Product Description

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.

  Cordially,

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

Table of Contents

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

Interrogatories

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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

Depositions

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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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