INTERROGATORIES
TO: _______________ C/O _______________
_______________
_______________, LA ______
NOW INTO COURT comes, plaintiff, _______________, through undersigned counsel, who
requests that the defendant, _______________, respond to the following interrogatories within
fifteen (15) days of this request at the offices of _______________, at _______________,
_______________, LA ______, pursuant to Louisiana Code of Civil Procedure Articles 1461 and
1462. This request is to be deemed continuing the nature and documents such as thos e listed below
which are pending in the future are to be provided for inspection and/or copying as they are
obtained.
INTERROGATORY NO. 1:
State the following with regard to any business which you own, in whole or pa rt, with which
you are affiliated, or by whom you are employed, to-wit:
A. Type of Entity (whether sole proprietorship, joint venture, partnership, corporation,
etc.);
B. Name and address of all owners or stockholders, together with the percent of
ownership of each, including yourself;
C. Title which you hold therein (President, Vice President, Secretary, Treasure r,
Manager, or stockholder);
D. What your position, opinion or best judgment is as to whether or not your p roprietary
interest herein belongs to your separate and paraphernal estate, or to the comm unity
of acquets and gains existing between you and your spouse; and
E. With respect to your answer to Sub-Section (D) above, state your reasons as to why
you so classify your ownership interest, giving the date and description of the event
or events of your reasons therefore.
INTERROGATORY NO. 2:
State the following concerning your receipts from each and every business set forth in your
answer to Interrogatory No. 1 for the last three (3) years: A. Gross income;
B. Net income; and,
C. Itemize all such amounts distributed to you as: 1. Salary;
2. Bonuses;
3. Dividends;
4. Director =s Fees;
5. Return of Capital; and
6. Expense Accounts, with an explanation of the items on such expense
accounts.
INTERROGATORY NO. 3:
With respect to all other income or other types of monies paid unto you or rece ived by you
during the last three (3) years, other than from those businesses listed in y our answers to the
interrogatories set forth hereinabove, such as salaries, rents, royalties, bonus es, leases, stock, sales,
sale of capital assets, loans, or the like, state separately:
A. Name of the person, business or entity from which it came;
B. Address of those persons, businesses, or entities;
C. Total amount received from each, and the date of your receipt thereof; and,
D. Explanation of the reasons for your receipt thereof.
INTERROGATORY NO. 4:
State the following with respect to any and all retirement plans or prog rams, or stock option
plans in which you had an interest in:
A. Type of plan;
B. Percent participation in the plan;
C. Name and address of sponsoring entity or trustee;
D. Separately, the date and amount of each contribution made by you and then
separately in your behalf during the entire existence of the plans, and until date of
judicial demand herein;
E. Date and amount of any withdrawals therefrom during the existence of the m arriage
upon until the date of judicial demand herein;
F. Value of your percent of the plan as of the date of judicial demand herein; and,
G. Value of your present interest therein.
INTERROGATORY NO. 5:
With respect to any and all stocks and bonds owned by you as of the date of judicial demand
herein, state as follows:
A. Name of the company or business;
B. Name in which your ownership is listed;
C. Number of shares or bonds owned by you on date of judicial demand herein;
D. Number of shares or number of bonds owned by you as of the date of your answer
hereto;
E. Your opinion, or best judgment as to the estimated value thereof as of the date of
judicial demand herein;
F. What your position, opinion, or best judgment is as to whether or not same i s an asset
of the community of acquets and gains existing between you and petitioner herein or
instead, the separate and paraphernal property of your separate and paraphernal
estate; and,
G. Give your reasons, including dates and descriptions of transactions, as to your
answers to Sub-Section F.
INTERROGATORY NO. 6:
With respect to any and all banks, savings and loan institutions, or other ins titutions wherein
funds have been deposited in your name, or in your behalf, or in the name of any bus iness in which
you are the sole proprietor, a partner, or a major stockholder, state the following: A. Name and address of institution;
B. Type of account;
C. Account number;
D. Name under which account is listed; and,
E. Current values or amount on deposit as of date of judicial demand herein.
INTERROGATORY NO. 7:
With respect to any and all real estate, wherever located owned by you or your spouse, in
either of your separate and paraphernal capacities, or the community estate existing betw een you,
state the following, as of the date of judicial demand herein, to-wit: A. Location and legal description;
B. Name or names under which purchased;
C. Date of purchase;
D. Purchase price;
E. What your position, opinion, or best judgments as to whether same belongs to the
separate estate of either you or your spouse, or the community estate previ ously
existing between you, giving the reasons, dates and types of transactions of your
reason;
F. Your opinion or best judgments to the fair market value of each as of date of judicial
demand herein, and your reasons therefore; and,
G. Current amount of any encumbrances or indebtedness owned against same, giving
the name and address of the creditor, the original date of the encumbrance, the
amount of any installment payments, there period on which such payments are due,
and the balance due as of date of judicial demand herein.
INTERROGATORY NO. 8:
With respect to each and every life insurance policy insuring your life or the life of you
spouse, state the following: A. Name of insurer;
B. Name of insured;
C. Owner of policy;
D. Beneficiary of policy;
E. Face amount of insurance;
F. Police number;
G. Type of policy;
H. Cash surrender value as of date of judicial demand herein; and
I. Amount of any indebtedness against each, the date of the origin of sa id indebtedness,
the reason for said indebtedness, and the balance due thereon as of date of judicial
demand herein.
INTERROGATORY NO. 9:
Do you maintain major medical/health/hospitalization insurance covering y ourself? If your
answer to this interrogatory is affirmative, please state the following: A. The monthly premium.
