Louisiana Interrogatories and Request for Production of Documents

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

: _____ JUDICIAL DISTRICT COURT

VS : PARISH OF , LOUISIANA

: DOCKET NO.

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

TO:

NOW INTO COURT comes , petitioner, through her attorney of record, and pursuant to Louisiana Code of Civil Procedure, Article 1420, et seq. propounds the following Interrogatories and Requests for Production to .

INSTRUCTIONS

1. Full and separate answers to each interrogatory and response to Request for Production, in writing and under oath, shall be served within fifteen (15) days of receipt hereof.

2. In answering the interrogatories, you shall furnish all information in the possession of your directors, partners, officers, employees, agents, representatives, investigators, lawyers, accountants, bankers, financial advisers, or other parties acting on your behalf, not merely information within the personal knowledge of the person or persons answering the interrogatories.

3. If you cannot answer the interrogatory in full after exercising due diligence to secure the information requested, or do not have precise information with respect to any part of any interrogatory, so state, describe in full your efforts to obtain the information requested, and answer to the extent possible. If a qualified answer must be given, answer the interrogatory as directly and fully as possible and state fully the reason a qualification is necessary.

4. Each interrogatory or part of an interrogatory shall be set out in full in the answers before each answer. A separate answer shall be provided in response to each interrogatory or each subpart of an interrogatory.

5. In reference to the Request for Production of Documents, the documents should be served within the delays allowed by law by producing them at the office of , Attorney at Law, , , , for inspection and copying, or by making them available for inspection and copying within the delays allowed by law.

INTERROGATORY NO. 1

List all checking, commercial banking, savings, credit union or other depository account or accounts of every nature in which you had or have an interest from through the present date, showing as to each account:

(1) The name and address of the institution;

(2) Account numbers;

(3) The name or names in which the account is listed;

(4) The amount in the account as of or if not in existence on that date, then the date said account was opened and the amount deposited on that date or the date said account may have been closed, if prior to the date you answer these interrogatories;

(5) The amount in the account on the date you answer these interrogatories;

(6) For each withdrawal since , indicate the date, amount, and purpose of said withdrawal;

(7) For each deposit since , state the date, amount and source of the funds deposited; and

(8) The amount of interest each account generated from through and including the date you answer these interrogatories.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 1

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 2

During the period of from through the present date, did you own or have any interest in any certificates of deposit, treasury bills, notes, government bonds, municipal bonds, commercial stocks or other securities? If so, you are asked to list for each security the following:

(1) The kind of security and date of issue (certificate of deposit, savings bond, stock, etc.);

(2) The serial number of each share, certificate, note or bond or security;

(3) The quantities of each;

(4) The face value thereof;

(5) The maturity date thereof;

(6) The name and address of the registered owner;

(7) The interest rate thereon, if applicable;

(8) The address where the security is or was located; and

(9) The amount of interest generated on each such security from January 1, 1999 through and including the date you answer these interrogatories.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 2

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 3

Do you have any interest in any profit-sharing, thrift plans or employee benefit plans? If so, you are asked to furnish the following information:

(1) Description of said plan and the account number of each plan;

(2) The present value of each plan; and

(3) Can said profit-sharing plans, thrift plans or employee benefit plans be withdrawn at this time and if not, explain in detail.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 3

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 4

Do you own or have any interest in any type of retirement fund or pension fund, whether owned individually or with the entity with whom you are employed? Special reference here is made to IRAs, 401-Ks, KEOGHs, or other retirement or pension-type funds. If so, for each such retirement or pension fund list:

(1) Name and description of said fund;

(2) Account number of each fund;

(3) Date said fund was initiated;

(4) The present balance of said fund;

(5) The name and address of the trustee of said funds; and

(6) The percentage of contribution made by you to said fund.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 4

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 5

Do you own or have any interest in any life insurance policies? If so, for each such policy, list:

(1) The name of the company issuing each policy and its local agent and address and the date of issuing each such policy;

(2) The type of policy (term, ordinary life, etc.);

(3) The policy number;

(4) The face amount of said policy;

(5) The present cash or surrender value;

(6) The name of the primary beneficiary;

(7) Amount of the monthly or annual premium; and

(8) Name and address of the person or entity who has possession thereof.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 5

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 6

Do you own or have any interest in any automobiles, recreation vehicles, boats, airplanes, jewelry, collections (coins, stamp, gun or otherwise), paintings, gold furniture, livestock or other chattel? If so, for each such movable, list:

(9) The kind of movable;

(10) The make and serial number;

(11) The percentage of your interest;

(12) The purchase price;

(13) The name of the manufacturer, artist, etc.;

(14) The location of said movable;

(15) The date of acquisition of purchase; and

(16) If any indebtedness or mortgages owed, the name and address of the mortgagee(s) and the present balance of said mortgage(s).

