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Library of Connecticut Employment Law Forms

  • ID: 2112765
  • January 2012
  • Region: United States
  • 910 Pages
  • ALM Media, LLC
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Library ofConnecticut Employment Law Forms is a comprehensive set of over 140 forms used for every aspect of an employment matter, from pre-judgment remedies to post-litigation issues.
The forms in this book are efficiently divided into those used in federal court, those used in state court, and CHRO forms which are used in both state and federal court.

These complaints are presented in book and electronic format on a CD-ROM, which may be opened in MS Word and in an online format. These forms may be edited to suit the unique facts and circumstances of each case. Use these forms as your templates and save valuable time drafting and typing. In addition, online access will be available at no extra cost.

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FEDERAL COURT
Chapter 1. Pre-Litigation
1-001 Breach of Contract -- Application for Pre-Judgment Remedy and Preliminary Injunction
1-002 Breach of Contract -- Memo in Support of Motion for Preliminary Injunction and Pre-Judgment Remedy
1-003 Breach of Contract -- Memo of Law in Response to Defendant's Objections to Prejudgment Remedy Ruling and Order

Chapter 2. Complaints
2-001 Complaint -- Race Discrimination -- Federal Court
2-002 Complaint --Age Discrimination -- Federal Court
2-003 Breach of Contract -- Change of Control Provisions -- Federal Court
2-004 Complaint -- Race Discrimination -- Federal Court
2-005 Amended Complaint
2-006 Amended Complaint -- Race Discrimination
2-007 Amended Complaint -- Pregnancy Discrimination
2-008 Sixth Amended Complaint --Pregnancy and Sex Discrimination

Chapter 3. Pending Litigation
3-001 Rule26(a) Initial Disclosures
3-002 Plaintiff's Memo in Opposition to Defendant's Partial Motion to Dismiss
3-003 Requests for Admission --Pregnancy and Sex Discrimination
3-004 Second Requests for Admission -- Pregnancy and Sex Discrimination
3-005 Plaintiff's Memo in Support of Motion to Compel --Wrongful Discharge
3-006 Plaintiff's Objection to Defendant's Motion to Compel
3-007 Plaintiff's Reply Memo in Support of Motion for Protective Order

Chapter 4. Discovery
4-001 Notice of Deposition Federal Court
4-002 Re-Notice Deposition Rule30(b)(6)
4-003 Plaintiff's First Interrogatories and Requests for Production (Federal)
4-004 Plaintiff's First Interrogatories and Requests for Production -- Pregnancy and Sex Discrimination
4-005 Request for Production
4-006 Plaintiff's Second Request for Production -- Pregnancy and Sex Discrimination
4-007 Plaintiff's Third Request for Production -- Pregnancy and Sex Discrimination

Chapter 5. Summary Judgment
5-001 Memo of Law in Opposition to Motion for Summary Judgment -- Pregnancy and Sex Discrimination
5-002 Plaintiff's Memo of Law in Opposition to Defendant's Motion for Summary Judgment -- Race Discrimination
5-003 Summary Judgment Opposition
5-004 Summary Judgment Opposition Memo -- Pregnancy Discrimination
5-005 Rule 56(a)(2) Statement of Disputed Facts -- Pregnancy and Sex Discrimination
5-006 Joint Pre-Trial Memo -- Pregnancy Discrimination

Chapter 6. Trial
6-001 Proposed Jury Instructions -- Pregnancy and Sex Discrimination

STATE COURT

Chapter 7. Pre-Litigation
7-001 Application for Prejudgment Remedy --Intentional or Negligent Infliction of Emotional Distress
7-002 Complaint -- Intentional or Negligent Infliction of Emotional Distress

Chapter 8. Complaints
8-001 Order for Prejudgment Remedy Against Defendant
8-002 Complaint -- Wrongful Discharge
8-003 Amended Complaint -- Wrongful Discharge
8-004 Complaint -- Disability Discrimination
8-005 Amended Complaint -- Disability Discrimination
8-006 Second Amended Complaint --Disability Discrimination
8-007 Complaint --Wrongful Termination Section 31-51q
8-008 Amended Complaint --Wrongful Termination Section 31-51q
8-009 Complaint -- Breach of Contract
8-010 Amended Complaint -- Breach of Contract
8-011 Complaint -- Defamation
8-012 Amended Complaint -- Defamation
8-013 Complaint -- Sexual Harassment
8-014 Complaint -- Section 31-51q Public Policy Violation
8-015 Amended Complaint- Section 31-51q Public Policy Violation

Chapter 9. Pending Litigation
9-001 Plaintiff's Response to Request to Revise -- Sexual Harassment
9-002 Notice of Deposition
9-003 Plaintiff's First Set of Interrogatories and Request for Production --Breach of Contract

Chapter 10. Discovery
10-001 Confidentiality Order -- Breach of Contract
10-002 Motion to Compel -- Breach of Contract
10-003 Opposition to Motion for Discovery of Medical Records -- Memo
10-004 Memo of Law in Opposition to Defendant's Motion for Protective Order

Chapter 11. Summary Judgment
11-001 Plaintiff's Memo in Opposition to Defendant's Motion to Strike -- Section 31-51q --Free Speech Claim --Public Policy Claim
11-002 Memo of Law in Opposition to Motion for Summary Judgment --Wrongful Termination --Section 31-51q

Chapter 12. Trial
12-001 Motion in Limine
12-002 Request to Charge -- Sexual Harassment
12-003 Supplemental Request to Charge -- Sexual Harassment
12-004 Jury Interrogatories

