Procunier v. Martinez Jurisdictional Statement

    MOLLER, HORTON & SHIELDS, P.C. 

ATTORNEYS AT LAW 

90 GILLETT STREET 

HARTFORD, CONNECTICUT 06105 

SUSAN M. CORMIER TELEPHONE 
WESLEY W. HORTON (203) 522-8338 
KIMBERLY A. KNOX TELECOPIER 

WILLIAM R. MOLLER* (203) 728-0401 
KAREN LL. MURDOCH 

CHRISTY SCOTT 

ROBERT M. SHIELDS, JR. 

*ALSO ADMITTED IN DISTRICT OF COLUMBIA April: 27, 1995 

To All Plaintiffs Lawyers: 

Enclosed are the appeal documents which have been filed in 
Hartford Superior Court and the Appellate Court today. Enclosed 
also is Chris Hansen’s pro hac vice motion which Judge Thelma 
Santos granted this morning before the appeal was filed. Our 
brief is due on June 12, 1995. I will let you know as soon as I 
hear from the Supreme Court clerk. 

Very truly yours, 

Wi, 
Wesley W. Horton 

WWH: jt 
cc: Ms. Elizabeth Horton-Sheff 

 



APPEAL - CIVIL 
JD-SC-28 New 8-92 (Old JD-SC-10) INSTRUCTIONS 
P.B. §§ 65, 4012, 4013, 4034 1. Prepare on typewriter. 

C.G.S. §§ 51-1971, 52-470 2. Sign "Appeal" and "Certification" sections below. 
3. Submit in triplicate to the trial court clerk with sufficient additional copies for 

TO SUPREME COURT each other counsel of record; serve copies on opposing counsel. 
TO APPELLATE COURT 4. File a copy of the endorsed appeal form together with the papers required by 

P.B. § 4013 with the Appellate Clerk. 
  

  

NAME OF CASE (State full name of case as appears in judgment file) 
; nd ; See Attached sheet for ' Milo Sheff, et al. v. William A. O'Neill, et al. { thes parties ) 
  

CLASSIFICATION OTHER (Speci 
: CROSS [] JOINT AMENDED CONSOLIDATED STIPULATION FOR CORRECTED/AMENDED (Specky) 

  

APPEAL APPEAL APPEAL APPEAL APPEAL RESERVATION APPEAL FORM 

. TRIED TO TRIAL COURT LOCATION 

X] court [] sury | Hartford 
  

TRIAL COURT JUDGE LIST ALL TRIAL COURT DOCKET NUMBERS 

Hammer, J. CV_89-0360977S     
JUDGMENT FOR (Where there are multiple parties, specify any individual party(ies) for whom judgment may have been entered.) 

[ JpLaNTIFE KX] DEFENDANT [| OTHER 
  

  

TRIAL COURT JUDGMENT DATE DATE FOR FILING APPEAL EXTENDED TO |DATE OF ISSUANCE OF NOTICE ON ANY ORDER ON ANY MOTION WHICH 

HISTORY 4/1 2/95 2 WOULD RENDER JUDGMENT INEFFECTIVE 

      
CASE TYPE 

[ Jouvenite XJ civil: Major/Minor code M50 [JFamiLy [| WORKERS COMPENSATION 

[] HABEAS CORPUS [ ]oTHER 
  

  

DATE CERTIFICATION GRANTED 

  
For habeas corpus or zoning appeals indicate the date certification was granted: 
  

ABPER FILED BY (Where there are multiple parties, specify the name of the individual party(ies) filing this appeal.) 

PLAINTIFFS |] DEFENDANT [ ]oTHER 
    

  

who appeal 
FROM (the action which constitutes the final judgment): Judgment for defendants entered 
  

APPEAL April 12, 1995 
  

  

IF TO SUPREME COURT, STATUTORY BASIS FOR THE APPEAL (C.G.S. § 51-199) 

  

        

i 

BY (Signaturejof attorney pr e Pag ~~. TELEPHONE NO. JURIS NO. (If applicable) 

X 522-8338 38478 
TYPE NAME AND ADDM®ESS OF PERSON SIGNING ABOVE (This is your appearance, see P.B. § 4034) 

Wesley W Horton, 90 Gillett Street, Hartford, CT 06105 
  

"X" ONE IF APPLICABLE 
APPEARANCE [] Pursuant to P.B. § 4034, counsel who files this appeal shall be deemed to have appeared in addition to counsel of 

record who appeared in the trial court. 
  

