Section TCT.02.11 — Discovery

(a) Parties may obtain discovery regarding any matters not privileged which are relevant to the pending action through the use of interrogatories, depositions, and/or requests for production, inspection or admission. All responses to discovery shall be made within thirty (30) days of the date of service.

(b) A party against whom discovery is sought may move the Trial Court for a protective order to prevent the disclosure of privileged or irrelevant information. The Trial Court may order that discovery cease or proceed only upon certain specified conditions.

(c) If a party fails to respond, produce, or appear for discovery as provided in this ordinance, the opposing party may move for an order to compel the defaulting party to perform, or in the case of a request for admissions for an order to have the requests deemed admitted, and the Trial Court may award costs to the non-defaulting party.