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Interrogatories
  1. State your full name, date of your birth, the address of your present place of residence, your social security number and the full name, date of birth and relationship to you of any other person(s) residing with you at your place of residence.
  2. With respect to your present employment, please state the name and address of your employer, your job duties and responsibilities, the number of hours worked per week, the frequency of each pay period (i.e. weekly, biweekly, monthly), the method by which your salary is computed, and if hourly, state the rate, the gross amount of salary or wages received each pay period, the gross amount of all compensations (including wages, salaries, commissions, bonuses, expense, reimbursement and other remuneration) received by you during your most recent pay period (Identify, by date, the pay period) and the net amount (take home pay) of your compensation during your most recent pay period.
  3. State whether any current or past employer of yours currently provides any of the following benefits:
    1. Accident, health or disability insurance and if so, identify each policy by number and identify the insurer, each insured, each beneficiary, the limits and describe the coverage.
    2. Life insurance. If so, identify each policy by number, the insurer, the insured, each beneficiary and describe the coverage.
    3. Any other fringe benefits. If so, describe each in detail.

  4. Please state all sources of income you are presently receiving or which have been received in the twelve (12) months preceding the filing of the Petition not otherwise disclosed in your answers to these Interrogatories, and if there is such income, please state:
    1. the name and address of the person, firm or corporation who paid you earnings or income;
    2. the purpose for which the earnings were paid or the income was received;
    3. the amount of weekly or monthly wage, salary, commission or other means of payment for each such earnings or income; and
    4. the total amount paid to you by such person, firm or corporation in the twelve (12) months preceding the filing of the Petition.

  5. With respect to each place you have been employed in the twelve (12) months preceding the filing of the petition, including your present employer, please state:
    1. the name, address and telephone of each person, firm or corporation by whom you were employed, or if self-employed, the name, address and telephone number of your business location;
    2. your job title and the inclusive dates of your employment;
    3. your rate of pay and your annual gross earnings for each year of employment (or your total gross earnings if employed for less than one year); and
    4. if other than your current employment, the reasons for and circumstances of the termination of your employment.

  6. If you have any interest in any pension, profit sharing, retirement, KEOUGH Plan, I.R.A. account, thrift plan, or any other form of employment-related asset with any past or present employer, state:
    1. The date first acquired and the type of assets (e.g. pension plan).
    2. The present vested or cash value to you of such asset and the name of the company that administers the plan or program and the name, address and phone number of the person who administers the plan.
    3. Attach a copy of the plan.
    4. Attach a copy of the latest report you have received from your employer on the administration of the plan indicating your interest in said plan.

  7. If in the twelve (12) months preceding the filing of the Petition you have had any savings, checking or commercial accounts in your name solely or jointly with others, with any bank or financial institution, please state the name and address of the bank or financial institution and the type of account, the names on the account and the names of all persons authorized to draw on the account, and the date the account was opened, the date the account was closed and the account number and the amount of the present balance, if any, or the amount of the last balance before the account was closed.
  8. If in the twelve (12) months preceding the filing of the Petition there has been any bank accounts on which your name did not appear, in which you deposited or withdrew money, or are authorized to withdraw money, please state with respect to each such account, please state the name and address of the bank or financial institution, each name under which the account is listed and the account number along with the approximate date or dates and amounts of each deposit or withdrawal made by you.
  9. If you have given any financial statements during the last three (3) years, state the name and address of each person or organization to whom you gave such financial statements, and attach a copy of said statement(s) to your answers to these interrogatories.
  10. If you have transferred any real or personal property within the last twenty-four (24) months, for each such item, state:
    1. Legal description of the property;
    2. The value of your equity interest in said property;
    3. The date you transferred the property;
    4. The name and address of the person to whom you transferred said property; and
    5. Net proceeds received for said property.

  11. Please state whether you have any credit card or charge accounts, in your name individually or jointly with any other person. If so, please state the following:
    1. The bank, institution or store name for any such credit card or charge account.
    2. The account number of any such credit card or charge account, along with the monthly payment due.
    3. The opening date of any such credit card or charge account, along with the closing date, if the account is now closed.
    4. The credit limit imposed for any such credit card or charge account, along with the current balance due for any such credit card or charge account.
  12. Identify each person you expect to call as an expert witness at trial by providing such expertís name, address, occupation, place of employment, and qualifications to give an opinion, or if such information is available on the expertís curriculum vitae, such curriculum vitae may be attached to these interrogatory answers as a full response to such interrogatory and state the general nature of the subject matter on which the expert is expected to testify, and the expertís hourly deposition fee.

  13. Identify each non-retained expert witness, including a party, you expect to call at trial who may provide expert witness opinion testimony by providing the expertís name, address and field of expertise. For the purpose of this interrogatory, an expert witness is a witness qualified as an expert by knowledge, experience, training, or education giving testimony relative to scientific, technical or other specialized knowledge that will assist the trier of fact to understand the evidence.
  14. State whether or not you believe that your spouse has been guilty of marital misconduct from the date of your marriage to the present and if so, please state:
    1. the nature of each such act of misconduct;
    2. whether said act took place before or after the separation of the parties;
    3. the name and mailing address of any person involved in such misconduct other than your spouse; and
    4. the names and mailing address of all persons known to you who witnessed each such act of misconduct.

  15. State whether you or anyone on your behalf has had the other party under surveillance of any kind, including electronic surveillance or used any recording equipment or listening device at any time during the partiesí marriage and if your answer is yes, state the following:
    1. Each date such surveillance or recording was maintained and the name and address of each person who maintained the surveillance or recording;
    2. The location at which such surveillance or recording was maintained;
    3. The activities that the other party was engaged in during each such period of surveillance or recording; and
    4. The name and address of each person who has custody of any recordings or copies made from any such surveillance.
  16. Please state whether you have any education or training beyond the high school level, including vocational training; and, if so, please state:
    1. If you received or will receive a degree or certificate for said education or training, together with the name and highest grade or level completed, and degree or certificate obtained;
    2. The area of concentration for your studies;
    3. Whether your current employment utilizes the training or education you have received;
    4. Whether you intend to work in the field for which you are currently or have studied, together with any job opportunities for which you are now a candidate.
  17. Do you have a physical, emotional or other condition which prevents you or makes you incapable of maintaining employment either on a full-time basis or a part-time basis? If your answer is yes, please identify your condition, the date this condition began, the date it was diagnosed, the name, address and phone number of the doctor who diagnosed it, and the nature or symptoms of this condition.
  18. Please state each and every factual reason, in specific detail, why you believe you are entitled to or should be awarded maintenance. Indicate the amount you are requesting and the basis for that requested amount.
  19. Please state whether any person, other than yourself, contributes to your regular household expenses and payments, and if so, please state the following:
    1. the name, address and telephone number of any person(s) that contributes to your regular household expenses and payments.
    2. the amount of the contribution made toward your regular household expenses and payments
    3. whether you have or had a verbal or written agreement with any such person(s).

  20. Are you requesting sole legal or sole physical custody of the minor child? If yes, list each and every reason why you believe you are fit to be the sole legal or sole physical custodian and why it is in the best interests of the child that you are the sole legal or sole physical custodian. List each name and address of every person who has knowledge of your and the other partyís individual parenting skills, co-parenting practices, family history, and home environment. Please list, in detail, each and every reason for that request, the date of each incident which led you to that request and the name and addresses of any witnesses to each such incident.
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