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 through 13-11 and all other applicable provisions of Connecticut law, [Plaintiff / Defendant] [________________________________] ("Propounding Party") hereby requests that [________________________________] ("Responding Party" or "You") produce and permit Propounding Party, or someone acting on its behalf, to inspect, copy, photograph, test, or sample the documents, electronically stored information ("ESI"), and tangible things described below, and/or to permit entry upon designated land or property as set forth herein, all 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. Such requests are served on the opposing party and are not filed with the court except as relevant to a pending motion.

2. Scope. This Request seeks discovery of material within the scope permitted by CPB Section 13-2, which allows discovery of information, not privileged, that is material to the subject matter of the pending action, including the existence, description, nature, custody, condition, and location of any documents or tangible things, if the disclosure sought would be of assistance in the prosecution or defense of the action and would not unduly burden the disclosing party.

3. Form of ESI. Propounding Party requests that ESI be produced in the following form(s): [e.g., single-page TIFF images with corresponding searchable text/OCR and a metadata load file, with native files for spreadsheets, presentations, databases, and audio/video].

II. DEADLINE FOR RESPONSE

Response Deadline. Pursuant to CPB Section 13-10, Responding Party must serve a written response to each Request, including the production of all requested non-objectionable items, not later than sixty (60) days after the date of certification of service of these Requests for Production.

For each Request, the written response must state, with respect to each item or category, that the inspection and related activities requested will be permitted, or that the item or category is objected to, in which event the reasons for objection shall be stated with specificity, as provided in CPB Section 13-11. If objection is made to part of an item or category, the part shall be specified.

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 all present and former parents, subsidiaries, affiliates, divisions, officers, directors, managers, members, partners, employees, agents, representatives, insurers, and attorneys, and all other persons or entities acting or purporting to act on Responding Party's behalf.

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 referring to, describing, evidencing, constituting, mentioning, reflecting, connected with, commenting on, regarding, or pertaining to, in whole or in part.

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

1. Manner of Production. Produce documents as they are kept in the usual course of business or organize and label them to correspond with the categories in these Requests.

2. Possession, Custody, or Control. These Requests require production of all responsive items within Your possession, custody, or control, including items held by Your agents, employees, attorneys, accountants, or other representatives.

3. Privilege and Work Product. If You withhold any item on a claim of privilege (including the attorney-client privilege) or work-product protection, You must expressly identify the privilege claimed and provide a privilege log sufficient to permit assessment of the claim, including the nature of the item, its date, author(s), recipient(s), general subject matter, and the specific privilege or protection asserted. See CPB Section 13-5.

4. Objections. Pursuant to CPB Section 13-11, any objection to a Request must be stated with specificity. Mere general or blanket objections are improper. Answers to, and production for, the unobjectionable portions of any Request must still be provided within the 60-day period.

5. Form of ESI. If a Request does not specify a form for producing ESI, produce it in a form in which it is ordinarily maintained or in a reasonably usable form. You need not produce the same ESI in more than one form.

6. Inability to Produce. If responsive items are no longer within Your possession, custody, or control, identify the present custodian and the circumstances and date of any loss, transfer, or destruction.

7. Continuing Duty. These Requests are continuing. Pursuant to CPB Section 13-15, You must seasonably supplement or correct Your response upon learning that it is incomplete or incorrect.

8. Construction. The singular includes the plural and vice versa; "and" and "or" shall be construed conjunctively or disjunctively as necessary to bring within the scope of the Requests all responses that might otherwise be construed outside their scope.

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: All Documents and ESI reflecting Your efforts to preserve potentially relevant Documents and ESI, including any litigation-hold notices issued in connection with this matter, and Your document retention and destruction policies during the Relevant Period.

REQUEST NO. 14: All reports, opinions, and supporting materials prepared by or for any expert You expect to call at trial, to the extent discoverable.

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 the limitations the court may impose under CPB Section 13-5, including for discovery that is unreasonably cumulative or duplicative, or unduly burdensome or expensive. Propounding Party expressly reserves the right to serve additional requests, interrogatories, requests for admission, deposition notices, and other discovery, and reserves all objections and privileges available under Connecticut law. Nothing herein shall be construed as a waiver of any right or as an admission concerning 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 hereby certify that on [__/__/____], a copy of the foregoing [PLAINTIFF'S / DEFENDANT'S] FIRST REQUESTS FOR PRODUCTION DIRECTED TO [RESPONDING PARTY] was served upon counsel of record (or upon the party, if self-represented) by the method indicated below, in compliance with Connecticut Practice Book Section 10-12 et seq.:

☐ Hand delivery
☐ First-class United States mail, postage prepaid
☐ Certified mail, return receipt requested
☐ Electronic service via the Judicial Branch e-filing system
☐ Email (by agreement of the parties)
☐ 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. 60-Day Response Deadline. Under CPB Section 13-10, responses to requests for production — including production of non-objectionable items — are due not later than 60 days after the date of certification of service. This window is distinctive to Connecticut; calendar it carefully.

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. For certain case categories (e.g., motor vehicle and premises personal injury), the Practice Book and Appendix of Forms prescribe standard production requests. Use the applicable standard forms where required; this template is intended for non-standard requests.

4. Not Filed With the Court. Requests for production and responses are served on the opposing party and are not filed with the court except when relevant to a pending motion (e.g., a motion for order of compliance under CPB Section 13-14).

5. Privilege Log. A privilege log consistent with CPB Section 13-5 and applicable case law is required to preserve privilege and work-product objections.

6. Motion for Order of Compliance. If the response is inadequate or items are withheld without proper objection, a motion for order of compliance under CPB Section 13-14 is available; sanctions may include nonsuit, default, preclusion of evidence, or adverse inferences. A good-faith effort to resolve the dispute is expected before seeking court intervention.

7. Electronic Filing and Service. The Connecticut Superior Court uses the Judicial Branch e-filing system. Confirm whether electronic service is available and required in the applicable Judicial District.

XI. SOURCES AND REFERENCES

• Connecticut Practice Book Section 13-2 — Scope of Discovery
• 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; 60-Day Time Limit
• Connecticut Practice Book Section 13-11 — Form of Request and Production; Objections
• 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.