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Yasmin L. StumpYASMIN L. STUMP LAW GROUP, PCTHREE MERIDIAN PLAZA, SUITE 100
10333 NORTH MERIDIAN STREETINDIANAPOLIS, IN 46290
Alexander Jesus LimontesMITCHELL HURST DICK & McNELIS, LLC
152 EAST WASHINGTON STREETINDIANAPOLIS, IN 46204
Rules 4 and 4.1: mechanics of preparing summons and modes of service
to gain personal jurisdiction Rules 4.2 - 4.10:
service upon particular types of persons and in particular types of action
Rules 4.11 - 4.13: Effectuating service for each mode of service
Rules 4.14 - 4.17: general provisions governing proof, validity, and scope of
service of process
Personal Jurisdiction, Service of Summons and Complaint
Ind. T.R. 4(A) provides manner for Court to obtain personal jurisdiction over parties/persons
Court acquires jurisdiction over a party or person who: Commences/joins in action; Served with summons or appears; or Subject to court’s jurisdiction under any other law
Person/legal entity falls within court's jurisdiction in a civil action only when properly made party to that action
Bowmar Instrument Corp. v. Maag, 442 N.E.2d 729 (Ind. Ct. App. 1982) (quoting Ind. T.R.4(A); Kilb v. Ennis, 74 Ind. 17 (1881))
Accomplished through service of process typicall
Service of process is inadequate, court lacks personal jurisdiction Bonaventura v. Leach, 670 N.E.2d 123 (Ind. Ct. App. 1996), trans. den., 683
N.E.2d 584, overruled on other grounds by Smith v. Johnston, 711 N.E.2d 1259 (Ind. 1999)
Ind. T.R. 4(C) requires that summons contain: Name and address of person being served; Name, address and telephone no. of court; Cause no. assigned to case; Title of case as in complaint;
May shorten title to first named plaintiff and defendant with indication that additional parties exist if multiple parties
Name, address and telephone no. of attorney for party seeking service; Time by which person being served has to respond; and Clear statement that if no response, default judgment may be entered
Additional information to be contained if it facilitates proper service Ind. T.R. 4(C)
Summons may also designate manner of service Ind. T.R. 4(D)
When filing complaint or similar pleading must provide clerk with as many copies of complaint and summons as necessary
Clerk must: Examine, date, sign and affix seal to summons; and Issue and deliver papers to the appropriate person for service
Praecipe necessary only when further information required to effectuate service Praecipe must be attached to or entered upon summons
Must include affidavits, requests and any other information related to summons and service
Praecipe then deemed to be part of summons Separate or additional summons may be issued by clerk upon proper
request
Potential manners of service: Registered or certified mail; Service on individual at listed address (residence/employment)
Service by sheriff; Service by service processor;
Service on agent; Service by publication; and Service by a party’s appearance
Choice of manner of service may depend upon: Type of action Party’s relationship to Indiana Difficulty in effectuating service
Must provide best possible notice available Morrison v. Prof. Billing Serv., Inc. 559 N.E.2d 366 (Ind. Ct.
App. 1990)
Ind. T.R. 4 and Ind. TR. 41(E) impose duty of due diligence upon complaining party when securing service of process Failure to do so result in motion to dismiss for failure to
prosecute Taylor v. Lewis, 577 N.E.2d 986, 989 (Ind. Ct. App. 1991)
Party seeking service may designate manner of service upon summons
Ind. T.R. 4(D) If not so designated --
Then clerk shall cause service to be made by mail or other public means, provided the mailing addresses are indicated in summons or can be determined
If mailing address not furnished or cannot be determined, or if service by mail or other public means is returned without acceptance – Then complaint and summons shall promptly be delivered to
sheriff who shall serve summons, unless otherwise directed
General rule: Must serve summons and complaint together unless
otherwise ordered by court
Failure to serve complaint with summons prevents court from obtaining personal jurisdiction over party Overhauser v. Fowler, 549 N.E.2d 71, 73 (Ind. Ct. App.
1990):
Court lacked personal jurisdiction when defendant received summons without complaint attached
Failure to timely issue summons within applicable statute of limitations renders action untimely See Ray–Hayes v. Heinamann, 760 N.E.2d 172 (Ind.
