S.D. Ala. Civ. L.R. 33

(a) Limitation on Interrogatories.

(1) Any party may serve upon any other party no more than twenty-five (25)

written interrogatories. The twenty-five (25) permissible interrogatories may

not be expanded by the creative use of subparts.

(2) For the purpose of computing the number of interrogatories served:

(A) Parties represented by the same attorney or law firm are regarded as

one party.

(B) 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 twenty-five (25) interrogatory limit.

(3) More than twenty-five (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 twenty-five (25) interrogatories may move the Court for permission

only after seeking the agreement of the party to 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.