Correspondence from Guinier to Atwell and Gergen

    S.C. 15255 

MILO SHEFF, ET AL. : SUPREME COURT 

VS. 

WILLIAM A. O’NEILL, ET AL. : MAY 10, 1995 

APPLICATION FOR PERMISSION TO APPEAR PRO HAC VICE 
  

The undersigned, who is a member of good standing of this Bar, 

moves that Marianne Engelman Lado, Theodore Shaw, Dennis D. Parker, 

Sandra Del Valle and Christopher A. Hansen be admitted pro hac vice to 

represent the plaintiffs in the above case. 

Brief History 
  

The plaintiffs, students in Hartford and Hartford area public 

schools, brought suit under various provisions of the Connecticut 

Constitution. The trial court entered judgment in favor of the 

defendants and the plaintiffs have appealed. 

Specific Facts 
  

All of the lawyers whose admission pro hac vice is requested have 

already been admitted pro hac vice in this case in the superior court. 

Affidavits of each of the lawyers is submitted herewith. Opposing 

counsel does not object to the granting of this application. 

OPPOSING COUNSEL CONSENTS 
TO THE GRANTING OF THIS MOTION    



  
    

Legal Grounds 
  

This Court may grant an application for permission to appear pro 

hac vice for good cause shown. This application and the accompanying 

affidavits show good cause. 

laine] Jlrs 
  

ORDER 

Wesley” W. Horton 
MOLLER, HORTON & SHIELDS, P.C. 

90 Gillett Street 
Hartford, CT 06105 

(203) 522-8338 
Juris No. 38478 

For good cause shown the foreoing is hereby GRANTED/DENIED. 

By the Court, 

  

   



S.C. 15255 

MILO SHEFF, ET AL. SUPREME COURT 

vs. 

WILLIAM A. O'NEILL, ET AL. ; 1995 

AFFIDAVIT IN SUPPORT OF PRO HAC VICE MOTTON 
  

STATE OF CONNECTICUT) 
: ) Hartford 

COUNTY OF NEW YORK ) 

THEODORE M. SHAW, being duly sworn, deposes and says: 

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

practice in the State of New York and California. TI am Associate 

Director-Counsel of NAACP Legal Defense and Educational Fund, Inc., 

99 Hudson Street, New York, New York, 10013. 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 by the United States District 

Court for the Central District of California, the District of 

Arizona, the U.S Courts of Appeal for the Fifth, Sixth, Eighth, 

Eleventh Circuits and the U.S. Supreme Court. 

3. I have never been sanctioned, reprimanded or otherwise 

disciplined by the court. 

4. The NAACP Legal Defense and Educational Fund, Inc., has 

provided representation to the plaintiffs throughout the pendency 

of the instant case.  



Be The NAACP Legal Defense and Educational Fund has brought 

many civil actions addressing the educational needs of African- 

Americans and other children. The Legal Defense Fund litigated 

Brown v. Board of Education, 347 U.S. 483 (1954), and many of the   

major school desegregation cases implementing its mandate. 

5, From 1979 until 1982 I litigated school desegregation 

cases as a trial attorney with the U.S. Department of Justice, 

Civil Rights Division, in Washington, D.C. From 1982 until October 

1, 1987 I served as Director of the Education Docket of the NAACP 

Legal Defense and Educational Fund, Inc., for which T litigated 

school desegregation cases throughout the country. 

7. From Octoker 1987 until November 1990, I served as 

Director of the Western Regional Office of the NAACP legal Defense 

Fund. In November 1990, I left the Legal Defense Fund to join the 

faculty of the University of Michigan Law School, where I teach 

Constitutional Law, Civil Procedure, and Civil Rights. In May of 

1993 I took a leave from Michigan Law School to rejoin the Legal 

- Defense Fund as Associate Director-Copasel. oh i 

Pot 7 
Theodore > Shaw 
  

  

GERTRUDE A. REYNOLDS 
Notary Public, Stats of Naw York 

No.24-4824270 
Certitizd in Kings County 

Commissicn Expires July 31,1996  



S.C. 15255 

MILO SHEFF, ET AL. : SUPREME COURT 

VS. 

WILLIAM A. O'NEILL, ET AL. : MAY 3 , 1995 

AFFIDAVIT IN SUPPORT OF PRO HAC VICE MOTION 
  

STATE OF CONNECTICUT) 

) ss: Hartford 

COUNTY OF NEW YORK ) 

DENNIS D. PARKER, being duly sworn, deposes and says: 

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

practice in the State of New York. I am employed with the NAACP 

Legal Defense and Educational Fund, Inc., 99 Hudson Street, New 

York, New York, 10013. 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 by the United States Supreme 

Court, the Eleventh Circuit Court of Appeals, and the United States 

District Court for the Southern and Eastern District of New. 

3. I have never been sanctioned, reprimanded or otherwise 

disciplined by the court. 

4. Since the inception of the case the NAACP Legal Defense 

and Educational Fund, Inc., has been actively involved in the 

instant case, rendering legal representation to the plaintiffs. 

5. The NAACP Legal Defense and Educational Fund has brought 

many civil actions addressing the educational needs of African-  



American children including Brown v. Board of Education and a 
  

series of cases before and after that enforcing the constitutional 

rights of those children. My work at the NAACP Legal Defense Fund 

consists primarily of education cases. 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. 
  