2002, modified on reh'g, 768 N.E.2d 899 Held: Civil action untimely commenced when
plaintiff did not tender summons to clerk after statute of limitations expired, even though complaint filed and filing fee paid within applicable statutory period
No requirement that summons be delivered to defendant within statutory period
Johnson v. Morgan 871 N.E.2d 1050, 1054 (Ind. Ct. App. 2007)
When serving by publication: complaint should not be published instead summons and complaint are deemed to be
served at end of the day of last required publication
When serving by party’s appearance: summons and complaint are deemed to be served at
time of appearance in jurisdiction acquired by appearance
Ind. T.R. 4.1(A) -- service on individual/representative may occur by: Sending copy of summons and complaint by registered/certified mail;
…or other public means by which written acknowledgement of receipt may be requested/obtained to residence, place of business or employment with return receipt requested and returned showing receipt of letter;
Delivering copy of summons and complaint personally; Leaving copy of summons and complaint at dwelling house or usual
place of abode; or Serving agent as provided by rule, statute or valid agreement
Follow “copy service” with mailed copy If serving by last 2 options, must send copy of summons (without
complaint) by First Class U.S. Mail to last known address, and this fact must be shown upon the return Ind. T.R. 4.1(B)
Registered/certified mail Often, the fastest, most effective and inexpensive method. Used extensively in Indiana for serving nonresidents through
governmental agents (i.e., nonresident motorists)
Personal service Classic “hand to hand” service
May be executed by Sheriff or process server
Dwelling house or usual place of abode Must leave with person of suitable age and discretion residing therein
Harvey, 1 Ind. Prac., Rules of Procedure Annotated R. 4.1 (3d. ed.) Stated in disjunctive
One’s dwelling house may not be one’s usual place of abode
Agent Includes “person of suitable age and discretion whose usual
duties/activities include prompt communication of such information” Id.
Service of Particular Individuals and during Particular Causes of Action
Infant or incompetent person – Ind. T.R. 4.2 If already represented, service must be made upon next of friend/guardian
ad litem If not yet represented, service must be made on court-appointed rep.
If infant has no court-appointed representative, must serve custodial parent If no parent, person known to be in position of custodian/parent.
If incompetent person has no court-appointed representative, must serve named party and person known to be custodian
Institutionalized person – Ind. T.R. 4.3 Service must be made by delivering or mailing copy of summons and
complaint to official in charge of institution Imposes duty upon official to:
immediately deliver copies to person; permit him/her to make provisions for representation by counsel; and indicate such upon the return
Applies to nonresidents, former residents or persons/organizations of unknown residence Submit to jurisdiction of Indiana courts. in any action arising from
following acts done by them/their agents: Doing business in Indiana Causing personal injury/property damage by act/omission done
within Indiana; Causing personal injury/property damage by act/omission done
outside Indiana. Only if: Regularly does/solicits business; Engages in other persistent conduct; OR Derives subst. revenue/benefit from goods, materials, or
services used/consumed/rendered in IN
Supplying/contracting to supply goods/services in Indiana; Owning, using, or possessing real property or interest therein in
Indiana; Insuring or acting as surety for any person, property or risk within
Indiana; Living in martial relationship in Indiana regardless of subsequent
departure; Only if: Other party to relationship remains in state; and Related to alimony, custody, child support, or property settlement
Abusing, harassing or disturbing peace of, or violating protective/restraining order for protection of, any person within IN by act/omission done: in Indiana; or outside Indiana if part of continuing course of conduct
having effect in Indiana
If subject to jurisdiction under Ind. T.R. 4.4 may serve with summons according to: Ind. T.R. 4.1 (discussed earlier) Ind. T.R. 4.5 (see Ind. T.R. 4.9) Ind. T.R. 4.6 (discussed later) Ind. T.R. 4.9 (in rem actions)
May serve summons:upon person/agent pursuant to Trial Rules; if outside Indiana, as provided by Ind. T.R. 4.1;by publication under Ind. T.R. 4.13
Types of organizations and who to serve: Domestic/foreign organization
Agent appointed (by agreement or law) to receive service; or
If no agent, executive officer
Partnership General partner
State governmental organization Executive officer and Attorney General
Local governmental organization Executive and organization’s attorney
Manner of service – Ind. T.R. 4.6(B) Must serve in manner provided by Ind. T.R. 4.1 Must not knowingly direct service at person’s dwelling
house/place of abode Unless address furnished under statutory requirements or valid
agreement; or Affidavit on/attached to summons states that service in another
manner is impractical
Service at organization’s office – Ind. T.R. 4.6(C) If service upon organization cannot be made as provided in Ind.
