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Library of Connecticut Personal Injury Forms

Joshua D. Koskoff, Sean K. McElligot

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$295.00
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ALL NEW 2nd EDITION!

This Second Edition of the Library of Connecticut Personal Injury Forms has been updated to reflect the changes to the Practice Book that went into effect on January 1, 2014. Over 165 model documents for all types of PERSONAL INJURY cases, from intake to final disposition. Use model documents created, tested and honed by attorney-experts. The collection includes forms for: auto negligence, medical malpractice, premises liability, product 

Over 730+ pages of model forms created, tested and honed by attorney-experts at the prestigious and respected Bridgeport law firm of KOSKOFF, KOSKOFF & BIEDER, edited by Joshua D. Koskoff, and Sean K. McElligott.



Use the Library of Connecticut Personal Injury Forms to simplify...
-AUTO NEGLIGENCE
-MEDICAL MALPRACTICE
-PREMISES LIABILITY
-PRODUCT LIABILITY
-WRONGFUL DEATH and MORE

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  • Availability: Available
  • Brand: The Connecticut Law Tribune
  • Product Type: Books
  • Edition: 2
  • Page Count: 653
  • ISBN: 978-1-57625-729-6
  • Pub#/SKU#: QBKPIF14
  • Pub Date: 07/24/2014
  • Volume(s): 1
  • CDs: 1

Author Image
  • Joshua D. Koskoff
Joshua Koskoff represents the third generation of Koskoffs at Koskoff Koskoff & Bieder. Known for his dedication, compassion and creativity, Josh brings all of his cases a fresh and unique perspective. He believes strongly in the role of the law as an agent to improve his client’s lives. His personal concern for the welfare of each of his clients has won their trust and devotion. Josh has won landmark verdicts in courtrooms throughout Connecticut on behalf of clients who have been permanently harmed or killed because of medical malpractice. His understanding of the significance of pleadings, motions and other forms covered in this book comes equally from experiencing their value in court as it does to the daily practice of law. In addition to trying complicated cases Josh has handled numerous other medical malpractice cases that have resulted in substantial settlements on behalf of his clients. Like the verdicts he has obtained, these settlements have helped his clients to have better and more satisfying lives. Josh has also participated in other cases that do not involve bad medical care. For example, he represented a nurse badly injured in a well-publicized med-evacuation crash and obtained a multi-million dollar settlement on her behalf. Josh also participated in Trial Lawyers Care and provided pro bono legal services to families that lost love ones on 9/11. Josh is the recipient of the Connecticut Law Tribune’s “new leader of the law” award, editor of the first CT Personal Injury Forms book, and sits on the Board of Connecticut Legal Services, an organization dedicated to helping Connecticut’s poorer citizens gain legal representation in civil cases. He is a frequent lecturer on matters related to trial practice, both locally and nationally.


Author Image
  • Sean K. McElligot
Sean K. McElligott, a graduate of Yale Law School, is an experienced trial and appellate lawyer and a member of the law firm of Koskoff, Koskoff & Bieder. Sean has obtained numerous record-setting verdicts, has published numerous articles on various legal topics, and is regularly consulted by the media to explain legal matters of public concern. Sean maintains an active civil rights and pro bono practice through the Civil Pro Bono Panel of the United States District Court and the Connecticut Pro Bono Network. He tried a recent pro bono civil rights case to verdict in federal court on behalf of a Connecticut citizen who was beaten by the police. He has also successfully represented the families of mentally ill inmates who died in the custody of the Connecticut Department of Correction.

Sean represented the Guardians Black Police Officers Association against the Bridgeport Police Department in the longest-running employment discrimination case in Connecticut. Sean serves on the board of the Brain Injury Alliance of Connecticut, an organization providing services to brain-injured individuals and their families in Connecticut. He is treasurer of the Connecticut Child Justice Foundation an organization that provides legal representation to children in DCF custody facing expulsions, suspensions, and administrative actions, including requests for special education tutors and programs. He is on the Board of Governors of the Connecticut Trial Lawyers Association and serves as a member of the Continuing Legal Education Committee. He is a member of the New Haven County Bar Association Pro Bono Committee. Sean also serves on the editorial board of the Connecticut Law Tribune and is an editor of the publication Medical Malpractice Law and Strategy. He served a two year term as a Commissioner on Connecticut’s Freedom of Information Commission.