Nea ve. 
Dennis D. Parker 
  

Subscribed and sworn to before 

me ag of May, 1995. 

Flutiat d 
v 

Lor THRUDE A. REYNOLDS 
Crary Puliic, State of/ New York 

No. 24-4524270 
Sersified 'n Kings County 
Cussion £ipires July 31,1998 

  

 



  

S.C. 15255 

MILO SHEFF, ET AL. : SUPREME COURT 

VS. : 

WILLIAM A. O’NEILL, ET AL. 3 MAY 5, 1995 

AFFIDAVIT IN SUPPORT OF PRO HAC VICE MOTION 
  

STATE OF CONNECTICUT) 

) ss: Hartford 

COUNTY OF NEW YORK ) 

MARIANNE L. ENGELMAN LADO, being duly sworn, deposes and says: 

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

practice in the State of New York. I am employed with the NAACP 

Legal Defense and Educational Fund, Inc., 99 Hudson Street, New 

York, New York, 10013. 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 by the United States District 

Court for the Southern and Eastern District of New York. 

3. I have never been sanctioned, reprimanded or otherwise 

disciplined by the court. 

4. The NAACP Legal Defense and Educational Fund, Inc., has 

brought many civil actions addressing the educational needs of 

African American children, including Brown v. Board of Education and a 

series of cases before and after enforcing the constitutional 

rights of these children. The NAACP Legal Defense and Educational 

 



  

Fund, Inc. has been actively involved in the instant case since its 

inception, rendering legal representation to the plaintiffs. 

5. My work at the NAACP Legal Defense and Educational Fund, 

Inc., consists primarily of advocacy on behalf of poor African 

Americans and includes cases to ensure that poor African American 

school children have access to equal educational opportunities. I 

have been involved in the instant case since its inception and 

represented the plaintiffs at trial, although from April, 1993 

through October, 1994, I took a leave of absence from the NAACP 

Legal Defense and Educational Fund, Inc., to "work on ‘a 

dissertation. I believe that I can bring expertise and assistance 

to this case, on behalf of the plaintiffs, and 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. 

a 
Marianne L. Engelman Lado 
  

Subscribed and sworn to before 

Ls his a of May, 1995. 

/ 

  

  2 7 
GERTRUDE A. REYNOLDS 

Notary Public, State of New York 
No. 24-4624270 

Certified in Kings County 
Commission Expires July 31,1996 

 



  

CV89-0360977S 
MILO SHEFF, ET AL. SUPREME COURT OF CONNECTICUT 

VS. 

WILLIAM A. O'NEILL, ET AL. ; MAY 8, 1995 

AFFIDAVIT IN SUPPORT OF PRO HAC VICE MOTION 
  

STATE OF CONNECTICUT ) 
) ss: Hartford 

COUNTY OF NEW YORK ) 

SANDRA DELVALLE, being duly sworn, deposes and says: 

l. I am an attorney in good standing, duly admitted to practice in the State of New 

York. I am a staff attorney at the Puerto Rican Legal Defense and Education Fund, Inc., 99 

Hudson Street, New York, New York 10013. I make this affidavit in support of my motion 

for admission to appear pro hac vice on behalf of the appellants in the above-captioned case. 

2, I am admitted to practice by the United States District Court for the Southern and 

Eastern Districts of New York. 

3. I have never been sanctioned, reprimanded or otherwise disciplined by the court. 

4. The Puerto Rican Legal Defense and Education Fund, Inc. (PRLDEF) provided 

representation to the appellants throughout the pendency of the instant case. 

5. PRLDEF has brought many civil actions addressing the educational needs of 

  Latino and Puerto Rican students including ASPIRA v. NYC Board of Education which 

mandated the provision of bilingual education in New York City in 1974. Since then PRLDEF 

has been involved in the continuing country struggle to insure that language minority children 

generally and Latino children particularly have equal access to educational opportunities. 

 



6. My work at PRLDEF consists primarily of education cases. I believe that I can 

bring expertise and assistance to this case on behalf of the appellant, which may contribute to 

the conduct of this litigation. For this reason, I respectfully request this Court to grant the 

motion and permit me to appear pro hac vice. 

, 

/ 

"SANDRA DELVALLE 
  

Subscribed and sworn to before 

me this I day of May, 1995 

Notary Public 

OLGA R. PEREZ 
Notary Public, Stata of Naw York 

Na. 3 14 hon ” 

Qualified in Mew York Coun 
Commission Expire , 19.2% 

eTo PE) > 

SDV102.95  



  

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) 

)Ss. 

COUNTY OF HARTFORD ) 

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‘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 

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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.     
 



  
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 conplex 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 

    

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permit me to appear pro hac vice. 

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Subscribed and sworn to before 

me this 24th day of April, 1995 

Wh J AAT 
Wesley W. Horton 

Commissionrof the Superior Court 

  

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CERTIFICATION 
  

I hereby certify that a copy of the foregoing was mailed to the 
following counsel of record on May 10, 1995: 

Richard Blumenthal, Attorney General 
Bernard F. McGovern, Jr., Asst. Attorney General 

Martha Watts Prestley, Asst. Attorney General 
STATE OF CONNECTICUT 

110 Sherman Street 

Hartford, CT 06105 

(203) 566-7173   
  

Wesley Hortén