Fill and Sign the Discovery Paternity Interrogatories Minnesota Form

TO: _____________ _____________ _____________ YOU WILL PLEASE TAKE NOTICE that the _________ demands answers, under oath, to the following interrogatories within _________ days of their service, pursuant to Rules 26 and 33 of the Minnesota Rules of Civil Procedure . These interrogatories are to be continuing in nature. This means that if new or additional information is discovered by, or becomes known to you, to your attorney, or to anyone else acting on your behalf, after you have answered the interrogatories, which would change or add to your responses, you are directed to furnish that information to the _________ ’s attorney immediately. PLEASE NOTE THAT OBJECTION WILL BE MADE AT OR BEFORE THE TIME OF TRIAL TO ANY ATTEMPT TO INTRODUCE EVIDENCE, WHICH IS SOUGHT BY THESE INTERROGATORIES, AND TO WHICH FULL DISCLOSURE HAS NOT BEEN MADE. 1. State your full name and address. 2. List the names of all individuals residing with you at the above stated address. 3. Describe in detail your educational background and include the names and addresses of all institutions that you have attended, the dates of attendance, and a description of the degrees or certificates obtained. 4. If you currently lack certification in any field in which you are degreed or have received training, describe in detail any and all requirements you must fulfill in order to obtain certification, how those requirements can be met, the time necessary to fulfill the requirements, and the costs of fulfilling the requirements. 5. With regard to any past employment, set forth: a. The name and address of each employer; b. The dates of employment; c. A job description; and d. A description of all compensation received, including bonuses and benefits, if any. 6. With regard to your present employment, set forth: a. The name and address of your employer; b. The date you began your employment; - 1 - c. Your job description; d. A description of your compensation; e. A description of your benefits, including, but not limited, to bonuses, meals, discounts, medical insurance, retirement plans, etc.; f. The number of hours per week that you work; and g. Whether you receive additional compensation for overtime work, and if so: i. the rate of pay for overtime work; and ii. the average number of hours of overtime you work per month. 18. If you are self-employed, state whether your self employment is through a partnership, corporation or as a self-employed individual. If you are self-employed as an individual, state the following for the year _________ : a. The amount of gross revenues generated by your work; b. The cost of supplies, equipment and other goods related to the generation of income as stated above in (a); c. A specific breakdown of the items that comprise the total in (b) above, including the specific amounts for each item; and d. A description of any additional deductions that were taken from gross income to arrive at your personal disposable income. NOTE: If such information is fully incorporated into your _________ tax return, you may provide a copy of said return and respond to those segments which are not incorporated into the return. 19. If you are self-employed as an individual, state the following for the year _________ : a. The amount of gross revenues generated by your work; b. The cost of supplies, equipment and other goods related to the generation of income as stated above in (a); c. A specific breakdown of the items that comprise the total in (b) above, including the specific amounts for each item; and d. A description of any additional deductions that were taken from gross income to arrive at your personal disposable income. 7. If you are receiving social security benefits, workers compensation, unemployment compensation, a pension or retirement benefit, investment income or any amount of money on a periodic basis not otherwise described by you in your answers to these interrogatories, please set forth the amount you receive, how frequently you receive it, when the payment commenced, when the payments will cease, and the taxes incurred on said payments, if any. 8. Please list your present indebtedness by stating: a. the name of each creditor; b. whether the obligation is solely yours or a joint obligation; c. name and address of the joint obligors; - 2 - d. the reason for the debt; e. the amount of the original debt; f. the present balance due and owing; g. whether there is written verification of the debt; and h. if payment in arrears, indicate the total amount in arrears and the date or dates of the arrearages. 9. If you are a beneficiary under any annuity or trust, describe in detail each instrument and your interest therein. (In lieu thereof a copy of each annuity or trust instrument may be attached hereto.) 10. Describe each policy of life insurance insuring your life, or a minor child's life, since _________ , and set forth: a. the name of the life insurance company; b. the name and address of the insured; c. the face amount of the policy; d. the policy number; e. the type of insurance (i.e., whole life, term, endowment, etc.); f. the date the policy was obtained; g. the names and addresses of the beneficiaries; h. a listing of loans taken against the policy indicating the date the loan was obtained, the purpose of the loan, name of the party securing the loan and the amount of the loan remaining to be paid; and i. the current cash surrender value (net of any loans remaining to be paid). 11. Set forth with specificity what you are currently spending for monthly living expenses pursuant to subsections below: a. Rent b. Mortgage Payment c. Contract for Deed Payment d. Homeowner's Insurance e. Real Estate Taxes f. Utilities g. Heat h. Food i. Clothing j. Laundry and Dry Cleaning k. Medical and Dental l. Transportation (including car payment) m. Car Insurance n. Life Insurance o. Recreation, Entertainment & Travel p. Newspapers and Magazines q. Social and Church Obligations r. Personal Allowances and Incidentals s. Babysitting and Child Care - 3 - t. Home Maintenance u. Children's School Needs & Allowances v. Additional Information re: debts (state creditor, current balance and monthly payment) w. Other expenses: Identify the expense and amount 12. Describe in detail any program of major medical, hospital or dental insurance available to you through your employment or otherwise, and indicate all eligible beneficiaries of said plan and whether said insurance coverage will be available to your spouse, _________ , after this action is concluded. 13. Identify each and every income producing asset in which you have an ownership interest, individually or together with others, including such assets as rental property, property used for room and board, stocks, bonds, savings accounts, certificates of deposit, partnership interests, etc. As to each asset state the following: a . A description of the asset, including the location and account number; b . The date on which the asset was acquired; c . The purchase price of the asset; d . How the asset was paid for; e . The amount of income produced by the asset and how often the income is produced; f . The rate of interest for each investment; and g . The date on which receipt of the income will be terminated. 