Notice of Filing and Defendants' Second Set of Interrogatories

    NO. CV-89-0360977 S 

M1LO SHEFF, ET Al. : SUPERIOR COURT 

: JUDICIAL DISTRICT OF 

Va. : HARTFORD/NEW BRITAIN 

: AT HARTFORD 

WILLIAM A. O'NEILL, ET AL. : SEPTEMBER 9, 1992 

NOTICE OF FILING OF DEFENDANTS’ 

SECOND SET OF INTERROGATORIES 
  

The defendants hereby give notice that, on the date noted 

above, the Defendants' Second Set of Interrogatories, consisting 

of five interrogatories, was sent to the plaintiffs' counsel to 

be answered in accordance with the rules of practice. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

     
  

SV i J LEE 
Martha AM. “Watts er 
/ assistant Attorney General 

110 Sherman Street 
Hartford, Connecticut 06105 
Tel. 

  

By: 
  

al R. Whelan - Juris 085112 
/Absistant Attorney General 

10 Sherman Street 

[Mistetora, Connecticut 06105 

Tel. 566-7173 

  

  
 



  

    

CERTIFICATION 
  

This is to certify that on this 10th day of September, 1892 

a copy of the foregoing was mailed to the following counsel of 

record: 

John Brittain, Esq. 

University of Connecticut 
School of Law 
65 Elizabeth Street 

Hartford, CT 06105 

Philip Tegeler, Esq. 
Martha Stone, Esq. 

Connecticut Civil 
Liberties Union 
32 Grand Street 

Hartford, CT 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 

Puerto Rican Legal Defense 
and Education Fund 
99 Hudson Street 
l4th Floor 

New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 

Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036 

Wilfred Rodriguez, Esq. 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

Wesley W. Horton, Esq. 
Moller, Horton & 

Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers, Esq. 

Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Education Fund, Inc. 
99 Hudson Street 

New York, NY 10013 

   



  

    

NO. CV-89-0360977 'S 

MILO SHEFF, ET AL. : SUPERIOR COURT 

JUDICIAL DISTRICT OF 

HARTFORD/NEW BRITAIN 

AT HARTFORD 

WILLIAM A, O'NEILL, ET AL. : SEPTEMBER 9, 1992 

DEFENDANTS' SECOND SET OF INTERROGATORIES 
  

Pursuant to Practice Book §§216 et seq., the defendants 

submit the following interrogatories to be answered by the 

plaintiffs or on their behalf: 

1. Please provide the data the plaintiffs' will rely on at 

trial to support any claim they intend to make that the 

educational "inputs" (i.e. resources, staff, facilities, 

curriculum, etc.) in the Hartford Public Schools are so deficient 

that the children in Hartford are being denied a "minimally 

adequate education." For all such data specify the source(s) 

and/or name and address of the person(s) that will be called upon 

to attest to that data at trial. 

2. Please provide the data, other than the results of the 

Mastery Test, which the plaintiffs will rely on at trial to   

  

 



      

support any claim they intend to make that children in Hartford 

are being denied a "minimally adequate education" because of the 

educational "outputs" for Hartford. For all such data specify 

the source(s) and/or name and address of the person(s) that will 

be called upon to attest to that statistic at trial. 

3. Please provide the data with respect to each and every 

category of educational "inputs" which the plaintiffs will rely 

on at trial in their effort to establish that the educational 

"inputs" 1n Hartford are not equal to the educational "inputs" of 

the suburban school districts. For all such data identify each 

and every statistical comparison between Hartford and any or all 

of the suburban school districts which the plaintiffs will rely 

on to show the alleged inequality. For each such comparison 

identify the source(s) and/or name and address of the person(s) 

that will be called upon to attest to the accuracy of that 

statistical comparison at trial. 

4, Please provide the data with respect to each and every 

category of educational "outputs", other than the Mastery Test, 

which the plaintiffs will rely on at trial in their effort to 

establish that the educational "outputs" in Hartford are not 

equal to the educational "outputs" of the suburban school 

  
 



        

districts. For all such data identify each and every statistical 

comparison between Hartford and any one or all of the suburban 

school districts which the plaintiffs will rely on to show the 

alleged inequality. For each such comparison identify the 

source(s) and/or name and address of the person(s) that will be 

called upon to attest to the accuracy of that statistical 

comparison at trial. 

Ba With regard to Interrogatories 11, 12, 13 and 14 as set 

forth in the Defendants' First Set of Interrogatories (July 13, 

1990), please provide a detailed description of the precise 

methodology or methodologies used by the plaintiffs and/or their 

epxerts to compile and manipulate each category of data described 

in the Plaintiffs' Second Amended Responses to Defendants' First 

Set of Interrogatories (August 24, 1992) upon which the 

plaintiffs will rely at trial to support any claim they intend to 

make that: 

(a) the educational "inputs" (i.e., resources, staff, 

facilities, curriculum, etc . . .) in the Hartford Public Schools 

are so deficient that the children in Hartford are being denied a 

"minimally adequate education"; 

  
 



  

  

      

(b) children in Hartford are being denied a "minimally 

adequate education" because of the educational "outputs," other 

than the results of the Connecticut Mastery Test, for Hartford; 

(c) educational "inputs" in Hartford are not equal to the 

educational "inputs" of the suburban school districcs; and 

(d) educational "outputs" in Hartford are not eaqual to the P gq 

educational "outputs" of the suburban school districts. 

By means of these interrogatories, and their Second Request 

for Production (September 9, 1992), the defendants seek 

information sufficient to allow the defendants to replicate any 

analyses done by the plaintiffs and/or their experts of the data 

on which the plaintiffs rely in support of their claims .as 

described above. If the information requested herein has already 

been provided to the defendants, please specifically identify the 

documents and/or materials that contain such information. 

The plaintiffs are hereby put on notice that the defendants 

will insist on compliance with Practice Book §232 in regard to 

the foregoing interrogatory and will assert the plaintiffs’ 

failure to comply with that section as a ground for excluding 

  

  

 



    

from evidence any facts or information requested by this 

interrgatory which is not disclosed in a timely fashion. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

ATTORNEY GENERAL 

BY: of wk 5 [AT 
‘MArtha M# ey “Juris 4 
Ssistant Attofney General 

110 Sherman Street 
Hartford, Connecticut 06105 
iy 566-7173 

  

  

  

He R. fre - Juris 085112 
/ Assistant Attorney General 
/ 110 Sherman Street 
/ Hartford, Connecticut 06105 
Tel. 566-7173 

        
 



  

    

CERTIFICATION 
  

This is to certify that on this 10th day of September, 1992 

a copy of the foregoing was mailed to the following counsel of 

record: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT 06105 

Philip Tegeler, Esq. 
Martha Stone, Esq. 

Connecticut Civil 
Liberties Union 
32 Grand Street 

Hartford, €T 06105 

Ruben Franco, Esq. 
Jenny Rivera, Esq. 
Puerto Rican Legal Defense 
and Education Fund 
99 Hudson Street 
14th Floor 
New York, NY 10013 

John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036 

Wilfred Rodriguez, Esq. 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

Wesley W. Horton, Esq. 
Moller, Horton & 

Fineberg, P.C. 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers, Esq. 
Marianne Lado, Esq. 
Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Education Fund, Inc. 
99 Hudson Street 
New York, NY 10013