Conn. Practice Book § 13-1

(a) For purposes of this chapter: (1) ‘‘statement’’

means (A) a written statement in the handwriting

of the person making it, or signed, or initialed, or

otherwise in writing adopted or approved by the

person making it; or (B) a stenographic, mechanical, electrical or other recording or a transcription

thereof, which is a substantially verbatim recital

of an oral statement by the person making it and

which is contemporaneously recorded; (2) ‘‘party’’

means (A) a person named as a party in the

action, or (B) an agent, employee, officer, or director of a public or private corporation, partnership,

association, or governmental agency, named as

a party in the action; (3) ‘‘representative’’ includes

agent, attorney, consultant, indemnitor, insurer,

and surety; (4) ‘‘electronic’’ means relating to technology having electrical, digital, magnetic, wireless, optical, electromagnetic, or similar capabilities; (5) ‘‘electronically stored information’’ means

information that is stored in an electronic medium

and is retrievable in perceivable form.

(b) The full text of the definitions and rules of

construction set forth in subsections (c) and (d)

herein is deemed incorporated by reference into

all discovery requests served pursuant to this

chapter and shall preclude any broader definition

of a term defined in subsection (c), but shall not

preclude: (1) the definition of other terms specific

to the particular litigation; (2) the use of abbreviations; or (3) a more narrow definition of a term

defined in subsection (c).

(c) The following definitions apply to all discovery requests:

(1) Communication. The term ‘‘communication’’

means the transmittal of information (in the form

of facts, ideas, inquiries or otherwise).

(2) Document. The term ‘‘document’’ means

any writing, drawing, graph, chart, photograph,

sound recording, image, and other data or data

compilation, stored in any medium from which

information can be obtained either directly or, if

necessary, after translation by the responding

party into a reasonably usable form. A draft or

nonidentical copy is a separate document within

the meaning of this term. A request for production of ‘‘documents’’ shall encompass, and the

response shall include, electronically stored information, as defined in subsection (a) above, unless

otherwise specified by the requesting party.

(3) Identify (with respect to persons). When

referring to a person, to ‘‘identify’’ means to pro -

vide, to the extent known, the person’s full name,

present or last known address, and when referring

to a natural person, additionally, the present or

last known place of employment. Once a person

has been identified in accordance with this subdivision, only the name of that person need be listed

in response to subsequent discovery requesting

the identification of that person.

(4) Identify (with respect to documents or electronically stored information). When referring to

documents or electronically stored information, to

‘‘identify’’ means: to provide, to the extent known,

information about the (A) type of document or

electronically stored information; (B) its general

subject matter; (C) the date of the document or

electronically stored information; and (D) author(s),

addressee(s) and recipient(s).

(5) Identify (with respect to oral communica -

tions). When referring to an oral communication, to ‘‘identify’’ means: (A) to state the date and

place of the oral communication; (B) to identify all

persons hearing, present or participating in the

communication; (C) to state whether the communication was in person, by telephone, or by some

other means or medium; (D) to summarize what

was said by each such person, or provide a transcript if one is available.

(6) Identify (with respect to an act or event).

When referring to an act or event, to ‘‘identify’’

means: (A) to describe the act or event, including

its location and its date; (B) to identify the persons

participating, present or involved in the act or

event; (C) to identify all oral communications

which were made at the act or event identified;

and (D) to identify all documents concerning the

act or event identified.

(7) Person. The term ‘‘person’’ is defined as

any natural person or any business, legal or governmental entity or association.

(8) Concerning. The term ‘‘concerning’’ means

relating to, referring to, describing, evidencing

or constituting.

(9) Y ou. The term ‘‘you’’ means the party or

person to whom a discovery request is directed,

except that: (A) if the party is the representative

of the estate of a decedent, ward, or incapable

person, ‘‘you’’ shall also refer to the party’s decedent, ward or incapable person, unless the context

of the discovery request clearly indicates otherwise; and (B) notwithstanding subsection (b)

above, the propounding party may specify a different definition of the term ‘‘you.’’

(d) The following rules of construction apply to

all discovery requests:

(1) All/Each. The terms ‘‘all’’ and ‘‘each’’ shall

both be construed as all and each.

(2) And/Or. The connectives ‘‘and’’ and ‘‘or’’

shall be construed either disjunctively or conjunctively as necessary to bring within the scope of

the discovery request all responses that might

otherwise be construed to be outside its scope.

(3) Number. The use of the singular form of any

word includes the plural and vice versa.

(4) Gender. Unless the context clearly requires

otherwise, the use of any pronoun or gender-identified form of any word includes both the male and

female genders.