Connecticut State Court Request for Production of Documents

SUPERIOR COURT OF THE STATE OF CONNECTICUT

JUDICIAL DISTRICT OF [________________________________]

AT [________________________________]

Docket No.: [________________________________]

Return Date: [__/__/____]

[PLAINTIFF'S / DEFENDANT'S] FIRST REQUESTS FOR PRODUCTION, INSPECTION AND EXAMINATION DIRECTED TO [RESPONDING PARTY]

ATTORNEY INFORMATION

Propounding Attorney:

Date of Certification: [__/__/____]

I. INTRODUCTORY STATEMENT

Pursuant to Connecticut Practice Book ("CPB") Sections 13-9 and 13-10, [Plaintiff / Defendant] [________________________________] ("Propounding Party") requests that [________________________________] ("Responding Party" or "You") permit inspection, copying, or photographing of the documents and electronically stored information ("ESI") described below; permit inspection, testing, or sampling of described tangible things; and, if requested, permit entry upon designated land or property, all to the extent within Your possession, custody, or control.

1. Authority. Under CPB Section 13-9, requests for production may be served upon any party without leave of court at any time after the return day. The request itself must not be filed with the court.

2. Scope. This Request seeks nonprivileged material relevant to the subject matter of the action that would assist its prosecution or defense and is more readily provided by the responding party, within CPB Section 13-2. The Court may limit discovery for good cause under Section 13-5.

3. Form of ESI. For responsive ESI, Propounding Party requests production in these form(s): [SPECIFY FORM BY CATEGORY, OR DELETE THIS REQUEST]. If no form is specified, Section 13-9(f) permits production in its ordinarily maintained form or a reasonably usable form.

4. Inspection logistics. The requested inspection will take place at [PLACE] on [DATE] at [TIME], by [REASONABLE MANNER], unless the parties agree otherwise. See Section 13-9(e).

II. DEADLINE FOR RESPONSE

Response Deadline. Under CPB Section 13-10(a), serve a written response within sixty (60) days after the date of certification of service, unless the Court allows a different time, the parties file a written extension stipulation, or timely objections affect the response deadline. Under Section 13-10(c), serve copies with the response when copies are requested and no objection applies.

Repeat each request before its response and state whether inspection will be permitted. An objection must identify the request, give specific reasons, and say whether responsive material is being withheld; respond to portions not objected to within the applicable sixty-day period. See CPB Section 13-10(b), (d), and (f).

III. DEFINITIONS

For purposes of these Requests, the following terms shall have the meanings set forth below. These definitions apply regardless of capitalization.

1. "You," "Your," or "Responding Party" means [________________________________], including responsive material within that party's possession, custody, or control. A separate entity's material is requested only to the extent within that control.

2. "Document" or "Documents" has the broadest meaning permissible under the Practice Book, including all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), and other data or data compilations stored in any medium from which information can be obtained, translated if necessary into reasonably usable form. This includes drafts, non-identical copies, and associated metadata.

3. "Electronically Stored Information" or "ESI" means information stored in an electronic medium, including email, text messages, instant messages, databases, metadata, voicemails, cloud-stored files, and information on servers, computers, mobile devices, and backup media.

4. "Tangible Thing" means any physical object, item, or sample, other than a document, that is within the scope of CPB Section 13-9.

5. "Communication" means any transmission of information by any means, whether oral, written, or electronic, including letters, memoranda, emails, text messages, instant messages, voicemails, social media messages, and telephone or in-person discussions.

6. "Concerning" or "Relating to" means relating to, referring to, describing, evidencing, or constituting the identified subject, within CPB Section 13-1(c)(8).

7. "Incident" means the events, acts, omissions, and circumstances giving rise to this action, as described in the operative pleadings.

8. "Relevant Period" means the period from [__/__/____] through the present, unless a particular Request specifies otherwise.

9. "Person" means any natural person, corporation, limited liability company, partnership, association, governmental body, or other legal entity.

