Form 206. Plaintiff’s Requests for Production—Premises Liability

Plaintiff’s Requests for Production—Premises Liability

No. CV-

: SUPERIOR COURT

(Plaintiff)

: JUDICIAL DISTRICT OF

VS.

: AT

(Defendant)

: (Date)

The Plaintiff hereby requests that the Defendant provide counsel for the Plaintiff with copies of the

documents described in the following requests for production, or afford counsel for said Plaintiff the

opportunity or, if necessary, sufficient written authorization, to inspect, copy, photograph or otherwise

reproduce said documents. The production of such documents, copies or written authorization shall

take place at the offices of

on

(day),

(date) at

(time).

In answering these production requests, the Defendant(s) are required to provide all information

within their possession, custody or control. If any production request cannot be answered in full, answer

to the extent possible.

(1) A copy of the policies, procedures, contracts, invoices, or records identified in response to

Interrogatories #4 and #5.

(2) A copy of the report identified in response to Interrogatory #7.

(3) A copy of any written complaints identified in Interrogatory #11.

(4) A copy of declaration page(s) evidencing the insurance policy or policies identified in response

to Interrogatories numbered

and

.

(5) A copy of any nonprivileged statement, as defined in Practice Book Section 13-1, of any party

in this lawsuit concerning this action or its subject matter.

(6) A copy of each and every recording of surveillance material discoverable under Practice Book

Section 13-3 (c), by film, photograph, video, audio or any other digital or electronic means, of any

party to this lawsuit concerning this lawsuit or the subject matter thereof, including any transcript of

such recording.

(7) A copy of any photographs or recordings, identified in response to Interrogatory #13.

py of each and every recording of surveillance material discoverable under Practice Book

Section 13-3 (c), by film, photograph, video, audio or any other digital or electronic means, of any

party to this lawsuit concerning this lawsuit or the subject matter thereof, including any transcript of

such recording.

(7) A copy of any photographs or recordings, identified in response to Interrogatory #13.

(8) A copy of any written lease(s) and any amendments or extensions to such lease(s) for the

premises where the Plaintiff claims to have been injured in effect at the time of the Plaintiff’s injury

between you and the person or entity identified in Interrogatory #2.

(9) A copy of any written contract or agreement regarding the maintenance and inspection of the

premises where the Plaintiff claims to have been injured in effect at the time of the Plaintiff’s injury

between you and the person or entity identified in Interrogatory #3.

PLAINTIFF,

BY