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 6

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 7

Do you own or have any interest in any real estate or options to purchase same, or any mineral rights? If so, for each piece of property or option, or mineral right, list:

(1) Area or size;

(2) Legal description;

(3) Date purchased;

(4) Purchased price;

(5) Nature of your ownership interest; and

(6) If mortgaged, the name of the mortgagee, holder or holders; the amount of the original mortgage; the date of the original mortgage and the present balance owed.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 7

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 8

Do you own or have any interest in any leases (agriculture, commercial, mineral or residential)? If so, for each such leasehold interest, list;

(1) The kind of leasehold interest;

(2) Legal description of the property upon which the leasehold interest bears;

(3) Term of lease;

(4) Amount of rent and whether paid monthly, annually, etc.;

(5) The nature or degree of your ownership interest;

(6) Name and address of lessee; and

(7) If any such leasehold interest is mortgaged or pledged as security, give the name of the pledgee; date of such pledge or mortgage, purpose for which pledged or mortgaged.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 8

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 9

During your marriage to your spouse, did or do you own or have any interest in any businesses? If so, for each such business.

(1) Is the business a corporation, partnership or sole proprietorship?

(2) The location of each business;

(3) The percentage or degree of your ownership;

(4) The amount of income you received from said business (whether salaries, dividends or otherwise) from to present date;

(5) The date you acquired or transferred ownership in said business;

(6) The date you acquired or transferred ownership in said business;

1. Number of shares owned or transferred by you;

2. Total shares outstanding;

3. Is the company a Sub-Chapter S Corporation;

4. Are you an officer? If so, what is your title? and

5. Are you a member of the board of directors?

(7) Was a balance sheet and/or profit and loss statement for the years 1998 and 1999 prepared? If so, what is the name and address of the person in possession of the balance sheet and profit and loss statement?

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 9

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 10

Are there any safe deposit boxes, vaults, safes, or other places of deposit in safekeeping in which you have deposited any money, documents or other items of movable property during your marriage to you have deposited any money, documents or other items of movable property during your marriage to your spouse, either in your name or in any other person’s name? If so, for each place of deposit state:

(1) The name and address of the depository institution;

(2) The number or other means of identification of deposit;

(3) The name and address of each person authorized to enter the deposit;

(4) The date the deposit was commenced;

(5) The date the deposit was terminated;

(6) A complete inventory of all items contained in said depository as of January 1, 1999 and the present date; and

(7) The date and time you last entered the safety deposit box, vault, safe or other place of deposit, together with a complete description of any and all items removed by you on that date.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 10

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 11

Do you or any other person own or have in your-their possession any movable property, real property or sum of money which you claim is your separate property? If so, for each item list:

(1) A description of the property;

(2) The location of the property;

(3) Present value of each piece of property;

(4) The date and method of acquisition of the property;

(5) The source of funds used to acquire the property;

(6) The name of each owner of the property and their respective ownership interests; and

(7) The facts upon which you base your claim that the property is your separate property.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 11

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 12

Do you or any other person own or have in your/their possession any movable property, real property or sum of money which you claim is community property? If so, for each item list:

(8) A description of the property;

(9) The location of the property;

(10) Present value of each piece of property;

(11) The date and method of acquisition of the property;

(12) The source of funds used to acquire the property;

(13) The name of each owner of the property and their respective ownership interests; and

(14) The facts upon which you base your claim that the property is your separate property.

INTERROGATORY NO. 13

Do you presently hold any interest in any stock options? If so, list the following:

(1) The date each unexecuted option was issued;

(2) The name of each company issuing such option;

(3) The exact number of shares authorized to purchase and the purchase price of each unexecuted option; and

(4) The expiration date of each option.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 13

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 14.

