Matrimonial Interrogatories

Matrimonial Interrogatories

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INTERROGATORY NO. 1: State your full name, current address, date of birth and social security number.

Full name:

Current address:

Date of birth:

Social security number:

INTERROGATORY NO. 2: List all employment held by you during the preceding three years and with regard to each employment state:

(a) Name and address of each employer:

(b) Position, job title or description:

(c) Employment contract:

(d) Commencement and termination details:

(e) Current gross and net income per pay period:

(f) Gross income, W-2 wages, and deductions:

(h) Additional benefits or perquisites:

INTERROGATORY NO. 3: During the preceding three years, have you had any source of income other than from your employment listed above?

(a) Source of income and address:

(b) Frequency received:

(c) Amount received during preceding three years:

(d) Monthly amounts during preceding three years:

INTERROGATORY NO. 4: Do you own any interest in real estate?

(a) Size and description of parcel:

(b) Name, address and interest of each person claiming ownership:

(c) Date interest acquired:

(d) Consideration paid/transferred:

(e) Current fair market value and interest:

(f) Indebtedness and creditor:

(g) Associations, partnerships, corporations, enterprises or entities:

INTERROGATORY NO. 5: During the preceding three years, have you had any account or investment in any type of financial institution?

(a) Type of account or investment:

(b) Name and address of financial institution:

(c) Name and address of each holder:

(d) High and low balance with dates:

INTERROGATORY NO. 6: During the preceding three years, have you been the holder of or had access to any safety deposit boxes?

(a) Bank or institution location:

(b) Box number:

(c) Contents of each box:

(d) Joint/co-owners or trustees:

INTERROGATORY NO. 7: During the immediately preceding three years, has any person or identity held cash or property on your behalf?

(a) Holder name and address:

(b) Type of cash or property and value:

(c) Stocks, bonds, securities or other investments:

(7) If applicable, sale date and amount realized:

INTERROGATORY NO. 8: Do you own or have any incidents of ownership in any life, annuity or endowment insurance policies?

(a) Company name:

(b) Policy number:

(c) Face value:

(d) Present value:

(e) Loan or encumbrance:

(f) Date of acquisition:

(g) Beneficiary or beneficiaries:

INTERROGATORY NO. 9: Do you have any right, title, claim or interest in or to a pension plan, retirement plan or profit sharing plan?

(a) Entity providing the plan:

(b) Date of initial participation:

(c) Amount currently held:

INTERROGATORY NO. 10: Do you have any outstanding indebtedness or financial obligations?

(a) Creditor name and address:

(b) Form of obligation:

(c) Date initially incurred:

(d) Original amount:

(e) Purpose/consideration:

(f) Security description:

(g) Interest rate:

(h) Present unpaid balance:

(i) Installment payments:

(j) Maturity date:

INTERROGATORY NO. 11: Are you owed any money or property?

(a) Debtor name and address:

(b) Form of obligation:

(c) Date initially incurred:

(d) Original amount:

(e) Purpose/consideration:

(f) Security description:

(g) Interest rate:

(h) Present unpaid balance:

(i) Installment payments:

(j) Maturity date:

INTERROGATORY NO. 12: State the year, make and model of each motor or motorized vehicle, motor or mobile home and farm machinery or equipment in which you have an ownership, estate, interest or claim of interest.

(a) Date acquired:

(b) Consideration paid:

(c) Other owners:

(d) Approximate fair market value:

(e) Indebtedness and creditor:

INTERROGATORY NO. 13: Have you purchased or contributed towards the payment for or provided other consideration or improvement with regard to any property on behalf of another person or entity other than your spouse during the preceding three years?

(a) Person/entity contributed to:

(b) Type of contribution:

(c) Property type:

(d) Property location:

(e) Written evidence of loan:

(f) Description of written evidence:

INTERROGATORY NO. 14: During the preceding three years, have you made any gift of cash or property, real or personal, to any person or entity not your spouse?

(a) Description of gift:

(b) Value of gift:

(c) Date of gift:

(d) Recipient name and address:

(e) Written evidence of gift:

(f) Description of written evidence:

INTERROGATORY NO. 15: During the preceding three years, have you made any loans to any person or entity not your spouse?

(a) Description of loan:

(b) Value of loan:

(c) Date of loan:

(d) Recipient name and address:

(e) Written evidence of loan:

(f) Description of written evidence:

INTERROGATORY NO. 16: During the preceding three years, have you sold, transferred, conveyed, encumbered, concealed, damaged or otherwise disposed of any property owned by you and/or your spouse individually or collectively?

(a) Description of property:

(b) Current location:

(c) Purpose or reason:

(d) Approximate fair market value:

(e) Written evidence of transaction:

(f) Description of written evidence:

INTERROGATORY NO. 17: During the preceding three years, have any appraisals been made with regard to any property listed in your answers?

(a) Appraiser name and address:

(b) Property appraised:

(c) Date of appraisal:

(d) Location of copies:

INTERROGATORY NO. 18: During the preceding three years, have you prepared or has anyone prepared for you any financial statements, net worth statements or lists of assets and liabilities?

(a) Preparer name and address:

(b) Type of document prepared:

(c) Date prepared:

(e) Location of copies:

INTERROGATORY NO. 19: State the name and address of any accountant, tax preparer, bookkeeper and other person, firm or entity who has kept or prepared books, documents and records.

INTERROGATORY NO. 20: List all nonmarital property claimed by you.

INTERROGATORY NO. 21: List all marital property of this marriage.

INTERROGATORY NO. 22: What contribution or dissipation has your spouse made to the marital estate?

INTERROGATORY NO. 23: Provide the name and address of each witness who will testify at trial and state the subject of each witness' testimony.

INTERROGATORY NO. 24: Provide the name and address of each opinion witness who will offer any testimony.

(a) Subject matter:

(b) Conclusions/opinions and basis:

(c) Qualifications:

(d) Written reports:

INTERROGATORY NO. 25: Are you in any manner incapacitated or limited in your ability to earn income at the present time?

INTERROGATORY NO. 26: Identify any statements, information and/or documents known to you and requested by the foregoing interrogatories which you claim to be work product or privileged.

DATED this the day of , 20.

Respectfully Submitted,

CERTIFICATE OF SERVICE

This is to certify that I, , have mailed this day, by U.S. Mail, postage fully prepaid, a copy of the above and foregoing interrogatories to:

This the day of , 20.