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