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If required showing is made, the court protects disclosure of mental impressions, conclusions, opinions, or legal theories of an attorney or other rep concerning the litigation. Without required showing, a party can obtain a statement re the action or its subject matter previously made by that party.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Any party can serve interrogatories upon another. A party must provide a reasonable space after each interrogatory for a response or objection. The interrogatory being answered (or objected to) must be placed immediately before the answer or objection.
(b) A party may discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or preparation for trial and who is not expected to be called as a witness at trial, only as provided in Rule 35(B) or upon a showing of exceptional circumstances ...
(B) Fraud, mistake, condition of the mind. In all averments of fraud or mistake, the circumstances constituting fraud or mistake shall be specifically averred. Malice, intent, knowledge, and other conditions of mind may be averred generally.
Rule 55 - Default (A) Entry. When a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise comply with these rules and that fact is made to appear by affidavit or otherwise, the party may be defaulted by the court.
(B) In civil actions, where a change may be taken from the judge, such change shall be granted upon the filing of an unverified application or motion without specifically stating the ground therefor by a party or his attorney. Provided, however, a party shall be entitled to only one [1] change from the judge.
What is a Rule 60(B) motion? Rule 60(B) is an equitable mechanism that allows a trial court to relieve a party from a judgment for eight different reasons. Rule 60(B) does not challenge the substantive legal merits of a judgment, only the procedural and equitable grounds justifying relief from that judgment.