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Mark Fuller Divorce Interrogatories

Mark Fuller Divorce Interrogatories

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Published by Roger Shuler
Interrogatories in divorce case against Mark Fuller, the judge in the Don Siegelman prosecution.
Interrogatories in divorce case against Mark Fuller, the judge in the Don Siegelman prosecution.

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Published by: Roger Shuler on May 14, 2012
Copyright:Attribution Non-commercial


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The Plaintiff requests that the Defendant answer the following interrogatories in the form and inthe manner prescribed by law
1. State your total income to date during the current calendar year.2. List your estimated monthly living expenses in detail, including but not limited to rent,mortgage payments, utilities, food, clothing, laundry and cleaning, transportation, medical and dentalcare, education, insurance, recreation, and other regular expenses.3. If during the last three (3) years, there have been any bank accounts on which your namedoes not appear that you have drawn money from, state the bank account number, the bank upon whichsame is drawn, the amounts withdrawn by you and the date.4. During the course of your marriage, either prior to or subsequent to the filing for divorce,state the name of each individual and the time, date and place of each occurrence of sexual intercoursewith anyone other than your spouse.5
If you contend that your spouse committed wrongdoing of any nature during the term of y
our marriage, state the nature of’ the alleged misconduct, giving in detail the facts and circumstances
which support your allegations.6. List any documentary evidence, photographs or testimony by any witness that you intendto use at the trial of this case or on deposition in this which tends to prove that your spouse has committedwrong-doing of any nature from the date of your marriage to the date you answered this interrogatory
including, but not limited to, what documentary evidence you intend to use, including the nature of whatis depicted, and the name and address of the person or persons who will so testify together with asynopsis of their expected testimony.7. Have you conducted any electronic surveillance of your spouse or have you caused anyelectronic surveillance to be conducted by any person or persons within the past five
years (electronicsurveillance being defined as the interception of any voice communication, c-mails or other onlinecommunications, or text messages made by your spouse by electronically recording the same, listening inon any voice communication made by your spouse, utilizing spyware or some other type of method to
record computer or online activity, or checking your spouse’s cell phone or handheld device)? If so:
 a. State the dates, times and places of said surveillance.b. The method employed for such surveillance.c. The person conducting such surveillance.d. Whether said surveillance was recorded.e. Whether any written transcripts or a electronic copies have been made of suchsurveillance.f. Relate in detail the conversation or communication which was intercepted and/orrecorded.8
State in detail each and every fact, occurrence, incident or opinion upon which you baseyour contention that you and your spouse are incompatible and that your marriage has suffered anirretrievable breakdown.9. If you contend that your spouse is not a fit and proper person to have the care, custodyand control of your minor child, state each and every fact upon which you base your contention.10. Describe in detail your present physical, mental and emotional condition.11. State in detail every occasion in which you have cursed or directed abusive language toyour spouse.12. State in detail every occasion in which you have ever hit, beat, struck, slapped or kicked
your spouse.13. List the names and addresses of each and every fact or expert witness whom you eitherhave spoken to in connection with this action or expect to call as a witness at the trial of this cause.14
If you contend that your spouse has had during this marriage, or is now having, sexualrelations with a person other than you, give details.15. If you have ever expressed dissatisfaction with your spouse as a sexual partner, parent,intellectual companion or otherwise, give details.16. Explain in detail each and every complaint which you have against your spouse whichyou contend is a valid basis for alleging incompatibility or irretrievable breakdown of this marriage.17. If your spouse has ever struck, slapped, kicked or otherwise touched you in an offensivemanner, give details.18. List each corporation in which you own stock, including in your answer the name of thecorporation, the number of shares owned by you, the date acquired, the purchase price paid for said stock,the number of shares of stock outstanding in said corporation, the business in which the corporation isengaged, and the amount of dividends or other compensation you have received from each corporationduring each of the last three (3) years.19. If you have sold, transferred or assigned any corporate stock or other interest in anycorporation in the last three (3) years, please state the name of the corporation, the number of shares sold,and the date of such transfer.20. If you have at any time during the last three (3) years had an account with any broker orbrokerage firm, please give the name and address of the brokerage firm, and your name and address asshown on each account.21. List all promissory notes, mortgages or bonds held by you either individually or jointlywith some other person, including in your answer the nature of each obligation (whether note, mortgageor bonds, etc.).22. State the amount of cash you presently have in your possession or subject to your control

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