Curry v. Burns
In Curry v. Burns, 225 Conn. 782, 801, 626 A.2d 719 (1993), the Court limited the "application of the rule to the following five scenarios:
(1) denial of separate counts of a complaint;
(2) denial of separate defenses pleaded as such;
(3) denial of separate legal theories of recovery or defense pleaded in one count or defense, as the case may be;
(4) denial of a complaint and pleading of a special defense;
(5) denial of a special defense, raised under a general denial, that had been asserted as the case was tried but that should have been specially pleaded." Id.