Chapter 13. Post-Trial
13-001 Defendant's Post-Trial Brief --Defense Against Enforcement of Non-Compete Clause
13-002 Plaintiff's Brief in Support of Prejudgment Interest
13-003 Plaintiff's Reply to Defendant's Objection to Plaintiff's Claim for Interest
13-004 Memo in Support of Award for Attorney Fees Costs and Punitive Damages
13-005 Plaintiff's Memo for Attorney Fees, Punitive Damages and Offer of Judgment
13-006 Plaintiff's Memo in Support of Future Lost Wages Damages
13-007 Plaintiff's Memo of Law in Opposition to Defendant's Post Verdict Motions
13-008 Plaintiff's Omnibus Response to Defendant's Motion for Judgment Notwithstanding the Verdict, Motion to Set Aside the Verdict, Motion for a New Trial and Motion for Remittitur
13-009 Plaintiff's Omnibus Response to Defendant's Motion for Judgment Notwithstanding the Verdict, Motion for a New Trial and Motion for Remittitur

CHRO - State & Federal

Chapter 14. Complaints & Affidavits
14-001 Age and Disability Discrimination -- CHRO Affidavit
14-002 CHRO Amended Complaint-Sexual Harassment
14-003 CHRO Complaint -- Sexual Harassment
14-004 CHRO Complaint Disability

Chapter 15. Replies
15-001 Pregnancy Discrimination --CHRO Reply
15-002 Race Discrimination -- CHRO Reply
15-003 Sexual Harassment -- Hostile Work Environment -- Reply to Position Statement

Chapter 16. Misc. Forms
16-001 CHRO -Important Information When Filing a Claim
16-002 CHRO -- Appearance
16-003 CHRO -- Sample Affidavit
16-004 CHRO -- Complaint (fillable)
16-005 CHRO -- Initial Filing Cover Letter
16-006 CHRO -- Withdrawal Form
16-007 CHRO -- Release of Jurisdiction
16-008 EEOC -- Charge of Discrimination Form
16-009 EEOC -- Withdrawal Form

MISC.

Chapter 17. Demand Letters
17-001 Demand Letter -- Age Discrimination
17-002 Demand Letter --Disability Discrimination
17-003 Demand Letter -- ERISA
17-004 Demand Letter -- Pregnancy Discrimination
17-005 Demand Letter -- Sexual Harassment

Chapter 18. Authorizations
18-001 Authorization for Employment Information
18-002 Authorization Personnel File
18-003 Authorization HIPAA Medical Records
18-004 Authorization Disability Records

Chapter 19. Misc. Cover Letters & Forms
19-001 Notice Re Requests for Admission State Court
19-002 Expert Witness Disclosure Preliminary -- Federal Court
19-003 Expert Witness Disclosure --Federal Court
19-004 Expert Witness Disclosure -- State Court
19-005 Letter to State Marshall for Service of Summons and Complaint
19-006 Letter Regarding Deposition and Errata Sheet
19-007 Application to Confirm Arbitration Award
19-008 Subpoena Duces Tecum
19-009 Certificate of Closed Pleadings -- State Court
19-010 Claim for Jury -- State Court
19-011 AAA -- Demand for Arbitration
19-012 AAA -- Answering Statement and Counterclaim
19-013 AAA -- Demand Cover Sheet

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Joseph D. GarrisonGarrison, Levin-Epstein, Chimes, Richardson & Fitzgerald has long been recognized as the pre-eminent law firm in the state representing individuals in employment disputes. The firm has litigated many of the landmark cases in the employment field in Connecticut and won some of the largest verdicts in the history of the state.
Joseph D. Garrison founded the law firm in 1975. From the beginning of his career, he has represented individuals. Employment law became an important part of his activities, and after some early successes he has concentrated his practice in this field. Mr. Garrison has tried numerous employment cases to conclusion before juries, as well as before arbitrators in arbitration proceedings. He is experienced in the federal and state trial courts of Connecticut.
Since 2003, Mr. Garrison has increasingly acted as a mediator and an arbitrator. He is a panel member on the American Arbitration Association's selective list of mediators and arbitrators. His experience in these procedures has further enhanced his ability to represent clients at all levels of employment in negotiations and other settlement processes.
The year 2007 will be the 20th consecutive year that Mr. Garrison has been listed in The Best Lawyers In America. Placement in Best Lawyers results from peer selection and represents the top 1% of lawyers in the particular listed fields. In addition, Mr. Garrison was selected as a Connecticut Super Lawyer, and within that group he earned a spot in the top 50 lawyers in the state. Because of his jury trial work, he has also been selected to the American Board of Trial Advocates, an honorary group in which he is the only lawyer selected in Connecticut who represents employees in employment matters.
Mr. Garrison has been writing a monthly column for the Connecticut Law Tribune since 2003, concentrating on issues in arbitration law and procedure. He contributed a chapter to Connecticut's Mediation Practice Book on mediation from the employee's perspective. He has acted as a book reviewer for works on alternate dispute resolution, arbitration, and jury instructions for employment litigation.
Mr. Garrison is also a nationally-known speaker. He has spoken annually at various seminars, including New York University Law School's employment law workshop for federal judges, the National Employment Lawyers Association's (NELA) conventions, and the Law Education Institute seminar for employment law. He has also spoken at many American Bar Association annual meetings and seminars, and is a frequent lecturer in Connecticut.

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