“[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.