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STATE OF MINNESOTA DISTRICT COURT
COUNTY OF JUDICIAL DISTRICT
FAMILY COURT DIVISION
In Re the Marriage of: Court File No.
,
Petitioner,
__________ FIRST SET
OF INTERROGATORIES TO
AND PETITIONER (RESPONDENT)
,
Respondent,
TO: ,
YOU WILL PLEASE TAKE NOTICE that the undersigned as attorneys for the
Petitioner(Respondent) herein demand that the (Petitioner) Respondent answer in writing under
oath, fully and completely, pursuant to Rules 26 and 33 of the Minnesota Rules of Civil Procedure
for District Courts, the following Interrogatories and that the Answers be signed by the person
making them and that they be served upon the undersigned counsel within thirty (30) days after
service of these Interrogatories.
INSTRUCTIONS
In answering these Interrogatories, furnish all information which is available to you,
including information in the possession of your attorneys or investigators, for you or your attorneys,
and not merely information as may be known of your own personal knowledge. If you cannot
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answer the following Interrogatories in full after exercising due diligence to secure the information
to do so, state the answer to the extent possible, specifying your inability to answer the remainder,
stating whatever information or knowledge you have concerning the unanswered portion.These Interrogatories shall be deemed to be continuing until and during the course of trial.
Information sought by these Interrogatories that you obtain after you serve your answers
must be disclosed by supplementary answer. It is demanded that the Interrogatory precede its answer as required by Rule 33.01 (4) of the
Minnesota Rules of Civil Procedure. Pursuant to Rule 34 of the Minnesota Rules of Civil
Procedure, please attach as exhibits all documents which have been prepared in connection with this
proceeding or upon which you may expect witnesses to rely or such other documents as may be
requested in the accompanying Request for Production of Documents. Where a question can be
answered by copying a document, then please do so and attach a copy of the document to your
answers. INTERROGATORY NO. 1
Identification. What is your name, address, social security number and date of birth?
INTERROGATORY NO. 2
#1 Education. What are the names and addresses of all schools, colleges, universities,
vocational schools, trade schools, or other education institutions you have attended since age 17, the
dates of attendance at each, work taken and completed and the diploma, certificate, degree, or
accreditation received, if any?#2 Education. With regard to your formal education, state the following:
A. How many years of high school have you completed?
B. If you received a high school diploma, identify the name and the city of said high
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school and the year said diploma was received;
C. Identify by name and city each post-secondary institution or vocational education
program attended by you after high school, identifying the beginning and ending
dates each institution/program was attended, the major course of training or study at
each institution, and the identity of each certificate, diploma, degree or other
evidence of completion of any course of study received from each institution;
D. For any license or certification you hold, i.e., pilot license, scuba diving, etc., list: 1. The date such certificate or license was obtained;
2. The name and address of institution where obtained;
3. The cost of obtaining said license or certification; and
4. The cost of maintaining on a yearly basis said license or certification.
INTERROGATORY NO. 3
Spouse's Contribution to Your Education. If ____________ made any financial
contribution to your education at all, state the following information: A. The amount ____________ contributed to your education during each of the years you attended college; and
B. What was the total cost of your education during each of these years.
INTERROGATORY NO. 4
# 1 Present Employment. With regard to your present employment, state the following:
A. Your hourly, daily, weekly, bi-weekly, or monthly gross pay;
B. Your average number of hours paid monthly;
C. The number of exemptions upon which your employer bases payroll deductions from your gross pay;
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D. Identify pay periods;
E. State your gross pay for each pay period within the last 12 months;
F. State the amounts of each deduction from your gross pay for each pay period within the last 12 months and identify each such deduction; and
G. State your net pay for each pay period within the last 12 months.
#2 Present Employment. For any employer for whom you have worked within the last five
years, state the name, address, and telephone number of each employer, and also state: A) The date you commenced your employment;
B) The date upon which the employment terminated;
C) Your job title or position;
D) The name and address of each accountant, bookkeeper, payroll clerk or other person who has custody of records of salaries, commissions, bonuses, allowances, expenses
or other such sums of money paid to you by your employer during the term of your
employment;
E) Your gross salary, specifying whether you are providing an hourly, weekly, or monthly figure;
F) State the number of hours per week that you normally worked at each position;
G) State the amount presently deducted from your present gross salary or wages per week or month for each of the following:
1. Federal withholding tax;
2. State withholding tax;
3. FICA tax, social security deductions;
4. Insurance premiums;
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5. Retirement contributions;
6. Contributions to savings plans, stock ownership plan, or profit sharing plan;
7. Credit union or other employment loans;
8. Other, please explain. Include all mandatory and voluntary deductions and specify whether each deduction is mandatory or voluntary.