NAME OF COUNSEL AND JURIS NO. 
[] Pursuant to P.B. § 65 counsel who files 

this appeal is appearing in lieu of: 
INDICATE WHICH OF THE FOLLOWING ARE ATTACHED BY PLACING AN *X" IN THE PROPER BOX(ES) 

1. PRELIMINARY STATEMENT OF THE ISSUES K] 4. DOCKET SHEETS (DS-1)/DOCKETING STATEMENT 

    

ATTACHMENTS |[X] 2. PRELIMINARY DESIGNATION OF PLEADINGS ~~ [X|5. STATEMENT FOR PREARGUMENT CONFERENCE 

3. COURT REPORTER'S ACKNOWLEDGEMENT/ 
CERTIFICATE RE TRANSCRIPT 

NAME OF PERSON RECOGNIZED TO PROSECUTE IN THE AMOUNT OF $400 TELEPHONE NO. 

Jane Tedford Dube 228-4626 
ADDRESS OF PERSON NAMED ABOVE 

RECOGNIZANCE| 71 Northam Road, Hebron, CT 06231 

  

    

  

        

SIGNED (O Je taking recognizance; $X" proper box) Comm. Sup. Court DATE SIGNED 

LANL 1) Cou Sie April 27, 1995 
| HEREBY CERTIFY THA PY HEREOF WAS SERVED ON |DATE SIGNED (I           

nffividual counsej 

CERTIFICATION | ALL COUNSEL AND PRO SE PARTIES OF RECORD IN ACCOR- 
(P.B. § 4012) DANCE WITH THE PROVISIONS OF P.B. § 4014 ON: 4/27/95 X 

To be completed by trial court clerk 
  

L] Entry Fee Paid [1] No Fees Required Security furnished: [] Cash [d Bond 

[1] Record Fee Paid [] Fees, Costs, and Security waived by Judge: [J Recognizance 

(A.C. only) 
  

  
(Judge) (Date) 

ini (Clerk of trial court) 

    

  

   



      

Additional Plaintiffs: 

Wilda Bermudez 
Pedro Bermudez 

Eva Bermudez 

Oskar M. Melendez 

Waleska Melendez 

Martin Hamilton 
Janelle Hughley 
Neiima Best 
Lisa Laboy 
David William Harrington 
Michael Joseph Harrington 
Rachel Leach 

Joseph Leach 
Erica Connolly 
Tasha Connolly 
Michael Perez 
Dawn Perez 

Additional Defendants: 

William A. O’Neill’s successor Governor of the State of 

Connecticut 

State Board of Education of the State of Connecticut 

Abraham Glassman, A. Walter Esdaile, Warren J. Foley, Rita 
Hendel, John Mannix, Julia Rankin, or their successor members of 
the State Board of Education of the State of Connecticut 

Gerald N. Tirozzi, or his successor Commissioner of the 
Board of Education of the State of Connecticut 

Francisco L. Borges, or his successor Treasurer of the State 

of Connecticut 

J. Edward Caldwell, or his successor Comptroller of the 
State of Connecticut 

  

 



  

  

    

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 
following counsel of record on April 27, 1995: 

Richard Blumenthal 
Martha Watts Blumenthal 

Bernard McGovern 

STATE OF CONNECTICUT 

110 Sherman Street 

Hartford, CT 06106 

  WesTey W. HArton 

  

 



MOLLER, HORTON & SHIELDS, P.C. 

ATTORNEYS AT LAW 

90 GILLETT STREET 

HARTFORD, CONNECTICUT 06105 

  

SusaN M. CORMIER TELEPHONE 

WESLEY W. HORTON (203) 522-8338 

KIMBERLY A. KNOX TELECOPIER 

WILLIAM R. MOLLER* (203) 728-0401 

KAREN L. MURDOCH 

CHRISTY SCOTT 

ROBERT M. SHIELDS, JR. 