T.R. 4.6(A) or (B): May serve by leaving copy of summons and complaint at any
office of organization located within Indiana with person in charge of such office
Must show such inability upon affidavit or in the return
Effectuating Particular Manners of Service
Clerk (or governmental agent under Ind. T.R. 4.10) must send summons and complaint to address supplied upon summons or furnished by person seeking service
Return Clerk or governmental agent must show:
Date and place of mailing; A copy of mailed or electronically-transmitted return receipt; and
If and when received by person to show that mailing was accepted/returned
If accepted, by whom Clerk must file return and receipt with the pleadings, so that it becomes
part of the record
If mailing by clerk returned without acceptance, clerk must re-issue summons and complaint for service as requested by person seeking service
Who serves: Sheriff; Deputy; or Person specially/regularly appointed by court
Manner of service available if: Delivering copy personally; or Leaving copy at dwelling house/place of employment (Ind. T.R. 4.1)
Service effective if made by person not otherwise authorized by rule, but proof of service by that person must be made as witness or by deposition without allowance of expenses as costs
Duty on server: Must act promptly and exercise reasonable care to cause service to be
made
Person seeking service must: Submit such request upon praecipe for summons along
with affidavits stating that: Diligent search has been made; and Defendant cannot be found, has concealed his whereabouts,
or has left the state Must prepare contents of summons to be published
Praecipe for summons by publication Names all persons to be served Separate publications for each party not required
Clerk/sheriff must sign summons in such manner as to indicate that it is made by his/her authority
General provisions governing proof, validity and scope of service of
process
Duty to make return Person making service shall promptly make return upon or attach to
copy of summons to be delivered to clerk
Form of return Signed by person making it and include statement that:
If service was made – That service was made upon person; and Time, place, and manner of service;
If service was not made – Manner in which it was thwarted (in terms of fact/law)
Other information as expressly required by Trial Rules
Return and affidavits as evidence Clerk must file return (along with summons), praecipe, affidavits
furnished with summons/praecipe and all other permitted affidavits with pleadings, etc. At that time, it is a part of the record and has evidentiary effect
Proof of filing and issuance dates Clerk must enter filing date upon every praecipe, pleading, return,
summons, affidavit or other paper filed with or entered of record Clerk must also enter issuance date upon any summons issued,
mailed or delivered by him, or other communication served/transmitted by him Filing/issuance date constitutes evidence of date of filing
/issuance without authentication when entered in court records, or paper/copy thereof properly admitted into evidence
Admission of service Written admission stating date and place of service, signed by
person being served, may be filed with clerk in order to file with pleadings Part of record, constitutes evidence of proper service and is
allowed as evidence
Amendment of process/proof of service Court may allow at any time in its discretion, unless clearly
and materially prejudices substantive rights of person against whom process issued
Defects in summons No summons/service thereof will be set aside/adjudged
insufficient when reasonably calculated to inform person to be served that: Action was instituted against him/her; Name of the court; and Time to respond
Every person served under Trial Rules must: Cooperate; Accept service; Comply with Trial Rules; and Acknowledge receipt of papers in signed writing
Only if served personally
If accepting service for another, must: Promptly deliver papers to person; Promptly notify person that he holds papers; OR Within reasonable time, notify clerk/person making service that notice
could not be made
Willful violation of Ind. T.R. 4.16 may subject person to contempt proceedings But person making service cannot subject person being served to
penalty/sanction because of service
Procedural prerequisite to initiating tort lawsuit against governmental entity or political subdivision Indiana Tort Claims Act (“ITCA”), IC 34-13-3, et seq.
Lawsuit barred unless tort claim notice filed within period Parke County v. Ropak, Inc., 526 N.E.2d 732, 737
(Ind. Ct. App. 1988), reh’g den.
IC 34-13-3-6, -8, -9, -10 and -12 govern filing and content of tort claim notices
“Governmental entity”: State of Indiana State departments, agencies and commissions Bureau of Motor Vehicle.
