Discovery Interrogatories

As you may already know, discovery is part of

the divorce process. It refers to a process by
which each party seeks to acquire necessary
information for trial including:
All assets
All liabilities
All financial and income information
All relevant factual allegations that will be
made by the opposing party
All potential witnesses
All potential documentary exhibits and other
evidence to support their case
Interrogatories are one form of this discovery.
They are simply written questions that are
submitted to the opposing party in a lawsuit.
Those questions must be answered in writing
under oath or under penalty of perjury within a
specified time (usually 30 days). Objections
may be made to questions that are overbroad,
unduly burdensome  or unlikely to lead to
admissible evidence.

Most states limit the number of interrogatories

that may be asked without the court's
permission to keep the questions from being a
means of oppression rather than a source of
information. Some states, such as Illinois
even have standard interrogatory questions
that may be asked.

Interrogatory questions may vary from case to

case depending on the issues that are in
dispute and the particular facts of the case.
Below you will find some sample questions.
Remember, these questions may not be right
for your case.

   State your present residence address, and

identify all other persons residing at your
residence address.

   escribe in detail your educational background,

and include the names and addresses of all
institutions that you have attended, the dates
of attendance, and a description of the
degrees or certificates that you have obtained.

   If you currently lack certification in any field in

which you have a degree or have received
training, describe in detail any and all
requirements you must fulfill in order to obtain
 certification, how those requirements can be
met, the time necessary to fulfill the
requirements, and the costs of fulfilling the
requirements.

    Describe each position of employment held

by you since,  and include the name and
address of your employer, the dates of your
employment, your official title, if any, a
description of all compensation that you
received including bonuses, and any benefits
provided by the employment.

   Describe in detail all of your sources of

income or compensation, whether or not
reported on any tax return, since      , and, as
to all income and assets or services received,
set forth the income, assets or services
received, the nature and amount of any
deductions or set-offs, and the net amount
received.

   State whether or not you have taken any

action since       to qualify for or secure Social
Security benefits, workers' compensation
benefits, unemployment compensation
benefits, or any form of public assistance,
and, if so, describe in detail the action taken,
the results of such action, any benefits
received, and the anticipated duration of any
benefits.

   Set forth in detail each and all of your assets,

not including household goods and
furnishings, and state the:

a.  A complete description of each asset (if

real property, set forth the common address
and the full legal description, and, if securities,
set forth the name of the issuer, the date of
issue, the certificate number, and the number
of shares or other type of denomination);

b.  The exact name or names of the record

and/or registered owners thereof;

c.  The date of acquisition;

d.  The original cost, if any (and, if the same

was acquired in any other manner than by
purchase on your part, describe the manner of
such acquisition);

e.  The tax basis;

 f.   The current fair market value as of the date
of the Answers to these Interrogatories; and

g.   All encumbrances, if any, against the

asset, setting forth the name and address of
the encumbrance, the date of the
encumbrance, the original amount thereof, the
present balance thereof, and the nature of the
payoff.

   If you have any interest in a sole

proprietorship, joint venture, or partnership, or
if you have five percent (5%) or more shares
of the stock in a closely held corporation, set
forth as to each such entity:

The date and place of organization;

A detailed statement of its capital structure and

your
investment in the entity;

The names, addresses and ownership interest of

all
officers, directors, shareholders and owners;

Whether or not there is any restrictive sales

agreement
between you and any others as to each entity, and, if
so,
the details of such agreement.  In lieu thereof, a copy
of
each such agreement may be attached;

A detailed description of the nature of the

business
engaged in by such entity;

Your tax basis in the entity;

The current fair market value of your interest;

Any encumbrances against your interest; and

A description of any services you render for the

entity.

    List all household goods and furnishings in

your possession and state your opinion as to
the fair market value of each item.

    Identify any particular household goods,

furnishings, or other assets to which you
assert a specific claim or right, and state the
factual grounds upon which any such specific
 claim or right is based.

    With respect to the homestead of the parties,

state your desires and/or plans as to the
following:

The duration and conditions of the use and

occupancy,
the identity of the proposed occupants, and the
reasons in
support of such occupancy; and

Any proposed sale or other disposition of the

property,
including the desired terms and the date of sale.

  If any sales, assignments, or gifts of real or

personal property (including cash) having a
fair market value in excess of $_______ were
made by you since_____, set forth:

A full description of any such real or personal

property
sold, assigned or gifted; the date thereof; the name
and
address of the purchaser, assignee, or beneficiary;
the
price, if any, charged therefore; and the terms of any
such
transaction, including the nature of the pay-off to you,
if
any, as to each such asset sold, assigned or gifted;
and

The complete details as to the disposition by you of

the
proceeds of any sale referred to in Subpart "a" of this
Interrogatory.

    If any person, corporation, partnership, or

entity of any nature owes you any money,
then for each debtor state:

The name and address of the debtor;

The amount due as of the date of these

Interrogatories,
the basis for the indebtedness, whether there is
written
evidence of the indebtedness, the date the
indebtedness
was incurred, and the terms for repayment; and

Whether the obligation is contingent and a

description
of any such contingency.

    Set forth the name and address of each of

your creditors, the basis for each debt, the
contents of any written evidence of each debt
(or attach a copy of such written evidence),
the date each debt was incurred, the amount
due on each debt as of the date of the
Answers to these Interrogatories, whether the
obligation is contingent, and a description of
any such contingency.

    Set forth the name and address of each

depository in which you have had any
checking account, savings account, money
market account, certificate of deposit, trust
certificate, and any other account in your
name, or with any other party, since
___________, and state the balances in each
of said accounts as of ___________.

    If since ____________, there have been any

bank accounts or depositories on which your
name did not appear and in which you have
deposited any money, state the place of the
deposit, the address of the depository, the
name of the account owner, the date of your
deposits, and the reason for the deposit by
you in the account.

    If you have any safe deposit boxes, state

where they are located, when first rented, and
give a detailed description of the contents of
each such box on January 1st of this year and
as of the date of the Answers to these
Interrogatories.

    If you have created any trust, either

irrevocable or revocable, describe in detail
each instrument incorporating such trust.  In
lieu thereof, a copy of each trust instrument
may be attached hereto.

    If you are a beneficiary of any past, current

and/or prospective annuity, trust, will or
estate, either irrevocable or revocable,
describe in detail any documents evidencing
your interest. In lieu thereof, a copy of the
documents may be attached hereto.

    Set forth any other tangible or intangible

property not referred to in any previous
Interrogatories, including any options to
acquire property or any property held for your
benefit by any firm, person or business entity,
 and for any such item state:

A detailed description of the property or option to

acquire property;
The purchase price;
The present market value; and
The name and address of any person, firm or
business
entity holding such property for your benefit.