INTERROGATORY NO. 10:
With respect to all of the property, movable, immovable, or mixed, whe ther owned by you in
your separate and paraphernal state, your spouse in community, separate and parapherna l estate, or
by the community of acquets and gains previously existing between you, othe r than that specifically
covered in the foregoing Interrogatories, state the following: A. Description and locations;
B. What your position, opinion, or best judgment is as to whether same belongs to t he
separate estate of either yourself, your spouse, or to the community of acquets a nd
gains giving your reasons therefore, a description and date of any transacti ons
backing up those reasons;
C. Your opinion or best judgment as to the fair market value thereof as of date of
judicial demand herein; and,
D. A description of any and all encumbrances against same, giving the dat e of the
incurrence thereof, the amount of any installment payments due thereon, and the
balances due thereon, as of date of judicial demand herein.
INTERROGATORY NO. 11:
State whether or not you have any collections or coins, savings bonds, stamps , guns, or other
valuable items. If so, describe them in detail, giving your opinion or best judgment as to their fair
market value, to whom you believe they belong, and your reasons for the latter.
INTERROGATORY NO. 12:
State separately, for the last three calendar years, and the period from date of judicial demand
herein, the amount of monies spent by you for the following items, on an annual basis where a full
year is involved, and on the total basis where less than a year is involved, to-wit: A. Rent or house note;
B. Utilities;
C. Household maintenance, upkeep and repair;
D. Insurance (life, burial, disability, homeowners, automobile, hospitalization and/or
medical, jewelry and fur, etc.
E. Laundry and dry cleaning;
F. Repairs and upkeep of vehicles;
G. Drugs and medical;
H. Life insurance;
I. Dues and donations;
J. Clothes;
K. Note obligations;
L. Miscellaneous;
M. Investments;
N. Vehicle purchases or notes;
O. Groceries; and,
P. Meals out.
INTERROGATORY NO. 14:
In connection with your answers to the Interrogatory immediately preceding t his
Interrogatory, state how much of each one of these items applied to the following persons:
A. Yourself, individually.
INTERROGATORY NO. 15:
For the last three calendar years, and then, separately, for the period from dat e of judicial
demand herein, state whether or not;
A. Any and all gasoline, oil, washings, greasings, and other items necessa ry for
maintenance and operation of the vehicle being operated by your spouse, yourself,
and/or your children being supported by either you or your spouse, were paid for by
any of the businesses in which you are a stockholder, partner, officer, or employee;
B. If so, state by whom, how frequently, and the dollars spent therefore, as to each
vehicle, designating which person was the primary operator thereof; and
C. Any funds for meals outside the home, trips either within or without the Unit ed
States of America, were paid for, and if so, who went on the trips, what sums of
monies were paid therefore, by whom, on what dates.
INTERROGATORY NO. 16:
State your position, opinion, or best judgment as to the net worth of your separate and
paraphernal estate as of date of judicial demand herein.
INTERROGATORY NO. 17:
State your position, opinion, or best judgment as to the net worth of the communit y of
acquets and gains owned by you as of date of judicial demand herein. Respectfully Submitted,
______________________________
_______________
Attorney for Plaintiff
_______________
______, LA ______
(___)______
La. Bar Roll No. ______
REQUEST FOR PRODUCTION OF DOCUMENTS
TO: _______________
C/O _______________
_______________
_______________, LA ______
PLEASE TAKE NOTICE that you are hereby requested and required to produce the items
listed below at the law offices of _______________ , at _______________, _______________, LA
______, within fifteen (15) days after service, in accordance with law. Thi s request is to be deemed
continuing: The items to be produced are:
1. All federal and state income tax returns for the past two years or past two filing periods.
2. All tax forms showing income from any source received during the immediat e past calendar
years.
3. All records and date showing income from any source received from Janua ry 1 of the current
year.
4. All books, documents, papers, receipts, and check stubs in your possession or under your
control with relation to all wages earned, salaries paid, compensation paid, fringe benefit s
received, income received or other monies paid to you for each and every month during the
current calendar year.
5. All canceled checks for the current calendar year drawn on your checking acc ount or other
bank depository account in your name and/or under your control or possession.
6. All certificates of deposit made towards any checking and/or savings account in your name
and/or under your control or possession during the current calendar year.
7. Statements of accounts for each and every month during the current calendar y ear relative to
any checking, savings account and/or saving certificates in your name or under your control
or possession.
8. Any and all books, papers, documents, mortgages, receipts or other items evidenci ng any
indebtedness of yours.
9. Any and all books, papers, documents, records, deeds, or other items evidencing any
property, whether movable or immovable, owned by you during the past two years.
10. Any and all documents, papers, records, deeds, transfer forms, or bills of sale i n relation to
any property, whether movable or immovable, sold by you or transferred by you to a third
party, during the past two years.
11. Any and all financial statements which you have signed during this year and last year.
12. Fully completed financial declaration statement of the ______ Judicial District Court and/or
statement of the following current information for the current calendar year: Gross monthly
income; all deductions from income; total monthly expenses includi ng rent or mortgage
payments; residential taxes and insurance; food and household supplies; waste r, electricity,
and gas for home; telephone; clothing, medical and dental; insurance; child care; school
expenses; entertainment and expenses; gasoline, oil and auto repairs; inst allment payments;
and any other miscellaneous monthly expense you incur.
13. Statement of accounts or other documents evidencing any inves tment accounts or investment
portfolio which is in your name or under your control or possession.
14. Statement of accounts or other documents evidencing any form of retirement benefits
available to you or under your control, including any pension plans, profit sharing plans, 401
K plans, IRA accounts or any other retirement plans.
This request for production may be satisfied by mailing copies of the re quested items to the
below-listed attorney before the date stated above. Respectfully Submitted,
______________________________
_______________
Attorney for Plaintiff
_______________
______, LA ______
(___)______
La. Bar Roll No. ______