H) Amount of your present take-home pay per week or month If using a weekly or bi- weekly figure to calculate a monthly figure, either multiply the figure by 52 and
divide by 12 or multiply the bi-weekly figure by 26 and divide by 12. Do not
multiply a weekly figure only by 4 to obtain a monthly figure. You are specifically
requested to attach to your answers to Interrogatories photocopies of the pay check
stubs you have received from your employer(s) during the last 24 months or such
other evidence of income as verify your income for the last 24 months;
INTERROGATORY NO. 5
#1. Other income. Describe in detail all of your sources of income or compensation,
whether or not reported on any tax return, during the four (4) calendar years preceding the date
hereof and, as to all income and assets for services received or rendered, set forth the income, assets
or services received and the nature and amount of any deduction or setoffs and the net amount
received. #2. Other Income. State whether you have received any income from any source not
disclosed in your answers to the foregoing interrogatories--including part-time, short-term, or
irregular employments and including any income you received in exchange for services performed
by you--during the five-year period preceding the date hereof. If so, state for each source:A. The source of said income;
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B. The amount or amounts received;
C. The date or dates of your receipt of income;
D. Whether there are any payments due from this source at the present time or in the future, and, if so, the amount due and the party from whom it is due and when it is
due.
#3. Other Income. Identify any source of income to you since _________________,
20___, which is not otherwise identified in these Interrogatories, including all rental income,
identifying the name and address of the source, the income-earning activity, the dates between
which the activity occurred, the gross amount earned, and any deductions from that gross amount.
INTERROGATORY NO. 6
Other Benefits. State whether you are presently receiving any Social Security benefits,
Workers' Compensation benefits, unemployment benefits, or any form of public assistance. If so,
describe the benefits being received with particularity including the amount or value of the benefits
and their duration or anticipated duration.
INTERROGATORY NO. 7
Stocks, Bonds, Securities. Identify any and all shares of stock, vested or unvested stock
options, bonds, or other securities that you own in your own name, jointly with another, as a
member of an investment group, or that are held in trust for you by any other person or business
entity, specifying for each such investment: A. The name of the company or institution issuing stocks, stock options bonds, or other securities;
B. The number of shares owned by you;
C. The value of each share, bond, or security as of the date of your answers to these
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interrogatories;
D. The date of maturity and value at date of maturity of any bonds owned by you.
E. State the date(s) on which each stock option became exercisable and the date of the
expiration of each stock option;
F. Name any other individual or business association owning or claiming any interest in such stocks, bonds, or other securities;
G. State how said shares of stocks, stock options, bonds, or other securities were acquired and the date upon which they were acquired;
H. Name the individual or business association or other entity from which said stock, stock options, bonds, or other securities were acquired;
I. State whether said stocks, bonds, or securities regularly pay a dividend and whether said stocks, bonds, or securities paid a dividend in the years ____, ____, ____ or
____ and, if so, the date you received the dividend and the amount thereof;
J. If the stock, stock options, bond or other securities were liquidated, state the date liquidated and the amount received by you.
INTERROGATORY NO. 8
Stocks. Do you have an interest in any shares of stock of any corporation, including
options? If so, state: a. The issuing corporation;
b. Class or classes of stock owned by you;
c. Number of shares of each class owned by you;
d. Date and mode of acquisition by you, whether by purchase, gift, inheritance or otherwise;
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e. Purchase price, or if otherwise acquired, the value at the time of acquisition; and
f. Present market value of each such share, stating your source for such information.
INTERROGATORY NO. 8
Bonds. Do you have an interest in any corporate bonds or debentures or savings bonds? If
so, state: a. Name of the issuing entity;
b. Date and mode of acquisition by you, whether by purchase, gift, inheritance or otherwise;
c. Maturity or due date;
d. Rate of interest; and
e. Present value and source of such valuation.
INTERROGATORY NO. 9
Other Investments. Other than as shown in your answers to these Interrogatories, do you
have an interest in any other investments? If so, state the terms of those investments.
INTERROGATORY NO. 10
Stockbrokers and Agents. State the names, addresses and telephone number of all
stockbrokers, accountants and insurance agents who provided services or transacted on your behalf
in the last six (6) years.
INTERROGATORY NO. 11
# 1. Investment Accounts. What are the details of each and every savings account, savings
certificate, checking account or investment of any kind in any financial institution or brokerage firm
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in which you have had an interest in the last six (6) years, including:a. The name and address of the bank or financial institution;
b. The extent of your interest in such account or certificate, and the names and
addresses of any other persons holding an interest in such accounts or
certificates;
c. The type of account or certificate and account or certificate number;
d. The date the account was opened or the certificate purchased; and
e. The present balance or value, if any, or the balance or value at the time the account was closed or reduced.
