Form 215. Plaintiff’s Requests for Production—Uninsured/Underinsured Motorist Cases

Plaintiff’s Requests for Production—Uninsured/Underinsured Motorist Cases No. CV- : SUPERIOR COURT (Plaintiff) : JUDICIAL DISTRICT OF VS. : AT (Defendant) : (Date) The Plaintiff(s) hereby request(s) that the Defendant provide counsel for the Plaintiff(s) with copies of the documents described in the following requests for production, or afford counsel for said Plaintiff(s) 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 authorizations shall take place at the offices of not later than sixty (60) days after the service of the Requests for Production. In answering these production requests, the Defendant is required to provide all information within its possession, custody or control. If any production request cannot be answered in full, answer to the extent possible. (1) A copy of the declarations page and complete policy for each insurance policy referred to in the allegations against you in the Complaint and for any other policy of insurance in effect on the date of the incident, by which you provided uninsured/underinsured motorist coverage with regard to any person or vehicle involved in the incident that is the subject of this action. (2) Copies of all documents and records regarding the existence of or the lack of insurance on the alleged tortfeasor(s) or the motor vehicle operated by the alleged tortfeasor(s), his, her, its or their agent, servant and/or employee, at the time of this incident, including but not limited to reservations of rights letters and letters about declination of coverage. (3) A copy of any written request by any insured for a lesser limit of uninsured/underinsured motorist coverage than the amount equal to their limits for liability imposed by law, under the policy or any earlier policy of which the policy was a renewal, extension, change, replacement, or superseding policy. (4) Any copy of any nonprivileged statement, as defined in Practice Book Sections 13-1 and 13-3 (b), of any party in this action concerning this action or its subject matter. (5) 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 action or the subject matter thereof, including any transcript of such recording. (6) A copy of any photographs or recordings identified in response to Interrogatory #11. PLAINTIFF, BY