Fill and Sign the Discovery Defendants Interrogatories to Plaintiff Paternity Minnesota Form

STATE OF MINNESOTA DISTRICT COURT COUNTY OF JUDICIAL DISTRICT FAMILY COURT DIVISION In Re the Marriage of: Court File No. , Petitioner, DEFENDANTS INTERROGATORIES TO PLAINTIFF AND , Respondent, TO: ___________________________ YOU WILL PLEASE TAKE NOTICE that the undersigned as attorneys for the Defendant herein demand that the Plaintiffs 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 that 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 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. - 1 - 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. DEFINITION Period of Conception: This is defined as the month preceding the alleged conception, the month of the alleged conception, and the month subsequent to the alleged conception. INTERROGATORY 1 1. FULL NAME, DATE OF BIRTH, AND PRESENT ADDRESS OF MOTHER. INTERROGATORY 2 2. IF ANY PERSON OTHER THAN THE MOTHER LIVES AT HER ADDRESS, STATE THE NAME OF EVERY SUCH OTHER PERSON AND THE RELATIONSHIP TO MOTHER, IF ANY. INTERROGATORY 3 3. A STATEMENT OF THE MOTHER'S PRESENT EARNINGS AND INCOME. INTERROGATORY 4 4. DATE AND PLACE OF BIRTH OF THE CHILD WHO IS THE SUBJECT OF THIS ACTION AND THE FULL NAME OF THIS CHILD. INTERROGATORY 5 5. IF THE ABOVE CHILD HAS BEEN BAPTIZED, THE DATE AND PLACE OF BAPTISM, AND THE NAMES AND ADDRESSES OF THE GODPARENTS, IF SUCH THERE BE. INTERROGATORY 6 6. IF THE ABOVE CHILD'S BIRTH HAS BEEN REGISTERED WITH ANY CHURCH, TEMPLE, SYNAGOGUE, OR OTHER PLACE OF WORSHIP, THE DATE AND PLACE OF SUCH REGISTRATION. - 2 - INTERROGATORY 7 7. WHETHER IT WILL BE CLAIMED THAT THE CHILD ABOVE-NAMED WAS BORN AFTER A NORMAL PERIOD OF GESTATION. INTERROGATORY 8 8. IF THE ANSWER TO NUMBER "7" ABOVE IS IN THE NEGATIVE, THEN STATE WHETHER IT WILL BE CLAIMED THAT THE CHILD WAS BORN PREMATURELY OR POSTMATURELY. INTERROGATORY 9 9. STATE WHETHER THE MOTHER HAS EVER BEEN MARRIED. INTERROGATORY 10 10. IF THE MOTHER HAS BEEN MARRIED, THEN STATE THE DATE AND PLACE OF EACH MARRIAGE, THE NAME OF HER HUSBAND, AND THE PERIOD DURING WHICH THE MARRIAGE WAS IN EXISTENCE. INTERROGATORY 11 11. STATE WHETHER THE MOTHER HAS EVER BEEN A PARTY TO A DIVORCE, ANNULMENT, SEPARATION OR OTHER PROCEEDING AGAINST HER HUSBAND. IF SO, STATE THE NAME OF THE COURT IN WHICH THE ACTION OR THE PROCEEDING WAS PENDING; THE TITLE AND NATURE OF THE COURT IN WHICH THE ACTION OR THE PROCEEDING WAS PENDING; THE JUDGMENT OR DECISION RENDERED AND THE DATE OF SAID JUDGMENT OR DECISION. INTERROGATORY 12 12. STATE THE DATES OF BIRTH AND