(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. In the notice of service of uniform interrogatories, a propounding party may specifically limit the scope of the uniform interrogatory to request less information than called for in the uniform interrogatory, such as by requesting information only as to particular persons, events, or issues. Such limiting instructions do not transform the uniform interrogatory into a non-uniform 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 therefor, 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 37(a)(2)(C) of these Rules. 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) Nonuniform Interrogatories. The method of propounding and answering Nonuniform Interrogatories shall be as follows:

(1) A party propounding interrogatories, other than Uniform Interrogatories, shall serve upon the answering party and not the clerk of the court, the original and one 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 typewritten answers.

(f) Uniform Interrogatories. The interrogatories set forth in the Appendix of Forms following these Rules are denominated as Uniform Interrogatories, and are approved for use as a standard or guide in preparation by counsel of interrogatories under Rule 33 of these Rules. The use of Uniform Interrogatories shall be governed by Rule 33 of these Rules, and this Rule. The use of Uniform Interrogatories is not mandatory. The interrogatories should serve as a guide only, and may or may not be approved as to either form or substance in a particular case. They are not to be used as a standard set of interrogatories for submission in all cases. Any uniform interrogatory may be used where it fits the legal or factual issues of the particular case, regardless of how the action or claims are designated. 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 the number only of each uniform interrogatory for which the propounding party requests an answer.

(3) The answering party shall:

(i) reproduce the text of each interrogatory requested and insert the answer below it;

(ii) serve the original upon the propounding party and a copy upon all other parties.