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IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI PLAINTIFF VERSUS CIVIL ACTION NO. DEFENDANT DEFENDANT'S RESPONSE TO FIRST REQUESTFOR PRODUCTION OF DOCUMENTS COMES NOW , Defendant, by and through counsel, and files this his/her Response to the Plaintiff's First Request for Production of Documents, and for such Response would show unto the Court the following, to-wit: REQUEST NO. 1: All of his/her state and federal income tax returns for the years    . ANSWER: All state and federal income tax returns are in the office of , a nd are open for inspection by the attorney for the Plaintiff at times suitable and agreeable with counsel for both Plaintiff and Defendant. REQUEST NO. 2: Copies of all financial statements prepared by or for him/her at any time during the past five years. ANSWER: None. REQUEST NO. 3: All records regarding his/her checking and savings accounts, whether solely in his/her own name or in his/her name jointly with someone else, or held for him/her in the name of someone else, in any and all banks and other financial instit utions during the past five years, including but not (records and documents showing any and all transfers by him/her of any and all such property since the date of the marriage of the parties. ANSWER: See answer to No. 1 and see answer to interrogatories. REQUEST NO. 5: All records and documents showing ownership by him/her of stocks, bonds, commodity contracts, promissory notes, certificates of deposit, ready asset accounts, cash funds, and any and all other chooses in action, whether owned by him/her alone or with someone else, or held for him/her in the name of someone else, together with al l records and documents showing the purchase and transfer by him/her of any and all such property since the date of the marriage of the parties. ANSWER: See answer to No. 1 and answers to interrogatories. REQUEST NO. 6: All life insurance policies on his/her life, together with all records showing the cash value of such life insurance policies. ANSWER: See answer to No. 1 and answer to interrogatories. REQUEST NO. 7: All appraisals of real and personal property owned by him/her or in which he/she has or had an interest from and after the date of the marriage of the parties. ANSWER: See answer to No. 1. REQUEST NO. 8: All documents showing encumbrances upon real and personal property downed by him/her or in which he has an interest, whether in the form of deeds of trust, financing statements or otherwise, and showing the balance owing thereon. REQUEST NO. 10: All records showing all transfers of property to anyone since the date of the marriage of the parties, and in each case, showing the name and addre ss of each person to whom each such transfer was made and showing the consideration received by him/her for each such transfer of property, as well as all records and documents showing all gifts ma de by him during this period of time. ANSWER: See answer to No. 1. REQUEST NO. 11: All promissory notes which he/she signed as maker, co-maker, co-signer, or endorser since the date of the marriage of the parties, as well as all documents showing each and every payment made on each of said notes and, also, the balance owi ng on each of said notes. ANSWER: See answer to No. 1. REQUEST NO. 12: All records showing loans made by him/her to anyone since the date of the marriage, including but not limited to, the following: the name and a ddress of the person or persons to whom such loan or loans were made; the amount of each such loan; the terms of payment of the loan, records of the payments made; the collateral receive d by him/her for each such loan; the balance remaining to be paid on each such loan; the intere st charged on each such loan; and, all records showing any of such loans as being in default. ANSWER: See answer to No. 1. REQUEST NO. 13 All records showing income received by him/her from and after the date of the marriage of the parties with any and all sources, including, but not limi ted to, all records giving the name and address of each source from which court and action number in which the estate is or was being administered; and, describing' the assets inherite d, whether or not such assets have actually been received by him/her. ANSWER: This is objected to as being completely irrelevant to the issues at hand and not being discoverable material under the Mississippi Rules of Civil Procedure. REQUEST NO. 15: All inventories of assets owned by him/her or in which he/she has an interest contained in any and all safety deposit boxes, safes, and vaults to which he/she has access. ANSWER: See answer to No. 1 and answers to interrogatories. REQUEST NO. 16: All records showing all property and assets, including cash, acquired by him/her since the date of the marriage of the parties, including, but not l imited to, records showing names and addresses of sources of such property and assets, including cash, acquired by him/her. ANSWER: See answer to No. 1. REQUEST NO. 17: All records showing all property and assets now owned by him/her or in which he/she has an interest. ANSWER: See answer to No. 1. REQUEST NO. 18: All documents and tangible evidence of every kind or character which he/she intends to offer at a hearing on his/her Complaint for Divorce filed herein. ANSWER: See answer to No. 1. Dated this day of , . The foregoing Answer to Request for Production are true and correct as therein stated. SWORN TO AND SUBSCRIBED BEFORE ME this the day of , . ___________________________ NOTARY PUBLIC My commission expires: CERTIFICATE OF SERVICE I, , do hereby certify that I have this date mailed by U. S. Mail, postage pre paid, a true and correct copy of the above and foregoing to This day of , .