DISCOVERY DEFICIENCY MEET-AND-CONFER LETTER

Connecticut Superior Court — Pursuant to Connecticut Practice Book §§ 13-14, 13-15

[ATTORNEY/FIRM NAME]
[________________________________]
[________________________________]
[City, State, ZIP]
Phone: [____________________]
Fax: [____________________]
Email: [________________________________]
Connecticut Juris No.: [____________________]

[__/__/____]

VIA [☐ EMAIL ☐ CERTIFIED MAIL ☐ HAND DELIVERY ☐ OVERNIGHT COURIER]

[________________________________]
[Opposing Counsel Name]
[________________________________]
[Law Firm Name]
[________________________________]
[Address Line 1]
[________________________________]
[City, Connecticut, ZIP]

Re: [________________________________] v. [________________________________]
Court: Superior Court, Judicial District of [________________________________], Connecticut, Docket No. [________________________________]
Subject: Discovery Deficiency Meet-and-Confer — [☐ Interrogatories ☐ Requests for Production ☐ Requests for Admission ☐ All Discovery Responses]

Dear [________________________________]:

I. PURPOSE OF THIS LETTER

This letter is written to document our good-faith effort to resolve the discovery deficiencies described herein without court intervention, pursuant to Connecticut Practice Book §§ 13-14 and 13-15. While Connecticut's Practice Book does not codify a specific pre-motion meet-and-confer rule in the same manner as federal practice, Connecticut courts expect and encourage counsel to attempt informal resolution of discovery disputes before filing a motion for compliance or objecting to discovery responses.

Under Practice Book § 13-14, the court may, on motion, enter appropriate orders requiring compliance with discovery obligations. Under Practice Book § 13-14(f), sanctions for failure to comply may include:
- Requiring the noncompliant party to pay the opposing party's expenses and attorney's fees
- Staying further proceedings until the order is obeyed
- Precluding evidence or witnesses
- Striking pleadings
- Rendering a default judgment

This letter serves to notify you of deficiencies and to provide an opportunity to cure them before we are compelled to seek judicial intervention.

We write on behalf of our client, [________________________________] ("[Plaintiff/Defendant]"), regarding deficiencies in [________________________________]'s ("[Responding Party]") discovery responses.

II. CONNECTICUT DISCOVERY FRAMEWORK — KEY RULES

A. Response Deadlines

• Interrogatories: 30 days after service (Practice Book § 13-6(b)); court may extend by motion
• Requests for Production: 30 days after service (Practice Book § 13-9(b))
• Requests for Admission: 30 days after service (Practice Book § 13-13(b)); failure to respond timely results in automatic admission

B. Interrogatory Limits

Practice Book § 13-6(a) limits each party to 25 interrogatories, including subparts, without leave of court. Additional interrogatories require a court order upon showing of good cause.

C. Scope of Discovery

Practice Book § 13-1 provides that a party may obtain discovery "of any matter relevant to the subject matter involved in the pending action or to the claim or defense of any other party." Discovery is not limited to admissible evidence but must appear reasonably calculated to lead to the discovery of admissible evidence.

D. Objections to Discovery

Practice Book § 13-5 governs objections to discovery. Objections must be filed within the time allowed for compliance. A party claiming privilege must provide a privilege log with sufficient information to assess the privilege claim.

E. Verification of Interrogatory Responses

Under Practice Book § 13-6(c), interrogatory responses must be signed under oath by the party. If the responding party is a corporation, a representative officer or agent must sign under oath.

F. Privilege Log Requirements

When a party withholds documents on the basis of privilege, Practice Book § 13-5(b) requires the party to describe the nature of the withheld documents in a manner that enables the other party to assess the applicability of the privilege. A general assertion of privilege without identification of withheld documents is insufficient.

G. Motion for Order of Compliance

Practice Book § 13-14 provides the mechanism for compelling compliance with discovery. The moving party must bring a motion for order of compliance if a party fails to respond to discovery or fails to cure deficiencies after notice. Courts in Connecticut expect attorneys to make a good faith effort to resolve disputes informally before filing such a motion.