*ALSO ADMITTED IN DISTRICT OF COLUMBIA April 27, 1995 

Michéle Angers, Deputy Chief Clerk 
APPELLATE COURT 

Drawer Z, Station A 
Hartford, CT 06106 

Re: Sheff, et al. v. O’Neill, et al. 

Dear Ms. Angers: 

Pursuant to P.B. §4024, the plaintiffs request that the Supreme 

Court immediately transfer this appeal to the docket because it 

involves a matter of great public importance. 

- Very truly yours, 

Wesley W. Horton 

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to 

Richard Blumenthal, Bernard McGovern and Martha Watts Prestley, State 

of Connecticut, 110 Sherman Street, Hartford, CT 06106. 

  

   



  
    

A.C 
(CV 89-0360977S) 

MILO SHEFF, ET AL. : APPELLATE COURT 

VS. 

WILLIAM A. O'NEILL, ET AL. : APRIL 27, 1895 

PRELIMINARY STATEMENT OF ISSUES 
  

Pursuant to P.B. §4013(a) (1), the plaintiffs intend to raise the 

following issues: | 

1. Did the court err in refusing to follow the construction of 

Article First, §§1 and 20 and Article Eighth, §1 of the Connecticut 

Constitution established in Horton v. Meskill, which held that the 
  

state is required to assure to all of Connecticut’s public school 

students an equal educational opportunity? 

,. Did the court err in failing to recognize as "state action" 

the state’s extensive involvement in public education in denying 

plaintiffs’ claims of racial and ethnic segregation, unequal 

educational opportunity and lack of a minimally adequate education? 

3. Did the court err in failing to recognize that the state 

constitution gives rise to an affirmative duty on the state to address 

racial and ethnic segregation, unequal educational opportunity and 

lack of a minimally adequate education and that the state failed to 

act to remedy these constitutional and statutory deficiencies?    



      

4% Did the admitted and undisputed evidence require the Court 

as a matter of law to find that the students in the Hartford public 

schools are not receiving an equal educational opportunity? 

PLAINTIFFS, MILO SHEFF, ET Al. 

By A A LIA 
We W§/ Horton 
MOLLFR, HORTON & SHIELDS, P.C. 

90 Gillett Street 
Hartford, CT 06105 

(203) 522-8338 
Juris No. 38478 

  

John Brittain 
UCONN Law School 

65 Elizabeth Street 
Hartford, CT 06105 

Martha Stone 

Philip D. Tegeler 
CCLU i 

32 Grand Street 

Hartford, CT 06106 

Christopher Hansen 

ACLU 
132 West 43rd Street 

New York, NY 10013 

Marianne Engelman Lado 

Theodore Shaw 

Dennis D. Parker 
NAACP-LDF 
99 Hudson Street 

New York, NY 10013 

Sandra Del Valle 
Puerto Rican Legal Defense 
99 Hudson Street 
New York, NY 10013 

Wilfred Rodriguez 

NEIGHBORHOOD LEGAL SERVICES 

1229 Albany Avenue 

Hartford, CT 08102 

  

 



  

  
    

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 
following counsel of record on April 27, 1995: 

Richard Blumenthal 
Martha Watts Blumenthal 

Bernard McGovern 

STATE OF CONNECTICUT 

110 Sherman Street 

Hartford, CT 06106 

Wo AAUETS 
  Wesléwy/W. Horton 

  

 



A.C. 

(CV 89-03609775) 

MI1LO SHEFF, ET Al. : APPELLATE COURT 

VS. 

WILLIAM A. O/NEILL, ET AL. : APRIL 27, 1995 

DESIGNATION OF PLEADINGS 
  

Pursuant to P.B. §4013(a) (2), the plaintiffs designate the 

following for the record on appeal: 

1. Revised Complaint dated November 23, 1994 (#214) 

2% Revised Answer dated November 25, 1994 (#218) 

3. Reply dated November 28, 1994 (#217) 

4. Motion to Strike and Ruling (#103) 

Motion for Summary Judgment and Ruling (#149) 

Memorandum of Decision (#222) 

Judgment 

Appeal 

Preliminary Statement of Issues 

PLAINTIFFS, MILO SHEFF, ET AL. 

