[FIRM LETTERHEAD OR CAPTION BLOCK]
[DATE]
[Opposing Counsel Name]
[Law Firm]
[Address]
Via [Email/ECF/Overnight Mail]
Re: [Case Name], [Court], Case No. [Number] - Discovery Deficiency Meet-and-Confer
Counsel:
We write pursuant to Connecticut Practice Book §§ 13-6 through 13-14 to address deficiencies in your [responses/production] served on [DATE]. This letter documents our good faith effort to resolve this dispute before seeking court intervention.
Connecticut Discovery Rules - Key Citations
- Response deadlines: 30 days from service (Conn. Practice Book § 13-6(a), § 13-9(a))
- Interrogatory limit: 30 interrogatories including subparts (Conn. Practice Book § 13-6(a))
- Request for Production: Conn. Practice Book § 13-9; 30 days to respond
- Motion to compel (Conn. Practice Book § 13-14): Court may enter appropriate order including sanctions
- Sanctions: Court may award reasonable expenses and attorneys fees for discovery abuse
- Complex Litigation Docket: Specialized discovery procedures for complex cases
Specific Deficiencies and Requested Cures
| No. | Request/Topic | Deficiency | Requested Cure | Deadline |
|---|---|---|---|---|
| 1 | [Interrogatory No. __/Request No. __] | [e.g., improper objections; failure to produce documents per § 13-9; inadequate answers under § 13-6] | [e.g., provide complete verified response; produce responsive documents; provide privilege log] | [Date] |
| 2 |
Additional Issues
- Privilege log (Conn. Practice Book § 13-5): [not provided/incomplete]; Connecticut requires express claim of privilege with sufficient detail—please provide by [DATE] with document date, author, recipients, privilege type, and general description.
- Verification: Interrogatory answers must be signed under oath per Conn. Practice Book § 13-6(c).
- ESI/formatting: [missing metadata/native format]; please re-produce in [reasonably usable form per § 13-9(b)].
- Protective order/clawback: [status]; propose to file agreed protective order by [DATE].
Connecticut-Specific Sanctions Warning
Under Conn. Practice Book § 13-14, the court may impose sanctions for failure to comply with discovery obligations, including award of reasonable expenses and attorney's fees, preclusion of evidence, and striking of pleadings.
Connecticut courts actively enforce discovery obligations and have emphasized the importance of good faith compliance with discovery rules.
Proposed Path to Resolution
- Meet-and-confer availability: [3 date/time windows] (Eastern Time). We are prepared to meet telephonically or in person.
- We propose resolving without court intervention if you confirm supplemental responses/production by [DATE].
- If unresolved by [DATE], we will file a motion for order of compliance under Conn. Practice Book § 13-14 and seek fees and costs.
- We will reference this correspondence in our motion.
Preservation Reminder
Please confirm litigation holds remain in place for email, text messages, messaging platforms, shared drives, cloud storage, and any custodian-specific data sources relevant to the disputed requests.
We look forward to your prompt response.
Sincerely,
______________________________
[Attorney Name]
[Law Firm]
Counsel for [Party]