Request for admission, as a matter of right, shall not exceed FORTY (40) in number. Request for admission as to the names and locations of witnesses, or the existence, location and custodian of documents of physical evidence each shall be construed as one (1) admission. All other request for admission, including subdivisions of one numbered request for admission, shall be construed as separate request for admission. If counsel for a party believes that more than FORTY (40) admissions are necessary, counsel shall consult with opposing counsel promptly and attempt to reach a written stipulation as to a reasonable number of additional admissions. Counsel is expected to comply with this requirement in good faith. In the event a written stipulation cannot be agreed upon, the parties seeking to submit additional admissions shall file a motion with the Court showing the necessity for relief.
Penn. Carb. Cnty. 4014