Conn. Practice Book Form 222

The Plaintiff(s) hereby request(s) that the Defendant ______________ (Defendant Health Care

Provider’s Name) 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 ____________ 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.

Definition: ‘‘Y ou’’ or ‘‘your’’ shall mean the Defendant to whom these interrogatories are directed,

except that if the Defendant has been sued as the representative of the estate of a decedent, ward,

or incapable person, ‘‘you’’ or ‘‘your’’ shall also refer to the Defendant’s decedent, ward or incapable

person unless the context of an interrogatory clearly indicates otherwise.

(1) All documents (excluding privileged documents, such as attorney-client, work product, and peer

review documents) that you know of, possess, or have power to obtain, concerning the Plaintiff’s care,

scheduling, appointments, treatment, evaluation, diagnosis, consultation or referral to others including

but not limited to:

(a) All documents normally maintained as part of a patient’s designated health record;

(b) Office management records including jackets, file covers, face sheets, transmittal documents for

any requests for studies or consultations, and/or transportation records;

(c) Nursing notes;

(d) Hospital records;

(e) Laboratory records;

(f) Testing records;

(g) Radiology requisitions, reports, images/studies (lossless images), and audio recordings of radiology reviews;

(h) Notes, sticky notes or written markings;

(i) Pharmacy medication records;

(j) Automated medication dispensing system records;

No. CV- : SUPERIOR COURT

(Plaintiff): JUDICIAL DISTRICT OF

VS. : AT

(Defendant): (Date)

(k) Any images/photographs taken during treatment or pathological examination;

(l) Pathology reports;

(m) Drafts and/or audio recordings of pathology reports;

(n) Quality improvement documents related to root cause analysis;

(o) Documents provided in connection with a peer review;

(p) Intradepartment transportation records;

(q) Laboratory test results;

(r) Documents and communications concerning the Plaintiff and the allegations in the Complaint; and

(s) Investigations or reports concerning the incident that is the subject of this lawsuit.

COMMENT:

Where privilege is claimed, counsel shall follow the relevant Practice Book rule(s). This request contemplates production of

all medical records and documents, not limited to the treatment related to the allegations in the Complaint, subject to the Plaintiff

providing a Health Insurance Portability and Accountability Act compliant authorization if necessary.

(2) Y our current curriculum vitae.

(3) Each document identified in response to Interrogatory #18.

(4) A copy of the declaration page(s) of each insurance policy identified in response to Interrogatories

#19 and #20.

(5) If the answer to Interrogatory #21 is in the affirmative, a copy of the complete policy contents of

each insurance policy identified in response to Interrogatories #19 and #20.

(6) Each nonprivileged statement identified in response to Interrogatories #25 and #27.

(7) 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.

PLAINTIFF,

BY____________________________

CERTIFICATION

I certify that a copy of this document was or will immediately be mailed or delivered electronically

or non-electronically on ( date) _______ to all attorneys and self-represented parties of record and that

written consent for electronic delivery was received from all attorneys exempt from e-filing and self-represented parties of record who received or will immediately be receiving electronic delivery.

Name and address of each party and attorney that copy was or will immediately be mailed or

delivered to*

*If necessary attach additional sheet or sheets with the name and address which the copy was or

will immediately be mailed or delivered to.

_________________________________________________________________________________

Signed (Signature of filer) Print or type name of person signing Date Signed

_________________________________________________________________________________

Mailing address (Number, street, town, state and zip code) or Email address, if applicable Telephone number

HISTORY—2026: In the first sentence of the certification, “exempt from e-filing” was added after “from all attorneys.”

COMMENTARY—2026: The changes to this form are consistent with the changes to the proof of service language in Section

10-14 (a).