Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 2:91 -cv-00180-RNC Document 550-2 Filed 04/16/2008 Page 1 of 3
UNITED STATES DISTRICT COURT . A
DISTRICT OF CONNECTICUT
P.J., et al., : CIVIL NO.
Plaintiffs, : 291CV00180 (RNC)
v. :
STATE OF CONNECTICUT, et al.
Defendants : APRIL 15, 2008
MOTION TO MANUALLY FILE
Please take notice that the Plaintiffs have manually filed Exhibits A through Q, listed
below, to their Memorandum in Support of Motion for Orders to Remedy Substantial Non-
Compliance with Settlement Agreement. These exhibits have not been filed electronically
because their size exceeds 1.5 megabytes and would require all but five of these exhibits to be
broken into multiple parts.
Exhibit A Plaintiffs’ Comments (10/ 18/02) to CSDE lst Annual Report of 9/30/02
Exhibit B EAP Report (11/03/03) to CSDE 2nd Annual Report of 6/30/03
Exhibit B.1 Plaintiffs’ Comments (12/18/03) to EAP Report of 11/3/03
Exhibit C EAP Report (01/30/04) to CSDE 2nd Annual Report of 6/30/03 Revised
Exhibit D Plaintiffs’ Comments (09/10/04) to CSDE 3rd Annual Report of 6/30/04
Exhibit E EAP Report (09/30/04) to CSDE 3rd Annual Report of 6/30/04
Exhibit F Plaintiffs’ Comments (07/26/05) to CSDE 4th Annual Report of 6/30/05
Exhibit G EAP Report (09/30/05) to CSDE 4th Annual Report of 6/30/05
Exhibit H EAP Final Report 2/2007
Exhibit I 05/25/04 Letter from Atty. Ralph Urban to Atty. David Shaw

Case 2:91 —cv-00180-RNC Document 550-2 Filed 04/16/2008 Page 2 of 3
Exhibit J 07/20/04 Letter from Atty. David Shaw to Atty. Ralph Urban
Exhibit K Data — Percent of CT K-12 ID/MR Students Spending 79-100%
Of their time with Non-Disabled Peers
Exhibit L 10/29/97 Letter from Atty. David Shaw to Atty. Darren Cunningham
Exhibit M 11/05/07 Letter from Atty. David Shaw to Atty. Darren Cunningham
Exhibit N 12/07/07 Letter from Atty. Cunningham to Atty. David Shaw
Exhibit O Data — Mean/Median Amount of Time CT K-12 ID/MR Students
Spend with Non-Disabled Peers
Exhibit P Data — Home School Enrollment for CT K-12 ID/MR Students
Exhibit Q Data — Extra Curricular Participation by CT K-12 ID/MR Students
PLAIN;l?IFFS, r 1.
By Ziggj :4;; / By 1 iz . 12.,.///, ( gy, my
David C. Shaw, Esq. Frank J. Laski, Esq.
The Law Offices of David C. Shaw, LLC Mental Health Legal Advisors Committee
Fed. Bar No. ct05239 Fed Bar No. ct 16180
34 Jerome Ave., Suite 210 399 Washington St., 4th Fl.
Bloomfield, CT 06002 Boston, MA 02108
Tel. (860) 242-1238 Tel. (617) 338-2345
Fax. (860) 242-1507 Fax. (617) 338-2347
Email: dcshawgciDcttel.net Email: [email protected]
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Case 2:91 —cv-00180-RNC Document 550-2 Filed O4/16/2008 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing was mailed first class, postage prepaid to
counsel of record on April 15, 2008.
Darren P. Cunningham
Assistant Attorney General
State of Connecticut
P.O. Box 120
Hartford, CT 06141
up C/601
David C. Shaw, Esq.
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