Connecticut State Court Request for Production of Documents

CONNECTICUT SUPERIOR COURT NONSTANDARD REQUESTS FOR PRODUCTION

Case-type gate. Do not use this packet as a substitute for mandatory Practice Book forms. Under § 13-9(a), motor-vehicle and premises-liability personal-injury actions, related loss-of-consortium actions, and uninsured/underinsured-motorist benefit actions use the applicable Forms 204, 205, 206, 209, 211, 215, and/or 216 unless the judicial authority permits otherwise. Under § 13-9(b), medical-negligence production is limited to Forms 219, 222, and 223 plus twenty additional requests as of right, without subparts, unless the judicial authority permits more.

1. CASE AND SERVICE CONTROL

Case type checked against § 13-9(a) and (b):

☐ This is not a case for which the cited standard forms are mandatory.

☐ The judicial authority granted leave for these nonstandard requests. Order and date: [________________________________]

☐ Medical-negligence case: these are within the twenty additional requests as of right and contain no subparts.

Scheduling or discovery order reviewed: [________________________________]

2. REQUEST

Pursuant to Connecticut Practice Book §§ 13-2, 13-5, 13-9, and 13-10, [Requesting Party] requests that [Responding Party] provide copies of the documents and electronically stored information described below, or afford the Requesting Party a reasonable opportunity to inspect, copy, photograph, test, or sample the designated items. Any permitted entry on land or examination of a tangible thing is separately described in Section 9.

Production will take place at or through [________________________________] on [day], [__/__/____], at [time], subject to the response period, court orders, and written agreements applicable to this case.

In answering these requests, the Responding Party must provide responsive information within that party's possession, custody, or control. If a request cannot be answered in full, respond to the extent possible.

The preceding two paragraphs track the instructions in Practice Book Forms 204–206, which § 13-9(h) requires for nonstandard production requests unless the court grants leave.

3. RESPONSE AND OBJECTION NOTICE

Under § 13-10(a), the Responding Party or counsel must serve a written response, which may be electronic, within sixty days after the date of certification of service, unless the judicial authority allows a different time, the parties file a written stipulation extending the time, or timely objections are filed and served.

Calendar worksheet:

Under § 13-10:

• Each response must repeat the request immediately before the response.
• For each item or category, the response must state that inspection and related activities will be permitted unless the request or part is objected to.
• Copies called for by an unobjectionable request are produced with the response served on all parties.
• A partial objection does not excuse a response to the unobjectionable portion.
• An objection must set out the request, specifically state the reasons, state whether responsive material is being withheld, be signed, and be filed with the court.
• A party withholding material on privilege or work-product grounds must also comply with § 13-3(d).

The request itself is served but not filed with the court under § 13-9(g).

4. DEFINITIONS

Use only definitions needed for the tailored requests. Delete any definition that would make a request broader than the permitted scope.

1. "Responding Party" or "You" means [________________________________].
2. "Document" includes papers, books, documents, and electronically stored information within the scope of § 13-2.
3. "Communication" means [________________________________].
4. "Incident" or "Transaction" means [________________________________].
5. "Relevant Period" means [__/__/____] through [__/__/____].
6. "Project, Property, Product, or Account" means [________________________________].
7. Other defined term: [________________________________].

5. PRODUCTION INSTRUCTIONS

1. Scope. Produce only nonprivileged material within the scope of § 13-2 and subject to the limits and protections available under § 13-5.
2. Identification. The requests designate each item individually or by category. The production place, time, and manner are stated in Sections 1 and 2 or in the particular request.
3. ESI form. For each ESI category, the requested form is: [________________________________].
4. Unspecified ESI form. If a request does not specify a form, § 13-9(f) calls for production in a form in which the information is ordinarily maintained or in a reasonably usable form. The same ESI need not be produced in more than one form.
5. Partial ability to comply. If a request cannot be answered in full, answer to the extent possible.
6. Privilege and work product. State the objection and whether material is withheld. If the requesting party asks for a privilege log, § 13-3(d) requires the listed log information within forty-five days from that request, subject to the rule's exceptions.
7. Continuing disclosure. Section 13-15 governs later-discovered or corrected material after compliance with a discovery request or order.
8. Protected health or substance-use records. Do not use a general request to compel an authorization. Section 13-9(i) and § 13-11A govern motions for authorizations, subject to the standard-form exceptions stated in § 13-9(i).
9. Expert material. Requests directed to expert opinions, reports, or materials must be conformed to § 13-4 and the approved Schedule for Expert Discovery.
10. Confidential or sensitive information. The parties will use this protective order, confidentiality agreement, or redaction protocol, if any: [________________________________].