THE NAMES OF ALL CHILDREN OF WHICH PLAINTIFF IS THE NATURAL MOTHER, AND THE NAME OF THE FATHER OF EACH CHILD BORN. INTERROGATORY 13 13. STATE WHETHER THE MOTHER HAS EVER APPLIED FOR OR RECEIVED FINANCIAL AID FROM ANY STATE, COUNTY, MUNICIPALITY OR DEPARTMENT THEREOF, OR ANY PRIVATE SOCIAL SERVICE AGENCY. IF SO, THE NAME AND ADDRESS OF EACH GOVERNMENTAL DEPARTMENT OR SOCIAL SERVICE AGENCY. INTERROGATORY 14 14. WITH REFERENCE TO EACH AND EVERY OCCASION YOU HAD SEXUAL RELATIONS WITH THE DEFENDANT, SET FORTH THE FOLLOWING INFORMATION: A) DATE OF EACH OCCURRENCE; _____________ B) PLACE AND TIME OF EACH OCCURRENCE; _____________ - 3 - C) TIME AND PLACE WHERE YOU AND THE DEFENDANT MET; _____________ D) WHERE YOU WENT AFTER MEETING; _____________ E) TIME YOU AND DEFENDANT PARTED; _____________ F) DID YOU USE ANY CONTRACEPTIVE DEVICE, MEDICINE OR PREVENTATIVE? _____________ G) DID THE DEFENDANT USE A CONTRACEPTIVE; AND _____________ H) IF ANY OTHER PERSON SAW YOU WITH THE DEFENDANT FROM THE TIME OF MEETING TO THE TIME OF DEPARTURE, GIVE THE NAME AND ADDRESS OF EACH SUCH PERSON. _____________ INTERROGATORY 15 15. IF ANY OF THE ACTS OF SEXUAL INTERCOURSE ARE CLAIMED TO HAVE OCCURRED IN CERTAIN PREMISES OR PLACES, THE SPECIFIC PORTIONS OR PLACES THEREOF. INTERROGATORY 16 16. STATE THE DATE, HOUR AND PLACE OF THE ALLEGED ACT OF SEXUAL INTERCOURSE THAT IT WILL BE CLAIMED RESULTED IN IMPREGNATION. INTERROGATORY 17 17. STATE THE DATE OF COMMENCEMENT AND TERMINATION OF YOUR LAST MENSTRUATION PRIOR TO CONCEPTION OF THE CHILD AND THE IMMEDIATELY PRECEDING MENSTRUATION. INTERROGATORY 18 18. HAD YOUR MENSTRUAL CYCLES BEEN REGULAR? INTERROGATORY 19 19. STATE WHEN, IF EVER, THE MOTHER FIRST INFORMED THE DEFENDANT OF HER PREGNANT CONDITIONS, OR OF THE BIRTH OF THE CHILD, WHICH THE PLAINTIFF CLAIMS WAS FATHERED BY THE DEFENDANT THEREIN. INTERROGATORY 20 20. STATE THE NAMES AND ADDRESSES OF ALL PHYSICIANS WHO: A) WERE CONSULTED BY THE MOTHER DURING THE PREGNANCY HEREIN; B) ATTENDED THE MOTHER DURING THE PREGNANCY OF THE CHILD NAMED HEREIN; AND - 4 - C) NAMES OF ANY PERSONS WHO DELIVERED OR ATTENDED THE DELIVERY OF THE CHILD, WHICH THE PLAINTIFF CLAIMS THE DEFENDANT HAS FATHERED. INTERROGATORY 21 21. WITH REFERENCE TO THE CHILD WHO IS THE SUBJECT OF THIS ACTION, SET FORTH THE FOLLOWING INFORMATION: A) NAME; _____________ B) DATE OF BIRTH; _____________ C) CITY OF BIRTH; _____________ D) HOSPITAL WHERE BORN; _____________ E) NAME OF THE FATHER OF THE CHILD ON THE CHILD'S BIRTH CERTIFICATE; _____________ F) NAME AND ADDRESS OF THE PERSON WHO SUPPLIED THE INFORMATION