(10) Any description of the PGC’s conduct, if any, that the DCS intends to introduce as an implied admission.

(11) Any promises, rewards, or inducements provided to DCS witnesses or PGC witnesses.

(12) Any victim’s statement that was recorded or memorialized and that is under the DCS’s control.

(13) Any and all medical reports in appropriate cases.

(14) That portion of police reports containing substantially verbatim statements of witnesses.

(15) The criminal record of the PGC, including arrests and convictions.

(16) Evidence of other crimes, wrongs, or acts pursuant to Evidence Rule 404(b).

(17) The DCS shall also allow counsel for the PGC to examine any and all physical evidence, whether or not the DCS intends to present the evidence at the fact-finding hearing, within fourteen (14) days after the initial hearing.

In all filed CHINS cases, unless relieved by court order, counsel for the PGC shall, within twenty-one (21) days after receiving the discovery from the DCS in any CHINS action filed against the PGC, furnish the attorney for the DCS the following:

(1) Any reports or results or testimony relative thereto, of physical or mental examination or of scientific tests, experiments or comparisons, or any other reports or statements of experts pertaining to this case.

(2) A summary of any special or statutory defense(s), which the PGC intends to make at a hearing or fact-finding in this cause.

(3) Names and last known addresses of persons the PGC intends to call as witnesses, together with their relevant written or recorded statements, including memoranda reporting or summarizing their oral statements, and any record of prior criminal convictions known to the PGC.

(4) Any books, papers, documents, photographs, or tangible objects the PGC intends to use as evidence or for impeachment at a hearing or trial.

If the PGC is not represented by an attorney, the above requirements do not apply, and the parties must file written motions with the Court to request discovery.

In all filed CHINS cases, unless relieved by court order, the following items are excluded from evidence, and the Court prohibits any reference at fact-finding hearing to the following. In addition, counsel and all witnesses may not refer to, mention, or testify about the following:

(1) Any questioning of the PGC, or any statements which the PGC may have made while he was in the custody of the police, absent proof beyond a reasonable doubt that