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Rule 31. Depositions upon writtenquestions.

(a) A party may depose a party or witness by written questions. Rules 30 and 45 applyto depositions upon written questions, except insofar as by their nature theyare clearly inapplicable.

(b) A party taking a deposition using written questions shall serve onthe parties a notice which includes the name or description and address of thedeponent, the name or descriptive title of the officer before whom thedeposition will be taken, and the questions to be asked.

(c) Within 14 days after the questions are served, a party may servecross questions. Within 7 days after being served with cross questions, a partymay serve redirect questions. Within 7 days after being served with redirectquestions, a party may serve re-cross questions.

(d) A copy of the notice and copies of all questions served shall bedelivered by the party taking the deposition to the designated officer whoshall proceed promptly to ask the questions and prepare a record of theresponses.

(e) During standard discovery, a deposition by written questioningshall not cumulatively exceed 15 questions, including discrete subparts, by theplaintiffs collectively, by the defendants collectively or by third-partydefendants collectively.