TT —— 

  

Wesley ® HortOn 

MOLLER, HORTON & SHIELDS, P.C. 

90 Gillett Street 
Hartford, CT 06105 

(203) 522-8338 
Juris No. 38478 

John Brittain 
UCONN Law School 
65 Elizabeth Street 

Hartford, CT 06105        



      

co 

Martha Stone 

Philip D. Tegeler 
CcCiU 

32 Grand Street 

Hartford, CT 06106 

Christopher Hansen 
ACLU 

132 West 43rd Street 

New York, NY 10013 

Marianne Engelman Lado 
Theodore Shaw 

Dennis D. Parker 
NAACP-LDF 

99 Hudson Street 

New York, NY 10013 

Sandra Del Valle 

Puerto Rican Legal Defense 
99 Hudson Street 

New York, NY 10013 

Wilfred Rodriguez 

NEIGHBORHOOD LEGAL SERVICES 

1229 Albany Avenue 
Hartford, CT 06102 

  

 



  

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 

following counsel of record on April 27, 1995: 

Richard Blumenthal 
Martha Watts Blumenthal 

Bernard McGovern 

STATE OF CONNECTICUT 

110 Sherman Street 

Hartford, CT 06106 

™ 
  

Wes¥ey W. Horton 

        
 



A.C. 

(CV 89-0360977S)   
MILO SHEFF, ET Al. : APPELLATE COURT 

VS. 

WILLIAM A. O'NEILL, ET Al. : APRIL 27, 1995   
CERTIFICATE RE TRANSCRIPT 
  

Pursuant to P.B. §4013(a) (3), the plaintiffs certify that they 

intend to rely on the transcripts of the entire trial. All 

transcripts have already been delivered to counsel. 

PLAINTIFFS, MILO SHEFF, ET AL. 

  

Wesl&G W. Horton 
MOLLER, HORTON & SHIELDS, P.C. 

90 Gillett Street 

Hartford, CT. 06105 

(203) 522-8338 
Juris No. 38478 

John Brittain 
UCONN Law School 

65 Elizabeth Street 

Hartford, CT. 06105 

Martha Stone 

Philip D. Tegeler 
CCLU 

32 Grand Street 

Hartford, CT 06106 

Christopher Hansen 

ACLU 

132 West 43rd Street 

New York, NY 10013 

Marianne Engelman Lado 

Theodore Shaw 

Dennis D. Parker 

NAACP-LDF 

99 Hudson Street 

New York, NY 10013          



      

pe : 

p
o
 

Sandra Del Valle 

Puerto Rican Legal Defense 
99 Hudson Street 

New York, NY 10013 

Wilfred Rodriguez 
NEIGHBORHOOD LEGAL SERVICES 

1229 Albany Avenue 
Hartford, CT 06102 

  

 



    

CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 
following counsel of record on April 27, 1995: 

Richard Blumenthal 

Martha Watts Blumenthal 

Bernard McGovern 

STATE OF CONNECTICUT 

110 Sherman Street 

Hartford, CT 06106 

  

   



  

    

A.C. 

(CV 839=038609778S) 

MILO SHEFF, ET Al. - APPELLATE COURT 

Vs. 

WILLIAM A. O/NEILL, ET AL. : APRIL, 27,.1995 

DOCKETING STATEMENT 
  

Pursuant to P.B. §4013(a) (4), the plaintiffs state as follows: 

(1) Plaintiffs: 

Milo Sheff, 144 Mark Twain Drive, Hartford, CT 
Wilda Bermudez, 378 Hillside Avenue, Hartford, CT 
Pedro Bermudez, 378 Hillside Avenue, Hartford, CT- 
Eva Bermudez, 378 Hillside Avenue, Hartford, CT 
Oskar M. Melendez, 23 Webster Lane, Glastonbury, CT 
Waleska Melendez, 23 Webster Lane, Glastonbury, CT 
Martin Hamilton, 82 Westland Street, Hartford, CT 
Janelle Hughley, 161 Martin Street, Hartford, CT 
Neiima Best, 12 Deerfield Avenue, Hartford, CT 