“Political subdivisions”: Community action agency;
IC 12-14-23-2 Individual/corporation providing public transportation per contract
w/commuter transportation district created IC 8-5-15
Volunteer fire dept. Defined in IC 36-8-12-2 acting pursuant to IC 36-8-17 or contract w/
“unit or fire protection district” IC 34-13-3-22
Ind. S.Ct. considered issue of whether county equal opportunity council and community services organization “political subdivisions”
Held: Lake County Equal Opportunity Council (“LCEOC”) was political subdivision, but Greater Hammond Community Service (“GHCS”) was not LCEOC political subdivision -- “community action agency”
under ITCA Ct. also analyzed entity’s level of public control
GHSC argued governmental entity: Primarily publicly-funded; Subject to provisions of Indiana Public Records Act; and Part of its board consisted of public officials
Ct. rejected GHSC’s argument If organization is governmental entity under statute other than ITCA --
not necessarily one under ITCA Held: GHSC’s alleged level of public control not significant enough to be
“public” and afforded ITCA protections If group is neither specifically named by statute as governmental
entity/political subdivision nor providing uniquely governmental services, cannot receive ITCA protection by contracting to be managed by established governmental entity Greater Hammond Comm. Serv. v. Mutka, 735 N.E.2d 780, 784 (Ind.
2000)
ITCA immunity to governmental entity for tortuous conduct of employees within employees’ scope of employment Celebration Fireworks, Inc. v. Smith, 727 N.E.2d 450, 452
(Ind. 2000)
Ensures public employees exercise independent judgment necessary to carry out duties without threats of harassment or litigation Indiana Dept. of Correction v. Stagg, 556 N.E.2d 1338,
1343 (Ind. Ct. App. 1990), trans. Den.
Governmental entity defends all affiliated parties – does not matter whether against political subdivision, its employee or both Bienz, 674 N.E.2d at 1004 (citing Poole v. Chase, 476 N.E.2d 828
(Ind. 1985))
ITCA provisions do not apply when governmental employee: Committed criminal act; Acted outside scope of employment; Acted maliciously, willfully and/or wantonly; or Actions were calculated to personally benefit him
IC 34-13-3-5(c) Tort claim notice would not be necessary in such lawsuits
Significant distinction between claim made against governmental employee in individual vs. official capacity Governmental employment alone insufficient to trigger
ITCA’s notice provision
Bienz, 674 N.E. 2d at 1004. If plaintiff sues employee in individual capacity, notice
required if act/omission causing plaintiff’s loss falls within scope of employment
No tort claim notice required: Plaintiff actually and reasonably lacks knowledge of
governmental employee’s status; Employee acts in the course of his duties in a manner that
disguises governmental employee; or Employee fails to reveal governmental employee status
Gregor v. Szarmach, 706 N.E.2d 240, 243 (Ind. Ct. App. 1999); see also, Fowler v. Brewer, 773 N.E.2d 858, 866 (Ind. Ct. App. 2002)
Government may be estopped from asserting defense in such situations Gregor, 706 N.E.2d at 243
Specific information needed in notice Format of information need not be complex Short, plain statements acceptable
IC 34-13-3-10 also requires : Circumstances which brought about the loss; Extent of the loss; Time and place that loss occurred; Names of all persons involved, if known; Amount of the damages sought; and Residence of claimant at the time of the loss and time of filing
Notice suffices if advises “of the accident so that it may promptly investigate the surrounding circumstances.” Galbreath v. City of Indianapolis, 255 N.E.2d 225, 229 (Ind.
1970)
ITCA also requires tort claim notice to be: Written; and Personally delivered/sent by certified/registered mail
IC 34-13-3-12
If notice not written, may suffice under doctrine of “substantial compliance” Bd. of Aviation Comm’rs v. Hestor, 473 N.E.2d 151, 154
(Ind. Ct. App. 1985)
Must serve notices against political subdivision on governing body and Ind. Political Risk Mgmt. Commission (IPRMC)
IC 34-13-3-8(a) IPRMC is separate body corporate and politic Instrumentality of state, but not state agency
Separate from state in its corporate and sovereign capacity
Aids political subdivisions in protecting themselves against liabilities IC 27-1-29-5
If not member of IPRMC, then failure to serve notice excused IC 34-13-3-8(b)
Must file tort claim notice against governmental entity other than state, its departments and agencies within 180 days after loss occurs IC 34-13-3-8
Must file tort claim notice against state of Indiana, its departments or agencies within 270 days after loss occurs IC 34-13-3-6
Filing period is tolled if claimant incapacitated or becomes disabled IC 34-13-3-9
Period for filing begins to run once incapacity or disability is removed IC 34-13-3-9.
