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A Practical Guide to Discovery and Depositions in Connecticut

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

748 pages in 1 volume (printed book)
1st Edition 2011, with 2013 & 2018 Supplements
© 2018 MCLE, Inc.
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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

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Chapter 1 - Discovery Planning and Investigation (Buy Chapter)
Chapter 2 - Preservation and Spoliation of Evidence (Buy Chapter)
Chapter 3 - Scope of Discovery (Buy Chapter)
Chapter 4 - Expert Discovery, Expert Testimony, and Trial Considerations (Buy Chapter)
Chapter 5 - Protecting Confidential Information (Buy Chapter)
Chapter 6 - Interrogatories (Buy Chapter)
Chapter 7 - Requests for Production, Inspection, and Examination (Buy Chapter)
Chapter 8 - Physical and Mental Health Examinations and Protected Health Information (Buy Chapter)
Chapter 9 - Admission of Facts and Execution of Writings (Buy Chapter)
Chapter 10 - Depositions (Buy Chapter)
Chapter 11 - Other Discovery Rules and Devices (Buy Chapter)
Chapter 12 - Motions for Orders of Compliance (Buy Chapter)
Chapter 13 - Discovery of Electronically Stored Information (Buy Chapter)
Chapter 14 - Obtaining Information from Government Sources: FOIA (Buy Chapter)
Chapter 15 - Using the Internet in Discovery and Investigation (Buy Chapter)


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


Kristin M. Ahern, Carmody Torrance Sandak & Hennessy LLP, Waterbury
Elizabeth A. Alquist, Esq., Day Pitney LLP, Hartford
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
Fatima Lahnin, Esq., Carmody Torrance Sandak & Hennessey LLP, New Haven
Grace J. Lee, Esq., Shearman & Sterling, New York
Todd R. Michaelis, Esq., Carmody Torrance Sandak & Hennessy LLP, Waterbury
Moy N. Ogilvie, Esq., McCarter & English LLP, Hartford
Zane C. Riester, Esq., McCarter & English LLP, Newark
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
Makenzie Windfelder, Esq., McCarter & English LLP, Wilmington
Andrew M. Zeitlin, Esq., Shipman & Goodwin LLP, Stamford



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