21ST JUDICIAL DISTRICT COURT FOR THE PARISH OF TANGIPAHOA

STATE OF LOUISIANA

DOCKET NO.: 2021-0000942 DIVISION: J

ZACHARY K. JOHNSON

VS.

JENIFER WHILEY

INTERROGATORIES

To: Zachary K. Johnson

Through Counsel of Record Russell Stegeman
Attorney at Law
506 Water Street
Madisonville, LA 70447

Jenifer Whiley propounds these Interrogatories to Zachary K. Johnson, pursuant to

Louisiana Code of Civil Procedure Article 1457 through 1460. Jenifer Whiley requests that each
interrogatory be answered separately and fully, in writing and under oath, signed by the person
making them, and the answers be served on Jesse P. Lagarde, attorney for Jenifer Whiley, at
118 North Cypress St., Hammond, Louisiana 70401, within fifteen (15) days of service hereof.
These interrogatories are deemed to be continuing and shall be updated and
supplemented as the information requested in these interrogatories changes, or as new
information develops.

Interrogatory #1
Please provide your full name, any and all alias(es) you are presently using or have used
in the past, address, phone number, date of birth, birthplace, social security number, driver’s
license number, and the state and parish/county where your driver’s license was issued.

Interrogatory #2
For each person who currently resides with you or provides for the care of your children,
please provide their name, address, and phone number, and whether to your knowledge he/she
has been arrested and/or convicted of any criminal offense. If they have been convicted of a
criminal offense state each charge, date of arrest, description of the event, disposition, and the
name, address, and phone number for the court where the criminal proceedings were held.

Interrogatory #3
For each illness or medical condition for which you are diagnosed, please provide the
symptoms, causes, and side effects relating to the diagnosis for which you suffer(ed), any
prescribed medications and dosages which have been prescribed to treat your diagnosis, and the
details for the prescribed or recommended treatment programs and whether you completed such
programs.

Interrogatory #4
 For each mental health professional or institution that you have spoken to or consulted
with relating to your mental health in the past five (5) years, please provide the name, address,
and phone number of the professional or institution you visited or consulted, the time period for
the visit or consultation, the reason for your visit or consultation, the names(s) of the diagnostic
test/exam given, and the treatment you received or were prescribed (e.g. prescribed medications
and other therapies or treatment programs).

Interrogatory #5
For each psychological or neurological disorder or condition for which you are
diagnosed, please provide the symptoms, causes, and side effects relating to the diagnosis for
which you suffer(ed), any prescribed medications and dosages which have been prescribed to
treat your diagnosis, and the details for the prescribed or recommended treatment programs and
whether you completed such programs.

Interrogatory #6
For each controlled substance that you have taken in the past twelve (12) months, please
provide the name of controlled substance, frequency with which you have taken the substance,
date you were initially prescribed or you initially took the substance, the name, address, and
phone number of provider who prescribed or who provided you the substance, the reason the
substance was prescribed or provided, and the name, address and phone number for each
pharmacy where you purchased the substance.

Interrogatory #7
For each crime that you have been charged with or convicted of, provide the name,
address, and docket number where the criminal proceedings were held, the name of each crime
that you were charged with, the disposition of each charge, the sentence/penalty imposed for
each charge, and the actual sentence/penalty which was served/imposed.

Interrogatory #8
For each of your current employers, provide the name, contact information, and the name
of a supervisor who can confirm your employment, your current job title, job description, length
of employment, the rate at which you are paid, the frequency at which you are paid, the number
of hours you work per week, and the gross monthly income that you have received from
employer for most recent three months.

Interrogatory #9
Describe your current work schedule, which should include: the days and times that you
are required to be at work; the time you leave for work and leave work to return home; and the
time you arrive home from work.

Interrogatory #10
 For each material change in circumstance that has occurred (in either your or the
children’s circumstances) since the most recent judgment of child custody, describe the nature of
the change in circumstances (e.g. financial, residential, professional, medical, etc.); the date the
circumstances changed; reason this change is material; and the name, address, and phone number
of any and all persons with personal knowledge of the facts surrounding the change in
circumstances.

