Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00977-CFD Document 78 Filed 05/05/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WENDELL HARP and :
ARCHITECTS ENVIRONMENTAL :
COLLABORATIVE INTERNATIONAL, P.C., :
: CASE NO: 3:03CV977(CFD)
Plaintiffs, :
v.
JOHN DeSTEFANO,
CITY OF NEW HAVEN and 1
NEW HAVEN BOARD OF EDUCATION, :
Defendants.
: MAY 4, 2006
SUPPLEMENTAL DECLARATION OF SUSAN WEISSELBERG
I, SUSAN WEISSELBERG, state under the pains and penalties of perjury as follows
i. I arn over the age of eighteen (E 8) and understand niy obligation when making a
statement to this Court under the pains and penalties of perjury.
2. I ain the Program Coordinator for the School Construction Program and have
served in this capacity since March 1998.
3. In Deceinher 1999, the School District hired Davis Brody Bond, an architecture
firm located in New York to design the Jackie Robinson School. One of my responsibilities was
to oversee the construction of the Jackie Robinson Schooi., and I ani familiar with the services
provided by David Brody Bond for that School.
4. When I contacted the firm in May 2003 about taking over the design for the
Prince Welch School, I was aware that David Brody Bond had performed satisfactorily under its
1999 contract with the School District.

Case 3:03-cv-00977-CFD Document 78 Filed 05/05/2006 Page 2 of 3
5. The termination of Architects Environmental Collaborative International, P.C.’s
contract and the hiring of Davis Brody Bond were considered at a special meeting of the
Administration & Finance Committee, rather than waiting for a regular meeting of the
Administration & Finance Committee, so that these items could appear on the next regularly
scheduled meeting ofthe full Board of Education, which was scheduled for May 27, 2003. The
School Construction Program was anxious to obtain approval of the new architect so that the
design could proceed as soon as possible, after having been delayed for so long. The project
schedule anticipated that the construction would begin in 2004 and be completed in the spring of
2006. The School Construction Program also wanted the School Based Building Advisory
Committee to meet with the new architect before the school year ended so that design work
could begin as quickly as possible.
6. ln May 2003, Thomas Ude was the Corporation Counsel of the City of New
Haven and in this capacity provided legal counsel to the Board of Education and the Department
of Education.
The foregoing statements were made under the pains and penalties of perjury.
gihieeaéw l}_Ni» Y/{Susan Weisselberg
936452.DOC 2

Case 3:03-cv-00977-CFD Document 78 Filed 05/05/2006 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on May 5, 2006, a copy ofthe foregoing was filed electronically [and
served by mail on anyone unable to accept electronic filing}. Notice of this tiling will be sent by
e—mail to all parties by operation of the Court’s electronic tiling system [or by mail to anyone
unable to accept electronic tiling}.
= ..i-i · · ..,... · · ·=--..,,,,. i —
Carolyn . Kone
@J6452.@0C 3