Sean is admitted to the bars of Connecticut, Massachusetts, and New York as well as various federal courts and the United States Supreme Court. He is an active member of the American Association for Justice and the Bridgeport and New Haven County Bar Associations. In 2012, Sean was named a “New Leader in the Law” by the Connecticut Law Tribune. He also received the Commitment to Justice Award from In Motion, an organization providing free legal services to indigent women seeking payment of child support.



CHAPTERS OF FORMS:

1 - PRE-LITIGATION
001 Case Intake Form
002 Authorization for Medical Records HIPPA Compliant
003 Authorization to Release Global Employment Info
004 Authorization for Release of Lost Wage Info For Defnite Time Period
005 Authorization for School Records
006 Retainer Agreement - Statutory Fee Structure
007 Retainer Agreement - Statutory Fee Structure - Referred Cas
008 Retainer Agreement - Waiver of Statutory Fee Structure
009 Retainer Agreement - Waiver of Statutory Fee Structure - Referred Case
010 Rejection Letter to Client
011 Rejection Letter to Referring Lawyer
012 Letter to Referring Lawyer Regarding Retainer Agreement and Fee Dist
013 Notice to Defendant Driver
014 Letter of Representation to Insurance Company
015 Letter of Request to Preserve Evidence
016 Notice of UIM Claim
017 Notice to Claims Commissioner Pursuant to Practice Book Section 4-160(b)
018 Notice to Claims Commissioner Regarding Malpractice Suit
019 Statutory Notice for Defective Highway
020 Statutory Notice to Town for Damages Caused by Firefighters

2 - COMPLAINTS
001 Complaint - Motor Vehicle - Rear End Collision
002 Complaint - Motor Vehicle - Bicycle/Parking Lot
003 Complaint - Motor Vehicle - Pedestrian
004 Complaint - Motor Vehicle - Motorcycle Lane Change
005 Complaint - Motor Vehicle - Recklessness - Wrongful Death
006 Complaint - Motor Vehicle - Recklessness - Insurance Company Negligence
007 Complaint - Motor Vehicle - UIM - Speeding - Drunk Driving
008 Complaint - Premises Liability - Fall Down
009 Complaint - Premises Liability - Electrocution - Death
010 Complaint - Premises Liability - Inadequate Security - Rape
011 Complaint - Product Liability - Ladder - Knee Injury
012 Complaint - Product Liability - Lighter - Brain Damage / Burns
013 Complaint - Product Liability - Toy - Eye Injury
014 Complaint - Product Liability - Wood Chipper - Amputation
015 Complaint - Medical Malpractice - Birth Injury - Asphyxia
016 Complaint - Medical Malpractice - Birth Injury - Shoulde Dystocia
017 Complaint - Medical Malpractice - Failure to Diagnose Carotid Artery Dissection
018 Complaint - Medical Malpractice - Apportionment Against Party Brought in by Defendant
019 Complaint - Lead Paint - Connecticut Unfair Trade Practice Act (CUTPA)
020 Complaint - Section 1983 - State Mental Facility - Suicide
021 Complaint - Liability of College for Cheerleading Injury

3 - PENDING LITIGATION
001 Summons
002 Writ of Attachment
003 Letter Requesting Employment Records
004 Letter to Physician Requesting Medical Records
005 Letter Requesting Information Per the Conn. FOIA CGS 1-200
006 Letter Disputing Right of Subrogation Despite Policy Language per 52-225c
007a Letter to Client Regardng Interrogatory Answers
007b Letter to Client Regarding Interrogatory Answers 2
008 Letter Seeking to Resolve Objections to Interrogatories
009 Letter Requesting School Records
010 Expert Disclosue of Treating Physicians
011 Letter Requesting Curriculum Vitae of Opponents' Expert
012 Letter to Client Re: Permission to File an Offer to Compromise
013 Letter of Protection
014 Letter to Department of Administrative Services Requesting Lien Information
015 Motion for Appointment of Guardian Ad Litem