Incompetency under ITCA refers to incapacity that makes it unreasonable to subject person to duty to file tort claim notice Indiana Dept. of Hwys. v. Hughes, 575 N.E.2d 676, 678 (Ind. Ct.
App. 1991) (citing Lett v. State, 519 N.E.2d 749 (Ind. Ct. App. 1988))
Lett v. State, 519 N.E.2d 749 (Ind. Ct. App. 1988) Claimant was paraplegic Incompetent for 11 months Held: When claimant’s condition stabilized and he could operate
wheelchair on own, he became competent Period for filing tort claim notice began to run at that time
Ind. Dept. of Hwys. v. Hughes, 575 N.E.2d 676 (Ind. Ct. App. 1991) Held: Claimant was never incapacitated
Claimant suffered badly broken leg Spent 2 months in hospital
During hospital stay, she performed numerous tasks, including: Paying bills, communicating by telephone and mail, seeing
visitors, clearly discussing accident and injuries, signing consent to treat forms and contemplating pursuing legal action
Ct. determined that, while physically impaired, claimant’s ability to perform tasks proved that compliance with ITCA not unreasonable
Courts require strict compliance with ITCA notice requirement, timeliness of notice and submission of notice to proper officers Daugherty v. Dearborn, 827 N.E.2d 34, 36 (Ind. Ct. App. 2005) (citing Volk v.
Michigan City, 32 N.E.2d 724, 725 (Ind. 1941))
But courts liberally construe ITCA when considering whether notice is sufficiently definite as to time, place, nature, etc. of injury Id. at 35 (citing Volk, 32 N.E.2d at 725)
Not all technical violations of this statute are fatal to claim City of Tipton v. Baxter, 593 N.E.2d 1280, 1282 (Ind. 1992) (citing Allen v.
Lake County Jail, 496 N.E.2d 412, 414 (Ind. Ct. App. 1986), reh’g. den.)
Non-compliance with ITCA excused in three separate and distinct doctrines: Substantial compliance; Waiver; and Estoppel
Substantial compliance Focus on nature of notice itself Concerned with extent to which form, content, and timing of notice complies
with ITCA Allen, 496 N.E.2d at 415
Often raised as defense to failure to comply with ITCA’s technical requirements
Waiver Focus on defendant’s failure to timely raise non-compliance with ITCA as
defense Baxter, 593 N.E.2d at 1282
Estoppel Emphasis on representations made by defendant or its agents to plaintiff, which
induce plaintiff to reasonably believe that formal notice is unnecessary Id.
It is significant to note that doctrines of estoppel or waiver are typically unavailable to plaintiff who is represented by counsel
Galbreath v. City of Indianapolis, 255 N.E.2d 225 (Ind. 1970) Ind. S.Ct. explained rationale underlying substantial compliance:
“The purpose of the notice statute being to advise the city of the accident so that it may promptly investigate the surrounding circumstances, we see no need to endorse a policy which renders the statute a trap for the unwary where such purpose has in fact been satisfied.” Id. at 229
ITCA requirements liberally construed when deciding whether notice requirement satisfied avoid denying plaintiffs day in court
Held: Notice, which plaintiff’s husband made without an attorney’s assistance, to the City Legal Department sufficient City attorney had authority to accept notice on behalf of mayor, whom
(according to the notice statute) proper party to serve with notice in suit against City
Collier v. Prater, 544 N.E.2d 497, 499 (Ind. 1989) Substantial compliance is question of law, not fact
But determination is fact-sensitive Held: Significant factor in deciding substantial compliance with ITCA
whether claimant conveyed intent to file tort lawsuit against gov’tal entity Ct. rejected substantial compliance argument because purported “notice”
ordinary complaint letter that did not state intent to file claim Notice substantially complies with ITCA, if:
It is filed within applicable period to file; It informs municipality of claimant’s intent to make a claim; and It contains sufficient information that reasonably affords municipality
opportunity to promptly investigate claim
Entirely new claims may not be raised in complaint if not mentioned in notice Simpson v. OP Property Mgmt., LLC, 939 N.E.2d 1098, 1103 (Ind. Ct. App.