14. If you prepared, or any other individual or entity prepared on your behalf, any financial statement, income statement, profit statement, balance sheet, financial projection or any other comparable statement for any corporation or business entity in which you have or had an interest during the marriage, please list: a. the purpose for which the statement was prepared; b. the date of preparation; c. the person or entity preparing the statement; d. the name and address of each person or entity to whom such statement was issued; and e. the name and address of the individual or entity presently having custody of such financial statement. 15. For all checking accounts in which the _________ claims an interest, state as follows: a. Name and address of the bank or financial institution; b. The type of account (regular checking, checking with interest, etc.) c. The account number; d. The purpose for which the account is used; and e. The source of all deposits since _________ . - 4 - 16. Describe in complete detail the contents of any books, records or other docu ments reflecting income and/or expenses that you have prepared or maintained during the last five (5) years. In lieu thereof, copies of such documents may be attached hereto. 17. If you claim a temporary or permanent mental or physical disability, please state in complete detail: a. the nature and extent of the mental or physical disability claimed, including its permanence; b. the source of the disability; and c. the date the disability occurred. 18. Have you ever been charged, arrested, or convicted of a misdemeanor or felony? If so, state the particulars in full. 19. State the permanent legal and physical custody arrangements that you believe are in the best interests of the minor child(ren) of the parties, and specifically address the time that each parent should have with said child(ren). 20. If you believe the minor child(ren) have a preference as to their physical custody, please indicate said preference, how and when you obtained knowledge of said preference, and the reasons for said preference. 21. If you believe that you were or are the primary caretaker of the minor child(ren) please indicate, very specifically, the reasons for said belief. 22. State in detail the reasons why you believe that (Plaintiff/Defendant) is an unfit person to have the sole legal, joint legal, sole physical or joint physical custody of the minor child(ren) of the parties. 23. What restrictions, if any, should be placed upon either party's relationship or contact with the minor child(ren)? 24. Describe in detail the custody and/or visitation arrangements which have existed since the birth of the child. 25. If you have taken oral or written statements from any person relative to the custodial issues in this case, please state: a. the name, address and telephone number of the person whose statement was taken; and b. the name, address and telephone number of the person having present possession of said statement. 31. If you are seeking joint custody of the minor child(ren) please state: - 5 - a. your assessment of the ability of the parties to cooperate in the rearing of the child(ren); b. your proposed method of resolving disputes regarding any major decision concerning the child(ren) and your assessment of the willingness of the parties to use these methods; and c. whether you feel it would be detrimental to the child(ren) if the (Plaintiff/Defendant) were to have sole authority over the child(ren)'s upbringing and, of so, for what reason. 26. If you are seeking sole physical custody of the minor child(ren), is there a possibility that you may leave the (City Name) metropolitan area and/or the State of Minnesota within the next 18 months? If yes, state: a. the city or cities and state or states to which you may relocate; b. the circumstances under which a move might or will occur; c. the first date on which it is possible you might wish to move; d. your proposal relative to visitation by your spouse in the event of a move; e. whether you believe there should be a reduction in child support for visitation, travel expenses and other related visitation expenses such as day care, etc. If yes, identify the amount of your proposed reduction and the basis for the proposed reduction. If no, identify the basis on which you believe there should be no reduction. 27. If you or the minor child(ren) have been seen, tested, evaluated or treated by any professional person such as a psychiatrist, psychologist, sociologist, social worker, family counselor, or other similar person, please state: a. the name and address of the professional; b. the date of each contact; and c. the purpose of each contact. 28. Set forth the identity, address and telephone numbers of any and all persons you intend to call or may call as witnesses relative to the child custody issues in your case and the specific substance of the intended testimony. 29. With respect to all witnesses whom you will or may call as experts to give opinion testimony in the trial of this matter, state the following: a. name and address; b. name and address of said witness's employer or the organization with whom he is associated in any professional capacity; c. the field in which he is to be offered as an expert; d. a summary of his qualifications within the field in which he is expected to testify; e. the substance of the facts to which he is expected to testify; f. the substance of the opinions to which he is expected to testify and a summary of the grounds for each opinion; - 6 - g. the name and date of any treatises, books, or other writing, published or unpublished, by the expert relating in any way to the subject matter on which the expert is expected to testify. For each published article, state the title of the book, journal, or other work in which it can be found and the name of the publisher; h. the type of each case, the court, the docket on file or file number, and date of each decision of each lawsuit in which the expert has testified as an expert witness; and i. state the dates and addresses of all reports, appraisals, or other documents rendered by such expert. 30. Please identify all persons who will or may testify in a trial concerning the issues involved in this proceeding, and state the following: a. Name, address and telephone number of all such individuals; b. The subject matter on which that named witness is expected to testify; c. The fact or facts to which said person will testify; d. The basis upon which each opinion will be based. 31. With respect to all witnesses whom you will or may call as experts to give an opinion or to testify at the trial of this matter, state the following: a. Name and address; b. Name and address of said witness's employer or the organization with whom the witness is associated in any professional capacity; c. The field in which the witness is to be offered as an expert; d. A summary of the expert's qualifications within the field in which the witness is expected to testify; e. The facts or data upon which the expert bases his opinions or inferences including those perceived by or made known to the expert at or before the trial; f. The subject matter on which the expert is expected to testify; g. The substance of the facts and opinions to which the expert is expected to testify; h. A summary of the grounds for each opinion. 32. Please identify each and every exhibit that you intend to produce at the time of trial. 33. Please identify each and every exhibit that you intend to produce at the time of trial. Dated: _______________ _______________________________ __________________ Attorney for Petitioner #1 Address #2 Address City, State Zip - 7 - Telephone ( ____ ) __________ Attorney Reg. No.: ______ - 8 -