Connecticut Interrogatories

Defendant's First Set of Interrogatories Propounded to the Plaintiff With Request for Production

Name of Defendant:

Address:

City, State, Zip:

Phone:

IN THE SUPERIOR COURT FOR

COUNTY, STATE OF CONNECTICUT

COMES NOW ("Defendant") and propounds the following interrogatories to ("Plaintiff") pursuant to Connecticut Rules...

Production requests are also made pursuant to the rules of the State of Connecticut. Defendant requests that Production of documents be made on the same date as the date Answers to Interrogatories are due and shall be made to Defendant at the following address:

INTERROGATORY NO. 1

State your full name, social security number, date of birth, residence address, and telephone number.

INTERROGATORY NO. 2

Please attach to your answer to these interrogatories copies of your income tax returns and W-2 forms for the past three years.

Attachment reference:

INTERROGATORY NO. 4

State your total income to date since , and attach to your answers copies of your last five paycheck stubs.

INTERROGATORY NO. 5

List all assets presently owned by you. Give a complete and detailed listing.

INTERROGATORY NO. 6

List the name, place of employment and telephone number of any person residing at your residence.

INTERROGATORY NO. 7

If you rent the place in which you live, give the name of your landlord, his or her address and telephone number.

INTERROGATORY NO. 8

Outline in detail your monthly living expenses.

INTERROGATORY NO. 9

List all other income received by you other than from your employment, stating the source and the amount.

INTERROGATORY NO. 10

If you claim to have grounds for divorce against the Defendant, please state all circumstances, facts, and events upon which you base such grounds.

INTERROGATORY NO. 11

What safety deposit boxes do you currently maintain whether alone or jointly held?

INTERROGATORY NO. 12

What bank accounts, if any, do you presently maintain, whether alone or jointly held?

INTERROGATORY NO. 13

Do third parties hold any property in trust for you or for your benefit?

INTERROGATORY NO. 14

Have you ever been arrested?

INTERROGATORY NO. 15

Have you ever received psychiatric treatment?

INTERROGATORY NO. 16

Are you taking any drugs, and the amount of money you spend each month for said drugs.

INTERROGATORY NO. 17

Do you use any type of drugs which are not prescribed by a physician?

INTERROGATORY NO. 18

Do you consume alcoholic beverages on a regular basis?

INTERROGATORY NO. 19

Are you addicted to alcohol or drugs of any kind?

INTERROGATORY NO. 20

Have you ever had sexual relations with anyone other spouse during the course of your marriage?

INTERROGATORY NO. 21

State whether or not you have provided any banks or other lending institutions with financial statements during the past 24 months.

INTERROGATORY NO. 22

For each person you shall call as a witness at the trial of this case, please state the witness's name and address, whether employed by you, and the subject matter to which the witness shall testify.

INTERROGATORY NO. 23

For each person you allege to be an occurrence witness, please state the witness's name and address, whether employed by you, and the subject matter to which the witness shall testify.

INTERROGATORY NO. 24

For each person you expect to call as an expert witness at trial, please provide the requested qualifications and testimony information.

INTERROGATORY NO. 25

For each document or other item you shall offer as an exhibit at trial, please state the title or name of the document, date of the document and purpose for which it will be used as an exhibit.

INTERROGATORY NO. 26

State the names and addresses of all persons involved in the answering of these interrogatories.

INTERROGATORY NO. 27

Have you read the answers to each and every one of the above interrogatories and requests for production and do you state that the answers are true, complete, responsive and correct?

INTERROGATORY NO. 28

If you come into possession of new information before trial, will you disclose it within fifteen days?

Respectfully submitted,

CERTIFICATE OF SERVICE

I, , Defendant, do hereby certify that I have this day mailed a true and correct copy to Plaintiff at:

Name of Plaintiff:

Address:

Dated, this the day of

Notice of Service of Discovery

Name of Defendant:

Address:

City, State, Zip:

Phone:

IN THE SUPERIOR COURT FOR

COUNTY, STATE OF CONNECTICUT

TO: All Counsel of Record:

Notice is hereby given that Defendants have this date served in the above entitled action:

DEFENDANT'S FIRST SET OF INTERROGATORIES PROPOUNDED TO THE PLAINTIFF WITH REQUEST FOR PRODUCTION

The undersigned retains the originals of the above papers as custodian thereof pursuant to Court Rules.

Dated:

Certificate of Service

I, , Defendant in the above referenced civil action, do hereby certify that I have this day caused to be delivered, via United States Postal Service, first class postage prepaid, a true and correct copy of the above and foregoing document to:

Plaintiff's Name:

Address:

This the day of , 20 .