Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00977-CFD Document 51 Filed O1/18/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

WENDELL HARP and 2
ARCHITECTS ENVIRONMENTAL 1
COLLABORATIVE INTERNATIONAL, BC., :
Z CASE NO; 3:O3C`V977(CFD)
Plaintiffs, :
v.
JOHN IDGSTEFANO,
CITY OF NEW HAVEN and i
NEW HAVEN BOARD OF EDUCATION, :
Defendants.
: JABEUARY/iz 2006
DECLARATION OF RICHARD ABBATIELLO
I, RICHARD ABBATIELLO, state under the pains and penalties efperji ary as follows:
1. I am over the age of eighteen (18) and understand my obligation when
making a statement to this Court under the pains and penalties ef perjury.
2.. I was a member of the Board ef Education fer the City of New Haven and
the B0ard’s Administration and Finance Committee in May 2003.
3. On May 23, 2003, a special meeting of the Administration and Finance
Committee Board of Education was held to discuss among other matters Architects
Envirenmental Collaberative International, P.C. ’ s (“AECl”} centraet to design the Prince
Weich Schoel. I was in attendance at the meeting. At the meeting, there was a discussion
about whether AEC} would previde the Board with the school that it wanted in a timeiy
HC18.DI1€1‘.

Case 3:03-cv-00977-CFD Document 51 Filed 01/18/2006 Page 2 of 3
4. The members of the Administration and Finance Corrunittee were very
familiar with A.ECI’s and Wendell Harp’s, its principal ("l~larp”) performance to the
Prince Welch School and the Hill Career High School project.
5. During conversations following other Administration and Finance
Committee meetings, the members of the Administration and Finance Committee learned
that Harp had not shown up at SBBAC meetings, Harp was concerned more with his
"vision" as to what he wanted the school to look like than the concerns ofthe School
Construction Program and the SBBAC and that although Harp would say that he would
malre design changes requested by the School Construction Progarn and the SBBAC, he
would, in fact, not alter his design.
6. ln addition, the members ofthe Committee knew from the School
Construction Program staff that Harp was unresponsive to requests from Claude Watt
("Watt”) for infomation, was generally uncooperative with the staff and that there were
delays in his producing useable drawings. The Administration and Finance Committee
recornmended that AECl’s contract be terminated, and I agreed with that
recommendation.
7. On May 27, 2003, a regular meeting ofthe Board of Education was held.
l was in attendance at that meeting. I voted to terminate A.ECI’s contract because Harp
had been resistant to input by the School Construction Program and the SBBAC on his
design for the Prince Welch School, wanted 100% control over the design and had an
attitude of "this is my building — take it or leave it." I understood that Harp had halked at
redesigning the school in the manner requested by the School Construction Program.
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8. In addition, I knew that Watt couid not get the information that he needed
from AECI, that Watt felt that AECI was not doing what it should be doing under its
contract with the Board of Education and that Harp was argmnentative and
uneooperative.
9. Additionally, {knew that Harp had made many mistakes in the design of
the Hitt Career High School and that there were cost overruns for that project.
10. I believed that the relationship between AECI and the Board of Education
was not working.
ll. I did read inthe New Haven Register that Harp and Mrs. Harp were
supporting Sherri Killins for Mayor but this information did not factor into my decision
to vote to terminate ABCPS contract with the Board of Education.
The foregoing statements were made meter the pains and penalties of perjury.
Richard Abbatieilo
l