Pro Se Notice of Hearing

DEFENDANT'S FIRST SET OF INTERROGATORIES PROPOUNDED TO THE PLAINTIFF WITH REQUEST FOR PRODUCTION

Name of Defendant:

Address:

City, State, Zip:

Phone:

IN THE DISTRICT COURT FOR COUNTY, STATE OF NEW MEXICO

YOUR NAME, , Petitioner/Plaintiff

Vs.

DEFENDANT'S NAME, , Respondent/Defendant

CASE NO.

COMES NOW ("Defendant") and propounds the following interrogatories to ("Plaintiff") pursuant to New Mexico Rules, and other applicable provisions of said Rules...

INTERROGATORY NO. 1

State your full name, social security number, date of birth, residence address, and telephone number.

INTERROGATORY NO. 2

Please attach to your answer to these interrogatories copies of your income tax returns and W-2 forms for the past three years.

INTERROGATORY NO. 4

State your total income to date since , and attach to your answers copies of your last five paycheck stubs.

INTERROGATORY NO. 5

List all assets presently owned by you...

INTERROGATORY NO. 6

List the name, place of employment and telephone number of any person or persons who are presently residing at the address which you listed as your residence in your answer to Interrogatory No. 1.

INTERROGATORY NO. 7

If you rent the place in which you live, give the name of your landlord, his or her address and telephone number.

INTERROGATORY NO. 8

Outline in detail your monthly living expenses.

INTERROGATORY NO. 9

List all other income received by you other than from your employment, stating the source and the amount.

INTERROGATORY NO. 10

If you claim to have grounds for divorce against the Defendant, please state all circumstances, facts, and events, upon which you base such grounds.

INTERROGATORY NO. 11

What safety deposit boxes do you currently maintain whether alone or jointly held?...

INTERROGATORY NO. 12

What bank accounts, if any, do you presently maintain, whether alone or jointly held?...

INTERROGATORY NO. 13

Do third parties hold any property in trust for you or for your benefit?

INTERROGATORY NO. 14

Have you ever been arrested?

INTERROGATORY NO. 15

Have you ever received psychiatric treatment?

INTERROGATORY NO. 16

Are you taking any drugs, and the amount of money you spend each month for said drugs.

INTERROGATORY NO. 17

Do you use any type of drugs which are not prescribed by a physician?

INTERROGATORY NO. 18

Do you consume alcoholic beverages on a regular basis?

INTERROGATORY NO. 19

Are you addicted to alcohol or drugs of any kind?

INTERROGATORY NO. 20

Have you ever had sexual relations with anyone other spouse during the course of your marriage?

INTERROGATORY NO. 21

State whether or not you have provided any banks or other lending institutions with financial statements during the past 24 months.

INTERROGATORY NO. 22

For each person you shall call as a witness at the trial of this case, please state...

INTERROGATORY NO. 23

For each person you allege to be an occurrence witness...

INTERROGATORY NO. 24

For each person whom you expect to call as an expert witness at the trial...

INTERROGATORY NO. 25

For each document or other item you shall offer as an exhibit at the trial of this case...

INTERROGATORY NO. 26

State the names and addresses of all persons involved in the answering of these interrogatories.

INTERROGATORY NO. 27

Have you, as the Defendant in this case, read the answers to each and every one of the above interrogatories and requests for production of documents and things?

Yes No

INTERROGATORY NO. 28

If, at any time between this date and the date of the trial of this cause, you come into possession of information... will you disclose such newly discovered information?

Yes No

Respectfully submitted,

CERTIFICATE OF SERVICE

I, , Defendant, do hereby certify that I have this day mailed, by United States mail, postage prepaid, a true and correct copy of the above and foregoing Defendant's First Set of Interrogatories to Plaintiff at:

Name of Plaintiff:

Address:

DATED, this the day of , 20.

NOTICE OF SERVICE OF DISCOVERY

TO:

Notice is hereby given that Defendants have this date served in the above entitled action:

DEFENDANT'S FIRST SET OF INTERROGATORIES PROPOUNDED TO THE PLAINTIFF WITH REQUEST FOR PRODUCTION

The undersigned retains the originals of the above papers as custodian thereof pursuant to Court Rules.

DATED:

CERTIFICATE OF SERVICE

I, , Defendant in the above referenced civil action, do hereby certify that I have this day caused to be delivered, via United States Postal Service, first class postage prepaid, a true and correct copy of the above and foregoing document to:

Plaintiff's Name:

Address:

THIS the day of , 20____.