(a) Limitation on Interrogatories.
(1) Any party may serve upon any other party no more than 25 written
interrogatories. The 25 permissible interrogatories may not be expanded by
the creative use of subparts.
(2) For the purpose of computing the number of interrogatories served
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 25
interrogatory limit.
(3) More than 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 25 interrogatories may move the Court for permission only after seeking
the agreement of the party on 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.