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. (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