Interrogatory #11
If you are granted custody with the minor children, provide the address where the
children would reside; description of the living arrangements including the number of bedrooms
and bathrooms; the name, address, and phone number of any and all other persons who will be
residing at the residence with you and the minor children; the distance from the children’s
school; and how the day care will be provided, including addresses where the children will be
cared for along with the name and phone number of any and all person(s) and facilities who will
be providing such care.

Interrogatory #12
List the dates and provide a description of each and every school activity, and/or school
conference, and/or medical appointment you have scheduled and/or attended, for the current year
and the previous three (3) years.

Interrogatory #13
If you believe that Jenifer Whiley is an unfit parent or has issues that negatively impact
her ability to parent safely and effectively, please provide any and all facts that support your
belief, and the name, address, and phone number of any and all persons who believe that Jenifer
Whiley is an unfit parent or has issues that negatively impact her ability to safely and effectively
parent.

Interrogatory #14
If you believe that Jenifer Whiley’s visitation and custody with the minor children should
be restricted and/or supervised, provide the recommended restriction and/or supervision; the
facts that support your contention; why you believe the restriction is in the best interest of the
minor children; and the name, address, phone number of each person who has information to
support your contention, along with a summary of the person’s relevant knowledge.

Interrogatory #15
If you have spoken with the minor children about issues or details of this case, provide a
summary of the details and content of the issues that you spoke upon. Your answer should
include, but should not be limited to, the substance of the conversation; time and date of
conversation, location of conversation; and whether you or the children initiated discussing the
issues or details of the case.
Interrogatory #16
For each person who has personal knowledge concerning any fact relating to the care,
visitation, and/or custody of your children, provide their name, address, and phone number; their
relationship of the person to the Parties and the children; and a summary of the person’s relevant
knowledge.

Interrogatory #17
Indicate whether or not you desire to be given domiciliary status over the minor children.
If yes, provide any and all reasons and supporting facts why you should be granted domiciliary
status and why Jenifer Whiley should not.

Interrogatory #18
Describe any and all current and historical disagreements between you and Jenifer
Whiley regarding significant issues affecting the health, safety, education, religious training,
discipline, medical care, and/or any other issue concerning the welfare of the minor children.
Your answer should include the details of each disagreement, including, but not limited to, the
factual circumstances surrounding disagreement, how your position differs from Jenifer
Whiley’s, facts and circumstances that support your position, and resolution of disagreement (if
resolved).

Interrogatory #19
For each act of physical or sexual abuse which you allege that Jenifer Whiley committed
upon you or the minor children, provide the date of incident; location of incident; a description
of the abusive behavior; description of any and all injuries sustained by you or the minor
children; and the name, address, and phone number of any and all medical facilities and treating
physician(s) who treated the injuries sustained by you and/or the minor children;

Interrogatory #20
For each act of abuse outlined in the previous interrogatory, provide the name, address,
and phone number for any and all persons with personal knowledge of the incident of abuse and
the injuries sustained by you or the minor children; and describe any and all exhibits and
evidence that you have to prove the act of abuse.

Interrogatory #21
For each time that you have physically or sexually abused Jenifer Whiley or the minor
children, provide the date of incident; location of incident; description of your abusive behavior;
description any and all injuries caused by your actions; and explanation for why you committed
the act of physical or sexual abuse.

Interrogatory #22
Have you or anyone in your household been investigated for child abuse or neglect by the
Louisiana Department of Children and Family Services (D.C.F.S.) or any other agency in any
jurisdiction of any state, parish, county? For each investigation, provide the name(s) and
relationship(s) to you of the children that were the subject(s) of the investigation; the name and
contact information for the investigating agency; the facts and allegations surrounding agency
involvement; and current status or finding of the investigation.

Interrogatory #23
For each exhibit and evidence pertaining to this action that you intend to use at trial or
hearing, describe the category of item of evidence/exhibit (e.g. documents, recorded statements,
e-mails, etc.); the location of exhibit; the name, address, and phone number of person in
possession of evidence/exhibit; the contents of the exhibit, verbatim; the issue(s) before the court
to which this the exhibit pertains; and the fact and/or allegation you believe this item will prove
or disprove.

Interrogatory #24
Provide the names, addresses, and phone numbers of any and all witnesses whom you or
your attorney may or will call on your behalf to testify at trial and/or at hearing of this suit,
including rebuttal witnesses. For each of these witnesses, describe the relationship to the Parties,
and explain the nature of his or her expected testimony.

