(a) Limitation on Interrogatories.
(1) Any party may serve upon any other party no more than twenty-five (25)
written interrogatories. The twenty-five (25) permissible interrogatories may
not be expanded by the creative use of subparts.
(2) For the purpose of computing the number of interrogatories served:
(A) Parties represented by the same attorney or law firm are regarded as
one party.
(B) Interrogatories inquiring about the names and locations of persons
having knowledge of discoverable information or about the existence,
location, or custodian of documents or physical evidence do not count
toward the twenty-five (25) interrogatory limit.
(3) More than twenty-five (25) interrogatories may be served on a party only
if that party agrees in writing or the Court so orders. A party seeking to serve
more than twenty-five (25) interrogatories may move the Court for permission
only after seeking the agreement of the party to whom the additional
interrogatories would be served. If a party desires to serve additional
interrogatories, the party must promptly consult with the party to whom the
additional interrogatories would be propounded and attempt to reach a
written stipulation as to a reasonable number of additional interrogatories.
The stipulation allowing additional interrogatories to be served should not be
filed with the Court except in connection with a motion to compel answers. If
a stipulation cannot be reached, the party seeking to serve additional
interrogatories may move the Court for permission to serve additional
interrogatories.
(4) The Court will not compel a party to answer any interrogatories served in
violation of this Rule.
(b) Answering Interrogatories. An objection or an answer to an
interrogatory must reproduce the interrogatory to which it refers.