4 - INTERROGATORIES / REQUEST TO ADMIT / PJR
001 Interrogatories - Dram Shop - Service of Alcohol to a Minor
002 Interrogatories Product Liability (Flammable Clothing) Including Request for a "Meta-Data"
003 Interrogatories - Medical Malpractice Surgery Case
004 Interrogatories for Nursing Home Case
005 Interrogatories Regarding Apportionment of Fault by Defendant Healthcare Provider
006 Interrogatories Regarding Death Occurrence of Ferry - Compliance with Coast Guard Regulations
007 Interrogatories for Lead Paint Case
008 Interrogatories Defendant Regarding Surveillance of Plaintiff
009 Defendant Consortium Interrogatories
010 Certification - Notary Page - Attached to Interrogatories
011 Motion for Extension of Time to Answer Interrogatories
001 Interrogatories - Dram Shop - Service of Alcohol to a Minor
012 Motion for Permission to File non-Standard Interrogatories & Request for Production Pursuant to 13-6(b) and 13-0(a) of the Practice Book
013 Affidavit Certifying Attempt at Resolving Objections to Interrogs Pursuant to Prac. Book 13-8
014 Notice of Filing Form Interrogatories
015 Notice of Filing of Objections to Interrogatories
016 Objection to Extension of Time to Answer Interrogatories
017 Practice Book Section 13-14 Motion ofr Order of Compliance Re: Answers to Interrogatories
018 Request for Production of Telephone and E-Mail Records
019 Request for Production of Hospital Protocols in Medical Malpractice Case
020 Objections to Interrogatories - Medical Malpractice Case
022 Objection to Motion for Non-Suit
023 Suppolemental Interrogatories Regarding Employment Relationship Among Co-Defendants
024 Notice of Service of Filing Request to Admit Pursuant to Practice Book &13-22(b)
025 Request to Admit Pursuant to Practice Book 13-22
026 Request to Admit Employment - Agency
027 Motion for Order to Permit Inspection
028 Application for Pre-Judgment Remedy
029 Motion for Pre-Judgment Remedy Disclosure of Property & Assets
030 Order for Hearing & Notice on Pre-Judgment Remedy
031 Order for Pre-Judgment Remedy
032 Sample Affidavit to Accompany Pre-Judgment Remedy
033 Motion to Determine Sufficiency of Defendant Responses to Plaintiff's Requests for Admission

5 - MOTIONS and REQUESTS
001 Motion for Default for Failure to Appear
002 Motion for Default for Failure to Plead
003 Motion to Strike Defendant's Special Defense
004 Reply to Secial Defenses (Denial)
005 Motion to Consolidate Actions Pursuant to Practice Book Section 9-5(b)
006 Motion for Order to Substitute Plaintiff
007 Motion for Order to Substitute Defendant
008 Request to Revise Defendant's Special Defenses of Contributing Negligence
009 Notice of Amended Complaint Pursuant to Practice Book Section 10-59
010 Request for Leave to File Amended Complaint
011 Motion for Protective Order - Ltd 1ME
012 Motion for Partial Protective Order of Plaintiff Psychiatric Records
013 Motion Regarding Service of Process Outside the U.S.
014 Motion for Reassignment Pursuant to Practice Book Section 11-19(b)
015 Motion for Re-argument Pursuant to Practice book 11-12
016 Motion for Reconsideration
017 Motion to Quash or for Protective Order Plaintiff's Prior Consel File
018 Motion for Modification of Scheduling Order (no trial date)
019 Motion to Preclude Defendant's Expert Pursuant to Practice Book Section 13-4
020 Motion for Determination of Expert Fees for Deposition
021 Motion for Protective Order Regarding Length of Deposition Pursuant to 13-5
022 Motion for Immediate Trial Due to Plaintiff's Health
023 Motion to Seal Record
024 Motion for Order of Compliance of Disclosure of Assets
025 Motion to Compel Defenant Deposition
026 Motion to Compel Address of Agent, Servant and/or Employee of Defendant
027 Motion to Set Aside Judgment of Dismissal Pursuant to Practice book 17-4
028 Motion to Terminate Action
029 Motion to Preclude Expert - Insufficient Information
030 Notice of Filing Supplemental Return
031 Withdrawal of Motion for Default

