Rule 4005 - Number of Interrogatories, Requests for the Production of Documents, and Request for Admissions(a) Interrogatories, requests for the production of documents, and/or requests for admissions to a party as a matter of right, shall not exceed forty (40) in number for each type.(b) Interrogatories, requests for the production of documents, and/or requests for admissions inquiring as to the names and locations of witnesses, or the existence, location and custodian of documents or physical evidence each shall be construed as one (1) interrogatory, request for the production of documents, and request for admission. All other interrogatories, requests for the production of documents, and/or requests for admissions, including subdivisions or one numbered interrogatory, request for the production of documents, and/or request for admissions, shall be construed as separate interrogatories, requests for the production of documents, and/or requests for admissions.(c) If counsel for a party believes that more than forty (40) interrogatories, requests for the production of documents, and/or requests for admissions are necessary, they shall consult with opposing counsel promptly and attempt to reach a written stipulation as to a reasonable number of additional interrogatories, requests for the production of documents, and/or requests for admissions. Counsel are expected to comply with this requirement in good faith. In the event a written stipulation cannot be agreed upon, the party seeking to submit additional interrogatories, requests for the production of documents, and/or requests for admissions shall file a motion with the court showing the necessity for relief.Amended effective 1/1/2024.