   Describe each policy of life insurance on your

life and/or your spouse's life, setting forth the
name of the company issuing the policy; the
number of each policy; the face amount of
each policy; the type of insurance, whether
whole, endowment, level term, reducing term
or otherwise; the names of the primary and/or
contingent beneficiaries designated in each
policy; and the amount of cash surrender
value for each policy as of the date of the
Answers to these Interrogatories.  If there has
been any change in the ownership, the
primary or contingent beneficiaries, or the
cash value of any of said policies since
____________, describe the changes and
include the date of such changes.

    State whether or not you have any beneficial

interest in any profit sharing, pension or
retirement plan and describe the plan in detail
indicating the gross amount of your beneficial
interest, whether vested or unvested; the
present fair market value of your interest; the
calculations which support your conclusions
concerning the present fair market value of
your interest; the name and address of the
trustee of the plan; the increase in the value of
your interest since ____________.  The
projected increase in value of your interest in
the present calendar year; and the name of
the administrator of the plan if different from
the name of the trustee.

    Describe in detail any program of medical,

dental, or disability insurance available to you
through your employment or otherwise and
indicate all eligible beneficiaries of said plan.

    If since _____________, you have prepared,

or had prepared, any financial statement or
lists of your assets and liabilities including, but
not limited to, any such documents prepared
for any lending institution or bank, for each
such financial statement or list of assets, state
the:
 Date of preparation;
Person or entity preparing the document;
Purpose for which the document was prepared;
Information contained therein.  In lieu thereof, a
copy
of each document may be attached hereto; and
Name and address of the person presently having
custody of each document.

   If since ____________, any sole

proprietorship, partnership, or corporation in
which you own an interest prepared, or had
prepared, any financial statements or lists of
assets and liabilities including, but not limited
to, any such documents prepared for any
bank or lending institution, for each financial
statement or list of assets, state the:

Date of preparation;
Person or entity preparing the document;
Purpose for which the document was prepared;
Information contained therein.  In lieu thereof, a
copy
of each document may be attached hereto; and
Name and address of the person presently having
custody of each document.

   Set forth the names and addresses of the

accountants or accounting firms who have
done accounting work for you personally or for
any business in which you have had an
interest since      .

   Set forth the names and addresses of all

stockbrokers with whom you have done
business since      .

    Describe in detail any and all written

appraisals made or caused to be made by you
or on your behalf with respect to any of your
assets listed in response to the preceding
Interrogatories. In lieu thereof, copies of the
written appraisals may be attached hereto.

    Identify each item of real or personal property

which you claim to be "non-marital property"
as defined by Minn. Stat. § 518.54, subd. 5,
by providing the following:

a. A description of the property;

b. The identity of the person from whom the property

was
acquired;
 The date of acquisition;

The manner in which the property was acquired

(i.e. by
gift, inheritance, purchase, etc.);

The market value at the time of acquisition;

The present market value;

Whether any gains, interest, dividends, rent, or

other
income has been received incident to your ownership
of
this property;

The disposition of any gains, interest, dividends,

rent or
other income received incident to your ownership of
this
property;

The facts upon which you rely in asserting that the

property is "non-marital" as defined by Minn. Stat. §
518.54, subd. 5; and

For each item of property which you assert to be non

-marital because it was acquired in exchange for
another
item of non-marital property, provide the information
requested in subparts "a" through "i" above with
respect to
the original item of non-marital property that was
exchanged.

    Describe each and every liability you had on

the date of your marriage to , and indicate
how and when each liability was satisfied.

    For each automobile, recreational vehicle,

trailer, motor, or boat owned or used by you
state the:

The make, model and year;

The owner;
The license plate number and state of issue;
The fair market value;
The name of the secured party;
The balance of any encumbrance thereon;
The amount of monthly payment; and,
The names of all persons using it.

   Describe in complete detail the contents of

any books, records or other documents
 reflecting income and/or expenses that you
have prepared or maintained since
___________.  In lieu thereof, copies of such
documents may be attached hereto.

    Set forth with particularity an itemized

schedule of your average monthly living
expenses (stating separately, wherever
possible, all expenses relating to the minor
child(ren)).

    If you have included expenses in your

itemized schedule of average monthly living
expenses for anyone other than yourself and
the minor child(ren) from your marriage to
herein, state with specificity what other
expenses have been included and to whom
the other expenses are attributable.

    As to each expense, state whether it has

been paid by check, money order, cash, or
some other medium of payment.

   If you anticipate an increase or decrease in

your income or any of your expenses, state
the nature and amount of the increase or
decrease, the reason for the increase or
decrease, and the date you expect the
increase or decrease to occur.

   State the permanent legal and physical

custody arrangements that you believe are in
the best interests of the minor child(ren) of the
parties, and specifically address the time that
each parent should have with said child(ren).

    Describe in detail the parenting

responsibilities assumed by each party during
the marriage and subsequent to the
separation of the parties, and specifically set
forth the time spent by each party with the
minor child(ren) during the marriage and
subsequent to the separation of the parties.

    If you or any of the minor child(ren) of the

parties have been seen, tested, evaluated, or
treated by any professional person such as a
psychiatrist, psychologist, sociologist, social
worker, family counselor, or other
professional, since      , identify the
professional by name, address and area of
practice, state the date of each contact with
the professional, explain the purpose of each
contact, and indicate whether the contacts are
continuing.
    Describe with particularity any medical care or
treatment that you or (any of) the minor
child(ren) receive or have received on a
regular basis, identify the person rendering
such treatment, and state the costs thereof.

    If you suffer from any physical or mental

impairment or infirmity, describe such
impairment or infirmity in detail and include a
complete description of the diagnosis, course
of treatment, any restrictions imposed and the
prognosis.

   For each criminal, civil, domestic abuse, or

other incident reported to the police, in which
you have been involved since
_______________, state the:

The nature and substance of the complaint or

incident;
The county and state in which the complaint or
incident occurred; and
The disposition of the complaint or incident.

   If you have been cited for any offense or

charged with any crime since ____________,
for each matter state the:

The date you were charged or cited;

The offense or violation for which you were
charged or

The date of the alleged offense or violation;

The names of any persons who were witnesses
to the
alleged offense or violation;
The disposition or outcome of the charge or
citation;
The dates of any incarceration or treatment;
The county and state in which you were charged
or
cited; and
The name and location of the court in which
proceedings occurred as a result of the charge or
citation.

