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A Practical Guide to Discovery and Depositions in Connecticut

Discovery types, techniques, strategies, and drafting tips for Connecticut litigators

  • Product Number: 2110365B00
  • Publication Date: 6/1/2018
  • Edition: 1st Edition 2011, with 2013 & 2018 Supplements
  • Copyright: © 2018 MCLE, Inc.
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  • Product Description
  • Table of Contents
  • Editors & Authors
  • Product Description

    Product Description

    This comprehensive guide presents discovery types, techniques and strategies, and provides the best "how-to" source in Connecticut for analyzing discovery, creating a discovery plan, preserving evidence, and drafting effective interrogatories and requests for production. It also teaches you how to conduct a variety of types of depositions, draft discovery motions, and handle discovery like an expert in various forums.

    Recent updates:

    • Update: May 2018

      Dear Subscriber:

      Thank you for choosing to keep your volume of A Practical Guide to Discovery and Depositions in Connecticut current with this 2018 Supplement. Inside, you will find new material including the following:

      • See Chapter 4 for a case regarding the qualification of experts, finding that admission of a physician's expert testimony was beyond the scope of the testimony originally elicited by the plaintiff, and that the court's subsequent denial of proper cross-examination about his qualifications colored the jury's perception and, therefore, constituted harmful error.
      • See Chapter 7 for a recitation of the rules of construction, contained in Conn. Prac. Bk. § 13-1(d), that apply to all discovery requests and should be included in the instruction for any set of production requests.
      • See Chapter 11 for discussion of disclosure of defense, and a case where the court concluded that a statement that a defense will be made and that the defendant will deny all material allegations asserted in each and every count of the complaint could be a sufficient disclosure.
      • See Chapter 12 for a cite to a 2016 Connecticut Appeals Court decision that applied the Millbrook three-part test to evaluate sanctions imposed against plaintiff's counsel in a legal malpractice case.
      • See Chapter 14 for a discussion of a 2016 case where privately created documents that otherwise do not "relate to the public's business" at the time of their creation were deemed "public records" once lawfully seized by police during a criminal investigation.
      • See Chapter 15 for a discussion of a 2018 case regarding social media and circumstantial evidence.

      We at MCLE trust that you will find this material useful in your litigation practice and valuable in keeping your law library current.


      Maryanne G. Jensen, Esq., MCLE Director of Publications

  • Table of Contents

    Table of Contents

    expand all
    Chapter 1 expand

    Discovery Planning and Investigation

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    Exhibit 1A

    - Sample Discovery Budget Buy Form
    Chapter 2 expand

    Preservation and Spoliation of Evidence

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    Exhibit 2A

    - Sample Documents for a Client Pertaining to a Litigation Hold Buy Form

    Exhibit 2B

    - Sample Litigation Hold Letter Sent to Opposing Counsel Buy Form
    Chapter 3 expand

    Scope of Discovery

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    Chapter 4 expand

    Expert Discovery, Expert Testimony, and Trial Considerations

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    Checklist 4.1

    - Outline for Expert Deposition: Products Liability Case Buy Form
    Chapter 5 expand

    Protecting Confidential Information

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    Exhibit 5A

    - Motion for Stipulated Protective Order Buy Form

    Exhibit 5B

    - Stipulated Protective Order Buy Form

    Exhibit 5C

    - Annotated Protective Order Template Buy Form

    Exhibit 5D

    - Motion to Seal (State Superior Court) Buy Form

    Exhibit 5E

    - Motion to Seal (Federal District Court) Buy Form

    Exhibit 5F

    - Memorandum in Support of Motion to Seal Buy Form
    Chapter 6 expand


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    Exhibit 6A

    - Form 201: Plaintiff’s Interrogatories Buy Form

    Exhibit 6B

    - Form 202: Defendant’s Interrogatories Buy Form

    Exhibit 6C

    - Form 203: Plaintiff’s Interrogatories—Premises Liability Cases Buy Form

    Exhibit 6D

    - Form 208: Defendant’s Supplemental Interrogatories— Workers’ Compensation Benefits—No Intervening Plaintiff Buy Form

    Exhibit 6E

    - Form 210: Defendant’s Interrogatories—Workers’ Compensation Benefits—Intervening Plaintiff Buy Form

    Exhibit 6F

    - Form 212: Defendant’s Interrogatories—Loss of Consortium Buy Form

    Exhibit 6G

    - Form 213: Plaintiff’s Interrogatories—Uninsured/? Underinsured Motorist Cases Buy Form

    Exhibit 6H

    - Form 214: Defendant’s Interrogatories—Uninsured/?Underinsured Motorist Cases Buy Form
    Chapter 7 expand

    Requests for Production, Inspection, and Examination

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    Exhibit 7A

    - Plaintiff’s Requests for Production (Form 204) Buy Form

    Exhibit 7B

    - Defendant’s Requests for Production (Form 205) Buy Form

    Exhibit 7C

    - Discovery and Deposition Dispute Order Buy Form

    Exhibit 7D

    - Request for Adjudication of Discovery or Deposition Dispute Under Statewide Standing Order (Form JD-CV-119) Buy Form

