§ 46a-58
- Citation
- § 46a-58
- Parent Document
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Jurisdiction
- Connecticut (state)
- Effective Date
- 2022-04-26
Other Sections in This Document (128)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
- § 46a-58
Full Text
2,686 charsrecords, the complainant filed what she styled as a motion
for a protective order. In that motion, she offered to
provide the branch (1) a summary of her unredacted
treatment history with Coyle, which would be filed
under seal and be reviewable only by the branch’s coun-
sel and expert witnesses, and (2) Coyle’s full treatment
notes, which would be reviewable only by counsel at
Coyle’s office. The complainant attached to the motion
a case summary drafted by Coyle, with certain personal
information regarding the complainant redacted.27 Also
attached was a treatment history listing the dates when
the complainant saw Coyle and the fees she paid for
those office visits.
The branch filed an objection to the motion, con-
tending that the only appropriate remedy for the com-
plainant’s alleged discovery noncompliance was to
preclude her from pursuing anything other than garden-
variety emotional distress damages. The referee sus-
tained the branch’s objection.28
On several occasions during the hearing, the referee
appeared to confirm that she had not unconditionally
ordered the complainant to produce the records at issue
but merely had ruled that the complainant would have
to do so in order to obtain anything more than garden-
variety emotional distress damages. In response to the
branch’s argument that the complainant was not permit-
ted to withhold relevant records, the referee stated:
27
The redacted information does not appear to be relevant to the complain-
ant’s claims, and we perceive nothing in the case summary that would serve
to undermine the complainant’s claim that she suffered emotional distress
as a result of Marco’s conduct and the branch’s failure to adequately respond
to the harassment.
28
In late 2014, the complainant belatedly provided the branch a release
to obtain Coyle’s full treatment notes, and, in early 2015, she gave the branch
what appeared to be Coyle’s original notes. She represented that Coyle had
refused her request to supply the notes for ‘‘ethical’’ reasons and, therefore,
that she had been forced to obtain them via subpoena. The parties filed
additional motions seeking the preclusion or inclusion of the records.
April 26, 2022 CONNECTICUT LAW JOURNAL Page 71