   State the name and address of each witness,

expert or otherwise, that you intend to call on
your behalf in this proceeding, and for each
such witness, state:

   The substance of the facts and opinions to

which the witness is expected to testify;
   Any assumed facts upon which the witness
 will rely;
   A summary of the grounds for each opinion;
   The contents of any documents upon which
the witness will rely.

Print out and prepare responses

I.
INSTRUCTIONS
A. These are sample written questions that you might receive in your divorce. These questions
are referred to as “Interrogatories”. While the Interrogatories you receive may not be exactly like
these, they will be substantially similar. Please read through these Interrogatories and prepare
your responses, this will save you time and trouble in the future.
B. Below are the instructions for the actual Interrogatories.

(1) Each interrogatory should be answered separately upon the knowledge or upon the
information and belief of the responding party, and any answer based upon information and
belief should state that it is given upon such basis.
(2) If the complete answer to an interrogatory is not known, so state and answer as fully as
possible each part of such interrogatory to which the answer is known.
(3) The following interrogatories shall be continuing to the full extent permitted under the
applicable provisions of the Georgia Civil Practice Act.
(4) If any information is withheld under any claim or privilege, the following shall be provided
with respect to such information: every person to whom such information has been
communicated by the responding party, and from whom such information was learned by the
subject matter of such information, and the basis upon which such privilege is claimed.
II.
DEFINITIONS
(1) As used herein, the word "Spouse" shall mean your spouse, including all officers, attorneys,
agents, employees and representatives acting on your spouse’s behalf, its predecessors and/or
successors.
(2) As used herein, the word "You" shall mean you, including all officers, attorneys, agents,
employees and representatives acting on your behalf.
(3) As used herein, the words "you" or "your" shall refer to You as defined hereinabove.
2002 David J. Casey Interrogatories Page 1 of 14
(4) As used herein, the words "every document" shall mean every writing or record, however
produced, reproduced or preserved, including, but no limited to every book, pamphlet,
periodical, letter, memorandum, telegram, report, record, study, inter-office and intra-office
communication, memorandum reflecting an oral communication, handwritten or other notes,
working paper, draft, application, permit, chart, drawing paper, graph, survey, index tape, disc,
data sheet, data processing card, computer print out and every other written, typed, recorded,
transcribed, filed or graphic matter, except such documents as are immune from production
under applicable law.
(5) As used herein, the word "person" shall include individuals, firms, partnerships, corporations,
proprietorships, associations, governmental units and every other type of organization or entity.
(6) As used herein, the word "date" shall mean the exact day, month and year, if ascertainable,
or otherwise the word "date" shall mean the best available approximation (including
relationships to other events).
(7) As used herein, the word "identify", when used in reference to:
(a) An individual, shall mean to state his or her full name, present or last known residence
address (designating which), and present or last known (designating which) business affiliation,
job title and employment address.
(b) A firm, partnership, corporation, proprietorship, association or other organization or entity,
shall mean to state its full name and present or last known (designating which) address and
telephone number.
(c) A document, shall mean to state the title, if any, the date, author, sender, recipient, the
identity of persons signing it, type of document (i.e. a letter, memorandum, book, telegram,
chart, etc.) or some better means of identifying it, a summary of its contents, and its present
location or custodian. In the case of a document within the possession, custody, control or
access of You, whether You will make it available to the undersigned attorneys for inspection
and/or copying; and, in the case of a document that was, but is no longer in the possession,
custody or control of You what disposition was made or it, when and to whom.
 III.
INTERROGATORIES
The following should be answered pursuant to O.C.G.A. §9-11-33 and all other provisions of the
Georgia Civil Practice Act.
1.
1. Please state your full name, giving all previous names, if any, by which you have been known.
2. What is your date of birth?
3. Please state the country, state, county and city of your birth
4. Please list the following information with respect to your current residence and all locations at which
you have previously resided since the date of your marriage to the present:
a. Address (street, apartment number, city, county and state);
b. type of residence (apartment, duplex, condominium, or single family dwelling);
c. Size of residence (number of square feet, number of bedrooms and number of bathrooms);
d. Beginning and ending dates of your residency at each location;
(e) other persons, besides yourself, including relatives and children, who now reside or have
resided, including dates, with you at each location.
5. Please give the following information with respect to your educational background:
a. High School from which you graduated and year of graduation;
b. Name and location of each college and university which you have attended as student, giving
beginning and ending dates of such attendance;
c. Any college or university degrees which you now hold, giving the date you received each degree,
the college or university and field of concentration (i.e. major and minor);
d. Any education or vocational training other than the above which you have received, giving the
names of the school(s) or institution(s) and the beginning and ending dates of your attendance
as a student.
6. With regards to employment since the date of marriage, please identify the following:
a. Your present and past employment;
b. Nature and description of your duties at each employment;
c. The gross income or earnings received from the employers listed on an annual basis;
d. If self-employed, please identify the nature of your work;
e. Do you have plans to change your present employment in the foreseeable future;
f. Have you interviewed or consulted with anyone concerning a change in your employer or
employment status within the past six (6) months. If so, please identify the future employer or
employment;
g. If not employed, do you have any skills or training which will enable you to obtain a job;
h. If not employed, have you ever attempted to obtain employment, and if so, please identify whom
and/or where you made such attempt.
7. Please list each and every source of income you have had since the date of marriage, including, but
not limited to, identifying the source, the salary or wages, commission and bonuses received by
you in each employment, interest, dividend and the amount of your gross income as shown on
your Federal Income Tax return, W-2 or 1099; or, if self employed, the name of any business
interest from which you drew an income, and the amount of the draw.
8. Do you have the use or possession of an automobile or other motor vehicle? If so, please state the
style, make and model of each automobile and the name of the respective owner.
9. Do you have the need of an automobile for personal transportation?
10. Are you a member of any social or civic organization? If so, please identify each such organization
and the beginning and ending dates of membership.
11. Are you a member of a professional or business organization or club? If so, please identify each
such organization(s) or club(s) and the beginning and ending dates of membership.
12. Do you have children born of this marriage with your spouse? If so, please answer the following:
a. Identify each child;
b. Birth date of each child;
c. Birthplace of each child;
d. School, kindergarten or nursery attended by each child.
13. Do you have children born of a previous marriage or relationship with anyone other than your
spouse? If so, please answer the following:
a. Identify each child;
b. Name, age and birth date of each child;
c. Current custodian of each child;
d. Identify each person with whom you had the child with giving the name, address and age of that
person.
14. Has any one of your children attended a private school? If so, please state the child, identify the
school, giving the beginning and ending dates of attendance and the tuition.
15. Please list all charge accounts or credit cards which you now use or of which you have possession
or control, including, but not limited to, the average monthly balance due for each of the listed
accounts or cards for since the date of marriage.
16. Where do you normally buy clothing for your self and your children?
17. What amount of money did you spend on clothing each year since the date of marriage for clothing
for yourself and the children?
18. Have you taken any vacations or trips since the date of marriage? If so, please identify where you
went, with whom and what your expenses were.
19. What percentage of your meals are taken in your home, and what percentage are taken outside the
home?
20. Please give the following information with respect to your leisure time activities:
a. Do you have hobbies or participate in recreational activities?
b. What do you typically do in your leisure time?
c. Do you own recreational equipment or vehicles (e.g. golf clubs, camping equipment, boats,
vehicles, etc...)?
21. Please give the following information with respect to your health and physical condition:

(a) What is the present condition of your health?

