Current Living Expenses - ICLE



Current Living Expenses

List your estimated monthly living expenses in detail, including:

A. Rent.

B. Purchase or mortgage payments.

C. Utilities.

D. Food.

E. Clothing.

F. Laundry and cleaning.

G. Transportation.

H. Medical and dental care.

I. Education.

J. Insurance.

K. Recreation.

L. Other regular expenses, including credit card payments and loans.

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What are your total monthly living expenses at the time of answering these Interrogatories?

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Do these expenses include the support of any person other than yourself?

A. If so, state the name of each such person and the monthly expenses attributable to such person.

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EDUCATION

Have you undertaken any education since graduation from high school.

A. If so, please state the following:

1. The institution attended.

2. The inclusive dates of attendance.

3. The type of course work studied.

4. Whether a degree, license or certificate was obtained, and type of degree, license or certificate.

5. Special skills or training or job training

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INCOME

Please state your gross and net income for the last three (3) years and attach copies of your Federal and State Income Tax returns, whether filed jointly or separately for those years, with all schedules attached.

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List your income earned for the year 2002 to date, include all fringe benefits, and any anticipated increases.

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Please state the amount and date of all bonuses since January 1, 2001.

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PENSIONS AND PROFIT SHARING

Do you have any pension, profit-sharing or deferred compensation interest of similar nature? If so, please answer the following questions for all programs in which you have participated (other than your present employer):

A. List the program and attach a copy of the plan.

B. What is your total contribution and evidence of the existing contribution thereto?

C. What is your vested interest in the plan, the present value of same, and attach evidence of same?

D. Where are the funds deposited?

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MENTAL AND PHYSICAL HEALTH

What is the condition of your mental health at the present time?

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What is the condition of your physical health at the present time?

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Do you claim you have any infirmities or chronic ailments?

A. If so, explain in detail the extent of these infirmities or ailments.

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LAST WILL AND TESTAMENT

Have you executed any Last Will and Testament?

A. If so, state:

1. The date of execution.

2. The place of execution.

3. The date of revocation, if any.

4. The date of each Codicil and Amendment.

5. A description of each specific bequest or devise, including a description of the property and the name and address of the beneficiary.

6. The name of each person receiving the residuary bequest.

7. A description of each testamentary trust in the Will, including a description of the property, name and address of the trustee and the name and address of each beneficiary.

8. The name and address of each attorney who prepared the Will and Codicils to the Will.

9. The present location of the Will and each Codicil and Amendment.

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FINANCIAL RECORDS

During your marriage did you ever prepare or have prepared any financial statement or list of your assets and liabilities?

A. If so, for each such document, state:

1. The date of preparation.

2. The name and address of the person or firm who prepared the document.

3. The purpose of the document.

4. The name and address of the person in present custody of the document.

5. Attach a copy of each such document to your answers to these Interrogatories.

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FAULT

Are you claiming Defendant is at fault for the breakdown of the marriage in this matter?

A. If so, please state all the grounds for your assertions and the witnesses, if any, you will rely on to support your assertion.

B. Please state if you believe you are at fault, to any extent, for the breakdown in the marriage and, why you believe you are/are not at fault to any extent.

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Do you claim there should be a disproportionate distribution of marital property based on fault, or for any other reason?

A. If you do claim there should be a disproportionate distribution of marital property, please state with specificity the percentage of marital property you believe should be awarded to each party.

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EXPERT WITNESS INTERROGATORIES

State the name and address of each person whom you expect to call as an expert witness at the time of trial of the above-entitled cause of action, and state his/her general field of expertise.

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State the subject matter upon which each expert listed in the answer to the previous Interrogatory is expected to testify, and state the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion.

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State the name and address of each person whom you hired or consulted as an expert, if any, but whom you do not expect to call as an expert witness at the time of trial of the above-entitled cause of action, and state his/her general field of expertise.

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State each analysis or examination made by each expert listed in the previous three answers to Interrogatories.

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Did any of the experts listed in the previous four answers to Interrogatories submit a report of their objective findings? If so, please state:

A. The date this report was submitted.

B. The name or other identification of the person to whom the report was submitted.

C. The name and address of the person who has present custody or control of any such report.

D. The identity of the person who requested the inspection and/or analysis and opinion.

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Please attach to your answers to these Interrogatories a copy of any report, including copies of any attachments, prepared by any expert listed in the preceding answers to Interrogatories.

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For each person who you expect to call as an expert witness at trial, please attach a copy of his/her current curriculum vitae/résumé. Or in the alternative, please state his/her educational background or the training in the matter to which he/she is testifying to, and please describe all qualifications he/she has in the area in which he/she will testify in.

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For each person who you expect to call as a lay witness at trial, please state:

A. Name, address, and telephone number.

B. The relationship of each witness to you.

C. What each witness is expected to testify.

D. Describe all knowledge each witness has in the area in which he/she will testify in.

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EXPECTANCIES/INHERITANCE

Are you the beneficiary under the terms of any trust instrument? If so, please state: A description of the property held in trust; The name and address of the trustor or settlor; The date the trust was created.

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During the past five years have you created, or contributed to, any trust for the benefit of someone else? If so, please state: When the trust was created; A description of the property contributed by you; The name, address and relationship of each beneficiary of the trust; The name and address of each trustee.

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Are you an heir-at-law or beneficiary under the terms of the Will of any person now deceased? If so, please state: The name of the decedent; The name and address of the court in which the estate is pending or the person who has possession of a Will; The amount and dates of any advancements received against your share.