FOR THE BIRTH CERTIFICATE; AND _____________ G) IF A PERSON OTHER THAN THE DEFENDANT WAS NAMED AS THE CHILD'S FATHER ON THE BIRTH CERTIFICATE, STATE THE REASON THEREFOR. _____________ INTERROGATORY 22 22. STATE WHETHER OR NOT YOU EVER HAD ANY OTHER CHILD OR CHILDREN BORN OUT OF WEDLOCK. INTERROGATORY 23 23. IF YOUR ANSWER TO NUMBER "22" ABOVE IS IN THE AFFIRMATIVE, SET FORTH THE FOLLOWING INFORMATION OF EACH CHILD: A) NAME OF CHILD; _____________ B) DATE AND PLACE OF BIRTH; AND _____________ C) NAME OF FATHER. _____________ INTERROGATORY 24 24. DID YOU HAVE SEXUAL INTERCOURSE WITH ANY PERSON OTHER THAN THE DEFENDANT DURING THE MONTHS OF _____________ , _____________ , AND _____________ , 20 ___ ? INTERROGATORY 25 - 5 - 25. IF YOUR ANSWER TO NUMBER "24" ABOVE IS IN THE AFFIRMATIVE, GIVE THE FOLLOWING INFORMATION FOR EACH PERSON: A) NAME AND ADDRESS OF THE PERSON; _____________ B) DATE ON WHICH INTERCOURSE OCCURRED; _____________ C) ADDRESS OR DESCRIPTION OF THE PLACE AT, WHICH INTERCOURSE OCCURRED; _____________ D) STATE WHETHER OR NOT SUCH PERSON GAVE YOU ANY MONEY OR PROPERTY OF ANY KIND OR NATURE AT ANY TIME; _____________ E) WHETHER ANY CONTRACEPTIVE OF ANY TYPE WAS USED BY EITHER; AND _____________ F) STATE EACH FACT ON WHICH YOU RELY TO SUPPORT THE CONTENTION THAT THIS PERSON IS THE FATHER OF THE CHILD. _____________ INTERROGATORY 26 26. DO YOU CONTEND THAT YOU SHARED A HOTEL OR MOTEL ROOM WITH THE DEFENDANT AT ANY TIME DURING THE TWELVE-MONTH PERIOD PRECEDING THE BIRTH OF THE CHILD? _____________ INTERROGATORY 27 27. IF YOUR ANSWER TO NUMBER "26" ABOVE IS IN THE AFFIRMATIVE, GIVE THE FOLLOWING INFORMATION FOR EACH HOTEL OR MOTEL: A) NAME AND ADDRESS; _____________ B) DATES OF OCCUPATION OF QUARTERS; _____________ C) DATE OF REGISTRATION; _____________ D) NAME OF PERSON REGISTERING; _____________ E) NAME OR NAMES GIVEN ON REGISTRATION; _____________ F) NAME OF PERSON PAYING FOR ROOM; AND _____________ G) AMOUNT PAID FOR ROOM. _____________ INTERROGATORY 28 28. DO YOU CONTEND YOU SHARED A COMMON DWELLING WITH THE DEFENDANT AT ANY TIME DURING THE TWELVE-MONTH PERIOD - 6 - PRECEDING THE BIRTH OF THE CHILD? _____________ INTERROGATORY 29 29. IF YOUR ANSWER TO NUMBER "28" ABOVE IS IN THE AFFIRMATIVE, GIVE THE FOLLOWING INFORMATION FOR EACH DWELLING: A) ADDRESS OF THE DWELLING; _____________ B) NAME AND ADDRESS OF EACH PERSON WHO HAD KNOWLEDGE OF THE FACT THAT YOU SHARED SAID DWELLING; AND _____________ C) DATES OF COMMENCEMENT AND TERMINATION OF THE SHARING OF SAID DWELLING. INTERROGATORY 30 30. IF ANY ACTION HAS BEEN COMMENCED IN ANY COURT