Ind. Allen Cnty. Fam. Local Rule LR02-TR33-11

A. Interrogatories, Request for Production of Documents, and Request for

Admissions shall be tailored to the case in which they are served and numbered

consecutively to facilitate response.

B. The recipient of Interrogatories may file a Motion for Protective Order (T.R.

26(C)) or a Motion to Strike specific interrogatories after fully complying with T.R.

26(F). Any such Motion shall be scheduled for hearing and does not extend the time

for answering unobjectionable Interrogatories.

C. Limit on Interrogatories. In any initial cause of action, a party may serve on

any other party no more than a cumulative total of fifty (50) written interrogatories,

including subparts, without leave of the Court or written agreement of the parties. For

purposes of this rule, each question asked, as well as each subpart, constitutes a

separate interrogatory, regardless of whether that part is logically or factually related to

another subpart. The following interrogatories shall not be counted against the above-set fifty (50) interrogatory limit: (a) general identifying and background information of a

party concerning a party’s full name, address, birth date, education history, employment

history, criminal history, and past lawsuits or claims; (b) interrogatories identifying expert

witnesses, the name and, if known, the address and telephone number of each

individual who may be called as a witness (expert or otherwise), and/or who has

discoverable information; (c) interrogatories asking to identify and describe by category and

location all documents, electronically stored information, photographs, videos, written or

recorded statements and tangible things that may be used to support a party’s claims or

defenses; and (d) interrogatories asking to identify any insurance agreement under which an

insurance business may be liable to satisfy all or part of a possible judgment in the action or to

indemnify or reimburse for payments made to satisfy any judgment.

D. Limits on Request for Production of Documents: In any initial cause of

action, a party may not serve more than twenty-five (25) requests for productions of

documents, including subparts, on another party.

E. Limit on Requests for Admission. In any initial cause of action, a party

may serve on another party no more than a cumulative total of thirty (30) requests for

admission without leave of the Court or written agreement of the parties. For purposes

of this rule, requests seeking admission of the authenticity of a document shall not be

counted against the above-set thirty (30) request limit.

F. Successive Claims for Relief. The discovery limits set forth in this rule shall

reset

(i) upon the dissolution of the parties’ marriage; and (ii) upon the entry of each and

every order granting a modification of custody, modification of parenting time, or

modification of child support; provided, however, that in the case of any such reset, the

limits shall be reduced, and each party shall have the right, without leave of the Court or

agreement of the parties, to serve up to a cumulative total of twenty-five (25)

interrogatories, fifteen (15) requests for production of documents, and/or fifteen (15)

requests for admission.

G. Serving in Excess of the Limit. The Court, for good cause shown, may

increase the discovery limits set forth in this rule. Any party desiring to serve more than

the applicable limits on interrogatories, requests for production of documents, and/or

requests for admission shall, after full compliance with T.R. 26(F), either:

1. File a stipulation of the parties, agreeing to the additional interrogatories,

requests for production of documents, and/or admissions; or

2. If an agreement cannot be obtained, file a written motion requesting

leave of the Court to serve more than the applicable limit on

interrogatories, requests for production of documents, and/or requests

for admission. Any such motion shall set forth the additional proposed

interrogatories, requests for production of documents, and/or requests

for admission, and shall explain their necessity. A party is required to

fully comply with T.R. 26(F) prior to filing any such motion.

Adopted effective November 1, 2021.