A. Presumptive Limitations. Except as provided in these rules, a party shall not serve upon any other party more than forty (40) interrogatories, which may be any combination of uniform or non-uniform interrogatories. Any uniform interrogatory and its subparts shall be counted as one interrogatory. Any subpart to a non-uniform interrogatory shall be considered as a separate interrogatory.
B. Stipulations to Serve Additional Interrogatories. If a party believes that good cause exists for the service of more than forty (40) interrogatories upon any other party, that party shall consult with the party upon whom the additional interrogatories would be served and attempt to secure a written stipulation as to the number of additional interrogatories that may be served.
C. Leave of Court to Serve Additional Interrogatories. If a stipulation permitting the service of additional interrogatories is not secured, a party desiring to serve additional interrogatories may do so only by leave of court. Upon written motion or application showing good cause therefore, the court in its discretion may grant to a party leave to serve a reasonable number of additional interrogatories upon any other party. The party seeking leave to serve additional interrogatories shall have the burden of establishing that the issues presented in the action warrant the service of additional interrogatories, or that such additional interrogatories are a more practical or less burdensome method of obtaining the information sought, or other good cause therefor. No such motion or application may be heard or considered by the court unless accompanied by the proposed additional interrogatories to be served, and by the certification of counsel required by Rule 65(A)(2)(c). The proposed additional interrogatories shall only be attached to the judge’s copy of the motion and the copy served on opposing parties.
D. Spacing. Whenever interrogatories are used, a space sufficient for the answer shall be left immediately below the question. The answering party shall insert the answer in the space below each interrogatory, or if it requires more space, on a separate sheet which restates the question before giving the answer.
E. Non-uniform Interrogatories. The method of propounding and answering Non-Uniform Interrogatories shall be as follows.
1. The party propounding interrogatories, other than Uniform Interrogatories, shall serve upon the answering party, and not the clerk of the court, the original and one (1) copy of the interrogatories and shall serve a copy upon every other party.
2. The answering party shall, within the time permitted by law, serve upon the propounding party and all other parties one copy of the interrogatories and answers.
F. Uniform Interrogatories. The Uniform Family Law Interrogatories set forth in Form 7 are approved for use by counsel as a standard or guide in accordance with Rule 60. The use of Uniform Interrogatories is not mandatory and should serve as a guide only. They are not to be used as a standard set of interrogatories for submission in all cases. Each interrogatory should be used only where it fits the particular case. The method of propounding and answering Uniform Interrogatories shall be as follows:
1. A party propounding Uniform Interrogatories shall serve a copy of a Notice of Service of Uniform Interrogatories upon each other party to the action.
2. The Notice of Service of Uniform Interrogatories shall contain the names of the party and attorney to whom the request is made and each uniform interrogatory for which the propounding party requests an answer.
3. The answering party shall:
a. insert the answer below the propounded interrogatory; and
b. serve the original upon the propounding party and a copy upon all other parties.