Memo RE: Next Strategy Meeting with Attached Plaintiff Plan

    HE 
MEMORANDUM 

To: Sheff Plaintiffs and Legal Team 

FROM: Dennis Parker 9.9.€. 

SUBJECT: Next Strategy Meeting 

DATE: November 19, 1999 

  

Because of the unavailability of a number of people, we had to reschedule the next 

meeting to December 7, 1999. The legal team will meet at 4:00 p.m. followed by the 

plaintiffs at 6:00 p.m. The meeting will be at the CCLU and will be attended by Len Stevens 

and (perhaps by phone) Tony Baez. The plan is to adjourn the meeting in time to watch and 

cheer on Elizabeth Horton Sheff during her swearing-in. 

Attached is a document that Len Stevens drew up following our discussion last week about 

strategy. Although it has not been adopted by the group but it is intended to provoke discussion 

and serve as a backdrop for our discussion about next steps. 

Please call Dianne Simmons at 1-212-965-2255 to confirm your attendance at this meeting. 

 



   
Stevens ™ 413-637-4075 ®011/16/99 12:42 02/2 

ASSUMPTIONS OF PLAINTIFFS’ PROPOSED PLAN 

1. The actions of the State since July 9, 1996 are insufficient to cure the 
Constitutional violations found by the Supreme Court in Sheff v. O'Neill. 

The State has not proposed a sufficient plan. 

2. Plaintiffs goal is implementation of a desegregation plan in Greater Hartford 
which provides “substantially equal educational opportunity” to all pupils by 
eliminating racial and ethnic segregation in the schools. 

« Plaintiffs expect a remedy that works, and works now--“before another 
generation of children suffers the consequences of a segregated public 
school education.” 

3. Plaintiffs will develop a proposed plan by June 30, 2000. 

* Plaintiffs will support their Proposed Plan with community informing 
and organizing activities. 

» Plaintiffs’ proposed plan will be consistent with Plaintiffs’ Guidelines for 
an Effective Plan for Quality Integrated Schools. 

Plaintiffs will use their Proposed Plan as a standard to measure the 
effectiveness of State actions and State plans. 

5. Until a comprehensive plan is developed by the State or by the Court, 
Plaintiffs encourage the Legislature and the Governor to enact any and all laws 
and regulations that are responsive in part to the ruling of the Supreme Court. 

« Plaintiffs position on each such matter will be based on Plaintiffs’ 
analysis as to whether the State’s proposed action is consistent with 
Plaintiffs’ Proposed Plan. 

+ Plaintiffs do not view piecemeal action by the State as constituting an 
“appropriate remedy for the plight of Hartford's public schoolchildren.” 

6. By March 30, 2000, and at each six month interval thereafter, Plaintiffs will 

determine when to seek further relief from the Court regarding a comprehensive 
plan for Greater Hartford. 

* Pending Court action on an appropriate remedy, Plaintiffs stand ready to 
enter settlement discussions with the State. 

NOU 16 ’99 12:58 41363748075 PRGE.B2 

 



JF 

COVER 
  

  
  
  
  
  

S HE EB. 1 

To: 

Deborah Archer 

Sandra Del Valle 

Derek Douglas 

Chris Hanson 

Wesley Horton 

Marianne Engelman Lado 

Wilfred Rodriquez 

Elizabeth Horton Sheff 

Martha Stone 

Philip Tegeler 

From: 

Subject: 

Date: 

Pages: 

Original: Will 

Message: 

Suite 1600 

NAACP LEGAL DEFENSE & EDUCATIONAL FUND, INC 

99 Hudson Street 

New York, NY 10013-2897 

(212) 965-2200 

Company: 

NAACP Legal Defense Fund 

Puerto Rican Legal Defense Fund 

NAACP Legal Defense Fund 

American Civil Liberties Union 

Horton, Shields & Cormer, P.C 

NY Lawyers for the Public Interest 

Greater Hartford Legal Assistance 

Community Renewal Team 

Center for Children Advocacy 

Connecticut Civil Liberties Union 

Dennis Parker 

Sheff Planning Meeting 

November 19, 1999 

3, including this cover sheet. 

Will Not X 

FAX 
Fax #: 

212/226-7592 

212/431-4276 

212/226-7592 

212/549-2651 

860/728-0401 

212/244-4570 

860/541-5050 

860/527-3305 

860/570-5256 

860/728-0287 

Follow this transmission 

Confidentiality Note: The information transmitted in this facsimile message is intended to be confidential and for the user of 

only the individual or entity named above. If the recipient is a client, this message may also be for the purpose of rendering 

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%% JOB STATUS REPORT #*% AS OF NOV. 19 1999 4:46. PM © PAGE. 01 

NAACP LEGAL DEFENSE 

  

JOB #535 

DATE TIME TO, FROM MODE MIN/SEC PGS STATUS 

001 11.719 4: 30P 212549265) EC——S 04° 14 003 OK 

002 4:35P 8607280401 EC--S gc 337: 003 OK 

003 4:37P NY LAWYERS PUB INT UE——5 00-42%. D003 OK 

004 4:38P 203 541 5050 EC—=S Ol 46" 003 OK 

005 4:40P 4314276 EC——5 0028" 003 OK 

006 4:41P 860-327 3305 BCS 00 43” 003 OK 

007 4:42P 8360 3570 5286 EC——5 Be S53= 003 OK 

008 4:44pP 860.728 0237 EC—S5 01278 «003 OK 

  

TIF NAACP LEGAL DEFENSE & EDUCATIONAL FUND, INC 
99 Hudson Street 

Suite 1600 
New York, NY 10013-2897 

(212) 965-2200 

  

  

  

  

  

  

  

COVER EF AX 

SH EEF T 

To: Company: Fax #: 

Deborah Archer NAACP Legal Defense Fund 212/226-7592 

Sandra Del Valle Puerto Rican Legal Defense Fund 212/431-4276 

Derek Douglas NAACP Legal Defense Fund 212/226-7592 

Chris Hanson American Civil Liberties Union 212/549-2651 

Wesley Horton Horton, Shields & Cormer, P.C 860/728-0401 

Marianne Engelman Lado NY Lawyers for the Public Interest 212/244-4570 

Wilfred Rodriquez Greater Hartford Legal Assistance 860/541-5050 

Elizabeth Horton Sheff Community Renewal Team 860/527-3305 

Martha Stone Center for Children Advocacy 860/570-5256 

Philip Tegeler Connecticut Civil Liberties Union 860/728-0287 

From: Dennis Parker 

Subject: Sheff Planning Meeting 

Date: November 19, 1999 

Pages: 3, including this cover sheet. 

Original; Will 

Message: 

WillNot X Follow this transmission 

Confidentiality Note: The information transmitted in this facsimile message is intended to be confidential and for the user of 
only the individual or entity named above. If the recipient is a client, this message may also be for the purpose of rendering 
legal advice and thereby privileged. If the reader of this message is not the intended recipient, you are hereby notified that 
any retention, distribution or copy of this telecopy is strictly prohibited. If you receive this facsimile in efror, pleases immediately 
notify us by telephone and return the original message to use at the address above via the mail service (we will reimburse 
postage}. Thank you