6 - OBJECTION TO MOTIONS / REQUESTS
001 Objection to Request to Revise
002 Objection to Motion to Strike CUPTA Claim
003 Objection to Motion for Reargument and Reconsideraation
004 Objection to Transfer to Complex Litigation Docket
005 Memorandum of Law in Opposition to Defendant Motion to Strike - Medical Expenses Count
006 Objection to Defendant's Request for Leave to File Amended Answer & Spec'l Defenses
007 Objection to Motion for Order of Compliance to Disclose All Medical Records & Bills
008 Objection to Motion for Non-Suit for Failure to Answer Interrogatories
009 Objection to Motion to Dismiss & Memorandum of Law Regarding Good Faith Certificate
010 Objection to Motion of Non-Suit for Failure to Produce Experts for Deposition
011 Objection to Motion for Stay
012 Objection to Motion for Stay of Hearing of Damages
013 Objection to Motion to Dismiss for Failure to Comply With the Order of the Court
014 Objection to Motion for Summary Judgment - Statute of Limitations
015 Objection to Defendant's Motion for Summary Judgment
016 Notice Re: Objections to Defendant's Request to Revise Complaint
017 Partial Objecton to Motion for Extension of Time to Respond to Plaintiff's Offer of Compromise

7 - DEPOSITIONS
001 Application for Commission To Take Deposition of Non-Resident
002 Ofder to Accompany Application for Commission to to Take Deposition of Non-Resident
003 Notice of Videotaped Deposition of Expert
004 notice of Deposition of corporate President to Discover Assets of Company
005 Notice of Deposition of Expert
006 Letter to Deponent With Errata Sheet for Review of transcript
007 Objection to Notice of Deposition to Non-Party
008 Objection to Request for Production Attached to Notice of Deposition
009 Objection to Defendant's Motion to Compel Deposition
010 Motion to Compel Deposition of Expert

8 - TRIAL
001 Application for Admission Pro Hac Vice
002 Objection to Application for Admission Pro Hac Vice
003 Motion for Continuance - Lawyer on Trial
004 Juror Information Form
005 Motion for "Unity of Interest" Determination
006 Juror Response Form
007 Motion for Alternate Exercise of Peremptory Challenges
008 Objection to Motion for Bifurcation of Trial
009 Memo Opposition to Defense Motion to Bifurcate
010 Subpoena to Court for Trial Testimony
011 Subpoena to Court With Documents ("Duces Tecum")
012 Objection to Motion to Quash Subpoena
013 Objection to Motion for Commission to Take Trial Testimony & Motion for Protective Order
014 Objection to Motion to Preclude Duplicative Expert Witnesses
015 Motion in Limine - Collateral Source - Current Residence - Activities Prior to Incident - Expert Testimony
016 Motion Limine - Informed Consent - Prior Settlement - Malpractice Claims Against Experts
017 Plaintiff's Verdict Form
018 Defendant's Verdict Form
019 Satisfaciton of Judgment
020 Motion to Set Aside Verdict
021 Objection to Motion to Set Aside Verdict
022 Objection for Bill of Costs
023 High Low Agreement Letter

9 - SETTLEMENT / PROBATE
001 Letter Requesting Lien Documentation in Anticipation of Settlement
002 Standard Release
003 Standard Release - Wrongful Death
004 Client Release to Attorney to Accept Settlement
005 Settlement Statement
006 Hold Harmless Agreement
007 Application to Compromise
023 High Low Agreement Letter