#2. Investment Accounts. List separately each and every financial institution including
banks, savings and loan associations, credit unions, or any other financial institution, with which
you have had any kind of a checking, savings or other investment account during the last 24
months. As to each, please state separately:
A. The name of the financial institution and its address;
B. The nature of the account the account number and the present balance in the account; and
C. If the account was liquidated, the date you liquidated it and the amount received by you.
INTERROGATORY NO. 12
Withdrawals from Accounts. List all withdrawals made by you from any bank checking
account, bank savings, savings and loan account, or credit union savings account, in your name, or
jointly with any other individual or organization, which withdrawal exceeds the sum of $500 and
which withdrawal was made by you on or after _________________, 20___, and for each such
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withdrawal state:A. The date and amount of such withdrawal; and
B. The number of the account and the financial institution from which withdrawn.
INTERROGATORY NO.13
Safety Deposit Boxes. State the name and address of each bank with which you have had a
safety deposit box within the last 5 years, and for each bank state the contents of said box as of the
commencement of this action and as of the date you answer these Interrogatories.
INTERROGATORY NO. 14
#1. Life Insurance. For each policy of life insurance in which you have an interest as
owner, beneficiary or insured, state: a. The name of the issuer;
b. The type of policy;
c. Policy number;
d. Amount of insurance;
e. Premium;
f. Present cash value, if any;
g. Owner; and
h. Beneficiary.
#2. Life Insurance. List all life insurance policies which you own, or have owned within
the last 36 months; for any incident of ownership state for each: A. The name of the company issuing such policy and the policy number;
B. The name of the insured;
C. The face value of the policy;
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D. The primary and contingent beneficiaries;
E. Whether a loan has been taken thereon, and if so, the date of the loan, the name of the lender, the amount of each such loan, and the disposition of the proceeds
received;
F. The present cash value of the policy.
INTERROGATORY NO. 15
#1 Motor Vehicles. List all automobiles, boats, boat motors, motorcycles,
snowmobiles, trucks, recreational vehicles, campers, trailers, mobile homes, and motor homes
owned by you individually or together with another person within the last 12 months, and for each
list: A. The date when you acquired it and the purchase price;
B. The make, model and year;
C. The registered or actual owner; and
D. If sold or transferred, the date of the sale or transfer, the name and address of the
transferee, the consideration for the transfer and the disposition of the proceeds.
#2. Motor Vehicles. If you have an ownership interest or claim in any motor vehicles, then
as to each one: a. What is the year and make of that motor vehicle;
b. If there is a mortgage against the vehicle, then state the terms thereof, including monthly payments and mortgage balance; and
c. What do you claim is the fair market value of that motor vehicle?
INTERROGATORY NO. 16
Present Employee Benefits. Please list with particularity each and every employee bene fit
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available to you through your employer including, but not limited to, medical, life, or disability
insurance, employee credit card, meals or meal reimbursement, self-retirement plan, bonus plan,
rent or utility reimbursement, etc. As to each such benefit, describe with particularity the nature of
the benefit, the value of the benefit on a monthly or annual basis, and the total value of the self-
employment retirement plan.
INTERROGATORY NO. 17
Pension, Retirement. Regarding any profit sharing, pension, or retirement plan or programs
of any kind including IRA's, Keogh plans, and employer-provided plans, state: A. The names, addresses and telephone numbers of each administrator or trustee of such plan;
B. The plan with which the administrator or trustee is associated;
C. The gross amount of your beneficial interest, whether vested or unvested, in each such plan;
D. The vesting schedule and your current vested portion of each such plan;
E. The present fair market value of your interest in each such plan;
F. The current balance in the account of each such plan;
G. The calculations which support your conclusions concerning the present fair market value of each such plan;
H. The contributions made to each such plan by you, and whether such contributions were voluntary or involuntary, for the past three plan years;
I. The contributions made to each such plan for you by your employer, and whether such contributions were voluntary or involuntary, for the past three plan years;
J. The increase in value of your interest in the plan(s) during the past three preceding
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plan years;
K. The projected increase in the value of your interest in the plan(s) in the current year;
L. Attach legible copies of all brochures or other writings, which describe your pension
plans, profit-sharing plans, and/or retirement plans;
M. For each profit-sharing plan, pension plan, retirement plan, IRA, Keogh or other retirement program in which you participate, attach a statement naming that plan;
showing the contributions made to that plan by you and any other person or entity;
showing the number of years, months and days of participation; showing the date of
vesting; showing the accrued vested monthly benefit; showing the current balance in
the account; showing the estimated monthly benefit upon retirement; showing the
amount of interest that has accrued on the account; and separately showing any
amount of employer contribution to the account;
N. Specify for each such retirement, profit sharing or pension plan in which you participate whether such plan is a defined benefit plan, defined contribution plan, or
a deferred benefit plan.
INTERROGATORY NO. 18
Personal Pension. Do you have an individual retirement account or other retirement plan,
which has been funded other than the plans described above? If so, state the terms of such plans or
accounts, the dates and amounts of contributions, and all other terms contained in the plan.
