Table of Contents
Chapter 1 Pre-Suit Investigation
1-001 Authorization, Employment Records
1-002 Authorization, Medical Records
1-003 Authorization, School Records
1-004 Authorization, Signature
1-005 Authorization, Telephone Records
1-006 Case Intake, Personal Injury
1-007 Case Intake, Medical Malpractice
1-008 Notice, Potential Defendant Driver
1-009 Notice, Representation to Insurance Company
1-010 Notice, Uninsured/Underinsured Motorist Claim
1-011 Medical Malpractice, 90-Day Extension of Statute of Limitations, General Statutes § 52-190a
1-012 Medical Malpractice, Attorney’s Certificate of Good Faith, General Statutes § 52-190a
1-013 Medical Malpractice, Physician Opinion Letter, General Statutes § 52-190a
1-014 Retainer Agreement, Statutory Fee
1-015 Retainer Agreement, Statutory Fee Waiver
1-016 Retainer Agreement, Referred Case, Statutory Fee
1-017 Retainer Agreement, Referred Case, Statutory Fee Waiver
1-018 Retainer Agreement, Limited Scope
1-019 Request, Death Certificate
1-020 Request, Department of Public Health Investigation
1-021 Request, Employment Records
1-022 Request, Freedom of Information
1-023 Request, Insurance Limits
1-024 Request, Preservation of Evidence, General
1-025 Request, Preservation of Evidence (ESI), Alternative
1-026 Request, Preservation of Evidence, Dram Shop
1-027 Statutory Notice, Claims Commissioner, General Statutes § 4-147
1-028 Statutory Notice, Defective Highway
1-029 Statutory Notice, Dram Shop, General Statutes § 30-102
1-030 Statutory Notice, Housing Authority, General Statutes § 8-67
1-031 Statutory Notice, Municipal Employee, General Statutes § 7-465
1-032 Statutory Notice, Volunteer Firefighter, etc., General Statutes § 7-308
1-033 Statutes of Limitations Summary Table
Chapter 2 Pre-Suit Parties
2-001 Motion for Appointment of Guardian Ad Litem
2-002 Motion for Appointment of Executor or Administrator
2-003 Petition for Voluntary Appointment of Conservator
2-004 Petition for Voluntary Conservatorship, Supplemental Form
2-005 Petition for Involuntary Appointment of Conservator
2-006 Petition for Involuntary Appointment of Conservator, Supplemental Form
2-007 Motion to File Under Pseudonym
2-008 Motion to Substitute Decedent’s Representative, General Statutes § 52-599
2-009 Defendant’s Use of a Fictious Name
Chapter 3 Commencement of An Action, General
3-001 Attorney’s Obligations
3-002 Form and Format of Pleadings
3-003 Civil Process, Service and Return, etc.
3-004 Appearance of Defendant
3-005 Appearance of Plaintiff
3-006 Service of Process Summary Table
Chapter 4 Complaint, Generic
4-001 Form and Format of Complaint
4-002 Sample Complaint
4-003 Joinder
Chapter 5 Complaints And Causes of Action
5-001 Accidental Failure of Suit, General Statutes § 52-592
5-002 Agency, Actual
5-003 Agency, Apparent
5-004 Animal Bite (see also, 5-010, Dog Bite)
5-005 Apportionment, General Statutes §§ 52-102b and 52-572h
5-006 Bystander Emotional Distress, General
5-007 Bystander Emotional Distress, Medical Malpractice
5-008 Child’s Suit Against Parent
5-009 Connecticut Unfair Trade Practices, General Statutes § 42-110a et seq.