(b) Are you now under the care of a health care professional? If so, please state the condition
for which you are being treated.
(c) When was the last time you consulted with a health care practitioner?
(d) Do you have an immediate need for health care attention? If so, please state the condition
for which you need treatment.
(e) What did you spend for personal medical services in the past year?
(f) Do you have a foreseeable need for dental services? If so, please state the condition for which
you need treatment.
(g)
(h) What did you spend for dental services in the past year?
22. Please describe any real property you now own or have owned or have any interest in at any time
since the date of this marriage to the present. Your description should include, but not limited to,
the nature of your interest, the address, including a complete legal description thereof; the
method of acquisition of interest; the date of acquisition; the purchase price; what portion of the
purchase price was in cash and what portion was financed; and the present balance due on the
purchase price.
23. Please state whether, as of the date of your receiving these interrogatories, you have any interest in
an option to acquire an interest in real property. If so, please state the terms of the option(s), the
optionee(s), and give a description of the real property subject to each option.
24. Please list all transfers of property, both real and personal, which you have made since the date of
marriage to any individual or legal entity, describing the property transferred, the date of the
transfer, to whom the such property was transferred, the consideration paid by such transferee
and the consideration paid by you at the time of acquisition of each property.
25. Please list each corporation in which you own stocks, bonds debentures, franchises or operating
rights, or of which you may be the payee of any note. With respect to each corporation, please
give the following information:
a. If you own stocks, state the number of shares of each class outstanding and the number of
shares of each class held by you. List the total amount of dividends you have received on each
of these stocks.
b. If you own debentures, state the total number and denomination of debentures held by you. Also
state the terms of the debentures, including the date of maturity and annual interest or coupons.
c. If you hold bonds, state the total number and denomination of bonds held. Also, state the terms
of the bonds, including the date of maturity and annual interest or coupons.
d. If you hold a franchise or other operating rights, please state in detail the nature of each franchise
or operating right, including when and where acquired.

e. If you have any other type of claim against any corporation, whether represented by a note or
otherwise, state the nature of the claim, the amount of the claim, and how evidenced with
respect to each corporation concerned.
f. State the date of acquisition by yourself with respect to any stocks, bonds, debentures, notes or
other claims or evidence of indebtedness listed in response to this question.
g. If any of the stocks, bonds, debentures, notes or other evidence of indebtedness listed in the
answer to this question are pledged as collateral, or otherwise used as security by you, state
what is pledged, to whom pledged, and the amount of the debt for which it is pledged or used as
collateral, as well as the date of the pledging.
26. Please identify all municipal bonds owned by you as of the date of filing these answers; please
state the date of acquisition, purchase price, maturity date, and interest rate with respect to such
bonds.
a. If you owned municipal bonds at any time during the marriage, or acquired thereafter, which you
no longer own, state the date of acquisition, purchase price, date upon which your title was
divested, whether by gift, sale or other transfer, and the consideration received, if any.
b. If any of the bonds listed in answer to this question are pledged as collateral, or otherwise used
as security by you, state what is pledged, to whom it was pledged, and the amount of the debt
for which it is pledged or used as collateral as well as the date of pledging.
27. With respect to any business venture, whether it be a corporation, a general or limited partnership,
sole proprietorship, joint venture, trust, or otherwise, in which you have a financial interest or
from which you have received income, please state the following:
 a. The name and principal location of the business, the financial interest which you have, the date
or dates the interest was acquired and the consideration paid;
b. The names and addresses of all other persons having a substantial interest in such business and
the ratio or proportion that your interest has to the interest of all others therein;
c. If any such business has an interest in real property, list such holdings, giving the date of
acquisition and acquisition price. Describe the improvements, if any, on such real property.
d. Attach the two (2) most recent operating statements and annual balance sheets, or similar
financial reports, with respect to each business venture;
e. If you owned an interest since the date of marriage, or acquired an interest thereafter, but did not
own an interest as of the date of filing these interrogatories, state the name and principal
location of such business, the date on which such interest terminated, whether by gift, sale or
otherwise, and the consideration received with respect to each business.
28. Have you paid a fee a stockbroker or investment counselor within the past two (2) years? Is so,
please state the name of each person or company and the amount paid.
29. Please state whether or not you own an interest in oil or gas wells? If so, please state the following:
a. The fair market value of you investment;
b. The names of all other individuals or legal entities having an interest in the involvement;
c. The amount of income received by you from your interest since the date of marriage.