H. Sanctions

Practice Book § 13-14(f) provides that in appropriate cases, the court may impose sanctions proportional to the noncompliance, including:
- Reasonable expenses and attorney's fees
- Evidentiary preclusion
- Striking of pleadings
- Default judgment or dismissal

I. Complex Litigation Docket

If this case is assigned to the Complex Litigation Docket, additional discovery management rules and procedures may apply. Please confirm whether this case has been assigned to the Complex Litigation Docket.

III. INTERROGATORY DEFICIENCIES

The following interrogatory responses are deficient under Connecticut Practice Book § 13-6.

Deficiency Checklist — Interrogatories

☐ Incomplete Answer — The response does not fully answer the interrogatory. Practice Book § 13-6(b) requires each interrogatory to be answered fully and separately in writing under oath. A partial answer without explanation for the omission is insufficient.

☐ Improper Relevance Objection — Practice Book § 13-1 defines the scope of discovery broadly. A conclusory relevance objection, without a specific showing of why the information sought falls outside permissible discovery, is insufficient.

☐ Improper Overbreadth/Undue Burden Objection — No specific showing of overbreadth or undue burden has been made. Please identify specifically what makes the interrogatory overbroad and provide a complete response to any unobjectionable portion.

☐ Improper Vagueness Objection — The interrogatory is reasonably clear. Please respond based on a good-faith interpretation of the question.

☐ Objection Without Response — Responding party has asserted objections but has provided no response, including to the portions of the interrogatory that are plainly not objectionable.

☐ No Verification (Oath) — Interrogatory responses are not signed under oath by the responding party as required by Practice Book § 13-6(c). Please provide a properly executed verification.

☐ Failure to Supplement — Connecticut courts recognize a duty to supplement discovery responses when a party learns that a prior response was incorrect or incomplete. Please supplement immediately.

☐ Boilerplate Objections — Multiple boilerplate objections have been stated without application to the specific interrogatory. Connecticut courts disfavor such practices.

☐ Exceeded Interrogatory Limit — More than 25 interrogatories (including subparts) have been served without leave of court, in violation of Practice Book § 13-6(a).

Specific Interrogatory Deficiencies

IV. REQUEST FOR PRODUCTION DEFICIENCIES

The following Requests for Production responses are deficient under Connecticut Practice Book § 13-9.

Deficiency Checklist — Requests for Production

☐ Blanket Objections Without Response — Responding party has asserted blanket objections without producing any responsive documents. Practice Book § 13-9(b) requires a substantive response indicating whether production will be made.

☐ No Privilege Log — Documents appear to have been withheld on privilege grounds without adequate identification as required by Practice Book § 13-5(b). Please provide a privilege log by [__/__/____].

☐ Incomplete Production — Based on [________________________________], additional responsive documents exist that were not produced. Please confirm completeness of the production or supplement.

☐ No Specific Date for Production — The response states that documents will be produced but provides no specific date. Please confirm production will be complete by [__/__/____].

☐ Improper Format of Production — Documents were not produced in a reasonably usable format. Please reproduce in [☐ native format ☐ TIFF with load file ☐ searchable PDF ☐ other agreed format].

☐ ESI Issues — The request encompasses electronically stored information. Please describe the search methodology used to collect and review ESI responsive to these requests.

☐ Documents Not Organized by Request — The production is not organized to correspond to the categories in the request or produced as kept in the ordinary course of business.

☐ Failure to Identify Withheld Documents — Where documents are withheld on any ground, they must be identified with sufficient specificity in a privilege log or withholding notice.

Specific RFP Deficiencies

V. REQUEST FOR ADMISSION DEFICIENCIES

The following Requests for Admission responses are deficient under Connecticut Practice Book § 13-13.

Deficiency Checklist — Requests for Admission

☐ Evasive Response — Neither Admission nor Denial — Practice Book § 13-13(b) requires each matter to be specifically admitted or denied, or a statement that the party cannot truthfully admit or deny, with reasons. A non-responsive answer is insufficient.

☐ Improper Objection — The objection lacks a valid legal basis under Practice Book § 13-13. Please withdraw the objection and provide a substantive response.

