3.1 Written Discovery

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(a)  No party shall serve on any other party more than thirty (30) written interrogatories in the aggregate including subsections except upon agreement of the parties or leave of court granted upon a showing of good cause. Pursuant to Supreme Court Rule 213, a motion for leave of court to serve more than thirty (30) interrogatories must be in writing and shall set forth the proposed interrogatories and the reasons establishing good cause for their use.

(b)  Within twenty-eight (28) days after service of a request for admission, the answering party shall serve upon the party requesting either a sworn statement denying specifically the matters of which admission is requested or setting forth in detail the reasons why the party cannot truthfully admit or deny those matters or a written objection to each request.

(c)   Pursuant to Illinois Supreme Court Rule 201 (m), no discovery may be filed with the Clerk of the Circuit Court except by order of court.  Any party serving discovery shall file a certificate of service of discovery document.

 {Amended April 22, 2013}