30. Please list all loans made by you to any person(s) other than corporations which have not been
satisfied as of the date of filing these Interrogatories, and state the following with respect to such
loan(s):
a. Identify the borrower, the amount loaned, the terms of the loan, including interest rate and
manner of payment, the amount due, both interest and principal;
b. If any loans are secured by collateral, describe the collateral securing such loan.
31. Do you have or have property located in a safe-deposit box(s), safes, vaults, or other places of
safekeeping valuable papers. If so, please:
a. List the location of all safe-deposit boxes, safes, vaults, or other places of safekeeping valuable
papers in the name of or used by yourself as of the date of filing these interrogatories;
b. Prepare an itemized inventory of all items kept in the place described in “a” above;
c. Identify the owner or holder of the place described in “a” above
32. Please prepare an itemized inventory of all your stocks, bonds, securities, notes, receivables,
deeds jewelry and other valuable papers and items not included in the answer to the preceding
interrogatory, and indicate the place where such item(s) are located.
33. Please describe any savings, checking, or commercial accounts in your name solely or jointly with
others, with any bank, or financial institution since the date of marriage you have had. Your
description should identify the bank or financial institution; type of account; the names on the
account; the name and present address if such information as is known to you concerning all
persons authorized to withdraw from the account; the account number; the amount of the
present balance in each account thirty (30) days prior to the filing of these interrogatories.
34. List all cash (in excess of $500.00) which was at any one time given or transferred since the date of
this marriage to any relative by blood or marriage, or any other individual or legal entity. State
the date of such transaction, identify the recipient, the amount involved and the purpose for
which such transfer was made.
35. Please describe any assets which you, within six (6) months prior to the filing of the pleading for
divorce to the present date sold, transferred, or encumbered. Your description should include,
but not limited to a description of the asset or assets that were sold, transferred, or encumbered;
the date of each transaction; and the party, firm, or agent who acquired your asset or assets.
36. Please list all transfers, gifts, or other acts whereby custody or possession of property, real or
personal, was transferred by you to any trust since the date of marriage. With respect to such
transfers, state the date of the transfer, the beneficiaries of the trust, and the acquisition cost of
the transferred property to you.
37. Please list any trust created by you, stating the date if its creation, the names of the trustees, the
beneficiaries, the terms of the trust, including the date or event upon which it will terminate and
the amount and source of the corpus of the trust.
38. List any trust(s) not included in the answers to the two preceding Interrogatories of which you are a
trustee. Please state the date of creation, names of the other trustees, the beneficiaries, the
terms of the trust(s), including the date or event upon which it will terminate and the amount of
the corpus of the trust(s).
39. Please list any trust(s) of which you are a beneficiary, and with respect to such trust(s), please state
the following:
a. The amount and original source of the trust corpus;
b. The annual income of the trust(s) for the past 2 years, the amount of income distributed to the
beneficiaries, and the amount received in each of the last two (2) years by each beneficiary;
c. The date of any encroachment of trust corpus paid to or used for the benefit of yourself.
40. Please list any estate, will and testament of which you have been an heir, devisee, legatee, or have
in any way received property. With respect to such estate, please state the following:
a. Identify the decedent, date of death, decedent’s relation to you, if any;
b. Identify the executor or administrator or personal representative;
c. All property, real or personal, which was received by you, or to which you are entitled;
d. Identify all other persons who have received property from such estate.
41. Please list all estates not included in the response to the preceding Interrogatory for which you are
an executor or administrator or personal representative or have held such position since the
date of this marriage.
42. Please describe any interest you may have in any life insurance or annuity policy, including
retirement. Your description should include, but not limited to, the name and address of the
insurance company; the type of policy (e.g., term, whole life, variable, etc.); the date on which
the policy was issued; the face amount of the policy; the amount of the annual premiums; the
surrender value, if any, as of the date of filing these answers to this Interrogatory; the name and
address of each owner of the policy; the date of assignment of the policy and the name of each
assignee, if the policy has been assigned; and the date of any change of beneficiary(ies)
effected by you as to the policy.
43. Please list all current loans to your self from any bank or lending institution. With respect to each
loan, please identify the lender, the date of the loan, the terms of the loan and the purpose of
the loan.
44. Please identify any and all financial statements you have compiled and/or submitted to any bank,
mortgage company or other lending institution including the date the financial statement was
submitted and purpose for submitting same.
45. Please state whether or not you have filed income tax returns with the State and Federal
governments for each year since the date of marriage. If so, please state the following (or attach
a complete copy of the returns):
a. Place of filing;
b. Your gross income;
c. Amount of deductions claimed by you;
d. Your taxable income;
e. Tax paid or refund given.
46. Please describe any personal property or real property or sum of money which you claim as your
separate property. Your description should include, but not limited to: a description of the
property; the present value of the property; the date and method of acquisition of the property;
the source of the funds used to acquire the property; the name of each owner of the property
and the respective ownership interests; the facts upon which you base the claim that the
property is your separate property.
47. Please state the names, present addresses and telephone numbers concerning all persons known
to you or your attorney(s) who will or may be called as witnesses in this action.
48. If you intend to call any expert or technician as a witness as the trial of this action, please state the
subject matter on which the expert is expected to testify and, state in detail, the opinions held by
such expert or technician and give a complete summary of the grounds for each opinion held.
49. Please describe in detail what, if any, grounds you have for divorce against your spouse, or what, if
any, complaints you now have against your spouse as a spouse or parent.

50. If you are claiming you should be awarded custody of the minor children, please list each and every
reason why:
a. You should be awarded custody; and
b. Your spouse should not be awarded custody.
51. Have you had sexual relations with any person, other than your spouse, since the date of marriage.
If so, please:
a. Identify the person with whom you had sexual relations;
b. Approximate date(s) of those sexual relations;
c. Where those sexual relations occurred (State, county, city, hotel, motel, or other place).
52. Please identify each person who has assisted in the preparation of the answers to these
Interrogatories, the capacity in which he/he assisted and the assistance given.
6. Identify yourself and all individuals with whom you reside. For each individual other than
yourself, state that individual's age, relationship to you, and marital status. State your own birth
date and social security number.
8. If you are currently employed in any capacity, identify each current employer and, for each
employment, state: (a) your job title, (b) your duties, (c) the number of hours in your average
work week, (d) your regular pay period, (e) your gross wages per pay period, and (f) the
deductions per pay period made by your employer from your wages. If overtime work was
available to you during the past 12 months, state: (a) the number of overtime hours you worked
during the 12 months and your rate of pay for those hours and (b) the number of overtime hours
that were available to you during the 12 months but that you did not work and the rate of pay
you would have received if you had worked those hours. (Standard Domestic Relations
Interrogatory No. 3.)
12. Please list each and every effort made by you during the past two years to secure gainful
employment, including: the dates attempts were made; the name, address and telephone
number of the individual or entity to whom the inquiry was directed; the position applied for; the
salary being offered for said position; whether or not a job was offered, and if so, why it was
refused.
16. Describe your career objectives and plans to progress toward becoming self-8

2. Do you own or rent your home? If you rent, when does your lease expire? Also, please
describe the physical layout of your home and the room in which the children will sleep and the
name of anyone that will share the sleeping quarters with the children.

ANSWER:

3. Why are you seeking custody in this case?

ANSWER:

4. Are you seeking joint or sole legal custody? State with particularity why you believe this is in
the children’s best interest.

ANSWER:

5. Are you seeking to be the residential parent? State with particularity why you believe this is in
the children’s best interest.
ANSWER:

6. Is spouse a fit and proper person to have the custody of the children? If no, why not? If yes,
why? (Name, identify and describe each and every incident which forms a basis for your belief.)

ANSWER:

7. Are you and spouse able to communicate and cooperate with each other regarding the best
interests of your children? If no, why not? If yes, why?