Lisa Laboy, 197 Bond Street, Hartford, CT 
David William Harrington, 25 Windwood Road, West Hartford, CT 
Michael Joseph Harrington, 25 Windwood Road, West Hartford, CT 
Rachel Leach, 51 Beverly Road, West Hartford, CT 
Joseph Leach, 51 Beverly Road, West Hartford, CT 
Erica Connolly, 50 Tredeau Street, Hartford, CT 
Tasha Connolly, 50 Tredeau Street, Hartford, CT 
Michael Perez, 84 Tremont Street, Hartford, CT 
Dawn Perez, 84 Tremont Street, Hartford, CT 

Plaintiffs’ Counsel 

Marianne Engelman Lado 
Theodore Shaw 
Dennis D. Parker 
NAACP Legal Defense & Educational Fund 

99 Hudson Street 
New York, NY “10013 

Sandra Del Valle 
Puerto Rican Legal Defense & Educational Fund 
99 Hudson Street 
New York, NY 10013 

Christopher A. Hansen 
ACLU . .- 

132 West 43rd Street 

New York, NY 10036    



  

| 

| Martha Stone 

| Philip Tegeler 

| CCLU 
| 

| 32 Grand Street 

Hartford, CT 06106 

| 

| John Brittain 

| UNIVERSITY OF CONNECTICUT SCHOOL OF LAW 

55 Elizabeth Street 

| Hartford, CT 06103 

| Wilfred Rodriguez 

| Neighborhood Legal Services 

| 1229 Albany Avenue 

| Hartford, CT 06112 

Wesley W. Horton 

Moller, Horton & Shields, P.C. 

90 Gillett Street 

"Hartford, CT 06105 

(203) 522-8338 

Defendants: 

William A. O’Neill, Governor of the State of Connecticut, Or his 

successor : 

State Board of Education of the State of Connecticut 

Abraham Glassman, A. Walter Esdaile, Warren J. Foley, Rita 

Hendel, John Mannix, Julia Rankin, or their successor members of the 

State Board of Education of the State of Connecticut 

Gerald N. Tirozzi, or his successor Commissioner of the Board of 

Education of the State of Connecticut 

Francisco L. Borges, or his successor Treasurer of the State of 

Connecticut 

J. Edward Caldwell, or his successor comptroller of the State of 

Connecticut 
                        |- | 

| 
 



  

Defendants’ Counsel: 

Richard Blumenthal, Attorney General 
Bernard McGovern, Asst. Attorney General 
Martha Watts Prestley, Asst. Attorney General 

STATE OF CONNECTICUT 

110 Sherman Street 
Hacvtford, CT 05105 

(11) None 

(1i1i) Yes 

(1v) Not Applicable 

PLAINTIFFS, MILO SHEFF, ET Al. 

  

Wes ly) Ww. 2 
MOLLER, HORTON & SHIELDS, P.C. 

90 Gillett Street 
Hartford, CT "06105 
(203) 522-8338 
Juris No. 38478 

John Brittain 
UCONN Law School 

65 Elizabeth Street 
Hartford, CT. 06105 

  
Martha Stone 

Philip D. Tegeler 
CCLU 

32 Grand Street 

Hartford, CT 06106 

Christopher Hansen 
- ACLU 

132 West 43rd Street 
New York, NY 10013 

Marianne Engelman Lado 
Theodore Shaw 

Dennis D. Parker 
NAACP-LDF 

99 Hudson Street 

New York, NY 10013 

Sandra Del Valle 

Puerto Rican Legal Defense - : 

99 Hudson Street 

New York, NY 10013       
 



Wilfred Rodriguez 

NEIGHBORHOOD LEGAL SERVICES 
1229 Albany Avenue 
Hartford, CT 06102   

  
       



  

    

CERTIFICATION 
  

I hereby certify that a copy .of the foregoing was malled to the 

following counsel of record on April 27, 1995: 

Richard Blumenthal 
Martha Watts Blumenthal 

Bernard McGovern 

STATE OF CONNECTICUT 

110 Sherman Street 
Hartford, CT 06106 

iB ae LZ A { 3 

W. Horton   

  

  

 



   
      

       

     
   

   

   
    

    

    

   

    

     

     
    

   

  

   