Interrogatory #25
For each person whom you have obtained any written, oral, or otherwise recorded
statement(s) from any person(s) relating to any issue in this case, provide the name, address, and
phone number for person who gave the statement; the form of the statement (e.g. hand-written,
audio recording, transcribed, etc.); summary of the statement; and relevancy of the statement to
the issues before the court.
Respectfully submitted this ___ day of September 2022.
 
THE LAGARDE LAW FIRM, APLC
 
 
_______________________________
JESSE P. LAGARDE #36538
118 NORTH CYPRESS STREET
HAMMOND, LA 70401
PHONE:  (985) 345-3138
FAX:  (985) 345-4233
Attorney for Jenifer Whiley

CERTIFICATE OF SERVICE
 
I hereby certify that a copy of the foregoing has been served upon all counsel of record either by
facsimile, electronic correspondence, or by placing the same in the U.S. Mail, properly addressed
and postage prepaid on this ___ day of September 2022.
 
___________________________
JESSE P. LAGARDE
 21ST JUDICIAL DISTRICT COURT FOR THE PARISH OF TANGIPAHOA

STATE OF LOUISIANA

DOCKET NO.: 2021-0000942 DIVISION: J

ZACHARY K. JOHNSON

VS.

JENIFER WHILEY

PRODUCTION REQUESTS

To: Zachary K. Johnson

Through Counsel of Record Russell Stegeman
Attorney at Law
506 Water Street
Madisonville, LA 70447

Jenifer Whiley propounds these Production Requests to Zachary K. Johnson pursuant to

Louisiana Code of Civil Procedure Article 1461 and 1462, and requests that he respond to these
Production Requests in accordance with law, and that the documents requested to be produced
are to be delivered to Jesse P. Lagarde, attorney for Jenifer Whiley, at 118 North Cypress St.,
Hammond, Louisiana 70401, for the purpose of inspection and replication commencing fifteen
(15) days after the receipt of this request, and shall continue for as long thereafter as may be
necessary to complete the inspection and replication, or at such other date, time and place as may
be mutually agreed in writing by all parties.
This Request for Production of Documents and Things is deemed to be continuing
and to require a continuous supplementation of answers thereto, as more information
becomes available.

Production Request #1
Provide a copy (front and back) of all your state and federally issued photo identification.
This includes but is not limited to your driver’s license.

Production Request #2
Copies of all documentation relating to each illness or medical condition for which you
are diagnosed. Said documentation includes, but is not limited to, medical records and
photocopies of prescribed medications.

Production Request #3
Copies of all documentation relating to the diagnosis and the treatment of any and all
psychological or neurological disorders or conditions. Said documentation includes, but is not
limited to, medical records and photocopies of prescribed medications.
Production Request #4
Copies of all documentation relating to any and all substance abuse treatment that you
have received. Said documentation includes, but is not limited to, medical records, certificate(s)
of completion for treatment programs, and photocopies of prescribed medications.

Production Request #5
Provide copies of any and all judgments of conviction, sentencing documents, bills of
information, indictments, and/or police reports for any and all crimes for which you have been
charged and/or convicted.

Production Request #6
Any and all calendars, records, notes, and any other writing of any type or nature you
have maintained that reflect the actual exercise of visitation with the minor children.

Production Request #7
Provide copies of all exhibits and evidence pertaining to each and every allegation that
Jenifer Whiley committed an act of physical and/or sexual abuse upon you and/or the minor
children.

Production Request #8
Provide copies of all exhibits and evidence contesting Jenifer Whiley’s allegations that
you physically and/or sexually abused Jenifer Whiley and/or the minor children.

Production Request #9
Copies of all evidence and exhibits, including, but not limited to, reports, documents,
recordings, and/or photographs that you intend to use at trial.

Production Request #10

Copies of all documents, statements, and affidavits signed by witnesses that you and/or
your attorney have obtained pertaining to this action.

Respectfully submitted this ___ day of September 2022.

 
THE LAGARDE LAW FIRM, APLC
 
 
_______________________________
JESSE P. LAGARDE #36538
118 NORTH CYPRESS STREET
HAMMOND, LA 70401
PHONE:  (985) 345-3138
FAX:  (985) 345-4233
Attorney for Jenifer Whiley