Craig v. Ohio Department of Administrative Services

INTERROGATORIES

Comes now the FIELD(4), , and desiring the testimony of FIELD(5), , propounds the following interrogatories to be answered separately and severally, in the manner and form provided by law: viz:

1. State each job or employment which you have held in the last five (5) years, listing the name of your employer, job title, salary or wages, years employed and reason for leaving said employment.

2. Please list all income, revenue, monies, or sums, from whatever sources, which you have received during the preceding three (3) years, stating the source and amounts which you have so received, and dates received.

3. Please list each and every bank account or account with any other financial institution, whether savings, checking, or otherwise, which you have maintained during the preceding three (3) years, or presently maintain, alone or together with any other person, or persons, in your own name or in any other name. As part of your answer, give the name and address of each bank or financial institution, the name in which the account was maintained and the account number.

4. Have you kept or made any books of accounts, personal financial statements, or loan applications or records of your financial affairs, during the last three (3) years? If so, give the names, addresses and telephone numbers of any persons having custody of those records.

5. Do you have an accountant? If so, please list his name and office address. List this information for any accountant you have used in the past five (5) years.

6. List, describe, and give present market value and the original purchase price of any of the following items that you own or have any interest in, directly or indirectly:

(a) Negotiable and non-negotiable instruments and securities of any description, including stock, bonds, mutual funds, treasury instruments, money market accounts, annuity contracts, and the like.

(b) Profit sharing trusts; pension plans, retirement plans, individual retirement arrangements.

(c) Household goods and furniture and equipment, household stores, wearing apparel and jewelry.

7. List all debts due to you by any corporations, partnerships, persons or other entities. Give the amounts of the debts, and the names and addresses of the persons or corporations owing you the debts or open accounts.

8. State whether you are the beneficiary of any estate, trust, insurance policy, or annuity. If so, describe the nature and amount of each of those benefits.

9. Please state with specificity each and every credit card, charge account, or other credit account which you presently have, including as part of your answer the name or names in which said card or account is maintained, the credit card or account number, the name of the card or account, and the current amount due on said card or account.

10. Please list each and every automobile or motor vehicle, boats, or airplanes, which you currently own, possess, control, or drive, stating the make, model and body style, the license plate number for the current year, and the owner of said vehicle.

11. Please list all real property which you own or have any interest in at the present time or for the preceding three years, giving in your answer the following information:

(a) The legal description of each tract or parcel;

(b) The date on which each tract or parcel was acquired or sold;

(c) If your ownership in each said tract or parcel is less than complete ownership, the extent of your interest and the names and addresses of the person or persons who own the remaining interest;

(d) The purchase or sale price of each parcel or tract;

(e) Any lien, encumbrance, or indebtedness against each parcel or tract, giving the name and address of the holder of such lien, encumbrance or indebtedness, the present principal balance outstanding, and the form of payment;

(f) The present fair market value of each tract or parcel;

(g) The names of the grantors, grantees, buyers, and sellers.

12. Please state, to the best of your ability, your present net worth.

13. During your marriage to your spouse, have you had sexual relations with any individual or individuals other than your spouse? If your answer is in the affirmative, please state the name and address of such person or persons, and the dates and places where such relations took place.

14. Please state whether you have ever hit, kicked, struck, or otherwise physically abused your spouse. If your answer is in the affirmative, please state the dates and places such physical abuse occurred, the facts surrounding such abuse, and the nature or type of injuries inflicted. Please state whether any person or persons have been present on such occasions, giving their names and addresses.

15. Please state whether you contend that your spouse committed wrongdoing of any nature during the term of your marriage. If so, state the nature of the alleged misconduct, giving in detail the facts and circumstances which support your allegation.

16. Have you conducted any surveillance, whether personally, by an investigator, by any other person, or by electronic means, including intercepting or taping telephone calls of your spouse within the past five (5) years, or has any person or persons conducted such surveillance on your behalf? If so:

(a) State what surveillance you have conducted, including the date, time and place of such surveillance and what you observed.

(b) If some other person or persons conducted such surveillance in your behalf, state the name and address of such person or persons, the date, time and place of such surveillance, and state what was related to you as to what was observed.

17. Are you aware of any documentary evidence, photographs or testimony by any witness that you intend to use at the trial of this case or on deposition in this case which tends to prove that your spouse has had sexual relations with any person other than yourself from the date of your marriage down to the date you answer this interrogatory? If so:

(a) State what documentary evidence you intend to use, including the nature of what is depicted in any photograph.

(b) State the name and address of the person or persons who will so testify together with a synopsis of the expected testimony.

18. If you claim you have any disability of any nature, please state:

(a) The nature or type of the disability;

(b) Please list the name, address and telephone number of each doctor, dentist, or other physician by whom you have been treated within the last five (5) years.

19. Please give the name and addresses of all witnesses whom you intend to call for any purpose in the trial of this cause.

20. Completely list and describe all documents or other physical evidence (tapes, photographs, records, diaries, files, etc) which you intend to use in the preparation or trial of this case.

21. Have you been advised that your answers are made under oath, may be used as material testimony in the event of a trial or hearing, and must be updated if your foregoing responses change?

Dated this the day of FIELD(6),

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the foregoing Interrogatories upon FIELD(8), , by placing a copy of same in the U. S. mail, properly addressed and postage prepaid this day of