STATE OF MINNESOTA DISTRICT COURT
COUNTY OF
JUDICIAL DISTRICT
FAMILY COURT DIVISION
In Re the Marriage of: Court File No.
,
Petitioner, RESPONDENT’S
INTERROGATORIES
TO PETITIONER
AND
,
Respondent,
TO:
YOU WILL PLEASE TAKE NOTICE that the undersigned as attorney for Respondent
demands that 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 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.
INSTRUCTIONS
In answering these Interrogatories, 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 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.
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These Interrogatories shall be deemed to be continuing until and during the course of
trial.
Information sought by these Interrogatories that you obtain after you serve your answers
must be disclosed by supplementary answer.
It is demanded that the Interrogatory 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 accompanying 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.
INTERROGATORY NO. 1
Present Employment . For each current employer, state the name, address, and telephone
number of that employer, and also state:
A) The date you commenced your employment;
B) Your job title or position;
C) Your gross monthly salary if applicable or the average of total gross monthly
wages paid to you this year;
D) State the amount presently deducted from your present gross salary each pay
period and describes the character of each deduction. You are specifically
requested to attach to your answers to Interrogatories photocopies of the pay
check stubs you have received from your employer(s) during the last twenty-four
(24) months or such other evidence of income as verify your income for the last
twenty-four (24) months;
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INTERROGATORY 2 .
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.
INTERROGATORY 3 .
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.
INTERROGATORY NO. 4
Other Income . State the amount, character, and source of any other income including but
not limited to all payments of money or valuable property you have received from each source
not set forth fully above in your answers to the foregoing interrogatories.
Illustrative examples.
The term other income as used in this interrogatory properly encompasses, merely
by example , payments not set forth in answers to questions above received in
compensation for other full-time, part-time, short-term, or irregular employment;
all bonuses or commissions from any employers, clients, or principals; any
payments you received in exchange for services performed by you for any
businesses or clients; any form of dividend income, interest income, or gain on
sale; trust or estate income; any regular periodic gifts from any source such as
significant monthly or annual cash transfers from family or relatives;
contributions by relatives to major purchases; and any grants or loans intended as
student financial aid totaling more than your current tuition and fees at the time
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payment was made, for past five (5) years.
INTERROGATORY NO. 5
Business Expenses . For each business expense reimbursed to you by any employer,
business, or other client in the last twelve (12) months, itemize the date of the expense, the name
of the employer, business, or other client, the date of reimbursement, the name and address of
the party to whom the expense was paid, and the purpose of the expense. Provide copies of all
vouchers or other reimbursement requests submitted by you to any such employer for any such
expense within said period. In the event there are no such vouchers, submit the itemized
statements and/or charge slips for any such expense incurred on a personal or corporate credit
card.
INTERROGATORY NO. 6
Personal Financial Statements . If you have given a personal financial statement to any
party within the last thirty-six (36) months, identify by name and address the
person or corporation to whom each statement was given and the date of each
statement and attach a copy of each such statement.
INTERROGATORY NO. 7
Medical Treatment . Set forth with particularity any and all health care treatment you
have sought or undergone for the last five (5) years to the date of the answers to these
Interrogatories, whether sought of a medical doctor, nurse practitioner, clinical staff under a
physician's direction, osteopath, chiropractor, herbalist, acupuncturist, hypnotist, physical
therapist, weight-loss counselor, or any other practitioner of the healing or counseling arts, and
with respect to each such incident set forth the names and addresses of the person to whom you
went, the symptoms you described to each such person, the treatment you received and the result
thereof.
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INTERROGATORY NO. 8
Professional Evaluation. If you have been seen, tested, evaluated, or treated within the
last five (5) years by any mental health care professional or any similar person such as a
psychiatrist, psychologist, sociolog ist, social worker, family counselor, mental health consultant,
marriage counselor, couples counselor, pastoral counselor (if paid specifically for consultations),
chemical dependency counselor, or other practitioner of the healing or counseling arts, identify
the professional by name, address and area of practice, state the date of each contact with the
professional, explain the purpose of each contact, and indicate whether the contacts are
continuing.
INTERROGATORY NO. 9
Prescription Medication. Describe any prescription medication, which you presently take
or have taken in the last twelve (12) months, the reason for the prescription, and the name and
address of the physician ordering the prescription.
INTERROGATORY NO. 10
Medications/Drugs . Set forth with detail the extent, purpose, and effect of your usage of
any other various drugs, prescription medicines, psychoactive substances, or controlled
substances you use or have used within the last five (5) years.
INTERROGATORY NO. 11
Describe in detail any vacations, fishing trips, hunting trips, or similar journeys out of the
Twin Cities metropolitan area you have taken in the last three years.
INTERROGATORY NO. 12
Describe in detail any boats or vehicles including motorcycles, four-wheelers, and
recreational watercraft owned or controlled by you or registered in your name.
INTERROGATORY NO. 18
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Documents Requested. If any of the documents requested in the Request for Production
of Documents previously served has been destroyed, please list the date of its destruction, the
reason therefore, and the identity of the person who authorized such destruction. If you have
been unable to locate any of the documents requested in the Request for Production of
Documents served contemporaneously with these Interrogatories, please describe all attempts to
locate such documents.
INTERROGATORY NO. 19
State the nature and exact present location of any documents reflecting any of the
information requested above.
The effect of these interrogatories is continuing, and Respondent shall be required
to produce promptly updated responses reflecting current information through judgment
or trial.
Dated:
Name:
Title:
Address:
Address:
City, State, Zip:
Phone:
Fax:
E-Mail:
Attorney Reg. No.:
CERTIFICATION
The undersigned attorney has read the foregoing request, response, or objection, and to
the best of the signor's knowledge, information and belief, formed after reasonable inquiry, the
same complies with Minnesota Rules of Civil Procedure 26.07.
