1E9Ct5D

“Statements” include both written and recorded materials, see Practice Book §13-1.Thus, unless protected by another recognized privilege (such as one’s own attorneyclientprivilege), all party statements – not just the requesting party’s own priorstatements -- are discoverable. See § 13-3(b). See Winot v. Dragon, 1995 WL 107321(Conn. Super. 1995); see also Matos v. Allstate Ins. Co., 2008 WL 5481711, at *1(Conn. Super. 2008). In addition, Connecticut courts favor production ofcontemporaneous eyewitness statements, see Decossard v. Pate, 1995 WL 79975(Conn. Super. 1995); Lopez v. Transportation General, Inc., 1994 WL 146832 (Conn.Super. 1994); and have, in some cases, ordered production even where the investigatorobtains the nonparty statement at the direction of counsel. See Crespo v. Marchand,2010 WL 1496331*2 (Conn. Super. 2010) (production ordered of nonparty statementtaken by investigator at counsel’s direction).3. Does your state recognize a self-critical analysis privilege?Likely no.Connecticut has no statutory self-critical analysis privilege, and the few State trial courtswhich have addressed this have mostly declined to recognize a common law self-criticalanalysis privilege. See Office of Consumer Counsel v. Dep't of Pub. Util. Control, 44Conn. Supp. 21, 665 A.2d 921(Conn. Super. 1994); see also Caccavale v. Ne. Utilities,No. CV 90-0377190S, 1994 WL 411315 (Conn. Super. 1994). In one case, theassertion of this privilege (along with others) was not rejected out of hand, see Dotsonv. Hartford Roman Catholic Diocesan Corp., 2011 WL 1021745*7 (Conn. Super. 2011),but instead was to be reviewed on a document-by-document basis through a privilegelog, id. Federal Courts within Connecticut have been somewhat more receptive to thisasserted privilege, see Miller v. Praxair, Inc., 2007 WL 1424316*3 (D. Conn. 2007)(precluding disclosure based upon Second Circuit law); but see United States v. DexterCorp., 132 F.R.D. 8 (D. Conn. 1990).