Conn. Practice Book § 13-5 (2026)

Sec. 13-5. —Protective Order Upon motion by a party from whom discovery is sought, and for good cause shown, the judi- cial authority may make any order which justice requires to protect a party from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following: (1) that the discovery not be had; (2) that the discovery may be had only on specified terms and conditions, including a designation of the time or place; (3) that the discovery may be had only by

© Copyrighted by the Secretary of the State of the State of Connecticut SUPERIOR COURT—PROCEDURE IN CIVIL MATTERS Sec. 13-6 a method of discovery other than that selected by the party seeking discovery; (4) that certain matters not be inquired into, or that the scope of the discovery be limited to certain matters; (5) that discovery be conducted with no one present except persons designated by the judicial author- ity; (6) that a deposition after being sealed be opened only by order of the judicial authority; (7) that a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a designated way; (8) that the parties simultaneously file speci- fied documents or information enclosed in sealed envelopes to be opened as directed by the judicial authority; (9) specified terms and conditions relat- ing to the discovery of electronically stored infor- mation including the allocation of expense of the discovery of electronically stored information, tak- ing into account the amount in controversy, the resources of the parties, the importance of the issues, and the importance of the requested dis- covery in resolving the issues. (P.B. 1978-1997, Sec. 221.) (Amended June 20, 2011, to take effect Jan. 1, 2012.) Sec. 13-6. Interrogatories; In General (a) In any civil action, in any probate appeal, or in any administrative appeal where the judicial authority finds it reasonably probable that evi- dence outside the record will be required, any party may serve in accordance with Sections 10- 12 through 10-17 written interrogatories, which may be in electronic format, upon any other party to be answered by the party served. Written inter- rogatories may be served upon any party without leave of the judicial authority at any time after the return day. Except as provided in subsection (d) or where the interrogatories are served electronically as provided in Section 10-13 and in a format that allows the recipient to electronically insert the answers in the transmitted document, the party serving interrogatories shall leave sufficient space following each interrogatory in which the party to whom the interrogatories are directed can insert the answer. In the event that an answer requires more space than that provided on interrogatories that were not served electronically and in a format that allows the recipient to electronically insert the answers in the transmitted document, the answer shall be continued on a separate sheet of paper which shall be attached to the completed answers. (b) Interrogatories may relate to any matters which can be inquired into under Sections 13-2 through 13-5, and the answers may be used at trial to the extent permitted by the rules of evi- dence. In all personal injury actions alleging liabil- ity based on the operation or ownership of a motor 227 vehicle or alleging liability based on the owner- ship, maintenance or control of real property, or in actions claiming a loss of consortium or unin- sured/underinsured motorist coverage benefits, the interrogatories shall be limited to those set forth in Forms 201, 202, 203, 208, 210, 212, 213 and/or 214 of the rules of practice, unless upon motion, the judicial authority determines that such interrogatories are inappropriate or inadequate in the particular action. These forms are set forth in the Appendix of Forms in this volume. Unless the judicial authority orders otherwise, the frequency of use of interrogatories in all actions except those for which interrogatories have been set forth in Forms 201, 202, 203, 208, 210, 212, 213, 214, 218, 220 and/or 221 of the rules of practice is not limited. (c) In all actions alleging medical negligence, the interrogatories shall be limited to: (1) those set forth in Forms 218, 220, and 221 of the rules of practice and contained in the Appendix of Forms in this volume to which no objections shall be allowed and (2) twenty additional interrogato- ries as of right, which may not contain subparts. The party to whom the additional twenty as of right interrogatories are directed may file specific, individual objections to each additional as of right interrogatory. (d) The standard interrogatories in civil actions, including standard and as of right additional inter- rogatories in medical negligence actions, are intended to address discovery needs in most cases in which their use is mandated, but they do not preclude any party from moving for permission to serve such additional discovery as may be nec- essary in any particular case as contemplated by Section 13-2. (e) In lieu of serving the interrogatories set forth in Forms 201, 202, 203, 208, 210, 212, 213, 214, 218, 220, and/or 221 of the rules of practice on a party who is represented by counsel, the moving party may serve on such party a notice of interrog- atories, which shall not include the actual interrog- atories to be answered, but shall instead set forth the number of the Practice Book form containing such interrogatories and the name of the party to whom the interrogatories are directed. The party to whom such notice is directed shall in his or her response set forth each interrogatory immediately followed by that party’s answer thereto. (f) The party serving interrogatories or the notice of interrogatories shall not file them with the court. (g) Unless leave of court is granted, the instruc- tions to Forms 201 through 203 are to be used for all nonstandard interrogatories. (P.B. 1978-1997, Sec. 223.) (Amended June 28, 1999, to take effect Jan. 1, 2000; amended Aug. 24, 2001, to take

© Copyrighted by the Secretary of the State of the State of Connecticut SUPERIOR COURT—PROCEDURE IN CIVIL MATTERS