Fill and Sign the Minnesota Family 497312445 Form

STATE OF MINNESOTA DISTRICT COURT COUNTY OF ____________ ____________ JUDICIAL DISTRICT FAMILY COURT DIVISION In Re the Marriage of: Court File No. ____________ ____________ , Petitioner, RESPONDENT’S INTERROGATORIES AND REQUEST FOR AND PRODUCTION OF DOCUMENTS ____________ , Respondent, TO: _____________ _____________ _____________ _____________ _____________ YOU WILL PLEASE TAKE NOTICE that the undersigned as attorneys for the Respondent herein demands that the Petitioner answer in writing under oath, fully and completely pursuant to Rules 26 and 33 of the Minnesota Rules of Civil Procedure for District Courts the following Interrogatories and Requests for Production of Documents and that the answers be signed by the person making them and that they be served upon the undersigned counsel within thirty (30) days after service of these Interrogatories and Requests for Production of Documents. INSTRUCTIONS In answering these Interrogatories and Requests for Production of Documents, furnish all information which is available to you, including information in the possession of your attorneys or investigators for you or your attorneys, and not merely information as may be known of your own personal knowledge. If you cannot answer the following Interrogatories and Requests for Production of Documents in full after exercising due diligence to secure the information to do so, state the answer to the extent possible, specifying your inability to answer the remainder, stating whatever information or knowledge you have concerning the unanswered portion. - 1 - These Interrogatories and Requests for Production of Documents shall be deemed to be continuing until and during the course of trial . Information sought by these Interrogatories and Requests for Production of Documents that you obtain after you serve your answers must be disclosed by supplementary answer. It is demanded that the Interrogatory or Request for Production of Documents precede its answer as required by Rule 33.01 (4) of the Minnesota Rules of Civil Procedure. Pursuant to Rule 34 of the Minnesota Rules of Civil Procedure, please attach as exhibits all documents which have been prepared in connection with this proceeding or upon which you may expect witnesses to rely or such other documents as may be requested in the Request for Production of Documents. Where a question can be answered by copying a document, then please do so and attach a copy of the document to your answers. INTERROGATORIES INTERROGATORY NUMBER 1 Identify each individual living in your residence and the relationship of that individual to you. INTERROGATORY NUMBER 2 State your current monthly living expenses on Exhibit A , attached hereto, and for each item which is shared jointly with another, then indicate the amount of contribution by each person on a monthly basis. INTERROGATORY NUMBER 3 With regard to your present employment, state: a. Your job title or position; b. Your gross salary per pay period, specifying your pay periods and the manner in which your salary is determined (i.e., hourly, annually, etc.); c. the number of hours per week you normally work; d. Whether you work overtime and, if so, the frequency of your overtime work and rate of pay; e. Whether you receive commission pay and the manner in which it is computed and the manner in which it is disbursed to you; f. Whether you have received or will be eligible for a bonus in Year and/or Year ; g. Identify all mandatory and voluntary deductions from your paychecks; h. Identify by amount and type all other forms of direct compensation received by you, - 2 - i.e., expense accounts, auto allowance, vehicle use, etc.; i. Identify all indirect benefits received by you such as pension, profit-sharing, 401K, deferred compensation, stock options, health insurance, life insurance. INTERROGATORY NUMBER 4 Identify all other income received by you, from Year to the present, whether or not reported on any tax return, specifying the nature, date and amount. INTERROGATORY NUMBER 5 Personal Pension . Do you have an individual retirement account or other retirement plan which has been funded other than the plans described above? If so, state the terms of such plans or accounts, the dates and amounts of contributions, and all other terms contained in the plan. INTERROGATORY NUMBER 6 Motor Vehicles . If you have an ownership interest or claim in any motor vehicles, then as to each one: a. What is the year and make of that motor vehicle; b. If there is a mortgage against the vehicle, then state the terms thereof, including monthly payments and mortgage balance; and c. What do you claim is the fair market value of that motor vehicle? INTERROGATORY NUMBER 7 Investment Accounts . What are the details of each and every savings account, savings certificate, checking account or investment of any kind in any financial institution or brokerage in which you have had an interest in the last six (6) years, including: a. The name and address of the bank or financial institution; b. The extent of your interest in such account or certificate, and