When I originally setup my esx 3.5 cluster, I setup a single nfs datastore, to our netapp filer. That was three years ago and it has served us well with no major issues.
We are now getting ready to replace the single head Netapp with a dual head active/active unit, where we will have to split the datastore into at least two volumes so as to balance the load across shelves/heads.
I have recently spoken to a consultant who recommended a balance of 20/25 vms per datastore, with attention paid to the demands of each vm so as to balance the load well. The suggestion was to try and group vms with the same OS in the same datastore so as to maximise the de-duplication function of the Netapp.
So if your storage has de-dupe capabilities, design your storage layout to maximise the benefit of this.
Esx 3.5 allows 32 nfs datastores, subject to changing the parameter in the configuration, advanced settings. I believe this limit is further raidr in vsphere.
There are also other parameters vmware advising changing for nfs datastores in the config guide.
Hope this helps!
Matthew