Frank. Cnty. Pa. 39-4005
Interrogatories or requests for admissions to a party, as a matter of right, shall not exceed forty (40) in number. Interrogatories 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 or requests for admissions. All other interrogatories or requests for admissions, including subdivisions or one numbered interrogatory or request for admission, shall be construed as separate interrogatories or requests for admissions. If counsel for a party believes that more than forty (40) interrogatories or requests for admissions are necessary, he shall consult with opposing counsel promptly and attempt to reach a written stipulation as to a reasonable number of additional interrogatories 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 or requests for admissions shall file a motion with the court showing the necessity for relief.
Frank. Cnty. Pa. 39-4005