ANSWER:

8. Is spouse any danger to your children? If yes, how?

ANSWER:

8. Is spouse any danger to your children? If yes, how?

ANSWER:

9. Is spouse a fit and proper parent? If no, why not? If yes, why?

ANSWER:

10. Please list the illness, treatment, and treating physician for any illnesses or infirmities
suffered by you within the last five years.

ANSWER:

11. Have you ever been treated for any nervous breakdowns, nervous disorder, substance
abuse, or mental illness within the last five years? If yes, provide complete details regarding
such conditions and treatment.

ANSWER:

12. Please describe the current status of any treatment, counseling, and/or therapy you are
currently receiving.

ANSWER:

13. Please list the names and addresses of any and all schools the children may attend should
you obtain custody. Describe in detail any investigation you have done into possible schools the
children may attend. Also, in what school do you intend to enroll the children if you obtain
custody? Finally, please list the method by which the children will get to and from school.

ANSWER:

14. If you claim to have been the children’s primary caretaker, please describe in detail your
basis for such belief.

ANSWER:

15. If you deny that spouse has been the children’s primary caretaker, please describe in detail
the basis for such belief.

ANSWER:

16. Please describe your work schedule as it relates to your available time with the children,
including a description of day care arrangements.

ANSWER:

17. If the opposing party’s sexual conduct is an issue, please describe in detail the conduct and
any effect on the children.

ANSWER:

18. If the opposing party’s use or abuse of alcohol and/or drugs is an issue, please describe in
detail the conduct and any effect on the children.

ANSWER:

19. Please state the frequency with which you consume alcoholic beverages or use illegal
drugs.

ANSWER:

20. Please describe any and all of your convictions, including case number, county, and state,
for misdemeanors or felonies, excluding minor traffic violations.

ANSWER:

21. Please describe any agreement or lack of agreement between you and spouse regarding
issues relating to the children (e.g., education, religion, health care, activities, etc.).
 ANSWER:

SAMPLE INTERROGATORIES IN A CASE INVOLVING AN ALLEGATION OF

ADULTERY

1. Are you currently living with another person? If yes, please state the following:

a. that person’s name, age, and occupation

b. how long you have lived together

c. who pays which living expenses (Please attach copies of cancelled checks and receipts for

the expenses you pay.)

2. Please state if you have ever occupied a room in any hotel, motel, or other public inn with

any unrelated adult man at any time during the three (3) years immediately preceding the

filing of this action for divorce. If yes, please state the following with respect to each

incident:

a. the date of the stay

b. the name and location of the hotel, motel, or public inn

c. the period of time you occupied the room

d. the reason you occupied the room

e. the name and address of each person present at any time during such occupancy

the name of the person who paid for the room and the amount paid

3. Please state if you have ever engaged in sexual intercourse with any unrelated male, other

than your spouse, during the course of your marriage. If so, please state:

a. the name or names of individuals with whom you engaged in sexual intercourse

b. the date of such activity

c. the location of such activity

4. Please state whether you have ever received a gift of any kind including, but not limited to,
 jewelry, money, or other property from any unrelated adult man during the three (3) years

immediately preceding the filing of this action for divorce, and please indicate with respect

to each gift:

a. the name of the person who gave you the gift

b. the date the gift was received

c. a description of the gift

d. the approximate value of the gift

e. the reason or occasion for the gift

5. Have you given any gifts to any unrelated adult men during the three (3) years immediately

preceding the filing of this action for divorce? If yes, please indicate with respect to each

gift:

a. the name of the person to whom the gift was given

b. the date the gift was given

c. a description of the gift

d. the amount paid for the gift

e. how the gift was paid for (cash or credit)

6. Please state if during the three (3) years immediately preceding the filing of this action for

divorce, any unrelated male has loaned, co-signed a note, or personally aided you in

obtaining a loan for money, vehicles, refinancing, personal loans, etc. If so, for each

occurrence, please state:

a. the name of the person who aided you

b. the date of the loan

c. the amount of the loan

d. the balance due on said loan

7. Please state if during the three (3) years immediately preceding the filing of this action for
 divorce, any unrelated male has ever paid any expenses incurred by you. If so, for each

payment, please indicate:

a. the name of the person who made the payment

b. the date of the payment

c. a description of the expense

d. the amount of the payment

e. the name and address of the person to whom the payment was made

the reason the payment was made

8. Do you currently own or have you in the past three (3) years immediately preceding the

filing of this action for divorce, owned any interest in real estate; whether future, joint,

contingent, or otherwise; and whether in your name solely, in your name jointly with another

or others, in the name of another, or in trust? If yes, please state the following with respect

to each interest:

a. the location of the real estate

b. the purchase price and date

c. its fair market value if still owned or the selling price and date, if sold

d. the names of all owners of the property at the time you owned it

9. Identify any and all electronic mail addresses through which you have sent or received e-

mail during the three (3) years immediately preceding the filing of the pending action for

divorce. For each account, state the following:

a. any and all usernames used by you

b. the period of time during which you used each account

c. the names and addresses of all other persons you authorized to use each account

d. whether you have deleted e-mails from any accounts since institution of this action, and, if

so, the nature of the deleted messages

e. the name and address of the person or company that paid for each account

10. State whether you have subscribed to any online dating or matchmaking services during

the three (3) years immediately preceding the filing of the pending action for divorce.

Provide the following with respect to each such service:

a. your login or username

b. the dates during which you subscribed to each service

c. the total fees paid, by you or on your behalf, for each service

d. the username(s) of any persons to whom you have sent and from whom you have received

correspondence through such services

11. Please provide copies of any letters, e-mails, cards, etc. that you have sent to or received

from any unrelated adult male identified in response to Interrogatories 1 through 7 during

the three (3) years immediately preceding the filing of this action for divorce.

12. List the name, address, and telephone number of each person who has knowledge of

relevant facts concerning issues of adultery in this case and, for each person listed,

describe the nature of his or her knowledge.

