In Renton v. Kone, Inc., No. HHDCV146050141S (Conn. Super. Ct. Sept. 26, 2014), two former employees of defendant brought a bill of discovery complaint in contemplation of an action challenging their terminations. The petition was brought under a Connecticut procedure that allows limited pre-suit discovery to ascertain the viability of claims. The dispute arose out of an anonymous call to the company’s CEO and a report to its hotline concerning theft and other improper business practices in the company’s Hartford office. The company’s General Counsel directed its Compliance Director and a Human Resources Director to conduct an internal investigation, which concluded that the Hartford office had a “fractured and polarized work force,” that one of the petitioners, the office’s branch manager, “lacked the judgment and ability to effectively manage and lead the office,” and that the branch manager and the other petitioner “had created a dysfunctional and hostile work environment.” The petitioners stated an intent to bring claims for defamation and negligent infliction of emotional distress, and claimed that various reasons the company provided for the terminations were baseless. The court found that the petitioners did not satisfy the required standard of providing detailed facts establishing probable cause to bring the potential causes of action. It also noted the privileged nature of internal investigations led by company lawyers, relying heavily on Upjohn Co. v. United States, 449 U.S. 383, 101 S. Ct. 677 (1981), and In re Kellogg Brown & Root, Inc., 756 F.3d 754 (D.C. Cir. 2014). Accordingly, it denied the bill of discovery.