INTERROGATORY NO. 19
Past Pensions. State whether in the past you have participated in or have accrued benefits
under any pension, retirement, or profit-sharing plan maintained through your present or past
employer(s) or through any other business entity in which you have had an interest, and, if so, state:
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A. The name and account number of the plan;
B. The name and address of the Plan Administrator;
C. The total contributions, if any, you have made under said plan(s);
D. The date you became eligible to receive or will become eligible to receive payments under said plan(s) and whether you may elect to begin receiving payments under the
plan(s) at different ages or dates and, if so, the different ages or dates at which you
may elect to begin receiving payments under said plan(s);
E. The date(s) on which you have withdrawn contributions made by you from said plan(s) or the date(s) on which you began to receive payments under said plan(s).
State the amount of the contributions withdrawn from said plan(s) and/or the amount
of the payments received under said plan(s);
F. The amount of the annual or monthly payments you will receive under the plan, specifying, if applicable, the different amounts of payments for the different ages or
dates at which you may elect to receive payments;
G. The present percentage of vesting of said plan(s), if any;
H. The cash value to you of said plan(s) if you terminated participation in said plan(s) as of the date of answering these interrogatories and whether you would receive the
value of your vested interest in a lump-sum payment or in installments and, if in
installments, the date and amounts of the installments;
I. Whether you have, or any actuary has calculated the present value of said pension, retirement, or profit-sharing plan(s) and, if so, the present value of said pension,
retirement, or profit-sharing plan(s).
INTERROGATORY NO. 20
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Business Expenses. For each business expense reimbursed to you by any employer or
business in the last 12 months, itemize the date of the expense, the name of the employer, the date of
reimbursement, the name and address of the party to whom the expense was paid, and the purpose
of the expense. Provide copies of all vouchers or other reimbursement requests submitted by you to
any such employer for any such expense within said period. In the event there are no such
vouchers, submit the itemized statements and/or charge slips for any such expense incurred on a
personal or corporate credit card.
INTERROGATORY NO. 21
#1. Other Personal Property. List all other items of property of a gross value of more than
Three Hundred Dollars ($300), and as to each property in which you have an interest, what are the:a. The nature of the property;
b. Extent of your interest therein, and the names and addresses of any other person having an interest therein;
c. Date and mode of acquisition by you, whether by purchase, gift, inheritance, or otherwise;
d. Purchase price, or if otherwise acquired, the value at the time of acquisition; and
e. Amount of encumbrance on each item, if any, and the terms of repayment of such encumbrance.
#2. Other Personal Property. Identify and describe any personal property, which you
now own or have owned within the last 24 months of a value greater than $50, excluding clothing,
which has not been included in your answers to any other Interrogatory herein. In this answer
identity:
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A. The property;
B. The date acquired;
C. Your opinion of the present value; and
D. If disposed of, the date of the disposition, the name and address of the person to whom transferred, the consideration received for such transfer, your opinion of the
value at the date of transfer, and the disposition of any funds received by you.
#3. Other Property. Other than as shown by your previous answers to these Interrogatories,
if you own any other property, or any other person, government agency, or business entity holds any
property or monies for you, state the nature and value or amount of each such property or sum of
money, and the extent of your interest therein.
INTERROGATROY NO. 22
Asset Increase Claim. If you claim to have contributed labor or services which increase the
value of assets or property possibly affected in this proceeding, then state in complete detail the: a. The labor or services contributed;
b. Dates such labor or services were contributed;
c. How the labor or services increased the value of the assets; and
d. Value of each contribution of labor or services, and the methods used to obtain the valuation.
INTERROGATORY NO. 23
Asset Decrease Claim. If you claim that your spouse has decreased the value of assets of the
marriage, then state the details of how the assets were decreased in the value, the value of the asset
before the decrease and the value of the asset after the decrease.
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INTERROGATORY NO. 24
Gifts, Loans Given, and Transfers Away. If in the last three (3) years you gave a gift or any
item worth more than $500.00 or gave a loan in excess of that amount or transferred property from
you having a value in excess of that amount, then state the specific terms of such gifts, loans or
transfers, including the date, reason, recipient, and the location of that property as of the date shown
at the end of these Interrogatories.
INTERROGATORY NO. 24
Trusts and Estates. If you have an interest in a present estate or probate proceeding, or if
you are the settlor, beneficiary or trustee of any trust, describe the trust and your interest therein
fully.
INTERROGATORY NO. 25
#1. Real Estate. Do you have any ownership interest in any real estate? If so, for each property,
state:a. The nature of the property and extent of your interest therein;
b. The address of the property;
c. The legal description of the property;
d. The date and mode of acquisition by you, whether by purchase, gift, inheritance or otherwise;
e. Purchase price, or if otherwise acquired, the value at the time of acquisition;
f. The extent of current encumbrance and the amount of the monthly payments thereon;
g. Amount of the current year's real estate taxes;
h. Approximate present value and the source of such valuation; and
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i. Monthly rental derived therefrom in case of rental property.
