Interrogatories Regarding Estate and Will

First Interrogatories Propounded

IN THE COURT OF COUNTY

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Petitioner/Plaintiff V. CAUSE NO.

Defendant/Respondent

FIRST INTERROGATORIES PROPOUNDED TO ,

AND , A MINOR

The following Interrogatories are propounded to the parties named above pursuant to Rule of the Rules of Civil Procedure and are to be answered in accordance with the provisions of said rule. Each Interrogatory is propounded to each and every person named above AND separate answers are to be given by each party unless otherwise stated in the Request.

1. In your answer you denied paragraph 8 of the Complaint. State whether the decedent ever executed a Will other than the Will which is the subject of this litigation.

2. If your answer to Interrogatory 1 is yes, state what knowledge you have regarding any previous wills of the decedent including:

a. the approximate date thereof;

b. the terms thereof which are related to disposition of assets and the beneficiaries of any and all bequests;

c. the last known location of such wills;

d. the manner in which the decedent revoked such wills;

e. whether such wills were holographic or otherwise and if not holographic the name and address of witnesses to the execution thereof and the attorney or other person who prepared such wills;

3. State what bank accounts the decedent maintained at the time of her death and provide the following information in regard to any such account:

a. the type of account, account number and name of the Bank;

b. the names of the authorized signatories on each said account;

c. the names of any persons who were joint owners of said accounts;

d. the disposition of the funds in said accounts since the date of death of the decedent;

4. State whether or not you ever have been authorized to sign checks on any account of the decedent and if so state the same information requested in interrogatory 3a, b and c.

5. State whether or not you provided any assistance to the decedent in making deposits and or withdrawals from any of the accounts named in your answers to Interrogatories 3 and 4 above and if so describe the nature of such assistance, the frequency thereof and the last such assistance you remember providing to the decedent prior to her death.

6. State whether you were present with the decedent at any time during the day of and state the time, places and purposes of your presence with the decedent on said date.

7. State whether you were present with the decedent immediately before, during and/or immediately after the execution of the Will dated and state all other persons who were present at such times.

8. State whether the decedent ever requested your advice in connection with the preparation of the Will dated and if so what advice did she request and what advice did you give her.

9. State whether the decedent informed you before and/or after the execution of the Will dated of the intended terms if before and the actual terms if after. If so, what did the decedent tell you regarding her reasons for making the dispositions made therein?

10. Did you know any of the terms of the Will dated prior to the death of the decedent? If so, how did you learn of said terms?

11. Did you ever have possession of the Will dated prior to the death of the decedent? If so, state how said will came into your possession.

12. Where was the Will dated kept prior to the death of the decedent?

13. State the names of all persons who had access to the said Will prior to the death of the decedent.

14. Did the decedent maintain a safe deposit box at the time of her death? If so, state the box number, bank location, the names of persons authorized to access said box, and the items located therein on the date of death of

15. Did the decedent make any gifts of real or personal property or make gifts or loans of money to you or anyone in your immediate family during the three (3) years prior to her death? If so, state the kind of property or property given or loaned, the approximate date and the amount of any such monetary gifts or loans and the unpaid balance thereof.

16. State what assets of the decedent you had in your possession at the time of her death and what assets of the decedent which have come into your possession since the death of the decedent.

17. State the name, address and telephone number of each person you may call as a witness in the trial of this case.

18. Did the decedent ever appoint you as her "attorney in fact" by execution of a Power of Attorney or other written instrument? If so please attach a copy thereof to your answers to these interrogatories.

19. Did the decedent name you as "beneficiary" or "payee upon death" of any insurance policy, investment account, bank account, certificate of deposit, individual retirement account, or other instrument and if so please state for each such item the benefit received by you, the date upon which the decedent named you as such beneficiary or payee and the amount of such benefit.

20. Do you intend to call an expert witness during the trial of this case? If so please state the name, address and qualifications of such expert and the area of expertise for which you intend to qualify said expert. Also state the opinions and conclusions which said expert has reached and the facts upon which said opinions and conclusions are made.

Respectfully submitted,

Certificate of Service

I, , do hereby certify that I have mailed this day by U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing Interrogatories to

Dated this the day of , .