IN WHICH YOU ALLEGE THAT A PERSON OTHER THAN THE DEFENDANT IN THE PRESENT ACTION WAS THE FATHER OF THE CHILD IN THE PRESENT ACTION, SET FORTH THE FOLLOWING: A) TITLE OF COURT; _____________ B) ACTION NUMBER; AND _____________ C) DISPOSITION OF THE ACTION. _____________ INTERROGATORY 31 31. IF YOU CLAIM THAT YOU AND THE DEFENDANT HAD ANY CONVERSATIONS CONCERNING YOUR PREGNANCY, THE DELIVERY OF THE CHILD, THE CHILD ITSELF, THE SUPPORT OF THE CHILD, OR ANY OTHER MATTER PERTAINING TO THE PRESENT ACTION, GIVE THE FOLLOWING INFORMATION FOR EACH CONVERSATION: A) DATE; _____________ B) PLACE (IF NOT BY TELEPHONE); _____________ C) IF BY TELEPHONE, WHETHER OR NOT ANY OTHER PERSON WAS LISTENING IN ON THE CONVERSATION AT YOUR END OF THE LINE; _____________ D) IF ANY PERSON WAS LISTENING IN AT YOUR END OF THE LINE, THE NAME AND ADDRESS OF SUCH PERSON; _____________ E) IF NOT BY TELEPHONE, THEN THE NAME AND ADDRESS OF ANY OTHER PERSON PRESENT; _____________ - 7 - F) WHAT WAS SAID BY EACH PERSON PARTICIPATING IN THE CONVERSATION? _____________ G) WAS ANY RECORDING MADE OF THE CONVERSATION? _____________ H) IF RECORDED, HAS IT BEEN TRANSCRIBED? _____________ I) IF RECORDED, WHO HAS POSSESSION OF THE RECORD? _____________ J) IF RECORDED AND TRANSCRIBED, WHO HAS POSSESSION OF THE TRANSCRIPTION?; AND _____________ K) CAN YOUR FURNISH EITHER THE RECORDING OR THE TRANSCRIPTION? _____________ INTERROGATORY 32 32. WERE THEIR ANY WRITTEN COMMUNICATIONS BETWEEN YOU AND THE DEFENDANT, OR THE DEFENDANT AND THE CHILD THAT HAVE ANY BEARING ON THE PRESENT ACTION? _____________ INTERROGATORY 33 33. IF YOUR ANSWER TO THE LAST QUESTION IS IN THE AFFIRMATIVE, SET FORTH THE CONTENTS OF SUCH COMMUNICATION (OR ATTACH A COPY THEREOF HERETO). INTERROGATORY 34 34. TO YOUR KNOWLEDGE, HAS THE DEFENDANT STATED TO ANY OTHER PERSON THAT HE IS THE FATHER OF SAID CHILD? _____________ INTERROGATORY 35 35. IF YOUR ANSWER TO THE LAST QUESTION IS IN THE AFFIRMATIVE, GIVE THE FOLLOWING INFORMATION FOR EACH SUCH STATEMENT: A) NAME AND ADDRESS OF PERSON TO WHOM STATEMENT WAS MADE; _____________ B) WHETHER OR NOT SUCH STATEMENT WAS MADE BY TELEPHONE; _____________ C) PLACE STATEMENT WAS MADE; _____________ D) DATE STATEMENT WAS MADE; _____________ E) THE NAME AND ADDRESS OF EACH PERSON WHO HEARD THE STATEMENT BEING MADE; _____________ F) THE CONTENTS OF THE STATEMENT; _____________ - 8 - G) WHETHER OR NOT A RECORDING OF THIS STATEMENT WAS MADE; _____________ H) IF RECORDED, HAS IT BEEN TRANSCRIBED?; _____________ I) IF RECORDED, WHO HAS POSSESSION OF THE RECORD?; AND _____________ J) WILL YOU