5-010 Dog Bite (see also, 5-004, Animal Bite)
5-011 Drowning
5-012 Emergency Medical Service Provider
5-013 Employer, Civil Suit Against
5-014 Highway Defect (Municipal), General Statutes § 13a-149
5-015 Highway Defect (State), General Statutes § 13a-144
5-016 Infliction of Emotional Distress, Negligent
5-017 Infliction of Emotional Distress, Intentional
5-018 Loss of Consortium, Parental
5-019 Loss of Consortium, Spousal
5-020 Medical Malpractice, Individual Health Care Provider and Practice Group
5-021 Medical Malpractice, Lack of Informed Consent
5-022 Medical Malpractice, Hospital
5-023 Minor, Civil Suit Against
5-024 Motor Vehicle, Negligence
5-025 Motor Vehicle, Owner and Operator
5-026 Motor Vehicle, Statutory Violation, General Statutes § 14-295
5-027 Motor Vehicle, Trucking
5-028 Motor Vehicle, Uninsured and Underinsured Claims
5-029 Municipal Liability, General Statutes §§ 7-465 and 52-557n
5-030 Municipal Liability (Teachers), General Statutes § 10-235
5-031 Negligence Per Se
5-032 Nuisance
5-033 Premises Liability, General
5-034 Premises Liability, Children
5-035 Premises Liability, Housing Authority, General Statutes § 8-67
5-036 Premises Liability, Inadequate Security
5-037 Premises Liability, Police and Firefighters
5-038 Premises Liability, Recreational Purposes, General Statutes § 52-557g
5-039 Premises Liability (Sidewalks), General Statutes § 7-163a
5-040 Product Liability
5-041 Service of Alcohol
5-042 Sexual Assault
5-043 Suit Against Power Company
5-044 Suit Against the Wrong Defendant, General Statutes § 52-593
5-045 Wrongful Death
Chapter 6 Pleadings
6-001 Pleadings Allowed and Their Order
6-002 Amendment
6-003 Answer and Special Defenses
6-004 Motion to Dismiss
6-005 Motion to Strike
6-006 Request to Revise
6-007 Service of Pleadings, Motions, Papers, etc.
Chapter 7 Pending Litigation
7-001 Assignment for Trial
7-002 Attorneys’ Fees, Motion for
7-003 Certificate of Closed Pleadings
7-004 Consolidate, Motion to
7-005 Correct Misnomer, Motion to
7-006 Default for Failure to Appear, Motion for
7-007 Default for Failure to Plead, Motion for
7-008 Dismissal for Lack of Diligence
7-009 Disqualify Judicial Authority, Motion to
7-010 Extend Time, Motion to
7-011 Immediate Trial, Motion for
7-012 Jury Claim
7-013 Memorandum of Law
7-014 Modify Scheduling Order, Motion to
7-015 Motions and Requests
7-016 Notice to Employer of Third Party Action, General Statutes § 31-293
7-017 Offer of Compromise
7-018 Open Judgment Upon Default or Nonsuit, Motion to
7-019 Oral Argument
7-020 Parties, Motion to Cite In/Add Defendant
7-021 Parties, Motion to Cite In/Add Plaintiff
7-022 Parties, Motion to Substitute Decedent’s Representative, General Statutes § 52-599
7-023 Parties, Motion to Substitute Plaintiff
7-024 Pretrial Memorandum
7-025 Privileged Cases in Assignment for Trial
7-026 Reargue/Reconsider, Motion and Objection
7-027 Sealing Files
7-028 Short Calendar
7-029 Stay, Motion to
7-030 Suing Over Against Third-Party Defendant
7-031 Suggestion of Death
7-032 Summary Judgment, Objection to
7-033 Terminate Action, Motion to
7-034 Transfer of Actions, Motion and Objection
7-035 Transfer to Complex Litigation Docket, Motion and Objection
7-036 Withdraw Appearance, Motion to
7-037 Withdrawal of Action
Chapter 8 Discovery, In General
8-001 Discovery, Overview
8-002 Definitions, Practice Book § 13-1
8-003 Scope of Discovery, Practice Book § 13-2
8-004 Work Product Protection, Practice Book § 13-3
8-005 Privilege Log, Practice Book § 13-3
8-006 Surveillance, Practice Book § 13-3
8-007 Experts, Practice Book § 13-4
8-008 Protective Order, Practice Book § 13-5
8-009 Protective Order, Motion for
8-010 Interrogatories, Practice Book §§ 13-6 et seq.