IV. INSTRUCTIONS

For these nonstandard requests, the instructions to Practice Book Forms 204 through 206 apply under Section 13-9(h), unless the Court grants leave for different instructions:

1. Provide responsive material within Your possession, custody, or control.
2. If a request cannot be answered in full, answer to the extent possible.

Definitions and rules of construction in Section 13-1 are incorporated into discovery requests by that rule. Objections, privilege logs, and supplemental responses are governed by Sections 13-10(f), 13-3(d), and 13-15, respectively.

V. REQUESTS FOR PRODUCTION

REQUEST NO. 1: All Documents and ESI that relate to the Incident described in the operative pleadings.

REQUEST NO. 2: All Documents and ESI constituting, reflecting, or relating to any Communication between You and Propounding Party concerning the subject matter of this action.

REQUEST NO. 3: All Documents and ESI that support, evidence, or relate to each special defense or affirmative defense asserted in Your responsive pleading.

REQUEST NO. 4: All Documents and ESI that support or relate to Your denial of any allegation in the operative pleading concerning [________________________________].

REQUEST NO. 5: All contracts, agreements, amendments, and addenda between You and Propounding Party relating to [________________________________], including all drafts.

REQUEST NO. 6: All Documents and ESI relating to the negotiation, formation, performance, modification, breach, or termination of the agreement(s) identified in Request No. 5.

REQUEST NO. 7: All Documents and ESI that relate to the damages claimed by any party in this action, including all calculations, supporting records, invoices, statements, and itemizations.

REQUEST NO. 8: All insurance policies (including primary, excess, umbrella, and surplus-lines policies) that may provide coverage for any claim asserted in this action, together with all reservation-of-rights letters and declarations pages.

REQUEST NO. 9: All Documents and ESI relating to any Communication with any non-party witness concerning the Incident or the subject matter of this action.

REQUEST NO. 10: All Documents and ESI identified, referenced, or relied upon in Your answers to any interrogatories served in this action.

REQUEST NO. 11: All photographs, video recordings, audio recordings, diagrams, and other depictions relating to the Incident or the items, conditions, or property at issue.

REQUEST NO. 12: All Documents and ESI relating to any policy, procedure, guideline, manual, or training material in effect during the Relevant Period concerning [________________________________].

REQUEST NO. 13: Nonprivileged Documents and ESI reflecting Your document retention and destruction policies during the Relevant Period and any nonprivileged preservation steps concerning the Incident.

REQUEST NO. 14: Reports, opinions, and supporting materials for any expert You expect to call at trial, to the extent discoverable under Section 13-4.

REQUEST NO. 15: All Documents and ESI relating to any prior or pending claim, lawsuit, or administrative proceeding involving the same subject matter, parties, or events at issue in this action.

REQUEST NO. 16: [________________________________]

REQUEST NO. 17: [________________________________]

REQUEST NO. 18: [________________________________]

VI. ENTRY UPON LAND / EXAMINATION (OPTIONAL)

ENTRY/EXAMINATION REQUEST NO. 1: Pursuant to CPB Section 13-9, Propounding Party requests permission to enter upon the land or property located at [________________________________], possessed or controlled by You, and/or to examine the tangible thing(s) described as [________________________________], on [__/__/____] at [____] [a.m./p.m.], so that Propounding Party may inspect, measure, survey, photograph, test, or sample the property or object relating to [________________________________].

VII. SCOPE, MATERIALITY, AND RESERVATION OF RIGHTS

These Requests seek only material within the scope of CPB Section 13-2 and are subject to any protective order under Section 13-5. Propounding Party reserves the right to seek additional discovery allowed by the Practice Book. Nothing here waives an objection or privilege or admits the materiality or admissibility of any matter.

