Requests for admissions to a party, as a matter of right, shall not exceed forty (40) in number. Requests for admissions 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 (1) request for admission. All other 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 forty (40) requests for admissions are necessary, he 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 submit additional requests for admissions shall file a motion with the court showing the necessity for relief.
Daup. Cnty. Pa. 4014