   

  

   
   

     

    

  

@: rr cuent MATERIAL - CONFIDENTIAL 

STATEMENT FOR PREARGUMENT CONFERENCE CONNECTICUT JUDICIAL BRANCH 
APPELLATE CLERK 

JD-AC-6 New 8-32 

  

     

  

  

  

  

  

      
  

  

P.B.§§.4013, 4133 
INSTRUCTIONS 

231 CAPITOL AVENUE 

1. Prepare on typewriter; serve copies on opposing counsel (P.B. § 4014). 
PO. DRAWER Z, STATION A 

2 List on the reverse side of form the names and addresses of opposing counsel and pro se STE ! 

parties that have been served with a copy of this form. 
HARTFORD CT 06106 

3. If you are the appellant, you are required to attach a copy of the trial court's written memo- 

randum of decision or a transcript of the trial court's oral decision pursuant to P.B. § 4059. 

4. Submit in duplicate to the Appellate Clerk at the address shown. 

5. Retain a copy for yourself to bring to the conference. 

NAME OF CASE(S) 

FOR COURT USE ONLY (Docket Numbers) 

Milo Sheff, et al. v. William A. O'Neill, et al, 

CASE TYPE 

M50 
    

BRIEFLY DESCRIBE THE FINAL JUDGMENT/RULING APPEALED 

Judgment for defendants 

PARTY OR PARTIES APPEALING 

All plaintiffs 

ATTORNEY OR PRO SE PARTY FILING STATEMENT FOR PR 

Wesley W. Horton/38478 

ADDRESS (No., street, town, state and zip) 

90 Cillett Street, Hartford, CT 

    

  

    

TELEPHONE NO. 

522-8338 
  
  
  

    

EARGUMENT CONFERENCE/JURIS NO 

  

    

                
  
  

  

06105     
  

  

FILING STATUS 

KA attorney [|PRosE KX APPELLANT [| CROSS-APPELLANT 

the appeal and/or cross-appeal or, altern 

ue on separate page if necessary. 

                

  atively, attach a copy of your Preliminary Statement of the 

1. State the issues you intend to present on 

Issues to this form (P.B. §§ 4005, 4013). Contin 

gee Attached. 

    

    
  

  

ellate Court, should it be transferred to the Supreme Court? X YES ] NO 

2. If this appeal was filed in the App 

great public importance. 
The appeal involves a matter of 

  

  

  

3. Would you be willing to waive oral argument in this case? [) YES X] NO (EXPLAIN BELOW) 

The appeal involves a matter of great public importance. 

      
  
  

  

      decision? [ves [] NO (EXPLAIN BELOW) 
4. Have you attached a copy of the memorandum of decision or a transcript of oral 

            

  

NOTICE TO COUNSEL 

preargument conference, may r 

te with each other to assure atte 

esult in the imposition of sanctions 

The failure to file this form, or the failure to attend a 
ndance at the conference. 

(P.B.§4184). It is the duty of counsel to communica 

arties of record in accordance with the provisions of Practice 

| hereby certify that a copy of the above was mailed to all counsel and pro se p 

Book section 4014 

SIGNATURE OF INDIVI y 
diy SIGN 
      

  

 



  

  

    

3. Did the court err. in‘refusing to follow the construction of 

Article First, §§1 and 20 and Article Eighth, §1 of the Connecticut 

Constitution established in Horton v. Meskill, which held that the 
  

state is required to assure to all of Connecticut’s public school 

students an equal educational opportunity? 

2. Did the court err in failing to recognize as "state action" 

the state’s extensive involvement in public education in denying 

plaintiffs’ claims of racial and ethnic segregation, unequal 

educational opportunity and lack of a minimally adequate education? 

3. Did the court err in failing to recognize that the state 

constitution gives rise to an affirmative duty on the state to address 

racial and ethnic segregation, unequal educational opportunity and 

lack of a minimally adequate education and that the state failed to 

act to remedy these constitutional and statutory deficiencies? 

4. Did the admitted and undisputed evidence require the Court 

as a matter of law to find that the students in the Hartford public 

schools are not receiving an equal educational opportunity? 