the names and addresses of any other persons holding an interest in such accounts or certificates; c. The type of account or certificate and account or certificate number; d. The date the account was opened or the certificate purchased; and e. The present balance or value, if any, or the balance or value at the time the account was closed or reduced. INTERROGATORY NUMBER 8 - 3 - Stocks . Do you have an interest in any shares of stock of any corporation, including options? If so, state: a. The issuing corporation; b. Class or classes of stock owned by you; c. Number of shares of each class owned by you; d. Date and mode of acquisition by you, whether by purchase, gift, inheritance or otherwise; e. Purchase price, or if otherwise acquired, the value at the time of acquisition; and f. Present market value of each such share, stating your source for such information. INTERROGATORY NUMBER 9 Bonds . Do you have an interest in any corporate bonds or debentures or savings bonds? If so, state: a. Name of the issuing entity; b. Date and mode of acquisition by you, whether by purchase, gift, inheritance or otherwise; c. Maturity or due date; d. Rate of interest; and e. Present value and source of such valuation. INTERROGATORY NUMBER 10 Other Investments . Other than as shown in your answers to these Interrogatories, do you have an interest in any other investments? If so, state the terms of those investments. INTERROGATORY NUMBER 11 Real Estate . Do you have any ownership interest in any real estate? If so, for each property, state: a. The nature of the property and extent of your interest therein; b. The address of the property; c. The legal description of the property; d. The date and mode of acquisition by you, whether by purchase, gift, inheritance or otherwise; e. Purchase price, or if otherwise acquired, the value at the time of acquisition; f. The extent of current encumbrance and the amount of the monthly payments thereon; g. Amount of the current year's real estate taxes; h. Approximate present value and the source of such valuation; and i. Monthly rental derived there from in case of rental property. - 4 - INTERROGATORY NUMBER 12 Life Insurance . For each policy of life insurance in which you have an interest as owner, beneficiary or insured, state: a. The name of the issuer; b. The type of policy; c. Policy number; d. Amount of insurance; e. Premium; f. Present cash value, if any; g. Owner; and h. Beneficiary. INTERROGATORY NUMBER 13 Trusts and Estates . If you have an interest in a present estate or probate proceeding, or if you are the settler, beneficiary or trustee of any trust, describe the trust and your interest therein fully. INTERROGATORY NUMBER 14 Debts . List your present indebtedness (including all debts in which you are individually, jointly, as a co-signer, or otherwise indebted), setting forth for each debt: a. The name and address of creditor; b. Whether the account is solely in your name or a joint obligation with any other party and, if joint, the names and addresses of any other obligees; c. The nature of the indebtedness; d. The original date and amount of the indebtedness; e. The present balance due; f. The terms of repayment; and g. The nature of the collateral, if any. INTERROGATORY NUMBER 15 State whether you personally have furnished to any bank or other financial institution within the last five (5) years, for the purposes of obtaining a personal or business loan or otherwise, any financial statements showing your income, assets, or liabilities. If so, state the name and address of the bank or other institution to which the financial statements were furnished, the date that the statements were furnished, and the reason that the financial statements were furnished. INTERROGATORY NUMBER 16 - 5 - For each account in a bank, savings and loan association, or other financial institution upon which you are or were at any time during the past five (5) years authorized to draw funds, state the name and location of the bank or other financial institution, the type of account, whether such account was or is owned entirely by you or jointly with another person, the name of any other person having an interest in said account, and, if said account was closed, the date upon which said account was closed and the balance immediately prior to the closing or, if said account was not closed, the present balance of said account. INTERROGATORY NUMBER 17 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' employer or the organization with whom [(s)he] is associated in any professional capacities; c. The field in which [(s)he] is to be offered as an expert; d. A summary of his/her qualifications within the field in which [(s)he] is expected to testify; e. The substance of the facts to which [(s)he] is expected to testify; f. The substance of the opinions to which [(s)he] is expected to testify and a summary of the grounds for each opinion. DATED: _____________ - 6 - _______________________________ __________________ Attorney for Respondent #1 Address #2 Address City, State Zip Telephone ( ____ ) __________ Attorney Reg. No.: ______