State Court Motion to Quash Subpoena (Civil) - Connecticut
MOTION TO QUASH OR MODIFY CIVIL DEPOSITION SUBPOENA
| Party | Role |
|---|---|
| [PLAINTIFF] | Plaintiff |
| v. | |
| [DEFENDANT] | Defendant |
| Court | Case details |
|---|---|
| Superior Court of Connecticut | Judicial District of [____________] at [____________] |
| Docket number | [____________] |
| Motion filed | [__/__/____] |
Before you use this: This form addresses a civil deposition subpoena issued in Connecticut. Identify the pending action and the judicial district where Practice Book § 13-28A(e) places the motion. A trial subpoena or a subpoena issued under a different procedure may require a different basis.
[MOVING PARTY]'S MOTION TO QUASH OR MODIFY DEPOSITION SUBPOENA
[Moving party], ☐ a party ☐ the subpoenaed person, moves under Conn. Gen. Stat. § 52-148e(d) and Practice Book § 13-28A(f) to ☐ quash ☐ modify the deposition subpoena described below. This motion is made promptly and at or before the stated time for compliance.
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Subpoena and action. The subpoena was issued on [__/__/____] at the request of [____________], served on [__/__/____] upon [____________], and commands ☐ appearance at a deposition ☐ document or tangible item production with a deposition, on [__/__/____] at [____] in [LOCATION]. The action is pending in [COURT, JUDICIAL DISTRICT, AND DOCKET]. A complete copy of the subpoena is attached as Exhibit A.
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Time to comply. The subpoena's compliance date is [__/__/____]. This motion is filed on [__/__/____]. For a document demand, Practice Book § 13-28A(c) ordinarily prohibits directing compliance in less than 15 days after service absent a Superior Court judge's order or written agreement of the parties. The dates, order, or agreement relevant here are [____________].
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Grounds supported by the facts below.
- ☐ Unreasonable and oppressive demand: [State the particular burden, time, scope, cost, or other facts: ____________]. Relief requested: [____________].
- ☐ Materials outside § 52-148e(b): [Identify the materials and explain why they are not material to the cause or defense, outside the examined person's possession or control, privileged, or otherwise protected by law from discovery: ____________]. Identify any particular protection relied on: [____________].
- ☐ Other defect or basis under the current rule: [Identify exact rule or order and the facts: ____________].
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Written objection, if any. ☐ The subpoenaed person served a written objection on [__/__/____], identifying the disputed materials or appearance as [____________]; a copy is attached as Exhibit B. ☐ No written objection was served. A document-production objection under § 52-148e(c) must be served on the issuing authority within 15 days of service or by the earlier compliance date. Practice Book § 13-28A(d) has its own objection, service, and exception provisions, including a special rule for specified medical malpractice actions; identify any reliance on that rule here: [____________].
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Requested modification, if quashing is denied. Limit the subpoena to [specific testimony/materials and dates: ____________], set compliance for [__/__/____], and direct [protective or cost terms: ____________]. Section 52-148e(d)(2) and Practice Book § 13-28A(f) allow the court to condition denial of a motion on advancement of reasonable production costs. If movant is a party from whom discovery is sought, a protective order under Practice Book § 13-5 is also requested for good cause shown by [facts: ____________].
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Supporting record. Movant submits ☐ declaration or affidavit of [NAME] ☐ cost estimate ☐ privilege or document-category schedule ☐ correspondence ☐ other [____________] as Exhibits [____________].
WHEREFORE, movant requests that the Court quash the subpoena in full or modify it as specified above, and grant the protective or cost terms supported by this motion.
Dated [__/__/____].
Signature: __________________________________
Printed name and capacity: [________________________________]
Connecticut Juris number, if counsel: [____________]
Address, phone, and email: [________________________________]
Certification of service
I certify that on [__/__/____], I sent a copy of this motion and its exhibits to the following counsel, parties, subpoenaing person, and subpoenaed person by [METHOD]:
| Recipient and role | Service address or electronic destination |
|---|---|
| [____________] | [____________] |
| [____________] | [____________] |
| [____________] | [____________] |
Signature: __________________________________ Printed name: [____________]
Sources and references
- Conn. Gen. Stat. § 52-148e: https://www.cga.ct.gov/current/pub/chap_899.htm#sec_52-148e
- Connecticut Judicial Branch, 2026 Connecticut Practice Book, §§ 13-28A and 13-5: https://www.jud.ct.gov/Publications/PracticeBook/PB.pdf
About this template
- Last updated
- October 4, 2026
- Citations checked
- October 4, 2026
- Jurisdiction
- Connecticut
- Category
- Litigation & Court Documents
Legal authority
- Conn. Gen. Stat. § 52-148e(b)-(d) (deposition document subpoena, objection, and motion to quash or modify)
- Conn. Practice Book § 13-28A (Deposition subpoenas; objection, motion, and venue; effective January 1, 2026)
- Conn. Practice Book § 13-5 (Protective order for discovery from a party)
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on October 4, 2026.
Conn. Gen. Stat. § 52-148e (checked October 4, 2026): "The court in which the cause is pending may, upon motion made promptly and in any event at or before the time for compliance specified in a subpoena authorized by subsection (b) of this section, (1) quash or modify the subpoena if it is unreasonable and oppressive or if it seeks the production of materials not subject to production under the provisions of subsection (b) of this section"
Conn. Practice Book § 13-28A (checked October 4, 2026): "A party or the person to whom the subpoena is directed may move to quash or modify the subpoena. The court may, upon motion made promptly and, in any event, at or before the time for compliance specified in a subpoena authorized by subsections (a) or (b) of this section, (1) quash or modify the subpoena if it is unreasonable and oppressive"
Conn. Practice Book § 13-28A(c) (checked October 4, 2026): "Unless otherwise ordered by a judge of the Superior Court or agreed upon in writing by the parties, any subpoena issued to a person commanding the production of documents or other tangible thing at a deposition shall not direct compliance within less than fifteen days from the date of service thereof."
Conn. Practice Book § 13-28A(d) (checked October 4, 2026): "The provisions of subdivisions (1) and (2) of this subsection shall not be applicable to a civil action filed to recover damages resulting from personal injury or wrongful death in which it is alleged that such injury or death resulted from professional malpractice of a health care provider or health care institution."
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