Product Description

Recent updates:

• Update: May 2021

  Dear Subscriber:

  Thank you for choosing to keep your copy of A Practical Guide to Discovery and Depositions in Connecticut up to date with this 2021 edition. Inside, there are updates on such topics as the following:

  • Discovery plan. See chapter 1 for a new checklist that guides the reader through elements that are essential to a discovery plan.

  • Spoliation. See chapter 2 for references to new case law in this area.

  • Expert testimony. See chapter 4 for discussion of the two requirements for expert testimony.

  • Trade secrets. See chapter 5 for new case law and discussion of the protection of trade secrets in litigation and discovery.

  • Disclosure of Medicare information. Chapter 8 addresses the situations in which release of such information as Medicare history is permissible in the course of discovery.

  • Electronic discovery. See chapter 13 for version 3 of the Electronic Discovery Reference Model.

  We at MCLE trust that you will find this update useful in your 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

Buy Chapter

Michael J. Coolican, Esq.,
Gregory W. Nye, Esq.,

Checklist 1.1

- Creating a Discovery Plan Buy Form

Checklist 1.2

- Fact-Gathering Stage of Litigation Buy Form

Checklist 1.3

- Types of Formal Discovery in Civil Litigation Buy Form

Exhibit 1A

- Sample Discovery Budget Buy Form

Chapter 2 expand

Preservation and Spoliation of Evidence

Buy Chapter

Rhonda J. Tobin, Esq., Robinson+Cole LLP
Jeffrey J. White, Esq., Robinson+Cole LLP

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

Buy Chapter

Hon. Rupal Shah Palanki, Connecticut Superior Court

Chapter 4 expand

Expert Discovery, Expert Testimony, and Trial Considerations

Buy Chapter

Elizabeth A. Alquist, Esq., Day Pitney LLP
David J. Elliott, Esq.,

Checklist 4.1

- Outline for Expert Deposition: Products Liability Case Buy Form

Chapter 5 expand

Protecting Confidential Information

Buy Chapter

Drew J. Cunningham, Esq., Carmody Torrance Sandak & Hennessey LLP
Todd R. Michaelis, Esq., Carmody Torrance Sandak & Hennessy LLP
Ann H. Rubin, Esq., Carmody Torrance Sandak & Hennessy LLP

Exhibit 5A

- Annotated Protective Order Template Buy Form

Exhibit 5B

- Motion for Stipulated Protective Order Buy Form

Exhibit 5C

- Stipulated Protective Order Buy Form

Exhibit 5D

- Motion to Seal (State Superior Court) Buy Form

Exhibit 5E

- Memorandum in Support of Motion to Seal Buy Form

Exhibit 5F

- Motion to Seal (Federal District Court) Buy Form

Chapter 6 expand

Interrogatories

Buy Chapter

Tanya A. Bovee, Esq., Jackson Lewis LLP
Sally Welch St. Onge, Esq., Jackson Lewis LLP

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

Buy Chapter

James A. Budinetz, Esq., McElroy, Deutsch, Mulvaney, & Carpenter LLP
Steven Lapp, Esq., McElroy Deutsch Mulvaney Carpenter LLP
Peter J. Zarella, Esq., McElroy Deutsch Mulvaney Carpenter LLP

Exhibit 7A

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

Exhibit 7B

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

Exhibit 7C

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

Exhibit 7D

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

Exhibit 7E

- Discovery and Deposition Dispute Order Buy Form

Exhibit 7F

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

Chapter 8 expand

Physical and Mental Health Examinations and Protected Health Information

Buy Chapter

Joseph B. Burns, Esq., Rome McGuigan

Chapter 9 expand

Admission of Facts and Execution of Writings

Buy Chapter

Barry J. Waters, Esq., Murtha Cullina LLP

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

Buy Chapter

Moy N. Ogilvie, Esq., McCarter & English LLP
Tara A. Sheldon, Esq., McCarter & English LLP

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

Buy Chapter

Dominic Fulco, III, Esq., Reid and Riege PC
Agnes Romanowska, Esq., Reid and Riege, PC

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 Motion for Appointment of Discovery Special Master, 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

Buy Chapter

Andrew M. Zeitlin, Esq., Shipman & Goodwin LLP

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

Buy Chapter

David A. Reif, Esq.,
Zane C. Riester, Esq.,
Alex A. Toribio, Esq.,
Makenzie Windfelder, Esq.,

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

Buy Chapter

Michael D. Blanchard, Esq., Morgan, Lewis & Bockius LLP
Christopher M. Wasil, Esq., Morgan, Lewis & Bockius LLP

Chapter 15 expand

Using the Internet in Discovery and Investigation

Buy Chapter

Fatima Lahnin, Esq., Carmody Torrance Sandak & Hennessey LLP

Editor(s)

Author(s)