8-011 Interrogatories, Medical Negligence
8-012 Interrogatories, Medical Negligence, Twenty as of Right
8-013 Permission to File Additional Discovery, Motion for
8-014 Notice of Interrogatories
8-015 Extension of Time, Motion for, Practice Book § 11-1
8-016 Answers to Interrogatories, Practice Book § 13-7
8-017 Objections to Interrogatories, Practice Book § 13-8
8-018 Affidavit Re: Attempt to Resolve Differences Concerning Objections to Discovery
8-019 Requests for Production, Practice Book §§ 13-9 et seq.
8-020 Requests for Production, Medical Negligence Cases, Practice Book § 13-9
8-021 Requests for Production, Medical Negligence Cases, Twenty as of Right
8-022 Notice of Requests for Production
8-023 Electronically Stored Information, Practice Book § 13-9
8-024 HIPAA Authorization, Practice Book § 13-9
8-025 Requests for Production, Responses and Objections, Practice Book § 13-10
8-026 Physical or Mental Examination, Practice Book § 13-11
8-027 Disclosure Of Insurance Policy, Practice Book § 13-12
8-028 Medicare Enrollment, etc., Practice Book § 13-12a
8-029 Disclosure of Assets, Practice Book § 13-13
8-030 Disclosure of Assets, Motion for
8-031 Disclosure of Assets, Prejudgment Remedy
8-032 Disclosure of Assets, Prejudgment Remedy, Affidavit
8-033 Order Of Compliance, Practice Book § 13-14
8-034 Order of Compliance, Sanctions, etc., Motion for
8-035 Order of Compliance Re: Disclosure of Assets, Motion for
8-036 Continuing Duty to Disclose, Practice Book § 13-15
8-037 Orders by Judge, Practice Book § 13-16
8-038 Disclosures in Equity, Practice Book § 13-18
8-039 Discovery Outside United States, Practice Book § 13-21
8-040 Requests for Admission, Practice Book §§ 13-22 et seq.
8-041 Depositions, Practice Book §§ 13-26 et seq.
8-042 Late Claim of Privilege, Practice Book § 13-33
Chapter 9 Standard Discovery
9-001 Standard Discovery
9-002 PB Form 201. Plaintiff’s Interrogatories (Motor Vehicle Cases)
9-003 PB Form 202. Defendant’s Interrogatories (Motor Vehicle Cases)
9-004 PB Form 203. Plaintiff’s Interrogatories—Premises Liability Cases
9-005 PB Form 204. Plaintiff’s Requests for Production (Motor Vehicle Cases)
9-006 PB Form 205. Defendant’s Requests for Production (Motor Vehicle Cases)
9-007 PB Form 206. Plaintiff’s Requests for Production—Premises Liability
9-008 PB Form 212. Defendant’s Interrogatories—Loss of Consortium
9-009 PB Form 213. Plaintiff’s Interrogatories—Uninsured/Underinsured Motorist Cases
9-010 PB Form 214. Defendant’s Interrogatories—Uninsured/Underinsured Motorist Cases
9-011 PB Form 215. Plaintiff’s Requests for Production—Uninsured/Underinsured Motorist Cases
9-012 PB Form 216. Defendant’s Requests for Production—Uninsured/Underinsured Motorist Cases
9-013 PB Form 217. Interrogatories—Civil Actions Alleging Personal Injury—Medicare Enrollment, Eligibility and Payments
9-014 PB Form 218. Defendant’s Interrogatories—Medical Negligence
9-015 PB Form 219. Defendant’s Requests for Production—Medical Negligence
9-016 PB Form 220. Plaintiff’s Interrogatories—Medical Negligence—Health Care Provider
9-017 PB Form 221. Plaintiff’s Interrogatories—Medical Negligence—Hospital and/or Medical Group
9-018 PB Form 222. Plaintiff’s Request for Production—Medical Negligence—Health Care Provider
9-019 PB Form 223. Plaintiff’s Requests for Production—Medical Negligence—Hospital and/or Medical Group
Chapter 10 Experts
10-001 Experts, Overview
10-002 Sample Expert Disclosure, Medical Malpractice
10-003 Sample Disclosure of Treating Physicians and Defendant, Medical Malpractice