VIII. SIGNATURE

Dated: [__/__/____]

Respectfully submitted,

Signature: [________________________________]
[________________________________], Esq.
Counsel for [Propounding Party]
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Juris No.: [________________________________]

IX. CERTIFICATE OF SERVICE

I certify that on [__/__/____], a copy of these requests was served on all appeared parties through counsel or, for a self-represented party, on that party, under Practice Book Sections 10-12 through 10-14. Electronic service on a self-represented party requires written consent; a nonexempt attorney must accept electronic delivery. If a document is electronically filed, Section 10-13 requires electronic service on consenting self-represented parties and nonexempt attorneys.

☐ Hand delivery
☐ First-class United States mail, postage prepaid
☐ Certified mail, return receipt requested
☐ Electronic delivery to [ELECTRONIC ADDRESS], with any required consent
☐ Other: [________________________________]

Served Upon:

[________________________________], Esq.
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Juris No.: [________________________________]

Signature: [________________________________]
[________________________________], Esq.
Counsel for [Propounding Party]
Juris No.: [________________________________]

X. PRACTICE NOTES

1. Response Deadline. Under Section 13-10(a), the ordinary response period is sixty days after certification of service, subject to court order, filed stipulation, and timely objections. Copies requested without objection accompany the response under subsection (c); unobjectionable portions are answered within sixty days under subsection (d).

2. No Leave of Court Required. Under CPB Section 13-9, requests may be served without leave of court at any time after the return day.

3. Standard Production Requests. Section 13-9 mandates standard forms in specified motor vehicle, premises, loss-of-consortium, uninsured or underinsured motorist, and medical-negligence actions, subject to its exceptions and leave procedure. Use this nonstandard request only where permitted. Its instructions must follow Forms 204 through 206 unless the Court grants leave under Section 13-9(h).

4. Not Filed With the Court. Section 13-9(g) directs the requesting party not to file its request or notice with the Court. Section 13-10 addresses service of responses and filing of objections.

5. Privilege Log. For material withheld on privilege or work-product grounds, Sections 13-10(g) and 13-3(d) govern the objection and the privilege log. The log is generally due within forty-five days after the requesting party asks for it, subject to the rule's exceptions, and is initially served on parties rather than filed.

6. Motion for Order of Compliance. Section 13-10(k) permits the requesting party to move under Section 13-14 for failure to respond. Section 13-14 permits proportional orders, including compliance, motion costs, established facts, evidence preclusion, nonsuit, dismissal, or default. For an objection placed on the short calendar, Section 13-10(i) requires the specified affidavit describing good-faith efforts to resolve it.

7. Electronic Service. Apply the recipient and e-filing rules in Section 10-13; electronic delivery to a self-represented party requires that party's written consent.

XI. SOURCES AND REFERENCES

• Connecticut Practice Book Section 13-2 — Scope of Discovery
• Connecticut Practice Book Sections 13-1 and 13-3(d) — Definitions and Privilege Logs
• Connecticut Practice Book Section 13-5 — Protective Orders; Limitations on Discovery
• Connecticut Practice Book Section 13-9 — Requests for Production, Inspection and Examination; In General
• Connecticut Practice Book Section 13-10 — Responses to Requests for Production; Objections; 60-Day Time Limit
• Connecticut Practice Book Section 13-14 — Order for Compliance; Failure to Respond; Sanctions
• Connecticut Practice Book Section 13-15 — Continuing Duty to Disclose
• Connecticut Practice Book Section 10-12 et seq. — Service of the Pleadings and Other Papers
• Connecticut Judicial Branch Official Website: https://www.jud.ct.gov
• Connecticut Practice Book (Current Edition): https://www.jud.ct.gov/publications/PracticeBook/PB.pdf

This template is designed for use in the Connecticut Superior Court for non-standard requests for production. For case types governed by mandatory standard production forms (e.g., motor vehicle and premises personal injury), use the applicable Appendix Forms. Verify all Practice Book citations, confirm any applicable Judicial District standing orders, specify the form of ESI production, and tailor each request to the specific claims and defenses at issue. Have the document reviewed by a licensed Connecticut attorney before service.