☐ Qualified Response Without Specification — Where a qualified admission is offered, the responding party must specify the portion that is true and qualify or deny the remainder. The qualification provided fails to meet this standard.

☐ Insufficient Claim of Lack of Information — A party claiming inability to admit or deny must state that it has made a reasonable inquiry and that the information available is insufficient to admit or deny.

☐ Untimely Response — Automatic Admission — Requests were served on [__/__/____] and responses were due by [__/__/____]. Under Practice Book § 13-13(b), failure to respond timely constitutes an automatic admission of the matters requested. Please advise whether you intend to seek leave to withdraw the deemed admissions.

Specific RFA Deficiencies

VI. PRIVILEGE LOG DEFICIENCIES

Pursuant to Connecticut Practice Book § 13-5(b), documents withheld on grounds of privilege must be identified with sufficient information to assess the privilege claim:

☐ Date of each withheld document
☐ Author(s) and all recipients, including cc and bcc
☐ General subject matter without disclosing privileged content
☐ Privilege asserted (attorney-client privilege, attorney work product, etc.)
☐ Whether any redacted version can be produced

Current status of privilege log: [________________________________]

Required action: Please provide a complete privilege log by [__/__/____].

VII. DEMAND FOR SUPPLEMENTATION AND DEADLINE

We demand that [Responding Party] serve complete, verified, and rule-compliant supplemental responses to all deficiencies identified in this letter no later than:

SUPPLEMENTATION DEADLINE: [__/__/____]

Failure to provide complete supplemental responses by this deadline will result in our filing a Motion for Order of Compliance pursuant to Practice Book § 13-14, and a request for sanctions including attorney's fees pursuant to Practice Book § 13-14(f).

VIII. MEET-AND-CONFER AVAILABILITY

We remain willing to discuss these deficiencies by telephone or in person in a good-faith effort to resolve them without court intervention. Connecticut courts expect attorneys to cooperate in discovery and to exhaust informal efforts before seeking court involvement.

We are available at the following times (Eastern Time):

• [________________________________] (Date/Time)
• [________________________________] (Date/Time)
• [________________________________] (Date/Time)

Please contact the undersigned by [__/__/____]. If we do not hear from you, we will proceed to file the appropriate motion.

IX. SANCTIONS WARNING

Practice Book § 13-14(f) authorizes the court to impose sanctions proportional to the noncompliance. Sanctions may include an award of expenses and attorney's fees, evidentiary preclusion, striking of pleadings, and entry of default judgment. Connecticut courts have imposed significant sanctions in cases of persistent discovery noncompliance.

X. LITIGATION HOLD REMINDER

Please confirm that [Responding Party] has implemented and is maintaining a litigation hold covering all potentially relevant documents and ESI, including emails, text messages, shared drives, and cloud storage. Connecticut courts recognize spoliation claims and have imposed evidentiary and dismissal sanctions for the destruction of relevant evidence.

XI. CLOSING

This letter represents our good-faith attempt to resolve these discovery disputes without court intervention. We look forward to your prompt response.

Sincerely,

[________________________________]
[Attorney Name]
[________________________________]
[Law Firm Name]
Counsel for [________________________________]
[Plaintiff/Defendant]

CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], a true and correct copy of the foregoing Discovery Deficiency Meet-and-Confer Letter was served upon the following counsel of record by the method indicated:

[________________________________]
[Opposing Counsel Name and Address]

☐ Email
☐ U.S. Mail, postage prepaid
☐ Hand Delivery
☐ Overnight Courier

[________________________________]
[Serving Attorney Name]

Sources and References:
- Connecticut Practice Book (2026 Edition): https://www.jud.ct.gov/publications/PracticeBook/PB.pdf
- Practice Book § 13-6 — Interrogatories (25 interrogatory limit)
- Practice Book § 13-9 — Requests for Production
- Practice Book § 13-13 — Requests for Admission
- Practice Book § 13-14 — Motion for Order of Compliance and Sanctions
- Practice Book § 13-15 — Ruling on Objections to Discovery