Best Custody Interrogatories

INTERROGATORIES

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF JUDICIAL DISTRICT

FAMILY COURT DIVISION

In Re the Marriage of:

AND

* * * * * * * * * * * * * * * * * *

TO: , ABOVE-NAMED, BY AND THROUGH (HIS)(HER) ATTORNEY, .

YOU WILL PLEASE TAKE NOTICE that demands Answers under oath by , within (thirty)(forty-five) (30)(45) days of the service hereof pursuant to Minn. R. Civ. P. 26 and 33, to the following Interrogatories. If information is discovered by or becomes known to you or to your attorneys or to anyone acting on your behalf, after answering the same and before trial, which would change or add to the answers given, you are hereby directed to promptly furnish such information to the undersigned.

DEFINITIONS

"Child" as used in these Interrogatories shall mean the child that is the subject matter of this suit, namely, .

"Conception" as used in these Interrogatories shall mean the period of time extending from through .

"Pregnancy" as used in these Interrogatories shall mean the period of time that carried the child, , in her womb.

1. State your name, age and present residence address, and identify all other persons residing at your present residence address.

2. State your permanent residence address if it is different from the address noted in your Answer to Interrogatory No. 1, and identify all other persons residing at your permanent residence address.

3. State all addresses at which you have resided since .

4. State the names and present addresses of any persons who resided with you during the period of conception.

5. State the full names of any persons you have been married to, the date of each marriage, the date of any dissolutions of marriage, and the county in which any such dissolutions were granted.

6. Describe 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.

7. 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.

8. Describe in detail all of your sources of income or compensation, whether or not reported on any Tax Return since , and, as and 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.

9. 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.

10. Set forth in detail each and all of your assets having a fair market value in excess of Dollars ($) and state the:

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. exact name or names of the record and/or registered owners thereof;

c. date of acquisition;

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

f. encumbrances, if any, against the asset, setting forth the name and address of the encumbrancee, the date of the encumbrance, the original amount thereof, the present balance thereof, and the nature of the payoff.

11. If any person, corporation, partnership, or entity of any nature owes you any money, then for each debtor state:

12. 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.

13. 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 (the date of these Interrogatories) ().

14. 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.

15. 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 these Interrogatories.

16. Describe in detail any program of medical, hospitalization, or dental insurance available to you through your employment or otherwise and indicate all eligible beneficiaries of said plan.

17. Describe any tests or medical procedures that were performed during pregnancy that might indicate the date of conception and indicate the results thereof and state the name and address of the clinic or physician who administered said tests.

18. State any facts or information that you have that would indicate the time or approximate time that the child was conceived.

19. State the length of time, if known, or the approximate length of time, that you carried the child and whether the child was born prematurely.

20. State the names and addresses of all institutions, doctors, or other persons providing care, treatment, or other services to you in connection with the conception, pregnancy, and birth that is the subject matter of this suit.

21. Describe in detail the circumstances surrounding each (alleged) act of intercourse between you and Defendant including, but not limited to, the time, date and location of each such (alleged) occurrence.

22. State the names and present addresses of any persons having knowledge of the (alleged) acts of intercourse.

23. State the names and addresses of all persons that have information or knowledge of any relationship between you and Defendant.

24. State whether or not the child has lived continuously with you from birth to the present.

25. If the child has not lived continuously with you since birth, state why the child did not live with you, who the child lived with, where the child lived, and the dates the child did not live with you.

26. State the names, ages and present addresses of all persons, other than hospital staff and your personal physician, who visited you while in the hospital incident to the pregnancy or the birth of the child.

27. State the names and addresses of all male persons who have given money, clothing, or items of value to the child on more than one occasion.

28. State the names and present addresses of all persons with whom you had sexual intercourse during the period of conception.

29. State the names and present addresses of all persons with whom you have discussed the parentage of the child.

30. State the names and present addresses of all persons who have admitted or alleged parentage of the child.

31. Describe in detail all contacts whether by phone, written document, or in person that you have had with Defendant since your first acquaintance with Defendant, since the conception of the child, and since the birth of the child.

32. State how you learned you were pregnant, who told you that you were pregnant and the date of your last menstrual period prior to the discovery of your pregnancy.

33. With respect to your menstrual periods in the year preceding conception, indicate whether your menstrual periods were regular and the date of your menstrual periods during the three (3) months prior to the period of conception.

34. If any contraceptives were used by you in the six (6) months preceding the period of conception, state each type of contraceptive used and the date of such use.

35. Describe with particularity any medical care or treatment that you or any of the minor children receive or have received on a regular basis, identify the person rendering such treatment, and state the costs thereof.

36. 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:

37. 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.

38. Set forth with particularity an itemized schedule of your average monthly living expenses stating separately, wherever possible, all expenses relating to other persons including, but not limited to, the minor child.

39. As to each expense, state whether it is typically paid by check, money order, cash, or some other medium of payment.

40. 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.

41. State the permanent legal and physical custody arrangements that you believe are in the best interests of the child, and specifically address the time that each parent should have with the child.

42. Describe in detail the custody and/or visitation arrangements which have existed since the child's birth, and specifically set forth the time spent by each party with the child.

43. If you or the child 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.

44. 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.

45. For each criminal, civil, domestic abuse, or other incident reported to the police, in which you have been involved since , state the:

46. If you have been cited for any offense or charged with any crime since , for each matter state the:

47. If you have been involved in any legal proceedings of any kind since , for each matter state the:

48. 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: