Library of Connecticut Personal Injury Forms and Commentary, 3rd Edition
616Library of Connecticut Personal Injury Forms and Commentary, 3rd Edition
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Overview
The Third Edition of the Library of Connecticut Personal Injury Forms and Commentary has been entirely revamped as compared to the two prior editions. The vision for the current edition went far beyond a compilation of forms. It aims to provide the plaintiff's trial lawyer in Connecticut with an up-to-date practical guide to civil litigation, drawing together the state's relevant Practice Book sections, statutes and case law explained by extensive commentary. This Edition gives the reader a succinct but complete understanding of the life of a civil case from start to finish. Chapters include:
- Pre-Suit Investigation
- Pre-Suit Parties
- Commencement of an Action, General
- Complaint, Generic
- Complaints and Causes of Action
- Pleadings
- Pending Litigation
- Discovery, In General
- Standard Discovery
- Experts
- Requests For Admission, In General
- Depositions
- Jury Trials
- Settlement/Probate
Product Details
ISBN-13: | 9781588526465 |
---|---|
Publisher: | ALM Media Properties, LLC |
Publication date: | 10/28/2022 |
Sold by: | Barnes & Noble |
Format: | eBook |
Pages: | 616 |
Sales rank: | 871,566 |
File size: | 3 MB |
About the Author
Carey B. Reilly
Carey B. Reilly has been with Koskoff Koskoff & Bieder for over thirty-five years. What drives her practice of law is the desire to champion the interests of the unheard, the disenfranchised, the forgotten. Leveling the playing field so the “little guy” can fight the establishment on equal terms is the true power of the law in her view. Carey’s ability to grasp, advance and argue the law in complex factual settings—both at trial and on appeal—is the cornerstone of her successful practice.
For decades, Carey has fought to expand the time limitations a victim has to sue a negligent party. On this issue alone, she has argued eight times before the Connecticut Supreme Court. One such victory was on behalf of a Koskoff client who was unknowingly infected with the AIDS virus thirteen years earlier when she received a contaminated blood transfusion as a teenager. In this landmark decision, Carey won her client the right to sue. Carey has also fought to change the law, which, due to her efforts, now prohibits gender discrimination in jury selection and allows a person to sue for injuries caused by a social host’s negligent service of alcohol to minors.
Since 2006, each year Carey has lectured to hundreds of Connecticut trial lawyers regarding the notable Supreme and Appellate decisions of the prior year. She is also an Editor-in-Chief of, and frequent contributor to, the Connecticut Trial Lawyer Association’s publication FORUM—a thought leadership magazine in the field of trial advocacy that is published twice a year. Carey is a tireless worker and believes in the ability of the law to effect great social change.
Table of Contents
Chapter 1 Pre-Suit Investigation1-001 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