#2. Real Estate. List all real estate owned by you or in which you claimed or claim to
have an interest with or through another individual, partnership or small business corporation,
within the last 24 months, and for each state:
A. The legal description and street address;
B. The amount of interest therein, the manner in which the interest was terminated, the name and address of the person acquiring your interest on termination and the
consideration if any;
C. If you continue to retain an interest therein, the present value of your interest;
D. The name (s) in which the property is held;
E. The name and address of any and all individuals, other than Respondent, who claims any interest in the property, either individually or through any form of association
and the extent of each interest claimed therein.
INTERROGATORY NO. 26
Appraisals. Describe in detail any and all written appraisals made or caused to be made by
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.
INTERROGATORY NO. 27
Homestead Disposition. With respect to the homestead of the parties, state your desires
and/or plans as to the following: a. The duration and conditions of the use and occupancy, the identity of the proposed occupants, and the reasons in support of such occupancy; and
b. Any proposed sale or other disposition of the property, including the desired
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terms and the date of sale.
INTERROGATORY NO. 28
#1 Business Interests. Identify the name and address of any business in which you have
had an ownership interest within the last 5 years and for each state:
A. The beginning and ending of your period of ownership or equitable interest in each business;
B. The nature of each business;
C. The extent of your interest in each business and your estimate of value of said interest;
D. If you are no longer an owner of such business, how your interest in the business
was disposed of including the date of transfer, the consideration received for
transfer, and the name and address of the person to whom your interest was
transferred;
E. The disposition of the consideration received for such transfer.
#2. Business Interests. Regarding any business in which you presently have an
ownership or equitable interest: A. Identify by date and amount each investment you have made into said business;
B. What is the present value of your interest in each said business;
C. Identify how your interest in the business is represented, whether by stock certificate, partnership agreement or other document, identifying by name
and address the person in possession of each document.
INTERROGATORY NO. 29
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Compensation from Business Interests. For each business in which you presently have an
ownership or equitable interest, if you have not so answered in any prior Interrogatory, state the
following:A. Your monthly compensation whether hourly, daily, weekly, monthly, annual pay, draw or other compensation, the rate of pay;
B. The amount of cash distributed or paid to you by said business in each month of the last 24 months for any purpose, identifying the nature of each amount (pay, salary,
draw, reimbursement for business expenses paid by you, or any other purpose).
INTERROGATORY NO. 30
Personal Financial Statements. If you have given a personal financial statement to any party
within the last 36 months, identify by name and address the person or corporation to whom each
statement was given and the date of each statement and attach a copy of each such statement .
INTERROGATORY NO. 31
#1. Living Expenses. Provide by answer or separate schedule an itemization of your
monthly living expenses, including each item you claim to be a regular monthly living expense and
also noting any that are current and unusual expenses. #2. Living Expenses. State your current monthly living expenses as set forth on
Exhibit B, attached hereto, and for each item which is shared jointly with another, then indicate the
amount of contribution by each person on a monthly basis.#3 Personal Expenses. Specifically list all of your current monthly living expenses.
INTERROGATORY NO. 32
#1. Debts. List your present indebtedness (including all debts in which you are
individually, jointly, as a co-signer, or otherwise, indebted), setting forth for each debt:
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a. The name and address of creditor;
b. Whether the account is solely in your name or a joint obligation with any other
party and, if joint, the names and addresses of any other obligees;
c. The nature of the indebtedness;
d. The original date and amount of the indebtedness;
e. The present balance due;
f. The terms of repayment; and
g. The nature of the collateral, if any.
#2. Debts. Provide by answer or separate schedule a listing of all debts upon which you
have any responsibility, listing the creditor, amount, date incurred, and amount of any payments you
have made against said debt within the last 24 months, listing all omissions and/or additions to s aid
debt, and stating for what reason each such debt was incurred, and for each cash loan, state what use
was made of the proceeds of each said loan.
INTERROGATORY NO. 33
Deferred Compensation. With regard to any current employment or consultation business in
which you presently have an ownership or equitable interest, state whether you have any
agreements for deferred compensation with any such employer or business; if so, state the date of
and the parties to any such agreement, and identify the name and address of the person(s) in
possession of the document representing such agreement, and summarize the terms of any
agreement.
INTERROGATORY NO. 34
Employment Agreements. With regard to any corporation by which you are currently
employed or have an ownership or equitable interest, state whether said corporation has by
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corporate resolution approved an employment agreement between the corporation and you; if so,
state the name of the corporation and the date of the corporate resolution.
INTERROGATORY NO. 35
Buy-Sell Agreements. With regard to any corporate stock that you own or in which you
claim an equitable interest, are you a party to any agreement to buy or sell such stock upon the
happening of any event? If so, identify the party to the agreement, the date of the agreement, and
whether any stock has been purchased or sold pursuant to that agreement.