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Dated:
Name:
Title:
Address:
Address:
City, State, Zip:
Phone:
Fax:
E-Mail:
Attorney Reg. No.:
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STATE OF MINNESOTA DISTRICT COURT
COUNTY OF
JUDICIAL DISTRICT
FAMILY COURT DIVISION
In Re the Marriage of: Court File No.
,
Petitioner,
REQUESTS FOR PRODUCTION
AND OF DOCUMENTS
,
Respondent,
TO: RESPONDENT and attorney , , ,
Minnesota ,
FAX .
Pursuant to Rule 34 of the Rules of Civil Procedure of the District Court of Minnesota,
Petitioner requests that Respondent produce and permit Petitioner, or someone acting on
Petitioner’s behalf, to inspect and copy documents and data compilations designated as follows:
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 REQUEST FOR PRODUCTION OF DOCUMENTS AND TO
WHICH FULL DISCLOSURE HAS NOT BEEN MADE.
1 . DOCUMENTS UNDERLYING ANSWERS TO INTERROGATORIES. Any
and all documents, correspondence, memoranda or other writings identified in your Answers to
Interrogatories, which Interrogatories have been served contemporaneously herewith.
2 . FINANCIAL STATEMENTS. Any and all financial statements or copies of such
statements, furnished by you to any bank or other lender, or otherwise prepared, in the last five
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(5) years.
3 . TAX RETURNS AND INCOME FORMS. Copies of your individual state and
federal income tax returns (including all W-2 wage statements, K-1s, federal forms 1099, and
any other schedules and attachments thereto) filed by you individually or jointly with your
spouse, for the past five (5) tax years for which you filed. For any income tax returns not yet
filed, provide copies of all W-2 wage statements, K-1s, federal forms 1099, and any other
documents upon which you will rely in the preparation of said returns.
4 . CURRENT PAYROLL RECORDS. Copies of any and all pay stubs or summary
statements of payroll amounts and deductions you have received from any of your employers
during the current year or a verified statement from your employer, showing gross earnings, all
deductions, and net take home pay.
5 . EMPLOYMENT AGREEMENT. Unless provided elsewhere, any employment
agreement, consulting agreement, or any and all documents relating to your remuneration and
other benefits from employment.
6 . FRINGE BENEFITS. All records showing any fringe benefits paid to you from
any business entity including, but not limited to, auto expense, travel expense, personal living
and entertainment expenses, life insurance, bonuses, accident and health insurance during the
last five (5) years.
7 . REAL ESTATE. Copies of any and all files and records regarding real estate in
which you currently have or claim an interest, including, without limitation, earnest money
agreements, closing statements, appraisal reports, deeds, mortgages, contracts for deed,
insurance policies, receipts for improvements and repairs, amortization schedules and current
real estate tax statements.
8 . BROKERAGE STATEMENTS. Copies of all brokerage account statements for
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the last five (5) years which will show all securities owned by you, including, but not limited to,
stocks, bonds, stock options, convertible debentures, warrants, mutual funds, treasury bills, tax
exempt municipal or government bonds, other such securities or contingent securities or any
other such accounts owned by you individually or jointly with another or owned by a business in
which you have an interest, showing name of issuer, certificate number, number of shares, cost
or other basis information, offering memoranda, subscription agreements, appraisal reports,
offers to buy or sell such securities, and current values.
9 . CASH ACCOUNT RECORDS. Your check register(s), bank statements,
canceled checks, and account records regarding deposits and withdrawals for the last five years
for each depository at which you had any checking or savings accounts (including cash, money
market, certificates of deposit, trust certificates, cash equiva lencies, or other cash accumulation
accounts, etc.) in your own name and/or jointly with any other party, or held or maintained by
others on your behalf as your agent, including any business trust accounts and business accounts.
10 . FINANCIAL POSITION. Any and all other documents in your possession,
custody or under your control which evidence your current financial position, living expenses
and liabilities.
11 . WILLS OR TRUSTS. If you have created any wills or trusts, either irrevocable
or revocable, provide copies of each will and/or trust instrument establishing such trust and all
accounting received or prepared in the last three (3) years to the date hereof.
12. VEHICLE REGISTRATION. Provide copies of any vehicle registration
documents including titles, transfer documents, or Department of Motor Vehicle register receipts
showing ownership of any boat, motor vehicle, recreational vehicle, or recreational water craft
owned by you in the last five (5) years.
It is requested that the above-designated documents and data compilations be made
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available for visual inspection and selective copying at the offices of , Attorney at
Law, , , , Minnesota , within thirty (30) days from the
date of these Requests.
This discovery is continuing until judgment or trial. If additional requested
documen tation becomes available, you are under a duty pursuant to Rule 26.05 of the
Minnesota Rules of Civil Procedure to inform Petitioner’s counsel and to permit inspection
and copying of it.
Dated: ________________ ______________________________
(Name of Attorney)
Attorney for Petitioner
(Address)
(Address)
(City, State, Zip)
(Telephone Number)
(Fax Number)
Attorney Reg. No.
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CERTIFICATION
The undersigned attorney has read the foregoing request, response, or objection, and to
the best of the signor's knowledge, information and belief, formed after reasonable inquiry, the
same complies with Minnesota Rules of Civil Procedure 26.07.
Dated: ____________ ______________________________
(Name of Attorney)
Attorney for Petitioner
(Address)
(Address)
(City, State, Zip)
(Telephone Number)
(Fax Number)
Attorney Reg. No.
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