10-004 Request for Expert’s File, Practice Book § 13-4 (b) (3)
10-005 Motion to Determine Reasonable Expert Fee, Practice Book § 13-4 (c) (2)
10-006 Disclosure of Previously Disclosed Expert, Practice Book § 13-4 (e)
10-007 Motion for Modification of Schedule for Expert Discovery, Practice Book § 13-4 (g) (4)
Chapter 11 Requests For Admission, In General
11-001 Requests for Admission, Overview
11-002 Admission of Facts and Execution of Writings, Practice Book § 13-22
11-003 Requests for Admission
11-004 Notice of Filing Requests for Admission
11-005 Answers and Objections to Requests for Admission, Practice Book § 13-23
11-006 Extension of Time, Motion for
11-007 Motion to Determine Sufficiency of Answers and/or Objections to Requests for Admission
11-008 Affidavit Re: Attempt to Resolve Differences Concerning Objections to Discovery
11-009 Effect of Admission, Practice Book § 13-24
11-010 Motion to Withdraw or Amend Admissions
11-011 Expenses on Failure to Admit, Practice Book § 13-25
11-012 Motion for Order of Expenses on Defendant’s Failure to Admit
Chapter 12 Depositions
12-001 Depositions, Overview
12-002 Depositions, In General, Practice Book § 13-26
12-003 Motion for Leave to Depose Prisoner
12-004 Notices of Deposition, Practice Book § 13-27 (a) Through (e)
12-005 Notice of Deposition, In General, Practice Book § 13-27 (a)
12-006 Notice of Expert Deposition, Sample
12-007 Notice of Deposition, Deponent’s Name Unknown, Practice Book § 13-27 (a)
12-008 Notice of Videotaped Deposition, Practice Book § 13-27 (f)
12-009 Notice of Deposition, Production of Documents and Tangible Things, Practice Book § 13-27 (g)
12-010 Notice of Deposition, Person Most Knowledgeable, Practice Book § 13-27 (h)
12-011 Persons Before Whom Depositions Taken, Practice Book § 13-28
12-012 Procedure for Compelling the Deposition of or Discovery from a Nonresident
12-013 Subpoenas, Practice Book § 13-28
12-014 Subpoenas, Forms
12-015 Capias, Practice Book § 13-28 (f)
12-016 Preservation of Testimony of a Witness
12-017 Place of Deposition, Practice Book § 13-29
12-018 Deposition Procedure, Practice Book § 13-30
12-019 Errata and Signing
12-020 Written Questions in Lieu of Participating in Oral Examination, Practice Book § 13-30 (B)
12-021 Use of Depositions in Court Proceedings, Practice Book § 13-31
12-022 Stipulations Regarding Discovery and Deposition Procedure, Practice Book § 13-32
Chapter 13 Jury Trials
13-001 Jury Trials, Overview
13-002 Application for Admission Pro Hac Vice
13-003 Objection to Application for Admission Pro Hac Vice
13-004 Motion for Continuance
13-005 Juror Information Form
13-006 Motion for “Unity of Interest” Determination
13-007 Motion for Alternate Exercise of Peremptory Challenges
13-008 Objection to Motion for Bifurcation of Trial
13-009 Objection to Motion to Preclude Duplicative Expert Witnesses
13-010 Motion in Limine, Collateral Source, Current Residence, Activities Prior to Incident, Expert Testimony
13-011 Plaintiff’s Verdict Form
13-012 Defendant’s Verdict Form
13-013 Satisfaction of Judgment
13-014 Motion to Set Aside Verdict
13-015 Objection to Motion to Set Aside Verdict
13-016 Objection to Bill of Costs
13-017 High/Low Agreement Letter
Chapter 14 Settlement/Probate
14-001 Overview
14-002 Letter Requesting Lien Documentation in Anticipation of Settlement
14-003 Standard Release
14-004 Standard Release, Wrongful Death
14-005 Client Release to Attorney to Accept Settlement
14-006 Settlement Statement
14-007 Hold Harmless Agreement
14-008 Application to Compromise