Discovery Deficiency Meet-and-Confer Letter

CONNECTICUT DISCOVERY DEFICIENCY CONFERENCE LETTER

[FIRM OR SENDER]

[________________________________]

[________________________________]

Telephone: [________________________________]

Email: [________________________________]
Juris No., if any: [________________________________]

[__/__/____]

VIA: ☐ Electronic delivery ☐ U.S. mail ☐ Hand delivery ☐ Other: [________________________________]

[________________________________]

[Recipient and firm]

[________________________________]
[Address or email]

Re: [________________________________] v. [________________________________]

Court: Superior Court, Judicial District of [________________________________]
Docket No.: [________________________________]

Dear [________________________________]:

This letter identifies specific discovery issues and proposes a conference before either party seeks court action. It also documents the efforts required before certain interrogatory objections, production objections, or admission-response disputes may be placed on the short calendar under Practice Book §§ 13-8(c), 13-10(i), and 13-23(b).

1. DISCOVERY RECORD

Order, stipulation, or scheduling provision changing a deadline: [________________________________]

Case type and mandatory Practice Book forms checked: [________________________________]

2. DEADLINE CHECK

Use the row that applies; do not calculate from the wrong event.

• Interrogatories: Under § 13-7(a), sworn answers are served within sixty days after the date of certification of service, unless a written stipulation is filed, the judicial authority allows a different time, or objections are filed and served within the sixty-day period.
• Production: Under § 13-10(a), a written response is served within sixty days after the date of certification of service, subject to the rule's stipulation, motion, court-order, and timely-objection provisions.
• Admissions: Under § 13-23(a), each matter is admitted unless a signed written answer or objection is filed and served within thirty days after filing the notice required by § 13-22(b), or within another time allowed by the judicial authority.

Deadline conclusion for this dispute:

[________________________________]

3. INTERROGATORY ISSUES

Sections 13-7 and 13-8 govern answers and objections. Answers are under oath, are served rather than filed, repeat each interrogatory immediately before the answer, and are signed by the person answering. An objection must set out the interrogatory, state specific reasons, state whether responsive information is withheld, be signed, and be filed with the court. A partial objection does not excuse timely answers to unobjectionable interrogatories.

Connecticut does not impose a general twenty-five-interrogatory cap on nonstandard cases. Section 13-6 instead mandates standard forms for specified case categories and allows twenty additional interrogatories as of right, without subparts, in medical-negligence actions.

Select and describe only supported deficiencies:

☐ No sworn answers were served.

☐ An answer does not repeat the interrogatory.

☐ An answer is incomplete or does not address the question asked.

☐ A partial objection was used to avoid answering an unobjectionable portion.

☐ An objection does not state a specific reason.

☐ An objection does not say whether responsive information is withheld.

☐ An objection was served but not filed.

☐ A mandatory standard form or medical-negligence limit was not followed.

☐ Other: [________________________________]

4. PRODUCTION ISSUES

Section 13-10 requires the response to repeat each request and state whether inspection and related activities will be permitted unless the request or a part is objected to. Copies called for by an unobjectionable request are produced with the response served on all parties. An objection must set out the request, state specific reasons, state whether responsive material is withheld, be signed, and be filed.

For ESI, § 13-9(f) provides that an unspecified form is the form in which the information is ordinarily maintained or a reasonably usable form; the same ESI need not be produced more than once.

☐ No written response was served.

☐ The response does not repeat each request.

☐ The response does not state whether inspection or production will be permitted.

☐ Copies were not produced with the unobjectionable response.

☐ A partial objection was used to withhold an unobjectionable portion.

☐ An objection lacks a specific reason or withholding statement.

☐ An objection was served but not filed.

☐ The production is not in the requested or a rule-compliant ESI form.

☐ The response does not identify when promised production will occur.

☐ Mandatory standard forms, nonstandard instructions, or medical-negligence limits were not followed.

☐ Other: [________________________________]

5. PRIVILEGE OR WORK-PRODUCT ISSUES

If responsive information or material is withheld on privilege or work-product grounds, §§ 13-8(b) and 13-10(g) require the applicable objection and compliance with § 13-3(d).

This letter expressly requests the § 13-3(d) privilege log. Subject to the rule's exceptions, the log is due within forty-five days from this request and identifies:

• type of document or ESI;
• general subject matter;
• date;
• author;
• each recipient; and
• privilege or protection asserted.

Privilege-log request date: [__/__/____]

Forty-fifth day: [__/__/____]

Claimed exception or court order, if any: [________________________________]

6. REQUEST-FOR-ADMISSION ISSUES

Section 13-23(a) requires a signed answer or objection addressed to each matter. An answer must admit, specifically deny, or explain in detail why the party cannot truthfully admit or deny. A lack-of-information answer must state that reasonable inquiry was made and the known or readily obtainable information remains insufficient. A qualified answer identifies the true portion and qualifies or denies the rest.

☐ No timely answer or objection was filed and served; the requested matter is treated as admitted under § 13-23(a), subject to any court relief.

☐ The answer neither admits nor specifically denies.

☐ A qualified response does not identify the admitted and disputed portions.

☐ A lack-of-information response does not state that reasonable inquiry was made.

☐ The objection does not state a reason.

☐ The response lacks the cover sheet required by § 13-23(a).

☐ Other: [________________________________]

7. CONTINUING DISCLOSURE

Section 13-15 applies after compliance with a discovery request or order when a party later discovers new material previously requested and ordered subject to discovery, or learns that prior compliance was incorrect or is no longer true under the rule's conditions.

Prior response requiring review: [________________________________]

New or corrected information identified: [________________________________]

Requested supplemental or corrected compliance: [________________________________]

8. PROPOSED RESOLUTION

Please provide the following by [__/__/____]:

1. [________________________________]
2. [________________________________]
3. [________________________________]

The proposed date is a resolution request and does not replace a Practice Book, court-ordered, or stipulated deadline.

We are available to confer at:

• [________________________________]
• [________________________________]
• [________________________________]

Proposed method: ☐ Telephone ☐ Video ☐ In person ☐ Written exchange

Please identify the requests resolved, partially resolved, and remaining in dispute before the conference.

9. POSSIBLE COURT PROCEDURE

If the issues are not resolved:

• Section 13-7(e) or § 13-10(k) permits the serving party to move under § 13-14 for failure to answer or respond.
• Section 13-14(a) permits an order proportional to the noncompliance as the ends of justice require.
• Section 13-14(b) lists possible orders including compliance, motion costs and a reasonable attorney fee, established facts, evidentiary preclusion, and dismissal, nonsuit, or default.
• Before an interrogatory objection is placed on the short calendar, § 13-8(c) requires the specified affidavit concerning bona fide resolution attempts.
• Before a production objection is placed on the short calendar, § 13-10(i) requires the specified affidavit concerning good-faith resolution attempts.
• Before a motion challenging the sufficiency of an admission answer or objection is placed on the short calendar, § 13-23(b) requires the specified affidavit concerning bona fide resolution attempts.

This letter does not predetermine which motion, objection, affidavit, or remedy is proper.

Sincerely,

[________________________________]

[Name and title]
Counsel for [________________________________]

DELIVERY RECORD

VERIFIED OFFICIAL SOURCE

Connecticut Judicial Branch, Official 2026 Connecticut Practice Book, §§ 13-2 through 13-10, 13-14 through 13-15, and 13-22 through 13-24 (accessed July 30, 2026):

https://www.jud.ct.gov/Publications/PracticeBook/PB.pdf