(A) Definition of and Right to Discovery. “Discovery” means the obtaining of information by a party to a legal action from another party, other person, or organization. All parties have the right to have information produced by other parties, and witnesses, unless the information is privileged by law. All parties have the duty to reasonably cooperate with other parties in providing discovery.
(B) Information Subject to Discovery. Unless otherwise limited by Court order, the scope of discovery is as follows: Parties to an action may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter.
“Documents” include paper, audio, visual, computer generated information, and other similar electronically stored information.
(C) Required Disclosures. No later than twenty-one (21) calendar days before the pretrial conference, a party must, without awaiting a discovery request, provide to the other parties:
(1) The name, and if known, the address and telephone number of each individual likely to have discoverable information, along with the subjects of that information, that the disclosing party may use to support its claims or defenses;
(2) A copy – or a description by category and location – of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses;
(3) A computation of each category of damages claimed by the disclosing party, and disclose all documents that support that computation; and
(4) A copy of any insurance agreement or policy that might provide coverage for the claims asserted in the petition.
(D) Court Order for Discovery. If a party has made reasonable efforts to obtain information from another party that is discoverable under these Rules, and a party or witness will not cooperate, the party seeking discovery may apply to the Court in writing for an order requiring discovery. The application shall clearly state the information sought, the reason or reasons why it is relevant to the case and needed, and the efforts that have been made to obtain the information. In exceptional cases where a party reasonably fears the destruction or disappearance of information, that party may apply to the Court for a discovery order without first having tried to obtain it by other means.