REQUIRE A MOTION TO PRODUCE EITHER THE RECORDING OR THE TRANSCRIPTION? _____________ INTERROGATORY 36 36. DO YOU CONTEND THERE IS ANY PHYSICAL RESEMBLANCE BETWEEN THE DEFENDANT AND THE CHILD? IF SO, SET FORTH IN DETAIL THE SIMILARITIES YOU CLAIM EXIST. _____________ INTERROGATORY 37 37. HAS THE DEFENDANT CONTRIBUTED ANYTHING TO THE SUPPORT OF THE CHILD WHO IS THE SUBJECT OF THIS ACTION? _____________ INTERROGATORY 38 38. IF YOUR ANSWER TO NUMBER "37" ABOVE IS IN THE AFFIRMATIVE, SET FORTH THE DATE AND THE AMOUNT OF EACH PAYMENT. _____________ INTERROGATORY 39 39. HAS THE DEFENDANT CONTRIBUTED ANY MONEY TOWARD THE DELIVERY OR PRENATAL OR POSTNATAL CARE OF THE CHILD WHO IS THE SUBJECT OF THIS ACTION? _____________ INTERROGATORY 40 40. IF YOUR ANSWER TO THE LAST QUESTION IS IN THE AFFIRMATIVE, SET FORTH THE DATE, AMOUNT, AND RECIPIENT OF EACH PAYMENT AND PURPOSE OF THE PAYMENT. _____________ INTERROGATORY 41 41. HAS THE DEFENDANT EVER GIVEN YOU ANY PROPERTY OR MONEY OTHER THAN THE DESCRIBED ABOVE? _____________ INTERROGATORY 42 42. IF YOUR ANSWER TO NUMBER "41" IS IN THE AFFIRMATIVE, STATE THE FOLLOWING FOR EACH ITEM: A) THE AMOUNT OF MONEY OR NATURE OF DONATION, IF NOT MONEY; _____________ B) DATE; _____________ - 9 - C) STATE WHETHER THE DONATION WAS PERSONAL OR MADE THROUGH THE MAIL, OR OTHERWISE; _____________ D) IF BY MAIL, WHETHER YOU HAVE THE ENVELOPE; _____________ E) ANY OTHER FACTS THAT WOULD PROVE SUCH DONATION WAS MADE. _____________ INTERROGATORY 43 43. IF THERE ARE ANY FACTS NOT COVERED BY THE ABOVE DEMANDS AND QUESTIONS ON WHICH YOU RELY TO SUPPORT THE CONTENTION THAT THE DEFENDANT IS THE FATHER OF THE CHILD, SET FORTH IN DETAIL EACH SUCH FACT AND GIVE THE NAME AND ADDRESS OF EACH SUCH FACT AND GIVE THE NAME AND ADDRESS OF EACH WITNESS TO SUCH FACT, IF ANY. INTERROGATORY 44A 44A. STATE THE PLACE OF RESIDENCE OF THE PLAINTIFF ONE-MONTH PRIOR TO THE ALLEGED DATE OF CONCEPTION, AS WELL AS THE NAMES OF ALL PERSONS WHO RESIDED THERE AT THAT TIME. INTERROGATORY 44B 44B. STATE THE LENGTH OF TIME EACH OF THE PERSONS SET FORTH IN "44A" RESIDED IN THE PREMISES. INTERROGATORY 45 45. STATE THE AGE OF PLAINTIFF ON THE DATE THEY FIRST MET. INTERROGATORY 46 46. DATE ON WHICH THE MOTHER AND/OR CHILD BECAME ELIGIBLE FOR PUBLIC ASSISTANCE, AND THE EXACT NATURE OF ANY AND ALL BENEFITS WHICH THE MOTHER AND/OR CHILD HAVE OR WILL RECEIVE FROM THE _____________ COUNTY DEPARTMENT OF SOCIAL SERVICES. DATED: ______ ______ ______ ________________________ Attorney for (Address) (Address) (City, State, Zip) (Telephone Number) - 10 - (Attorney Reg. No.:) - 11 -