INTERROGATORY NO. 36
Tax Preparers. Give the name(s) and business address(es) of each and every person that has
assisted you in the preparation of individual or business income tax returns for the years _________________, 20___.
INTERROGATORY NO. 37
State and Federal Taxes Paid. List all payments made on state or federal income taxes from
_________________, 20___, to the present date, and for each such payment set forth:
A. The date of the payment;
B. The amount of the payment;
C. The name of the taxing authority;
D. Whether the payment was for the then current year's taxes, for prior years, or a combination; and
E. If the answer to (D) above is a combination, set forth the amount of the same to be credited to the then current year's tax and the amount to be credited to arrears.
INTERROGATORY NO. 38
Credit Cards. List the company name, address, and account number of all car rental,
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gasoline service, and/or general purpose credit card accounts upon which you are, or have been
within the last 24 months, entitled to charge.
INTERROGATORY NO. 39
Clubs. List the names, addresses, regular annual and special dues for monthly payments to
any clubs, including athletic clubs, in which you have had a membership within the last 24 months.
INTERROGATORY NO. 40
Health and Medical Insurance. List all medical, dental, hospitalization and disability
policies under which you are, or within the last 24 months have been, covered and for each state:
A. The name of the company;
B. Policy number;
C. Type of coverage provided;
D. Any deductible maximum provisions;
E. Person(s) covered; and
F. If no longer covered, the date and reason for Termination.
INTERROGATORY NO. 41
#1. "Non-Marital Property". Identify each item of real or personal property, which you
claim to be "non-marital property" as defined by Minnesota Statutes Section 518.54, Subd. 5, by
providing the following information: a. A description of the property;
b. The identity of the person from whom the property was acquired;
c. The date of acquisition;
d. The manner in which the property was acquired (i.e. by gift, inheritance, purchase, etc.);
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e. Market value at the time of acquisition;
f. The present fair market value;
g. The facts upon which you rely in asserting the property in "non-marital" as defined by Minn. Stat. 518.54, Subd. 5; and
h. 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 "g" above with respect to the
original item of non-marital property that was exchanged.
#2. Non-Marital Property. For each item claimed by you to be non-marital property, fully
describe the same and state legal theory under which you characterize the property as non-marital.
INTERROGATORY NO. 41
Household Goods and Furnishings. Regarding your household goods, furniture and other
personal property not previously listed in these Interrogatories, state the following: A. A complete description of this personal property; and
B. The present fair market value of each item of personal property.
INTERROGATORY NO. 42
Medical Treatment. Set forth with particularity any and all medical treatment you have
sought or undergone for the last 3 years to the date of the answers to these Interrogatories, whether
sought of a medical doctor, osteopath, chiropractor, mental health consultant, psychologist,
psychiatrist, chemical dependency counselor, or other practitioner of the healing or counseling arts,
and with respect to each such incident set forth the names and addresses of the person to whom you
went, the symptoms you described to each such person, the treatment you received and the result
thereof.
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INTERROGATORY NO. 43
Professional Evaluation. If you have been seen, tested, evaluated, or treated within the last
three (3) years by any professional person such as a psychiatrist, psychologist, sociologist, social
worker, family counselor, or other professional, 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.
INTERROGATORY NO. 44
Prescription Medication. Describe any prescription medication, which you presently take,
the reason for the prescription, and the name and address of the physician ordering the prescription.
INTERROGATORY NO. 45
Medications/Drugs. Set forth with detail the various drugs you have used, whether
prescription or non-prescription within the last 3 years other than aspirin, and with respect to each
such drug or controlled substance, set forth the reason for the use, the extent of your use, whether
the same was prescribed or non-prescribed, the date you used such drugs or other controlled
substance, and the drugstores or other outlets in which you purchased or otherwise received such
drugs or controlled substances.
INTERROGATORY NO. 46
Chemical Health History. Are you now, or have you at any time in your life, been
dependent upon any chemical substance, whether a controlled substance or not? If so, state full
particulars with respect thereto.
INTERROGATORY NO. 47
Chemical Health Evaluation. Have you ever had any evaluation done or testing performed
to determine if you may be or are chemically dependent? If your answer is in the affirmative, state
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the date, by whom such evaluation or testing was done, the results thereof, and the location at the
present time of the records of such evaluation or testing.
INTERROGATORY NO. 48
Physical Custody. Are you seeking sole physical custody of the minor children of the
parties?
INTERROGATORY NO. 49
#1 Facts Supporting Custody Claim. If your answer to the above is yes, set forth all of
the facts upon which you will rely to establish physical custody of the minor children with yourself
rather than with _____________.#2 Facts Supporting Custody Claim. If it is your contention that the best interest and well-
being of the minor children will be served by granting sole custody to you rather than to Respon-
dent, set forth all facts upon which you rely in making said statement.
