036 

Respectfully Submitted, 

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, CT 06105 

Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
New York, NY 10013 

  

 



  

FOR THE DEFENDANTS 

CLARINE NARDI RIDDLE 

ATTO Y GENERAL : 

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ordi L/L 
A sistant Attorney General 
¥10 Sherman Street 
Hartford, Connecticut 06105 
Telephone: 566-3696 

By: 
    
ORDER   

( For good cause shown the foregoing motion is hereby: 

GRANTED/DENIED 

BY THE COURT 
  

  

      
 



      

CERTIFICATION   

This is to certify that a copy of the foregoing was mailed, 

postage prepaid on December B, 1990 to the following counsel or 

record: 

John Brittain 

University of Connecticut 
School of Law 

65 Elizabeth Street 
Hartford, CT 06105 

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

Philip Tegeler 
Martha Stone 

Connecticut Civil Liberties Union 

32 Grand Street 
Hartford, CT 06106 

Wesley W. Horton 
Mollier, Horton & Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

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

Julius L. Chambers 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 

  

 



      

NAACP Legal Defense Fund and 
Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

John A. Powell 

Helen Hershkoff 

American Civil Liberties Union 

132 West 43rd Street 

New York, NY 10036 

SEL 

John R. Whelan 
Asgistant Attorney General 

   
  

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