Plaintiffs' Motion for Extension of Time to Respond to Defendants' First Set of Interrogatories; Amended Notice of Service

    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 DECEMBER 10, 1990 

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PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO RESPOND 
TO DEFENDANTS’ FIRST SET OF INTERROGATORIES 
  

  

Plaintiffs respectfully request an extension of time until 

January 30, 1991 in which to respond to Defendants’ First Set of 

Interrogatories. In support of this motion, plaintiffs state the 

following: 

l. Plaintiffs served their responses to Defendants’ First 

Set of Interrogatories on October 31, 1990. 

2. After consultation with defendants, plaintiffs seek to 

respond in more detail to certain interrogatories, and may also 

seek to amend certain interrogatory responses to clarify the 

issues in dispute. 

3. Defendants have been contacted and have no objection to 

the granting of this Motion. 

ORAL ARGUMENT NOT REQUESTED 
TESTIMONY NOT REQUIRED 

  

  
 



  

  
  

    

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, 

J LF TEELer< | 
Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 
Union Foundation 

32 Grand Street 
Hartford, CT 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, CT 06105 

Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
New York, NY 10013 

  
 



  

CERTIFICATE OF SERVICE 
  

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

mailed postage prepaid to John R. Whelan and Diane W. Whitney, | 

Assistant Attorney Generals, MacKenzie Hall, 110 Sherman Street, 

Hartford, CT 06105 this /9 May of December, 1990. 

  

Philip D. Tegeler 

      
 



      

Cv89-0360977S 

  

MILO SHEFF, et al. SUPERIOR COURT 

Plaintiffs 

Yv. JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

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

Defendants DECEMBER 10, 1990 

  

AMENDED NOTICE OF SERVICE OF PLAINTIFFS' RESPONSES TO 
DEFENDANTS’ FIRST SET OF INTERROGATORIES 
  

  

On. October 31, 1990, plaintiffs filed their Notice of 

Service of Plaintiffs’ Responses to Defendants’ First Set of 

Interrogatories. 

With the consent of defendants, plaintiffs hereby amend 

their notice as follows: 

1. Plaintiffs have objected to interrogatories 8, 9 and 10, 

by objection filed September 20, 1990. 

2. Plaintiffs have objected in part to interrogatory 20, by 

objection filed September 20, 1990. 

3. Plaintiffs served answers to Defendants’ First Set of 

Interrogatories 1, 2,.3, 4, 5, 6, 7,.11, 12, 13, 14, 15, 16, 17 

and 19 on October 31, 1990. 

  
 



      

4. In addition, in consultation and with the consent of 

defendants, plaintiffs have moved to extend time to respond to 

defendants’ interrogatories up to and including January 30, 1991, 

in order to more fully respond to certain interrogatories or to 

amend responses to certain interrogatories. 

De Plaintiffs and defendants have made a Joint Motion for 

Extension of Time to Disclose Expert Witnesses Pursuant to 

Practice Book Section 220(d) (filed December 3, 1990) in regard 

to disclosure of expert witnesses requested in interrogatories 18 

and 19 or in other interrogatories. 

Respectfully Submitted, 

Vy AZ 
  

Philip D. Tegeler 
Martha Stone 

Connecticut Civil Liberties 
Union Foundation 

32 Grand Street 
Hartford, CT 06106 

Wesley W. Horton Wilfred Rodriguez 
Moller, Horton, & Fineberg Hispanic Advocacy Project 
90 Gillett Street Neighborhood Legal Services 
Hartford, CT 06105 1229 Albany Avenue 

Hartford, CT 06112 

Julius L. Chambers John Brittain 
Marianne Lado » University of Connecticut 
Ron Ellis 3 School of Law 
NAACP Legal Defense & 65 Elizabeth Street 

Educational Fund, Inc. Hartford, CT 06105 
99 Hudson Street 
New York, NY 10013 

  

  
 



      

“il 

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 to John R. Whelan and Diane W. Whitney, 

Assistant Attorney Generals, MacKenzie Hall, 110 Sherman Street, 

: - 
Hartford, CT 06105 this /2 day of December, 1990. 

pw p. Jeezize 
  

Philip D. Tegeler