INTERROGATORY NO. 50
Witnesses Relative to Custody. Set forth the identity, addresses and telephone numbers of
any and all persons you intend to call, or may call as witnesses relative to the custodial issue s in this
matter.
INTERROGATORY NO. 51
Custody Expert Witnesses. With respect to any expert witnesses you intend to call
concerning the custody of the child, state the following: A. Name, address and telephone number of such person;
B. The field of expertise of each such person;
C. The fact(s) as to which each of said persons will testify;
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D. The opinion which you expect to elicit from each said person and the basis upon which each such opinion is based.
INTERROGATORY NO. 52
Custody Plan. Set forth with particularity your plan for custody of the minor children.
INTERROGATORY NO. 53
Statements Relative to Custody. Have you taken any statements from any person(s) relative
to the custodial issue in this case? If your answer is in the affirmative, state the following: A. Name, address, and telephone number of the person whose statement was taken;
B. Name, address, and telephone number of the person having the present possession of said statement(s);
C. Whether said statement will be voluntarily provided to counsel for _____________ without the necessity of a formal motion and/or whether counsel for _____________
will be allowed to photocopy said statement(s) without the necessity of a formal
motion.
INTERROGATORY NO. 54
Joint Physical Custody. If you are seeking joint custody of the minor children, state the
following: A. Your assessment of the ability of the parents to cooperate in the rearing of the children;
B. Your proposed method of resolving disputes regarding any major decisions concerning the life of the children, and your assessment of the willingness of the
parents to use those methods;
C. Whether you feel it would be detrimental to the children if _____________ worked
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or had sole authority over the children's upbringing and, if so, for what reason.
INTERROGATORY NO. 55
Support, Expenses of Others. List all persons with whom you reside or for whom you
provide support or pay expenses and specifically set out in detail the type of support or expenses
that you have paid for each such person(s) for the past two (2) years.
INTERROGATORY NO. 56
Spousal Maintenance. State whether or not you will be seeking spousal maintenance from
the Respondent. If you are seeking spousal maintenance, please:
a. Set forth in detail you plans to become self-supporting, including training to be taken, the
cost and length of time said training will take;
b. State what amount and for what length of time you
desire maintenance.
INTERROGATORY NO. 57
Rehabilitative or Permanent Maintenance. Will you make a claim for rehabilitative or
permanent maintenance? If so, state the monthly amount you will request. If you will make a claim
for rehabilitative or permanent maintenance, answer Interrogatory No. 2 below. If you will not
make a claim for permanent maintenance, skip to Interrogatory No. 3.
INTERROGATORY NO. 58
Considering the factors set forth in M.S. 518.552, subd. 1 and 2, concerning an award of
maintenance, which states as follows: Subdivision 1. In a proceeding for dissolution of marriage or legal separation, or in a
proceeding for maintenance following dissolution of the marriage by a court which lacked
personal jurisdiction over the absent spouse and which has since acquired jurisdiction, the
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court may grant a maintenance order for either spouse if it finds that the spouse seeking
maintenance:
(a) lacks sufficient property, including marital property apportioned to the spouse, to
provide for reasonable needs of the spouse considering the standard of living established
during the marriage, especially, but not limited to, a period of training or education, or
(b) is unable to provide adequate self-support, after considering the standard of living
established during the marriage and all relevant circumstances, through appropriate
employment, or is the custodian of a child whose condition or circumstances make it
appropriate that the custodian not be required to seek employment outside the home.
Subd. 2. The maintenance order shall be in amounts and for periods of time, either
temporary or permanent, as the court deems just, without regard to marital misconduct, and
after considering all relevant factors including:
(a) the financial resources of the party seeking maintenance, including marital property
apportioned to the party, and the party's ability to meet needs independently, including the
extent to which a provision for support of a child living with the party includes a sum for
that party as custodian;
(b) The time necessary to acquire sufficient education or training to enable the party
seeking maintenance to find appropriate employment, and the probability, given the party's
age and skills, of completing education or training and becoming fully or partially self-
supporting;
(c) The standard of living established during the marriage;
(d) The duration of the marriage and, in the case of a homemaker, the length of absence
from employment and the extent to which any education, skills, or experience have become
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outmoded and earning capacity has become permanently diminished;
(e) The loss of earnings, seniority, retirement benefits, and other employment opportunities
forgone by the spouse seeking spousal maintenance;
(f) The age, and the physical and emotional condition of the spouse seeking maintenance;
(g) The ability of the spouse from whom maintenance is sought to meet needs while
meeting those of the spouse seeking maintenance; and
(h) The contribution of each party in the acquisition, preservation, depreciation, or
appreciation in the amount or value of the marital property, as well as the contribution of a
spouse as a homemaker or in furtherance of the other party's employment or business.
