(3) Any previous arrest or detention of the child which did not result in a delinquency adjudication, or any other alleged offenses, purportedly involving the child, in which he was neither arrested nor charged.

(4) Any prior delinquency adjudication of the child, except those which may be used for the purpose of impeachment.

The rule regarding Motions in Limine shall apply to cases in which the Child is not represented by an attorney.

(Amended effective March 4, 2019)

LR18-JC00-DLR-0004 DISCOVERY AND MOTIONS IN LIMINE IN
CHINS CASES

(I) Discovery

(A) Duty of Counsel for the DFC

In all filed CHINS cases, unless relieved by court order, the attorney for the Indiana Department of Child Services (hereinafter DCS) shall, within fourteen (14) days after the initial hearing in any CHINS action filed, furnish the attorney for the parent(s), guardian(s) or custodian(s) (hereinafter PGC) the following:

(1) The names and addresses of persons whom the DCS intends to call as witnesses at the fact-finding hearing, together with their relevant written or recorded statements.

(2) Any written or recorded statements and any summaries of oral statements made by the PGC herein or any statements of others which contain a declaration of the PGC.

(3) The relevant testimony which is reduced to writing of persons whom the DCS intends to call as a witness at the fact-finding hearing.

(4) Any reports or statements of experts made in connection with the case, including results of physical or mental examination and of scientific tests, experiments, or comparisons.

(5) Any books, papers, documents, photographs or tangible objects, which the DCS intends to use in the fact-finding hearing or which were obtained from or belong to the PGC.

(6) Any record or prior criminal convictions of persons whom the DCS intends to call as witnesses at the fact-finding hearing.

(7) Any declarations against interest made by the PGC.

(8) Any evidence the DCS might have, favorable to the PGC.

(9) Copies of any photographs which the DCS has in its possession which it intends to introduce as evidence.