Interrogatories Regarding Assets and Liabilities

Interrogatories

TO:

____________________

,

____________________, ____________________,

Pursuant to Rule 33 of the Rules of Civil Procedure of the District Courts of Minnesota, demands answers to the following Interrogatories.

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 INTERROGATORIES AND TO WHICH FULL DISCLOSURE HAS NOT BEEN MADE.

IDENTITY

1. State your present address, including the names of any individuals residing with you, and social security number.

ASSETS

2. Assets. Please set forth in detail each and all of your assets (including all real, personal and/or mixed property and retirement funds), furnishing as to each such asset the following information:

a. A complete description of each.

b. The exact name or names of the record and/or registered owner.

c. The date of acquisition, the source and amount of any down payment and your basis for tax purposes;

d. The amount of said property you claim as nonmarital property;

e. The original cost, if any, and if the same was acquired in any other manner than by purchase on your part, please describe the manner of such acquisition, providing all relevant details;

f. The fair market value as of the date of your answers to these Interrogatories;

g. The encumbrances, if any, against the asset.

h. State whether or not any appraisal of the value of any such asset has been made during the last five years.

3. Profit Sharing, Pension or Retirement Plans. Unless provided in your answer to Interrogatory No. 2, regarding any profit sharing, pension or retirement plans, accounts, or programs of any kind, including IRAs, Keogh Plans and employer provided plans, state:

a. The gross amount of your beneficial interest, whether vested or not vested;

b. The vesting schedule and your current vested portion;

c. The fair market value of your interest in the plan;

d. The calculations or data which support your conclusions concerning the value of the plan;

e. The names and addresses of the trustee and administrator of the plan;

f. The contributions made to the plan for you, whether by you or your employer and whether voluntary or not, for the past three plan years.

4. Business/Professional Interests. Unless provided in your answer to Interrogatory No. 2, state specifically for all business interests in which you have an interest:

a. The name and address of the business;

b. The business activities and history of the enterprise from its inception;

c. The dates on which your interest in the business commenced;

d. Your proportionate share in the ownership and profits of the business;

e. List the company's stockholders and provide the following information.

f. List any transactions of the company's stock during the past five years.

g. Furnish a history of the company.

h. Describe the nature of the business and operations of the company.

i. Discuss any changes anticipated in the immediate future in the nature of the company's operations and whether or not any liquidation, in whole or in part, is intended;

j. List the five largest customers for each of the last five years and the amount of the sales to each by year;

k. Provide management's projection of total revenues and earnings for the next three to five years in total and by division;

l. Describe any nonrecurring or special accounting terms during the five years that are not specifically disclosed in the financial statements;

m. Describe management's projected needs for fixed asset additions for the next five years, including the amounts and the source of funding for these assets;

n. Provide the compensation for all owners or officers for the most recent five years;

o. Identify any public companies considered most similar to the company;

p. If the company is a member of any trade associations, provide the names and phone numbers of any persons who may be contacted;

q. If any offers to purchase, sell or merge the company have been made in the last five years, identify price, terms, and potential buyer.

5. Life Insurance. Unless provided in your answer to Interrogatory No. 2, state specifically for each policy of life insurance in which you have an interest, the following:

a. The name of each insurance company;

b. The number of each policy;

c. The owner of each policy;

d. The type of insurance;

e. The face amount of each policy;

f. The name(s) of the primary and/or contingent beneficiaries designated in each policy.

g. The present cash surrender value of each such policy;

h. The amount and dates obtained, if any, of any loans against each such policy.

6. Securities. Unless provided in your answer to Interrogatory No. 2, state specifically, with respect to your share holdings, including, but not limited to, stocks, bonds, stock options, convertible debentures, warrants, mutual funds, treasury bills, tax exempt municipal or government bonds, or other such securities or contingent securities, the following:

a. A complete description of each;

b. The exact name or names of the record and/or registered owner;

c. The date of acquisition, and the source and amount of your basis for tax purposes;

d. The amount of said property you claim as nonmarital property;

e. The original cost, if any;

f. The fair market value as of the date of the answers to these Interrogatories.