State all facts, which pertain to the following:
A. Regarding subd. 1 (a):
(1) Will you claim you lack sufficient property to provide for your reasonable needs?
(2) If so, set forth all facts upon which you will rely.
(3) Itemize by categories your reasonable needs on a permanent basis as set forth in the attached Exhibit A.
(4) What do you claim is the standard of living established during your marriage? Specify all facts and identify each item of documentary evidence
upon which you will rely to establish the standard of living established
during the marriage.
B. Regarding subd. 1 (b): (1) Will you claim you are unable to provide adequate self-support as set forth herein?
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(2) If you did not answer Interrogatory 2.A. (3) and (4) above, answer fully here.
C. Regarding subd. 2 (a), state all facts upon which you will rely;
D. Regarding subd. 2 (b), state all facts upon which you will rely, including your goals
and specific plans in finding appropriate employment.
E. Regarding subd. 2 (c), state all facts upon which you will rely which you have not previously set forth, if any.
F. Regarding subd. 2 (d), state all facts upon which you will rely;
G. Regarding subd. 2 (e), state or identify separately all forgone earnings; seniority, retirement benefits; and other foregone employment opportunities.
H. Regarding subd. 2 (f), describe each physical or emotional condition you will claim
as affecting the amount or duration of maintenance sought.
I. Regarding subd. 2 (g), state all facts upon which you will rely.
J. Regarding subd. 2 (h), state all facts upon which you will rely.
INTERROGATORY NO.59
Present Residence. With regard to your present residence, set forth the following:
A. Address
B. The name of each other person residing in this residence and the nature of the relationship to you;
C. The owner of said residence;
D. The date and amount of each contribution you have made to the mortgage, rent, CD or similar payment and identify all documents, which substantiate said payments.
E. Do you intend to stay at your present residence? If yes, for how long? If no, describe your future plans to change residences, and any associated costs by amount
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and type.
INTERROGATORY NO.60
Temporary Possession of Household Goods and Personal Property. Identify any items of
household or personal property, which you desire to be awarded to you on a temporary basis.
INTERROGATORY NO. 61
Permanent Possession of Property. Identify each item of personal or real property, including
financial assets, you will ask to be awarded to you on a permanent basis, and state your current
estimate of value for each item.
INTERROGATORY NO. 62
Temporary Maintenance. If you will make a claim for temporary maintenance, set forth the
monthly amount you will request and the basis therefore.
INTERROGATORY NO. 63
Social Security. State with specificity the amount of future social security, pension, or other
retirement income, which you will be entitled to receive.
INTERROGATORY NO. 64
Other Court Proceedings. If you have been involved in any court proceedings or lawsuits of
any kind since __________, for each matter state:
a. The type of matter and nature of the claims;
b. The names of the involved parties;
c. The date when the lawsuit was commenced; and
d. The venue, case caption, and case number of any such lawsuit.
INTERROGATORY NO. 65
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Witnesses. State the name and address of each witness, expert of otherwise, that you intend
to call, or may call on your behalf in this proceeding, and for each such witness, state:a. The substance of the facts and opinions to which the witness is expected to testify;
b. Summary of the grounds for each such opinion; and
c. The contents of any documents that the witness will rely upon.
INTERROGATORY NO. 66
Documents Requested. If any of the documents requested in the Request for Production of
Documents served contemporaneously with these Interrogatories has been destroyed, please list the
date of its destruction, the reason therefore, and the identity of the person who authorized such
destruction. If you have been unable to locate any of the documents requested in the Request for
Production of Documents served contemporaneously with these Interrogatories, please describe all
attempts to locate such documents.
Dated: ___________________________ ATTORNEY _________________________________
Attorney for Petitioner _________________________________________________________________________________
Telephone: ( ) -
Attorney Reg. No. _________
NOTICE OF MISCELLANEOUS PROVISIONS REGARDING PAYMETN OF CHILLD
SUPPORT AND/OR SPOUSAAL MAINTENANCE:
The parties are notified that:
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(a) Payment of support and/or spousal maintenance is to be in cash as ordered herein, and
giving gifts or making purchases of food, clothing, and the like will not fulfill the obligation.
(b) Payment of support and/or spousal maintenance is to be paid as it becomes due, and
failure to secure or denial of rights of visitation is not an excuse for non-payment, but the
aggrieved party must seek relief through a proper motion filed with the Court.
(c) The payment of support and/or maintenance takes priority over payment of debts and
other obligations.
(d) A party who remarries after dissolution and accepts additional obligations of support
does so with the full knowledge of his/her prior obligations under this proceeding, and will
be given no consideration for those additional obligations when accused of "contempt of
court" for failure to make the payments as ordered.
(e) Child support and/or maintenance is based on annual income, and it is the responsibility
of a person with seasonal employment to budget her/her income so that payments are made
regularly throughout the year as ordered.
