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Chapter 12 Final

12 i Chapter 12 Motions for Orders of Compliance Andrew M. Zeitlin Introduction .. 12 1 Sanctionable Conduct and Available 12 2 Standard for Imposing Sanctions .. 12 3 Procedure for Resolving Discovery Disputes or Seeking Sanctions .. 12 6 EXHIBIT 12A Defendants Motion to Compel Production of Medical Records .. 12 7 EXHIBIT 12B Defendant s Motion to Compel Plaintiff s Signature on Authorization Forms Required to Obtain Plaintiff s Updated Medical 11 EXHIBIT 12C Plaintiff s Motion to Compel and for Sanctions.

§ 12.3 DISCOVERY & DEPOSITIONS IN CONNECTICUT 12–4 Conn. 1 (2001), the Connecticut Supreme Court set forth a three-part test for imposing sanctions based on the violation of a discovery order, as well as appel-

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