7. Cash Accounts. Unless provided in your answer to Interrogatory No. 2, set forth the names and addresses of each depository in which you had any checking, savings or other cash accounts or assets for the past five years, and to the date of your Answers to these Interrogatories.

8. Receivables. Unless provided in your answer to Interrogatory No. 2, do you hold any promissory notes from other persons or entities or do you have any outstanding loans or accounts receivable due to you from any persons or entities?

9. Vehicles, Aircraft, Etc. Unless provided in your answer to Interrogatory No. 2, list and describe in detail each automobile, truck, boat, motorcycle, aircraft, or other vehicle owned, driven or leased by you or by any corporation, entity, or other party on your behalf, stating:

10. Real Property. Unless provided in your answer to Interrogatory No. 2, with respect to each parcel of real estate which is presently owned by you, either individually or jointly, please set forth in detail:

11. Cash Assets. Unless provided in your answer to Interrogatory No. 2, describe in detail any other liquid assets in which you have any interest.

12. Furs, Jewelry, Collectibles, Etc. Submit a schedule of all furs, jewelry, precious stones, gold, silver, paintings, antiques and art work presently owned by you or in which you have an interest.

13. Sales, Etc. of Property. If any sales, assignments, transfers or gifts of real or personal property were made by you during the preceding five years, set forth the following:

14. Debts. For each debt owed by you to others, state:

15. Employment and Income. With respect to your employment and occupation, state:

16. Other Income. If you receive income from any source other than that stated in your answer to the preceding interrogatory, state the source of such income, the amount, and when the income is paid.

17. Living Expenses. State your living expenses for the calendar year and your estimated living expenses for the next calendar year.

18. Health. State the condition of your health; are you presently being treated by any physician or other person for any physical or mental health problems; have you been so treated or have you consulted with anyone regarding your emotional or psychological state during the past 10 years?

19. Medical Treatment. If the answer to the preceding interrogatory is in the affirmative, indicate the name and address of said physician(s) or other provider and briefly describe the condition being treated and what medications have been prescribed for you in the past five years.

20. Beneficial Interest. With respect to any probate, trust(s) or other proceeding existing or contemplated proceeding in which you may be designated a beneficiary, devisee, designee or other recipient, please state:

21. Safe Deposit Boxes. State whether you have the right of entry to a safe deposit box located at any bank or other similar financial institution, and if so, please state the name and address of such institution, the box number, and contents.

22. Nonmarital Property. Identify each item or real or personal property acquired by you before, during or after the existence of the marriage.

23. Other Property. Do you have an interest in any assets or property of any nature whatsoever that has not been disclosed in your answers to any of the preceding interrogatories?

24. Employment History. Set forth a detailed summary of your employment history during the course of your marriage.

25. Education. Set forth a detailed summary of your educational background.

26. Legal or Administrative Proceedings. If you have been a party to any legal or administrative proceeding during the past five years, state the nature, title, court or agency, file number, and status.

27. Witnesses. Please identify all persons who have any knowledge or information whatsoever concerning the issues involved in this proceeding who are known to you, your counsel, associates, investigators, employees or agents, and state the following:

28. Expert Witnesses. With respect to all witnesses whom you will or may call as experts to give an opinion or to testify at the trial of this matter, state the following:

29. Custody. With respect to the legal and physical custody of your minor child[ren], state whether you feel your spouse is a fit and proper parent to care for the minor child[ren]. If you feel your spouse is unfit, state all facts upon which you rely.

30. Have you ever been charged, arrested, or convicted of a misdemeanor or felony? If so, state the particulars in full.

PLEASE TAKE NOTICE, that pursuant to Rule 26.05 of the Minnesota Rules of Civil Procedure, you are under a duty to supplement the answers to these interrogatories.

PLEASE TAKE FURTHER NOTICE, that a copy of your answers to these interrogatories must be served upon the undersigned within thirty (30) days after service of these interrogatories.

CERTIFICATION

The undersigned counsel for the petitioning party certifies that she has read the above request for discovery, response or objection and that to the best of her knowledge, information and belief, formed after reasonable inquiry, that they are consistent with the standards of Rule 26.07 of the Minnesota Rules of Civil Procedure.