Connecticut Rules Sample Request for Production of Records

Below is from Davis Sterling 1365.2  with editing to "sound" like a proper discover request.  DO NOT USE THIS WITHOUT CONTACTING YOUR OWN ATTORNEY OR DOING YOUR OWN INDEPENDENT RESEARCH.

(C) Interim financial statements, periodic or as compiled, containing any of the following:

(i) Balance sheet.

(ii) Income and expense statement.

(iii) Budget comparison.

(iv) General ledger. A "general ledger" is a report that shows all transactions that occurred in an association account over a specified period of time.

(D) Executed contracts

(E) vendor or contractor proposals or invoices.

(F) State and federal tax returns.

(G) Reserve account balances and records of payments made from reserve accounts.

(H) Agendas and minutes of meetings of the members, the board of directors and any committees appointed by the board of directors pursuant to Section 7212 of the Corporations Code;

(J) Check registers.

(2)  invoices, receipts and canceled checks  purchase orders approved by the association, credit card statements,  statements for services rendered, and reimbursement requests submitted to the association,§1365.2

(a) Any  pro forma operating budgets, including:

(1) The estimated revenue and expenses on an accrual basis.

(2) Summaries  of the association's reserves accounts

(d) association's policies and practices in enforcing lien rights

 

 association's property, general liability, earthquake, flood, and fidelity insurance policies,  association's insurance policies 1365

(1)  governing documents of the common interest development, including any operating rules, and including a copy of the association's articles of incorporation,

(4) amount of the association' s current regular and special assessments and fees, any assessments levied upon the owner's interest

(5) A copy or a summary of any notice Section 1363  any alleged violation of the governing documents

(6)  preliminary list of defects provided to each member of the association pursuant to Section 1375,

(8)  association's current regular and special assessments and fees which have been approved by the association's board of directors, 1368

1. "Documents" are documents, records, books, papers, contracts, memoranda, invoices, correspondence, notes, studies, reports, photographs, drawings, charts, maps, graphs, other writings, recording tapes, recording discs, mechanical or electronic information or recording elements, and any other "documents" as defined in Rule 34, Fed. R. Civ. P. If a document has been prepared in several versions, or if additional copies have made which are not identical or are no longer identical by reason of subsequent notation or marking of any kind, each nonidentical copy is a separate document.
    
2. "Relating" means referring to, being evidence of, memorializing, or concerning in any way all or any portion of the specified facts or contentions.
    
3. Bank and Savings and Loan Associations or Credit Union Statements, from 2/2006 to present, including:
   
   Any and all Checking Accounts;
   Any and all Savings Accounts;
   Any and all Certificates of Deposit.
   Any and all investment funds;
   Any and all reserve accounts;
   
   usdoj.gov/
   
   
    

all records made or received by officers, directors or anyone on their behalf, namely property managers, in performance of their jobs, Records include papers, memos, notes, letters, books, maps, photographs, and other documentary materials regardless of physical form, including e-mails and databases, asu.edu/

 Ask for a document, and be as specific as you can when describing it. You can't ask them to tell you information, instead you must request a record. For example: "Final, executed contract between vendor and Secretary of State’s Office." black box voting.org