Interrogatories - Domestic Relations

Divorce or Separation ¹

[Non-Worker to Breadwinner] ²

1. State your full name, date of birth, residence address, occupation and social security number.

2. [GENERAL HEALTH] State the condition of your health at the present time and indicate whether or not you have any infirmities or chronic ailments? If so, explain each one in detail.

3. [MEDICAL TREATMENT] Have you consulted a doctor or psychiatrist for any reason within the past ______ years? If so, to the extent that you have not already done so, provide the following information with respect to each ailment:

   1. The details of the illness or disorder.

   2. The period during which each doctor or psychiatrist treated you.

   3. The name and address of each of doctor or psychiatrist treating you and each hospital or institution to which you were admitted.

   4. The state of this illness at the present time.

4. [EMPLOYMENT DURING MARRIAGE] Have you been employed during the time of this marriage? If so, for each employer, please state:

   1. The name and address of the employer.

   2. The inclusive dates of employment.

   3. The type of work that you performed, your occupation and job title.

   4. The gross annual income received from such employment in each of the years ___ through _______.

   5. The net annual income received from such employment in each of the years _________ through _______.

5. [EMPLOYMENT CONTRACTS] Are you presently employed under a written employment agreement? If so, please state:

   1. The name and address of each party to the agreement other than yourself.

   2. The term of the contract, its expiration date and principal conditions of the agreements contained therein.

   3. The name and address of each person who has a copy of the agreement.

   4. Will you, without a motion to produce, attach a copy of each written employment agreement to your answers to these interrogatories?

6. [EMPLOYEE FRINGE BENEFITS] With respect to every fringe benefit (including, but not limited to, health insurance, life insurance, disability insurance, other insurance, pension plans, medical or dental plans, profit sharing plans, paid vacations, use of automobiles or aircrafts, employee stock option plans, and expense accounts) that you are presently receiving, please provide the following information:

   1. Please describe the fringe benefit in detail.

   2. State the name and address of the employer providing the benefit.

   3. Whether or not there is a written plan covering the benefit; and if there is, please state whether or not you have access to it, and if so, state whether or not you will, without a motion to produce, attach a copy to your answers to these interrogatories.

   4. Whether or not there is a written summary or description of the plan; and if there is, please state whether or not you have access to it, and if so, state whether or not you will, without a motion to produce, attach a copy to your answers to these interrogatories.

   5. What is the name, address, and telephone number of the person or entity that administers the plan?

   6. With respect to your participation, state the monthly value of the plan.

   7. State the total benefits that you have actually received under the plan for the period starting on __________, 20 __ and continuing through __________, 20 __.

   8. Please state the degree to which you are vested in the plan as of the date of your answers to these interrogatories.

7. [FEDERAL INCOME TAX RETURNS] Have you ever filed a federal income tax return since the date of your marriage? If so, for each return, please state:

   1. The year for which it was filed, whether it was separate or joint, and the address of the IRS office in which it was filed.

   2. The amount of gross and taxable income reported, and the amount of tax paid.

   3. The name and address of the person who prepared the return.

   4. Please state whether you will, without a motion to produce, attach a copy of each federal income tax return for the years ____________ to your answers to these interrogatories.

8. [STATE INCOME TAX RETURNS] Have you ever filed a state income tax return since the date of your marriage? If so, for each return, please state:

   1. The state for which it was filed, the year for which it was filed, whether it was separate or joint, and the address of the state office in which it was filed.

   2. The amount of gross and taxable income reported, and the amount of tax paid.

   3. The name and address of preparer of the return.

   4. Please state whether you will, without a motion to produce, attach a copy of each federal income tax return for the years ___________ to your answers to these interrogatories.

9. [CURRENT LIVING EXPENSES] With respect to your current monthly living expenses please provide the following information:

   1. A detailed list of expenses, including, rent or mortgage payments, utilities, food, clothing, laundry, transportation, cleaning, medical and dental care, education, insurance, recreation, other regular expenses (Please specify any “other”).

   2. What are your total monthly living expenses at the time of answering these interrogatories?

   3. Do the foregoing expenses include the support of any person other than yourself? If so, state the name and address of each such person, the relationship to you, and the monthly expenses attributable to such person.

10. [EXPENSES FOR CLUBS AND ORGANIZATIONS] Do you belong to any club, organization or association to which you pay dues or regular charges (This includes both pre-paid and periodic)? If so, for each such club state:

    1. The name and address of the organization.

    2. The amount that you pay as monthly or annual dues.

    3. The date that your membership commenced. The date that your membership terminated.

    4. The amount of any prepaid dues, and the term of membership that it covers.

11. [CREDITORS] Do you have any outstanding obligations, including but not limited to mortgages, conditional sales agreements, loans, contract obligations and promissory notes? If so, for each obligation, state:

    1. The name and address of the creditor and the type of obligation.

    2. The date the obligation was incurred, and the consideration received for the obligation; also, if the consideration is in the form of property, identify by name and address, the person who currently possesses the property.

    3. A description of any security given for the obligation.

    4. The amount of the original obligation and the rate of interest on the obligation.

    5. The present unpaid balance on the obligation.

    6. The dates and amounts of all installments.

    7. Please identify by title, date, stated amounts, signatories and guarantors, all written instruments evidencing the obligation. Also, please state whether or not you will, without a motion to produce, attach copies of the instruments to your answers to these interrogatories.

12. [CREDIT CARDS] Do you have any outstanding balances owing on any credit cards? If so, for each credit card, please state:

    1. The issuer of the card, the date of issuance and the account number.

    2. The outstanding balance as of the date of your answers to these interrogatories.

    3. For each item in excess of $ _________ that appears on the card after ___________, 20 __, please identify the item and the person who now has possession of it.

13. [DEBTORS] Are you owed any money? If so, for each debtor, state:

    1. The name and address of the debtor and the amount owed.

    2. The type of debt.

    3. The date the debt was incurred, and the date the debt matures.

    4. The conditions for payment.

    5. The consideration given for the debt.

    6. Please identify by...