Connecticut Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: Request for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I am writing to you as the plaintiff in the aforementioned case to request a Protective Order, Motion to Quash, and to object to the recently served Notice of Deposition Ducks Cecum. I believe that these actions are necessary to protect my rights and interests in this matter. 1. Plaintiff's Motion for Protective Order: In consideration of the sensitive nature of the information being sought through discovery, I respectfully request that the court issue a Protective Order to prevent the unnecessary disclosure or dissemination of confidential and privileged materials. Such an order would ensure the protection of personal, proprietary, and confidential information belonging to me or any third parties involved in this case. 2. Plaintiff's Motion to Quash: I hereby move to quash the Notice of Deposition Ducks Cecum, as I believe the deposition is unduly burdensome, oppressive, and not reasonably calculated to lead to the discovery of admissible evidence. The nature of the requested documents, their relevance to the case, and the time and effort required to collect and produce them all contribute to the undue burden imposed upon me. 3. Objection to Notice of Deposition Ducks Cecum: Considering the aforementioned reasons, I respectfully object to the Notice of Deposition Ducks Cecum. I firmly believe that the deposition sought by the opposing party is oppressive, irrelevant, and purely intended to harass, annoy, or impose undue burden. As such, it does not comply with the rules of civil procedure and should not be permitted. If necessary, I am prepared to present supporting legal authorities and arguments to strengthen my request for a Protective Order, Motion to Quash, and Objection to the Notice of Deposition Ducks Cecum. Please consider this letter as my formal notification, and kindly reply acknowledging the receipt of this correspondence. Thank you for your attention to this matter. I trust that a fair and just resolution will be reached promptly. Yours sincerely, [Your Name]
Connecticut Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Duces Tecum
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How to fill out Connecticut Sample Letter For Plaintiff's Motion For Protective Order, Motion To Quash, Objection To Notice Of Deposition Duces Tecum?
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FAQ
Although it is prohibited to mix lawyer funds with client funds, Rule 1.15 of the Connecticut Rules of Professional Conduct permits a lawyer's own funds to be placed in a trust account for the sole purposes of paying financial institution service charges on the account or to obtain a waiver of fees and service charges ...
Rule 1.10 - Imputation of Conflicts of Interest: General Rule (a) While lawyers are associated in a firm, none of them shall knowingly represent a client when any one of them practicing alone would be prohibited from doing so by Rules 1.7, 1.8(c), or 1.9, unless the prohibition is based on a personal interest of the ...
Regulatory Scheme: Connecticut Rule of Professional Conduct 7.4A permits attorneys to state or imply that they are certified specialists where certification is granted "by a board or other entity which is approved by the Rules Committee of the Superior Court." [Rule 7.4A].
Rule 4.2 of the Rules of Professional Conduct provides that ?[i]n representing a client, a lawyer shall not communicate about the subject of the representation with a party the lawyer knows to be represented by another lawyer in the matter, unless the lawyer has the consent of the other lawyer or is authorized by law ...
Rule 7.1. A lawyer shall not make a false or misleading communication about the lawyer or the lawyer's services.
Rule 1.7 - Conflict of Interest: General Rule (a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest.
Motions for orders of compliance (or motions to compel, as they are frequently called) are governed by Section 13-14 of the Connecticut Practice Book. As in many jurisdictions, judges in Connecticut generally prefer that parties and their counsel resolve discovery disputes without the need for judicial intervention.
