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IN THE CIRCUIT COURT COUNTY, MISSISSIPPI
PLAINTIFF VS. CIVIL ACTION NO.
DEFENDANT
PLAINTIFF'S FIRST SET OF INTERROGATORIESREQUEST OF ADMISSIONS AND REQUEST
FOR PRODUCTION OF DOCUMENTS
AND THINGS PROPOUNDED TO DEFENDANT
Comes now , Plaintiff, and propounds this his/her First Set of Interrogatories,
Request for Admissions and Request for Production of Documents to Defendant to be answered
in accordance with Mississippi Rules of Civil Procedure.
INTERROGATORIES
1. State the date, time, and place when you first personally met .
2. State time, date, and place where you were at the time you ever talked to .
3. State the place where was the first time (s)he talked to you.
4. List in detail, including the date and time, of every telephone conversation that
you have had with since you initially met .
5. State the name and address of any financial institutions where you have accounts
in which you may deposit or withdraw monies. State the type of account, style of account, and
the account number of each.
6. List the balances of all the bank accounts in which you have any interest on
, including the account number and the name and address of each bank.
7. List each credit card that you have or have had the ability to use during the year
, including the account number of each credit card, the date each credit card was used each
time during the year and what the credit card was used for.
8. State each and every airline trip that you have taken during the year ,
including the date and time of the airline and where you got on the airplane and whe re you got
off and the date and time you returned.
9. State each and every airline flight that you know of that was taken by
during the year , including the date and time of the departure of that airli ne and the date
and time of the return of that airline.
10. State the name and last known address of every hotel or motel or other location
where you have stayed when was in the same city during the year .
11. State the date, time and location of each incident that you had sexual rel ations
with during the year .
12. State the name and address of your employer, including your direct supervisor
and his/her name, address and telephone number.
13. Please list any person you intend to call as a witness at the trial of this ca se. For
each person you expect to call as a witness, please state the witness's name, addre ss, whether
related to you, and a short summary of the subject matter to which the witness shall testify.
14. State the name and last known address of any expert witness whom you intend to
call at the trial of this cause and for each provide the following:
a. Qualifications;
b. The subject matter, which the expert will testify on;
c. The substance of the facts and opinion to which the expert is expected to test ify;
and
d. The summary of the grounds of each opinion of each of the aforesaid experts. REQUEST FOR ADMISSIONS
1. Admit that was the lawfully wedded husband/wife of from
until .
2. Admit that was married to for approximately ( ) years
prior to the relationship that developed between you and .
3. Admit that you had a sexual relationship with while he/she was married to
.
4. Admit that and you telephoned each other prior to a sexual relationship
developing between you.
5. Admit that on or about , found you and at the .
6. Admit that your interference with 's relationship with his/her husband/wife
has caused the Plaintiff great emotional distress and harm.
7. Admit that as a result of your actions that the minor children have suffered
extreme emotions and physical distress and harm.
8. Admit that as a result of your actions that the financial income available to the
Plaintiff and his/her children has been reduced.
9. Admit that you have, through sexual enticements, gifts, vacations and travel
provided by you to , destroyed 's marriage to .
10. Admit that Plaintiff's minor children are now permanently deprived of the time
with their natural father/mother.
11. Admit that the Plaintiff has suffered the loss of love and affection from .
12. Admit that the Plaintiff has suffered the loss of consortium with .
13. Admit that the Plaintiff has suffered mental agony and anguish, humiliation,
damage to his/her honor and destruction of her family life and wounded pride.
14. Admit that you willfully and intentionally had a sexual relationship with
during the time that (s)he was married to .
PRODUCTION OF DOCUMENTS AND THINGS
1. Please produce copies of all your check stubs, bank statements and any other
information for any account that you had with any financial institution during the year .
2. Please produce copies of all your credit card bills for the year .
3. Please produce copies of all your airline tickets for the year .
4. Please produce copies of all your hotel bills for the year .
5. Please produce copies of all your telephone bills for the year .
6. Please produce a copy of your State and Federal income tax return for the years
and .
7. Please produce copies of your check stubs from your employment during the year
.
8. Please produce copies of any vacation schedule or any documentation showing
any vacation that you have taken during the year .
Respectfully submitted, _______________________________________
Attorney for
CERTIFICATE OF SERVICE
I, , attorney for , do hereby certify that I have this date maile d, postage
prepaid, a true and correct copy of the above and foregoing Plaintiff's First Set of Interrogatorie s,
Request for Admissions and Request for Production of Documents and Things to
This the day of .
__________________________
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