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UNEMPLOYMENT/UNDEREMPLOYMENT/DISABILITY

If you are not presently employed, please indicate whether you receive unemployment compensation of any kind, the type of compensation you are receiving, the monthly amount of compensation you are receiving, the date this compensation started, and the last date you are eligible to receive this compensation.

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If you are not presently employed, please provide a detailed description of the efforts you have made in the past year to secure employment, including but not limited to contacts you have made with prospective employers, the number of contacts you have made, the type of contacts you have made, the areas in which you are seeking employment, the type of employment you are seeking, any assistance you have obtained from third parties or agencies, all offers of employment you have received, and the reasons for declining any offers you have received.

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If you are not presently employed and claim that you cannot work, please provide a detailed explanation of the reasons that you cannot work and provide copies of all documentation, medical/mental health records, test results and other confirmation of the condition precluding you from employment.

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If you are receiving any disability benefits, please provide the source of these benefits, the monthly amount of these benefits, the date you become eligible for the benefits, how long you are eligible for the benefits, whether your condition must be reviewed, the date your condition must be reviewed, and copies of all documentation substantiating your disability.

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If you are claiming that income should not be imputed to you at a level higher than your actual, current income, please provide a detailed explanation of your objection to the imputation.

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PROPERTY RECEIVED AS BENEFICIARY OF TRUST DURING MARRIAGE

Since the date of your marriage, have you received any property as a beneficiary of a trust?

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If so, for each item of property placed in trust for you, state:

A. Date the property was placed in trust.

B. Description of the property.

C. Value of the property at the time of entrustment.

D. Present value of your interest in the trust property.

E. Date and amount of each distribution of income or corpus to you.

F. Name, address and relationship to you of the settlor (or trustor) of the trust.

G. Purpose of the trust.

H. Whether any consideration was paid by our for your interest in the trust, and, if so, describe the consideration and state its value.

I. Name and address of each trustee.

J. Name and address of each other beneficiary of the trust and his respective interests in the trust property.

K. Whether there is a written trust agreement.

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Attach a copy of each written trust agreement to your answers to these interrogatories.

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Were any funds received by you as a distribution from any trust mentioned above used to purchase property?

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If so, for each purchase, state:

A. Date of purchase.

B. Description of property purchased.

C. Amount of purchase price paid from trust funds.

D. Total amount of purchase price.

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Were any funds received by you as a distribution from any such trust deposited in a savings account or commercial bank account.

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If so, for each account, state:

A. Name and address of depository institution.

B. Description and number of account.

C. Total amount of funds from such trusts deposited in the account.

D. Date of each deposit.

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If funds received by you as a distribution from such trusts were neither used to purchase property nor deposited in an account, explain in detail how the money was used, or state its present location and amount.

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INHERITANCES RECEIVED DURING MARRIAGE

Since the date of your marriage, have you received any property by bequest, devise or descent?

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If so, for each item of property received, state:

A. Date of receipt.

B. Description of property received.

C. Value of property when received.

D. Present value of your interest in the property.

E. Present location of the property

F. Name of the estate.

G. Name and address of the executor or administrator of the estate.

H. Title and address of the court administering the estate.

I. File number of the estate in the court records.

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Has there been a final distribution from any estate referred to in the preceding interrogatory?

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If so, state the date of final distribution for each such estate.

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If any property received by bequest, devise or descent is not in your possession or owned by you at the present time, identify the property and state in detail what you did with it.

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DAMAGES OR SETTLEMENTS RECEIVED DURING THE MARRIAGE

Since the date of your marriage, have you received any damages for personal injuries, or any amount in compromise or settlement of a personal injury cause of action in your favor?

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If so, for each cause of action, state:

A. Date of injury.

B. Date action filed.

C. Title and address of court.

D. File number of case.

E. Name and address of each party plaintiff and defendant, other than yourself.

F. Whether the action was settled, and, if so, state:

1. Date of settlement.

2. Settlement amount.

G. Amount of final judgment.

H. Date and amount of each payment to you.

I. Name and address of each person making such payments.

J. Name and address of each attorney representing you in the action.

K. Total amount of attorney fees and expenses of the action or settlement negotiations.

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Attach a copy of each written settlement, release and judgment to your answers to these interrogatories.

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Were any funds received by you from a judgment or settlement of a personal injury cause of action in your favor since the date of your marriage used to purchase property?

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If so, for each purchase, state:

A. Date of purchase.

B. Description of property purchased.

C. Amount of purchase price paid from these funds.

D. Total amount of purchase price.

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Were any of these funds deposited in a savings account or commercial bank account?

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If so, for each account, state:

A. Name and address of depository institution.

B. Description and number of account.

C. Total amount of funds from this source deposited in the account.

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If these funds were neither used to purchase property nor deposited in an account, explain in detail how the money was used, or state its present location and amount.

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PENSION RIGHTS

Do you have an interest in any kind of retirement or pension fund or employee stock ownership plan?

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If so, for each such fund, state:

A. Name or description of the fund.

B. Name and address of the custodian of the fund.

C. Name of employer contributing to the fund.

D. Total amount of your contributions to the fund to date.

E. Total amount of employer contributions made to date.

F. Present balance of your interest in the fund as of the date you filed for divorce and as of the date you are answering these interrogatories.

G. Date you are entitled to receive retirement or pension benefits.

H. Amount of benefits receivable per month on retirement.

I. Amount of funds available to you and method of obtaining them without retirement.

J. Do you have an interest in any pension or retirement benefits from any other employers or from your individual contributions to any IRAs, mutual funds, 401k plans, SEP plans, or any other retirement fund of any kind during your marriage?

K. If yes, answer the aforementioned questions as each relations to the asset described in paragraph J.

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