31. If you are a member of a partnership, please provide the name, address and telephone
number of all partners, the amount of drawings or earnings for each partner, an accounting of all
monies drawn from the partnership or charged to your drawing or capital account, statement of
your capital account, at the beginning and end of each year and an itemization of all expenses
paid for travel, entertainment, petty cash and personal items for you from January 1, (Year)
through the date of trial.
35. If you received any assets during the marriage by way of gift or inheritance, whose value
exceeds $250, please identify each and every asset. A sufficient answer to this question must
include the name, address and telephone number of the donor, the date of the transaction and
the value of the item received.
36. If you contend that you owned assets prior to the marriage to which you now make a claim,
please list each and every asset. A sufficient answer to this interrogatory should include the
value of the asset, and the means utilized by you to arrive at said value.
37. Describe in detail each and every item of personal property, whose value exceeds $250,
owned by you or the &Client& prior to the marriage which may be traceable by you to a form
which currently exists today.
[Undisclosed/Dissipated Asset]
38. If you contend your spouse owns or owned, legally or beneficially, directly or indirectly, any
asset as to which full disclosure has not been made, or with respect to which there has been
any disposition that is improper, illegal or otherwise not related to marital purposes, please
provide all details, to include, but not be limited to, the identify of the asset, the date of its
acquisition, the person or entity from whom the asset was acquired, the fair market value at the
time of acquisition and at either the present time or at the time of its disposition and if you allege
the asset was disposed of, state the date of its disposition and identify the person to or
through which such disposition was effected.
[Changes to Financial Statement]

