Fax to All Counsel RE: Request of Deposition Documents with Attached Subpoena and Certificate of Service

    FOUNDATION 
ThirtyTwo Grand Street, Hartford. CT 06106 

203/247-9823 Fax 203/728-0287 

TRANSMITTED BY FAX September 18, 1992 

Mr. John Whelan 
Assistant Attorney General 
110 Sherman Street 
Hartford, CT 06105 

RE: Sheff v. O'Neill 
  

Dear John, 

Pursuant to paragraph 4 of the Final Pretrial Order of 
September 2, 1992, we are giving notice as to the documents 
requested for the deposition of Michael Levin scheduled for October 
2, 1992. If any of the documents you have previously submitted to 
us are responsive to this request, please indicate the number of 
the document. In order to save time at the deposition, we would 
appreciate receiving these documents at least two days in advance. 

In addition, as we have discussed in relation to other expert 
witnesses, we are requesting that a more detailed description of 
Mr. Levin’s anticipated testimony be provided to us prior to the 
deposition. 

Thank you for your cooperation. 

Sincerely, 

AY See 
Philip D. Tegeler 
Attorney for Plaintiffs 

PDT/dmt 

Enclosure 

CC: All Counsel 

The Connecticut Civil Liberties Union Foundation 

5 

 



  

SUBPOENA DUCES TECUM 
  

TO: Michael B. Levin 
Vice President and Research Director 
Connecticut Policy and Economic Council, Inc. 
21 Lewis Street 
Hartford, CT 06103 

GREETING: 

BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby 
commanded to appear before an appropriate officer at a deposition 
which will take place beginning at 10:00 a.m. on the 2nd of October, 
1992, or to such day thereafter and within sixty days hereof to 
testify what you know in regard to a certain civil action pending 
before the Superior Court for the Judicial District of Hartford/New 
Britain entitled Sheff v. O'Neill, No. CV 89-0360977sS. Said 
deposition shall be conducted at the offices of the Connecticut Civil 
Liberties Union Foundation, 32 Grand Street, Hartford, Connecticut 
(Conference Room). 

  

Pursuant to Practice Book §245(c) you are further directed to 
produce and permit inspection and copying of the following: 

l. Any studies, reports, tables, charts, or other trial 
exhibits you have prepared in this case. 

2. Copies of any research, papers, or articles you have 
prepared that discuss the state’s fiscal treatment of 
Connecticut cities and towns, or fiscal treatment or 
condition of the city of Hartford and its school system. 

3. A copy of Municipal Expenditures in Connecticut, 1980-90 
(March 1992). 
  

4. A copy of the most recent annual report entitled Connecticut 
Municipal Budgets. 

  

  

HEREOF FAIL NOT, UNDER PENALTY OF THE LAW. 

rH 

Dated at Hartford, Connecticut this [3 day of September, 1992. 

PY Sar 
  

Philip D. Tegeler/Martha Stone 
Commissioner of the Superior Court 

 



  

CERTIFICATE OF SERVICE 
  

This is to certify that a copy of the foregoing has been faxed 
and mailed postage prepaid to John R. Whelan and Martha M. Watts, 
Assistant Attorneys General, MacKenzie Hall, 110 Sherman Street, 
Hartford, CT 06105 this (1g day of September, 1992. 

wy ze 
  

Philip D Tegeler/Marthe Stone 
A torneys f or Plaintiffs