2010); see also Boushehry v. City of Indianapolis, 931 N.E.2d 892, 896 (Ind. Ct. App. 2010) (claims in cause of action entirely different than those contained in notice -- prevented notice from substantial compliance)
Substantial compliance applies where claimant satisfied ITCA’s notice provisions in complete absence of writing
Claimants failed to provide written notice to proper authorities Held: Government’s insurer actually knew of and investigated accident, and
had attempted to settle claim In deposition, government’s insurer testified that he knew:
Date of accident; Identities of persons involved; Injuries had occurred and extent of those injuries; Location of the accident; and Contact information of claimants
Held: Level of knowledge and reasonable inferences showed substantial compliance with ITCA’s notice provisions
Delaware County v. Powell, 393 N.E.2d 190 (Ind. 1979) Found that substantial compliance relieved claimant from written notice
Mere actual knowledge of occurrence or routine investigation does not substantially comply, but notice requirement may be waived or substantial compliance may be proven
Held: Lower court erred by failing to permit plaintiff to submit proof of substantial compliance
Several factors if proven may satisfy ITCA notice provisions and constitute substantial compliance: Preparation of a defense; Admissions of liability; Letters describing the accident; Causes of the accident; Injuries involved; and Payments, settlements or other conduct /acts of defendant or its agents
Ind. S.Ct. refrained from extending holding in Powell in deciding that claimant had not substantially complied with ITCA notice provisions Claimant sent ordinary complaint letter to the mayor
-- omitted description of accident or any injuries arising therefrom
Held: Notice to department acting without knowledge and advice of city legal department does not substantially comply with ITCA
Governmental entity can waive defense that plaintiff failed to comply with ITCA notice provisions Focus on “[D]efendant’s failure to timely raise
non-compliance with ITCA as the defense” Allen, 496 N.E.2d at 415
Primarily governed by Ind. T.R. 12(b) and 8(b). Waiver must be stated in short, plain terms in
responsive pleading to complaint
Statement in responsive pleading that defendant lacked information to form belief about allegation that written notice had been served is insufficient assertion of waiver Geyer v. City of Logansport, 370 N.E.2d 333, 337 (Ind.
1977); see also Allen, 496 N.E.2d at 415, n.3
Political subdivision must assert defense in answer to complaint Health & Hosp. Corp. of Marion County v. Gaither, 397
N.E.2d 589, 592 (Ind. 1979)
Although defendant must assert defense in its responsive pleading failure to do so may not be fatal
Allowed defendant to amend answer to include affirmative defense of waiver Ct. relied on general policy providing for liberal amendment
of pleadings, and trial courts’ broad discretion to allow amendments
Fowler failed to assert affirmative defense in original answer, but allowed to amend answer 1.5 years after complaint was filed Amendment permitted because plaintiff failed to prove
undue prejudice if amendment was allowed
Focuses on representations made by defendant or its agents to plaintiff, which induce a reasonable belief that formal notice is unnecessary Baxter, 593 N.E.2d at 1282
Conduct of defendant or its agents and/or plaintiff may satisfy purpose of ITCA notice provisions Estops defendant from asserting plaintiff’s non-
compliance with ITCA Powell, 393 N.E.2d at 192
Conduct that satisfies purpose of ITCA includes: Preparation of defense or admissions of liability; Letters/writings involving descriptions of the incident, causes and
conditions thereof or Nature and extent of the injuries; Promises, payments, settlements or other conduct/acts of defendant
or plaintiff
Crucial issues when considering estoppel: Whether “governmental unit had actual knowledge of and
investigated the accident and surrounding circumstances” Coghill v. Badger, 418 N.E.2d 1201, 1208 (Ind. Ct. App. 1981)
Court should focus on whether plaintiff actually believed, by way of the government entity’s acts, that formal notice under ITCA was unnecessary
Yasmin L. StumpYASMIN L. STUMP LAW GROUP, PCTHREE MERIDIAN PLAZA, SUITE 100
10333 NORTH MERIDIAN STREETINDIANAPOLIS, IN 46290
Alexander Jesus LimontesMITCHELL HURST DICK & McNELIS, LLC
152 EAST WASHINGTON STREETINDIANAPOLIS, IN 46204