42. State the date on which you separated from your spouse and describe the circumstances of
the separation. (Standard Domestic Relations Interrogatory No. 14.)
43. If you contend that you are entitled to a divorce because your spouse's conduct toward you
or your minor child was cruel or vicious or that your spouse constructively deserted you,
describe your spouse's conduct and state the date and nature of any injuries sustained by you
or your minor child and the date, nature, and provider of health care services rendered
regarding the injuries. Identify all persons with personal knowledge of your spouse's conduct
and all persons with knowledge of any injuries you or your minor child sustained as a result of
that conduct.
44. State the date on which you and your spouse last had sexual relations with each other.
45. If you have had sexual relations with a person other than your spouse during your marriage,
identify the person(s) with whom you have had sexual relations, state the date of each act of
sexual relations, and state the location where each act took place. If you refuse to answer this
interrogatory as framed because the answer would tend to incriminate you, so state and answer
for the period ending one year prior to the date of your answers. (Standard Domestic Relations
Interrogatory No. 17.)
46. If you have had sexual relations with a person other than your spouse during the marriage
and you contend that your spouse has forgiven or condoned your actions, state the facts upon
which your contention is based. (Standard Domestic Relations Interrogatory No. 18.)
47. Please give the name, address and telephone number of any detective hired by you or your
attorney to obtain information regarding the activities of the [Plaintiff/Defendant].
48. List the name, address and telephone number of any and all persons with whom you claim
the [Plaintiff/Defendant] committed adultery, and detail each and every instance.
49. If you, since the date of your marriage, committed adultery and/or had sexual
relations/contact with any person other than your spouse, please give the name, address and
telephone number of each and every individual with whom you committed adultery and/or each
and every individual with whom you had sexual relations/contact; the dates and places of each
act; and the name, address and telephone number of each and every individual with knowledge
of each act.
50. Please state whether or not you deserted your (Spouse) and (dependents) on (Month day,
year), and if the answer to this question is no, please explain, in detail, the reasons why you left
the marital home.
51. Please give the name, address and telephone number of each and every individual who can
corroborate the facts enumerated in answer to Interrogatory No. 47 above.
52. If you contend that your spouse is not entitled to a divorce on the grounds alleged in
[his/her] pleadings, then state all facts which support your contention, and identify those
persons who have personal knowledge of these facts.
53. If you contend that your spouse was totally or partially responsible for the estrangement of
you and your spouse, state the facts upon which you base your contention and identify those
persons who have personal knowledge of these facts.
[Child Custody - Fitness]
54. If you contend that your spouse is unfit to have custody of the children, state the facts upon
which your contention is based and identify all persons having personal knowledge of these
facts. If your contention is based on the use of controlled dangerous substances or the abuse of
alcohol on specific occasions, identify the substance used, the other persons present at the
time of the use, and the date, time, and place of the use. If your contention is based on the
repeated use of controlled dangerous substances or the repeated abuse of alcohol, identify the
substance and all persons with personal knowledge of the repeated use or abuse. (Standard
Domestic Relations Interrogatory No. 19.)
[Medical Care Providers]
55. If you have sought or received treatment or therapy at any time during the past 10 years for
any physical, mental, or emotional condition, including drug addiction or alcoholism, describe
the condition and the treatment or therapy provided, state the date or dates of treatment or
therapy, and identify all persons providing treatment or therapy. (Standard Domestic Relations
Interrogatory No. 20.)
[Child Custody]
56. If you contend that placing the children in your sole, shared, or joint custody will be in their
best interest, specify the facts and circumstances upon which you rely. (Standard Domestic
Relations Interrogatory No. 21.)
57. Describe the child care plan you intend to follow when the children are with you. Include in
your answer a description of the place where the children will reside, specifying the number of
bedrooms, bathrooms, and other rooms, the distance to the school which the children will
attend, and the identity of all other persons who will be residing in that household. Identify all
persons who will care for the children in your absence, state the hours during which they will
care for the children, and the location where the care will be provided.
58. Describe in detail the health and well-being of your child since her date of birth.
59. Describe in detail all developmental and recreational activities you have engaged in with
your child since January 1, (Year), including in your answer the dates you engaged in such
activities and the names of any and all persons present during such activities.
60. If there are currently or have been in the past disagreements between you and
Plaintiff/Defendant as to major issues affecting the welfare of the minor child, state all pertinent
facts concerning such disagreement(s), including but not limited to the nature of the
disagreement, the position taken by each of you, and how, if at all, said disagreement was
resolved.
61. If you contend that you and Plaintiff/Defendant do not agree on the children’s education,
child care, religious training, discipline, or medical care, state how you differ from each other,
and state the facts and circumstances that support your contention.
62. If you have any complaints, concerns or criticism of Plaintiff's/Defendant’s parenting of the
minor children, state with particularity each complaint, concern or criticism, and identify all
persons with personal knowledge of these facts.
63. State the specific custody and access schedule you contend is in the best interest of the
minor children including but not limited to when the minor children would spend time with each
parent, and explain why the schedule would be in the best interests of the minor children.
64. If you or anyone in your household (or anyone who has cared for your child(ren) has been
arrested for or convicted of any alcohol- or drug-related offense, or of any other criminal offense,
since ____________________, state as to each charge the date of arrest, the charge, the court
and case number, the trial date, the disposition, and the disposition date.
65. State with particularity and in detail what conversations you have had with the minor
child(ren) relative to the issues in this case and the substance of said conversations, specify
who initiated said conversation. Include in your answer what, if anything, the minor child(ren)
has communicated to you or anyone else about her preferences about her living arrangements,
about the relationship between the minor child(ren) and the other parent, about the relationship
between the minor child(ren) and you and, specifying form (written or oral), the substance of the
communication, date, time, place, and who was present.
66. State all facts upon which you rely in support of your contention that there has been a
change in circumstances since ___________ that warrants modification of legal custody
awarded by the Court, and identify all persons with personal knowledge of these facts.
67. State all facts upon which you rely in support of your contention that there has been a
change in circumstances since ___________ that warrants modification of physical custody
awarded by the Court, and identify all persons with personal knowledge of these facts.
68. State all facts upon which you rely in support of your contention that there has been a
change in circumstances since ___________ that warrants modification of visitation/access
awarded by the Court, and identify all persons with personal knowledge of these facts.
69. State all facts upon which you rely to support your contention that modification of the Court
ordered legal custody/physical custody/access is in the minor child(ren)'s best interest, and
identify all persons with personal knowledge of these facts.
70. If you contend that [Plaintiff/Defendant] has denied you access to the minor child(ren) in any
way since ______________, state the date you were denied access by [Plaintiff/Defendant],
state what access you requested and how [Plaintiff/Defendant] responded, and identify all
persons with personal knowledge of these facts.
71. If you contend that the residence at (Address) is not the "family home" as defined by Section
8-201(c) of the Family Law Article, state the facts upon which you base said contention.
72. If you claim that any tangible personal property located at the "family home" is not "family
use personal property" as defined by the Section 8-201(d) of the Family Law Article, state the
facts upon which you base said contention.
73. If you claim that any automobile being used by either you or your spouse is not "family use
personal property" as defined by Section 8-201(d) of the Family Law Article, state the facts upon
which you base said contention.
74. State all facts upon which you rely in support of your contention, if any, that the court should
award you the sole possession and use of the family home and family use personal property.
75. If you contend that the child does not have a need to continue to reside with your spouse in
the family home in the State of Maryland, state the facts upon which you base said contention.
[Custody - Out of State Removal]
76. With respect to your proposed move from the Maryland-Washington, D.C. Metropolitan
Area, please state: (a) the date you intend to move and the place to which you intend to move;
(b) where you intend to reside, including in your answer the names and ages of all persons who
will reside at such residence, the number of bedrooms, the number of bathrooms and the size of
the yard; (c) the child-care plan which you would provide to your minor children during periods
of time she may be with you, stating the names, ages and qualifications of all persons who
would care for her, the hours during which you would utilize their services, the cost of such
services, and the location where they would care for her; (d) the facts, circumstances and
reasons for such move; (e) a detailed and specific visitation schedule to which you believe you
and any other person(s) should be entitled if Plaintiff is awarded custody, and a schedule to
which you believe Plaintiff should be entitled if you are awarded custody.
[Custody - Complaint Allegations]
77. State all facts upon which you rely in support of your allegation in Paragraph (#) of your
(Name of Pleading) that _____________________________.
78. State all facts upon which you rely in support of your allegation in Paragraph (#) of your
(Name of Pleading) that you have been the parent who has provided your child’s religious
upbringing including, without limitation, a detailed description of your involvement in the (Type)
faith during the past five years including, without limitation, the dates, place and occasion of
each instance of church/synagogue attendance by you during said period.
[Health Insurance Coverage; Extraordinary Medical Expenses]
79. If you have health insurance, identify the insurer, the policy number, the State in which the
policy was written, who are covered under the plan, the actual cost to you of your coverage, the
actual cost to you of including the child(ren) in such coverage, and describe the coverage
provided.
80. If you contend that any child has extraordinary medical expenses, i.e., uninsured expenses
over $100 a year for a single illness or condition including, without limitation, uninsured,
reasonable, and necessary costs for orthodontia, dental treatment, asthma treatment, physical
therapy, treatment for any chronic health problem, and professional counseling or psychiatric
therapy for diagnosed mental disorders, identify the child’s illness or condition, identify all
persons providing any diagnosis, treatment, therapy or counseling for the child, the amount of
the extraordinary medical expenses for each illness or condition incurred in each of the past
three calendar years, and the current calendar year, and the anticipated future uninsured costs.
[School Expenses]
81. If you contend that there are expenses incurred or which may need to be incurred on behalf
of any child for attending a special or private elementary or secondary school to meet the
particular educational needs of the child, state all facts upon which you rely in support of your
contention including in your answer identification of the school, the nature and amount of such
expenses, the child’s particular educational needs, and the reasons that a public school is not
able to meet the child’s particular educational needs.
[Child Support Guidelines – Deviation/Departure]
52. If you contend that application of the child support guidelines would be unjust or
inappropriate in this case, please state all facts upon which you rely in support of your
contention.
[Prenuptial Agreement]
83. Describe in detail the circumstances surrounding the preparation and execution of a certain
"Pre Nuptial Agreement" dated (Date) to which you are a party, including in your answer the
date and substance of any and all discussions you had with [Plaintiff/Defendant] concerning the
terms of the Agreement, the date and nature of any and all services performed by [Name of
attorney], Esquire in connection with the Agreement including the date and substance of any
and all advice, explanations or other communications between either or both parties and said
attorney, whether said attorney represented either or both parties in connection with the
agreement, the cost of said attorney's services, and the date, amount and person who paid for
said attorney's services.
[Alleged Agreements]
84. If you claim that an agreement exists between you and the Plaintiff concerning support, the
division of assets, or any other matter, state: (a) the terms and date thereof; (b) Whether oral or
in writing; (c) If either of you agreed to pay certain amounts, how such amounts were to be
calculated; (d) whether you divided any assets and, if so, what assets each of you obtained; (e)
whether the Plaintiff has ever contested the existence of such Agreement and, if so, when she
did so.
[Child Support Modification]
85. Itemize the income you have received from any and all sources for each calendar year
(Year) through (Year), including in your answer the sources of such income and the amounts
received from each such source each year.
86. Please itemize the amounts you spend on a monthly basis for all living expense and itemize
all liabilities.
87. Please itemize the amounts you spent on a monthly basis for all living expenses at the time
of your divorce, and itemize all liabilities you had at that time.
88. State what amount you contend should be paid by you for the support of your children, and
all facts upon which you rely in support of your contention.
89. Describe in detail any and all differences between your current financial circumstances and
your financial circumstances at the time of your divorce, including in your answer any changes
in your income, expenses, assets, and liabilities.
90. If you contend that there has not been any material change in circumstances since the date
of your divorce and that the Plaintiff/Defendant is not entitled to an increased award of child
support, then state all facts upon which you rely in support of your contention.
91. If you contend that the children's expenses as set forth on the Plaintiff's/Defendant’s
financial statement dated (Date) are inaccurate or unreasonable, state all facts upon which you
base your contention, and describe in detail what amounts you believe to be reasonable
expenses for your children with respect to each category of expense.