Interrogatories - Testamentary Challenges

Will Contest [by Contestant]

1. State your name, address, telephone and your relationship, if any, to the Estate of _______________ , who died on ___________, 20 __ , (Hereafter referred to as “Decedent”).

2. On what date did you begin residing at your present address? Also, please provide the address of your residence prior to that date.

3. Are you appearing in this matter as a litigant on your own behalf or are you appearing in a representative capacity, or both? If you are appearing in any representative capacity please set forth the following information specifically and in detail:

   1. Your representative capacity in this litigation (i.e., Are you a Personal Representative, Executor or Executrix of a Decedent’s Estate, Guardian Ad Litem, Trustee, etc.?).

   2. Your relationship to the Decedent.

   3. Whether or not you were appointed by way of a court order, and if so, please identify that order by setting forth the name and address of the court and the judge who issued it, the date of the order, its heading and the title of the action or proceeding wherein it was issued.

   4. In addition to your representative capacity, please set forth details pertaining to any personal interest that you presently have, or anticipate having in the subject litigation.

4. Were you associated with the Decedent with respect to any business venture or enterprise? If your answer is anything other than an unqualified “No,” then for each business or enterprise, please set forth the following information specifically and in detail:¹

   1. The business’ formal name, address and entity.

   2. The name, address, dates of ownership and percentage of ownership for each person or entity that owns or has ever owned any portion of the business.

   3. Summarize and briefly describe the nature and operation of the business. Include in your summary the reason or purpose for its creation.

   4. Please identify (by title, date and signatories) all written instruments, contracts and agreements that relate to your interest or relationship with the business. Briefly summarize the content of each document, and please indicate whether or not you will, without a motion to produce, attach a copy of each such document to your answers to these interrogatories.

   5. With respect to any writings that you identified pursuant to the preceding paragraph, please identify the name, address, telephone number and occupation the person who prepared each instrument and provide the name, address, telephone number and occupation of each person who has custody of the instrument or a copy of it.

5. Did you have a personal relationship with the Decedent? If your answer is anything other than an unqualified “No,” then please set forth the following information specifically and in detail:²

   1. The place wherein you first met the Decedent and the approximate date of the meeting.

   2. The circumstances under which you met.

   3. The precise nature of your relationship at the time that you met the Decedent.

   4. The precise nature of your relationship as of the Decedent’s date of death.

   5. The precise nature of your relationship as of ______, 20 __ [The date of the execution of the Last Will and Testament or Last Codicil].

6. Please state where the Decedent resided on the date of his [her] death, and with respect to each place wherein the Decedent resided during the last ________ months of his [her] life, please set forth the following information with respect to each residence:

   1. The address of the residence.

   2. The inclusive dates of residence.

   3. The reason for the move to and from the residence.

   4. The name, address, and relationship, if any, of each person who resided with the Decedent at the residence, and the reason why that person did so.

7. During the ________ weeks preceding the Decedent’s death, did any persons (other than maids, cooks, cleaning personnel, servants or repair persons) reside overnight at the Decedent’s residence? If your answer is anything other than an unqualified “No,” then for each such person, please set forth the following information specifically and in detail:

   1. The person’s name, address, telephone number, occupation and relationship, if any, to the Decedent.

   2. The date and reason for each visit.

8. During the ________ weeks preceding the Decedent’s death, did any persons other than maids, cooks, cleaning personnel, servants or repair persons, visit the Decedent at least once per week? If your answer is anything other than an unqualified “No,” then for each such visitor, please set forth the following information specifically and in detail:

   1. The person’s name, address, telephone number, occupation and relationship, if...