Do you own any interest in any lawsuits presently pending either as party plaintiff or defendant and, if so, give the following information:

(1) The caption of said suit and the date filed;

(2) The trial date scheduled in said suit; and

(3) The interest that your realistically expect to recover in value, either by settlement or judicial decree.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 14

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 15

Have you disposed by sale or otherwise any of the community assets between January 1, 1999 and the present date and, if so, give the following information:

(1) The description of the property disposed of or alienated;

(2) The date said property was disposed of or alienated and the name of the person or entity receiving same; and

(3) The exact amount of the consideration paid to you for such asset and a detailed accounting setting forth exactly where the funds received by you for such asset are located or were used.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 15

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 16

Except as answered hereinabove, do you owe any money to any person, entity or corporation? If so, for each indebtedness, list the following:

(1) When the indebtedness was incurred;

(2) Amount of indebtedness;

(3) Name and address of creditor;

(4) Type of indebtedness (bank loan, credit card, etc);

(5) Why the indebtedness was incurred;

(6) Whether the indebtedness is a community obligation, your separate obligation, or the separate obligation of your spouse; and

(7) The facts upon which you base your claim that the indebtedness is a community obligation, your separate obligation, or the separate obligation of your spouse.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 16

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 17

Do you owe any contingent or unliquidated claims to any person or entity, including, but not limited to unfiled lawsuits or claims for damages, continuing guarantees executed by yourself and/or your spouse, unfiled or unpaid taxes to the Internal Revenue Service or the State Taxing Authority which have not yet been assessed? If so, for each such contingent or unliquidated claim, list the following?

(1) The potential amount of the contingent liability;

(2) The name and address of the potential creditors;

(3) The facts giving rise to the contingent or unliquidated claim;

(4) Why the contingent or unliquidated was incurred;

(5) Whether the contingent or unliquidated claim is a community obligation, your separate obligation, or the separate obligation of your spouse; and

(6) The facts upon which you base your assertion that the unliquidated or contingent claim was a community obligation, your separate obligation or the separate obligation of your spouse.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 17

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 18

In the last three (3) years, have you prepared a financial statement or loan application, either for yourself, any business entity in which you were or are involved or for the community of acquets and gains? If so, please state the following:

(1) For what years did you prepare said financial statements;

(2) The name and address of the bank, financial institution or other such entity and the possession of the original of said financial statement or loan application; and

(3) The reason or purpose for preparing the financial statement or loan application.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 18

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 19

Are you a beneficiary of any trust? If so, please state for each such trust:

(1) The date the trust was created and the name and address of the trustee;

(2) Notary Public before whom the trust was created;

(3) Amount of money and/or description of property held in trust; and

(4) Income and principal received by you during the past three (3) years from such trust, specifying receipt dates and amounts

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 19

Please produce all documents in your care, custody and control which would verify your answer to the preceding interrogatory.

INTERROGATORY NO. 20

Please state whether you are currently employed. In doing so, please provide the following information:

(1) Name and address of employer and name of your immediate supervisor;

(2) Your current wages or income, including all fringe benefits which you are entitled to through your employment, such as insurance, vacation pay, sick pay, profit sharing, company vehicle, mileage reimbursement, overtime, or bonuses.

(3) Please provide any and all information concerning your retirement plan(s), such as copies of all records showing the amount in the account(s) as of the date you are responding to these interrogatories any income derived therefrom.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 20

Please produce copies of any and all income records of whatever nature, including, but not limited to tax returns, 1099s, W-2s, wage statements, payroll check stubs financial statements, ledgers, journals and/or other documentation of income, including any and all cash income and whether earned or unearned, and from whatever source, including, but not limited to, employment or any business in which NOLAN PAUL SIEBER may be or may have been involved.

INTERROGATORY NO. 21

Do you understand and agree that these interrogatories and requests for production of documents are to be deemed continuing in nature and that immediately upon receipt of any information or data which may necessitate a change, amendment or supplementation of the heretofore filed responses should be filed immediately?

St. Martinville, Louisiana, this _____ day of 20 .

PLEASE SERVE DEFENDANT AT: