October 21, 2026
Connecticut Court Keeps Litigation Funding Agreements Out of Steffanci v. DFG Trial

A Connecticut state court has joined a long line of precedent holding that a litigant’s communications with a litigation funder are irrelevant and improper subjects of discovery.
On October 19, 2026, the Connecticut Superior Court (Stamford) granted plaintiff Thomas Steffanci’s motion in limine and barred any evidence or argument about his litigation funding agreements at trial in Steffanci v. DFG Trademarks V, LLC (Docket No. FST-CV20-6045998-S). Judge Sheila Ann Ozalis found the agreements irrelevant, prejudicial, and unnecessary for the point defendants wanted to make.
The dispute
Steffanci moved to exclude his funding agreements as irrelevant to the claims and defenses in his upcoming trial, in which he is seeking at least $4 million in contract and fiduciary duty claims against his former employer.
Defendants opposed on two grounds:
- Drafting intent. A central issue is whether the operative contract required amendments to be in writing. Defendants argued the funding agreements contain express written-amendment clauses, i.e., the kind Steffanci allegedly deleted from the LLC Agreement, showing he knew how to require a writing when he wanted one.
- Jury narrative. Defendants said the funding evidence was needed to rebut a misleading picture of a David vs. Goliath story.
The court’s reasoning
The court sided with plaintiff, finding that admitting the funding agreements for either purpose would be prejudicial and irrelevant to the claims and defenses.
The decisive point was cumulativeness. Defendants did not need the funding agreements to show Steffanci knew how to draft a written-amendment requirement, because another contract at issue in the case (and admissible at trial) contains language “virtually identical” to the clauses defendants pointed to in the funding agreements.
The order did not separately address the “corporate family” narrative argument beyond rejecting it as part of the overall relevance and prejudice finding.
Why it matters
The ruling adds to the line of decisions keeping litigation funding agreements away from juries absent a specific, case-tied need. The ruling also further supports the view that courts should not adopt procedural rules requiring the mandatory disclosure of litigation funding. Courts already have inherent power to require such disclosure if appropriate, and they usually find that disclosure is inappropriate.
A few practical points for funders:
- Creative relevance theories still face a prejudice and necessity screen. Defendants offered a contract-interpretation rationale rather than a generic bias attack, and it still failed.
- Cumulative alternatives sink the argument. Where the same point can be made with an ordinary deal document already in evidence, courts have little reason to put the funding agreement in front of the jury.
- “David vs. Goliath” rebuttal arguments are not enough. The court did not accept that funding evidence is needed to balance a sympathetic plaintiff narrative.
- Boilerplate travels. Defendants’ theory rested on standard written-amendment clauses in the funding documents. Funded parties should expect opponents to mine funding agreements for drafting comparisons and be ready with an argument like the one that worked here.
Steffanci v. DFG Trademarks V, LLC, No. FST-CV20-6045998-S (Conn. Super. Ct. Oct. 19, 2026) (Ozalis, J.) (order on Motion in Limine, Entry No. 892.00).
Certum’s Model Brief
Certum Group has published a model brief advising claimants and their counsel on how to resist discovery requests like those Steffanci faced in his Connecticut case. If you are interested in further reading on the discoverability of litigation finance agreements, click here to download the brief.
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