  

 



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Ccve9-0360977S 

MILO SHEFF, ET AL. SUPERIOR COURT 

VS. JUDICIAL DISTRICT OF HARTFORD/ 

NEW BRITAIN AT HARTFORD 

WILLIAM A. O'NEILL, ET AL. APRIL 27, 1995 

MOTION FOR PERMISSION TO APPEAR PRO HAC VICE 
  

Pursuant to P.B. §24, the undersigned, who is a member of good 

standing of this Bar, moves that Christopher A. Hansen be admitted pro 

hac vice to represent the plaintiffs in the above case. The reason for 

this motion is that he is employed by the ACLU. Previously, Attorney 

Helen Hershkoff, who will be resigning from the ACLU and Attorney Adam 

Cohen who has already resigned from the ACLU appeared in this case pro 

hac vice. Therefore the purpose of this motion is to replace the 

Appearance of Attorneys Cohen and Hershkoff. Either I or other members 

of the Connecticut Bar will be in attendance when they appear in Court 

in this case. 

A 
Wesley W. Horton 

MOLLER, HORTON & SHIELDS, ».C. 
90 Gillett Street 
Hartford, CT 06105 

  

DEFENSE COUNSEL CONSENTS 

TO THE GRANTING OF THIS MOTION 

ry. 1h fe 4, 
{rh 2 Watts Pre&tiss 

XKssistant Attorney General    



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Cv89-0360977S 

MILO SHEFF, ET AL. SUPERIOR COURT 

VS. : JUDICIAL DISTRICT OF HARTFORD/ 

NEW BRITAIN AT HARTFORD 

WILLIAM A. O'NEILL, ET AL. : APRIL 24, 1995 

AFFIDAVIT IN SUPPORT OF PRO HAC VICE MOTION 
  

STATE OF CONNECTICUT) 

)SsSs. 

COUNTY OF HARTFORD ) 

CHRISTOPHER A. HANSEN, being duly sowrn, deposes and says: 

1. I am an attorney in good standing, duly admitted to practice 

in the State of New York. I am the Senior Staff Counsel of the ACLU, 

132 West 43rd Street, New York, NY 10036. I make this affidavit in 

support of my motion for admission to appear pro hac vice on behalf of 
  

the plaintiffs in the above-captioned case. 

2. I am admitted to practice in the United States Supreme Court, 

New York Courts and a number of federal courts of appeal and district 

courts. I have been admitted pro hac vice in other state courts. 

3. I have never been sanctioned, reprimanded or otherwise 

disciplined by the court. 

4. The ACLU has provided representation to the plaintiffs 

throughout the pendency of the instant case. 

  

 



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5. The ACLU has brought many civil actions addressing the 

educational needs of African-American children. My work at the ACLU 

has consisted primarily of complex litigation. I believe that I can 

bring expertise and assistance to this case, on behalf of the 

plaintiffs, which might contribute to the conduct of the litigation. 

For this reason, I respectfully urge the Court to grant the motion and 

permit me to appear pro hac vice.   

  

( / zz Zr 

Christoper A. Hansen 

Subscribed and sworn to before 

me this 24th day of April, 1995 

1 

Wesley W. Horton 
Commissionrof the Superior Court 

  

   



CERTIFICATION 

I hereby certify that a copy of the foregoing was faxed and 
mailed to the following counsel of record on April 27, 1995: 

John Brittain 
UNIVERSITY OF CONNECTICUT 

School of Law 

65 Elizabeth Street 
Hartford, CT 06103 

Martha Stone 

Philip D. Tegeler 
CCLU 

32 Grand Street 

Hartford, CT 06106 

Helen Hershkoff 

-Adam S. Cohen 

ACLU 

132 West 43rd Street 

New York, NY 10036 

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Theodore Shaw 

Dennis D. Parker 
NAACP Legal Defense & Educational 

Fund, Inc. 

99 Hudson Street 

New York, NY 10013 

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Sandra Del Valle 

Puerto Rican Legal Defense & 
Educational Fund, Inc. 

99 Hudson Street 

New York, NY 10013 

Wilfred Rodriguez 
NEIGHBORHOOD LEGAL SERVICES 
1229 Albany Avenue 
Hartford, CT 06102   

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