6. DOCUMENT REQUESTS

Tailor each request to the operative claims and defenses. Delete generic categories that are not material to this action.

REQUEST NO. 1: Produce the final and amended versions of the agreement, instrument, policy, or written terms identified in paragraph [____] of [pleading], dated [__/__/____].

REQUEST NO. 2: Produce the documents identified in Your response to Interrogatory No. [____].

REQUEST NO. 3: Produce the invoices, receipts, payment records, or calculations supporting the amount of $[________________________________] alleged in paragraph [____] of [pleading].

REQUEST NO. 4: Produce communications between [identified persons] from [__/__/____] through [__/__/____] concerning [narrow subject].

REQUEST NO. 5: Produce photographs, audio, or video recordings depicting [identified event, location, item, or condition] during [time period].

REQUEST NO. 6: Produce the version of each policy, procedure, manual, or instruction in effect on [date] concerning [narrow subject tied to a claim or defense].

REQUEST NO. 7: Produce documents supporting the factual basis for [specific allegation, denial, or special defense] in paragraph [____] of [pleading].

REQUEST NO. 8: Produce nonprivileged statements of a party concerning [this action or identified subject], as defined in Practice Book § 13-1.

REQUEST NO. 9: Under § 13-12, produce the declarations or agreement provisions sufficient to show the existence, contents, and policy limits of insurance under which an insurer may be liable to satisfy or reimburse a judgment in this action.

REQUEST NO. 10: Produce the following tangible item for inspection, testing, or sampling under the protocol in Exhibit [____]: [________________________________].

REQUEST NO. 11: [________________________________]

REQUEST NO. 12: [________________________________]

7. ESI PROTOCOL FOR SELECTED REQUESTS

Complete only if ESI is requested.

This protocol does not expand the permitted scope of discovery or require preservation discovery without a case-specific basis.

8. OPTIONAL EXPERT REQUEST

Use only after checking § 13-4, the expert disclosure, the approved Schedule for Expert Discovery, and any agreement or order.

REQUEST NO. [____]: Produce the materials that § 13-4(b)(3), an agreement, or the following court order requires the disclosed expert [name] to produce: [________________________________].

Applicable deadline or deposition date: [________________________________]

9. OPTIONAL ENTRY ON LAND OR EXAMINATION

Complete only if § 13-9 authorizes the requested inspection and the details are reasonable and specific.

The Requesting Party asks to enter or examine:

Connection to a claim or defense: [________________________________]

10. SIGNATURE

Dated: [__/__/____]

Respectfully submitted,

11. CERTIFICATION OF SERVICE

I certify that a copy of this document was or will immediately be mailed or delivered electronically or nonelectronically on [__/__/____] to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys exempt from e-filing and self-represented parties of record who received or will immediately be receiving electronic delivery.

Signature of attorney or self-represented party: ________________________________________

Printed name: [________________________________]

Mailing address or email address: [________________________________]

Date signed: [__/__/____]

Telephone: [________________________________]

This certification tracks § 10-14(a) and the certifications in Forms 204–206 as amended effective January 1, 2026. Section 10-13 controls the permitted service method and when electronic delivery is required or requires written consent.

12. POST-SERVICE CHECKLIST

☐ Request served on every party who appeared, through counsel where represented.

☐ Request not filed with the court.

☐ Response date calendared from the certification date.

☐ Any objection checked for filing, service, specificity, and a statement whether material is withheld.

☐ Unobjected-to material and copies checked for timely production.

☐ If privilege or work product is asserted, a written request for the § 13-3(d) log was sent on [__/__/____].

☐ Before placing an objection on the short calendar, the § 13-10(i) good-faith conference and affidavit requirements were reviewed.

☐ Any motion under § 13-14 requests an order proportional to the identified noncompliance.

VERIFIED OFFICIAL SOURCE

Connecticut Judicial Branch, Official 2026 Connecticut Practice Book, including §§ 10-12 through 10-14; 13-1 through 13-5; 13-9 through 13-15; and Appendix Forms 204–206 (accessed July 30, 2026):

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