Interrogatories to a party, as a matter of right, shall not exceed twenty five (25) in number.
Interrogatories 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
interrogatory. All other interrogatories, including subdivisions of one numbered interrogatory,
shall be construed as separate interrogatories. If counsel for a party believes that more than
twenty five (25) interrogatories are necessary, counsel shall consult with opposing counsel
promptly and attempt to reach a written stipulation as to a reasonable number of additional
interrogatories. 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 shall file a motion with the court showing the necessity for relief.
