Case 3:03-cv-00977-CFD Document 58 Filed 01/18/2006 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRECT OF CONNECTICUT
WENDELL HARP and 2
ARCHITECTS ENVIRONMENTAL :
COLLABORATIVE lNTERNATiON'AL, P.C., :
: CASE NO: 3;03C\/977(CFD)
Plaintiffs, :
v.
JOHN DeSTEFANO,
CiTY OF NEW HAVEN and :
NEW HAVEN BOARD OF EDUCATION, 1
Defendants.
: JANUARY 14, 2006
DECLARATION OF DR. CARLOS TORRE
I, CARLOS TORRE, state under the pains and penalties ofperj ury as follows:
1. T am over the age of eighteen (18) and understand my obiigation when
making a statement to this Court under the pains and penalties of perjury.
2. l was the President of the Beard of Education for the City of New Haven
in May 2003.
3. On May 27, 2003, a regular meeting of the Board of Education was held.
I was in attendance at the meeting.
4. I voted to terminate the Board’s contract with Architects Environmental
Collaborative Internationai, RC. (“‘AECl"), because I understood that AECI was balking
at the design criteria in the proposed redesign contract and in my view, this was the straw
that broke the <:amel’s back.
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Case 3:03-cv-00977-CFD Document 58 Filed O1/18/2006 Page 2 of 2
5. I, as President of the Board of Education, spoke frequently to the
Superintendent —- approximately 2-3 tirnes each week. In addition, I would often speak to
John Prokop (“Prokop"), as Prokop was chair of the Administratior¤’Finance Committee
and he and I were employed by the Southern Connecticut State University.
6. In addition, on occasion, as President of the Board, I would attend
Administration/Finance Committee meetings. I understood that AECI had not followed
the requirements of the School Construction Program, that the Hill Career High School
had been plagued by delays and other problems and that Wendell Harp ("Harp", the
principal of AECI was difficuit to work with.
7. I felt that it was not going to work to have AECI redesign Prince Welch.
S. I did not know that Harp or his wife were supporting Sherri Killins for
Mayor and just learned of this fact in the past two weeks in connection with this lawsuit.
The foregoing statengen . •‘ ere " a: c. nder the pains and penalties of perjury. l
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`S ` Carlos Torre
2