“[W]hen the discovery matters cannot be resolved by the sincere efforts of counsel, the issues presented to the court should be sharply focused in fact, law, and number, so that the trial court’s time required is minimal and well spent.” Howard, 813 N.E.2d at 1223. Unfortunately, neither party fully complied with this expectation and the Court admonishes them both for failing to do so.
For all the above-stated reasons, the Court GRANTS Popovich’s Motion to Compel, with the exception of Interrogatory Number 4. The Court DENIES the Department’s Motion for Protective Order, with the exception of Interrogatory Number 4. The Department must fully respond to Popovich’s discovery requests and identify the 20 work-product and attorney-client privilege objections with respect to Interrogatory Number 4 with the particularity contemplated by Trial Rule 26(B)(5) within forty-five (45) days of this Order. Consistent with the requirements of Indiana Trial Rule 37(A)(4), the Court will schedule a hearing regarding the propriety of an award of expenses by separate order.