Ind. Marion Cnty. Mass Tort Local Rule LR49-TR26 Rule 707

TO DEFENDANTS

A. Service. A plaintiff may serve upon any defendant a Master Set of Interrogatories and

Production Requests tailored appropriately to the type of defendant being served. Plaintiff may serve

the Master Set of Interrogatories and/or Production Requests by letter, which must specifically

reference the File & ServeXpress TID number assigned to the document containing the discovery

requests being served. A single service letter to all defendants may be served and applies to all

defendants, regardless of time of filing their appearance. If plaintiff serves all defendants by letter

prior to the appearance of a defendant, the discovery shall be deemed served on the defendant.

B. Time for responding. In a non-exigent case, defendants shall respond to Plaintiff’s

Master Set of Interrogatories and Production Requests within 120 days after the date of service or the

filing of an Answer, whichever is later. In an exigent case, defendants shall respond to Plaintiff’s

Master Set of Interrogatories and Production Requests or any other discovery within 60 days after the

date that the Motion for Expedited Trial Setting was filed, the date of service of the discovery, or the

filing of its Answer, whichever is later. Responses to any other case-specific discovery shall be due

60 days after the date of service of the discovery requests, including requests for admission. A

defendant will not be required to respond to any discovery until after the defendant has filed its

Answer, except for good cause shown by plaintiff.

C. Master Responses. Defendants may serve a Master Set of Answers to Plaintiffs’ Master

Set of Interrogatories and Production Requests on the Master Docket and incorporate those answers

into responses to discovery requests in individual cases.

D. Case-specific Discovery. Plaintiffs may serve case-specific discovery that is not

duplicative of any master discovery.