    Exhibit 7E

    - Plaintiff’s First Request for Production of Documents Buy Form

    Exhibit 7F

    - Defendant’s Responses and Objections to Plaintiff’s Requests for Production of Documents Buy Form
    Chapter 8 expand

    Physical and Mental Health Examinations and Protected Health Information

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    Chapter 9 expand

    Admission of Facts and Execution of Writings

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    Exhibit 9A

    - Sample Notice of Service of Requests for Admission Buy Form

    Exhibit 9B

    - Sample Requests for Admissions Buy Form

    Exhibit 9C

    - Sample Responses to Requests for Admissions Buy Form

    Exhibit 9D

    - Sample Motion to Determine Sufficiency of Responses and to Deem Matters Admitted Buy Form

    Exhibit 9E

    - Sample Motion to Deem Requests for Admissions Admitted Buy Form

    Exhibit 9F

    - Sample Motion to Withdraw and Amend Responses Buy Form

    Exhibit 9G

    - Bibliography Buy Form
    Chapter 10 expand


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    Exhibit 10A

    - Sample Notice of Deposition Buy Form

    Exhibit 10B

    - Sample Motion for Commission Buy Form

    Exhibit 10C

    - Sample Motion to Quash Buy Form
    Chapter 11 expand

    Other Discovery Rules and Devices

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    Exhibit 11A

    - Sample Motion for Prejudgment Disclosure of Assets Buy Form

    Exhibit 11B

    - Sample Application for Order Authorizing the Issuance of a Subpoena Duces Tecum Buy Form

    Exhibit 11C

    - Sample for Motion for Appointment of Discovery Special Practice, Pendente Lite Buy Form

    Exhibit 11D

    - Sample Order Regarding Discovery Special Master and Setting Procedures Buy Form

    Exhibit 11E

    - Sample Stipulation RE: Referee for Discovery Disputes Buy Form
    Chapter 12 expand

    Motions for Orders of Compliance

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    Exhibit 12A

    - Defendants’ Motion to Compel Production of Medical Records Buy Form

    Exhibit 12B

    - Defendant’s Motion to Compel Plaintiff’s Signature on Authorization Forms Required to Obtain Plaintiff’s Updated Medical Records Buy Form

    Exhibit 12C

    - Plaintiff’s Motion to Compel and for Sanctions Buy Form

    Exhibit 12D

    - Motion for Order of Compliance Buy Form

    Exhibit 12E

    - Objection to Motion to Compel Buy Form

    Exhibit 12F

    - Defendants’ Objection to Motion to Compel Production Buy Form

    Exhibit 12G

    - Affidavit in Support of Defendant’s Objection to Motion to Compel Discovery Buy Form

    Exhibit 12H

    - Discovery and Deposition Dispute Order Buy Form

    Exhibit 12I

    - Request for Adjudication of Discovery or Deposition Dispute (Form JD-CV-119) Buy Form
    Chapter 13 expand

    Discovery of Electronically Stored Information

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    Exhibit 13A

    - Electronic Discovery Reference Model Buy Form

    Exhibit 13B

    - Sample Electronic Discovery Outline for Preparing or Deposing a Business Witness Buy Form

    Exhibit 13C

    - Sample Questionnaire for Interviewing Client Technology Personnel Buy Form

    Exhibit 13D

    - Sample Notices (Formal and Basic) Buy Form

    Exhibit 13E

    - Sample Preservation Letter Buy Form

    Exhibit 13F

    - Model Order Regarding Preservation Buy Form
    Chapter 14 expand

    Obtaining Information from Government Sources: FOIA

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    Chapter 15 expand

    Using the Internet in Discovery and Investigation

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  • Editors & Authors


    Donald J. Marchesseault, Esq., Hubbell Incorporated, Shelton


    Tanya A. Bovee, Esq., Jackson Lewis LLP, Hartford
    James A. Budinetz, Esq., McElroy, Deutsch, Mulvaney, & Carpenter LLP , Hartford
    Joseph B. Burns, Esq., Rome McGuigan, Hartford
    Drew J. Cunningham, Esq., Carmody Torrance Sandak & Hennessey LLP, New Haven
    Fatima Lahnin, Esq., Carmody Torrance Sandak & Hennessey LLP, New Haven
    Todd R. Michaelis, Esq., Carmody Torrance Sandak & Hennessy LLP, Waterbury
    Moy N. Ogilvie, Esq., McCarter & English LLP, Hartford
    Ann H. Rubin, Esq., Carmody Torrance Sandak & Hennessy LLP, Waterbury
    Hon. Rupal Shah Palanki, Connecticut Superior Court, Hartford
    Tara A. Sheldon, Esq., McCarter & English LLP, Hartford
    Sally Welch St. Onge, Esq., Jackson Lewis LLP, Hartford
    Andrew M. Zeitlin, Esq., Shipman & Goodwin LLP, Stamford