Slaughter, J.,
This case arises from a discovery dispute between AMW Investments and Midwest Entertainment, on one hand, and the Town of Clarksville, on the other. The Town revoked Midwest Entertainment’s adult-entertainment license, prompting this litigation. In the ensuing lawsuit, Midwest Entertainment and AMW failed to respond in substance to the Town’s written discovery requests. Even after the trial court ordered Midwest Entertainment and AMW to respond, they still refused. The court imposed a $30,000 sanction to coerce their compliance. Midwest Entertainment and AMW appealed, the court of appeals reversed, and we granted transfer.
There are two issues before us. The first is whether Midwest Entertainment and AMW, while appealing the trial court’s monetary sanction, may also challenge the underlying discovery order they violated. Holding that they may, we must also decide whether Midwest Entertainment and AMW waived their discovery objections. We hold they did waive the objections because they lodged them after the response deadlines imposed by our trial rules. Thus, we affirm the trial court’s sanction and discovery order and remand.
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We begin with appellate jurisdiction and hold that a party appealing a contempt sanction may challenge both the sanction and the underlying discovery order on which the sanction is based. An unfavorable discovery order by itself is seldom grounds for an interlocutory appeal of right. But a monetary sanction is. A party sanctioned to pay money for violating a discovery order can appeal the sanction as of right, along with the discovery order.
On the merits, a party waives discovery objections that are untimely, but a trial court may excuse the waiver. This approach accords with our trial rules and gives their terms full effect. On this record, AMW waived all but its jurisdictional objection to discovery, and neither the trial court’s discovery order nor its contempt sanction was an abuse of discretion.
AMW appeals both the trial court’s contempt sanction and its underlying discovery order. The contempt sanction is appealable as a matter of right as an order for the “payment of money”, App. R. 14(A)(1), but the discovery order is not. We hold as a matter of first impression that appealing a monetary sanction necessarily brings up for review the propriety of the underlying discovery order. Thus, AMW may challenge the contempt sanction and discovery order, too.
A discovery order directed to a party generally is not an appealable final judgment because it does not dispose of all claims as to all parties…
The court of appeals holds that appealing a monetary discovery sanction also puts the underlying discovery order before the appellate court. Allstate Ins. v. Scroghan, 851 N.E.2d 317, 322 (Ind. Ct. App. 2006) (adopting the Allstate rule); see also White-Rodgers v. Kindle, 925 N.E.2d 406, 411 (Ind. Ct. App. 2010) (acknowledging the Allstate rule); Johnson v. Dr. A., 973 N.E.2d 623, 628 (Ind. Ct. App. 2012) (same). We adopt the Allstate rule for two reasons. First, a discovery sanction is improper if the underlying discovery order is erroneous. “If the [discovery] order is invalidated, the contempt judgment falls with it.” Marrese v. Am. Acad. of Orthopaedic Surgeons, 726 F.2d 1150, 1157 (7th Cir. 1984), rev’d on other grounds, 470 U.S. 373 (1985). Second, reviewing discovery orders during sanction appeals affords relief to parties from particularly egregious and burdensome orders. “[D]iscovery orders may impose heavy and irrecoverable costs on a party”. Id. at 1158. And “complying with the court’s discovery order, proceeding through a trial, and ultimately winning on appeal” is “a hollow victory indeed” once “the information sought to be protected” has “already . . . been disclosed.” Allstate Ins., 851 N.E.2d at 322. As the Seventh Circuit puts it, “once a party produces certain information, nothing can unring that bell.” Mac Naughton v. Harmelech, 932 F.3d 558, 566 (7th Cir. 2019).
Given those stakes, parties facing irremediable harm may opt to incur a monetary sanction to appeal a discovery order. “[W]e certainly do not encourage parties to intentionally violate a discovery order so as to be sanctioned and thus obtain an interlocutory appeal”, but parties in extreme cases may have no other choice. Allstate Ins., 851 N.E.2d at 322. “If a party is willing to pay the price of being punished for contempt (or suffering an equivalent sanction such as dismissal of the complaint)”, the reasoning goes, a party “can get immediate review of that order by appealing from the contempt judgment.” Marrese, 726 F.2d at 1157. Thus, AMW may challenge both the sanction and underlying discovery order on appeal.
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The trial court did not lose jurisdiction over AMW’s action during the injunction appeal. Nor did the trial or appellate courts stay proceedings pending completion of that appeal. AMW’s discovery objections were due, according to the trial court’s extension order, sixty days after they were served. AMW’s objections, lodged nearly a year later, were thus late. Late objections under the trial rules are presumptively waived, though the trial court may excuse waiver. On this record, the trial court did not abuse its discretion in finding the objections late and hence waived, in declining to excuse AMW’s waiver, or in sanctioning AMW.
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Next, we must decide whether AMW waived its discovery objections because they were untimely. Answering this question requires interpreting our trial rules, which we interpret like statutes, Noble Cnty. v. Rogers, 745 N.E.2d 194, 197 n.3 (Ind. 2001), by giving them “their plain meaning”, ESPN, Inc. v. Univ. of Notre Dame Police Dep’t, 62 N.E.3d 1192, 1195 (Ind. 2016). Under the trial rules, we hold that late objections are presumptively waived. This result both follows from the operation of the rules’ deadlines by giving meaning to every word in the rules and accords with how we read other trial rules.
By default, the trial rules require parties to answer or object to interrogatories, requests for production, and requests for admission thirty days after service. Supra, at 10 (discussing the trial rules’ default deadlines). We interpret the trial rules to give every word “effect and meaning” so that “no part is rendered meaningless”. Bagnall v. Town of Beverly Shores, 726 N.E.2d 782, 786 (Ind. 2000) (cleaned up). To give the rules’ deadlines their full effect, we conclude that missing the deadline waives the objection. Holding otherwise would read the deadlines out of the rules because no consequences would follow from late objections.
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Though late-raised objections are waived, trial courts may exercise their discretion and excuse any waiver. On this record, the trial court did not abuse its discretion in refusing to excuse AMW’s waiver or in sanctioning AMW for flouting the court’s discovery order…
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For these reasons, we affirm the trial court’s discovery order and sanction and remand for further proceedings consistent with our opinion.
Rush, C.J., and Massa, Goff, and Molter, JJ., concur.