Judiciary of New York



STATE OF NEW YORK

FAMILY COURT: COUNTY OF

Petitioner,

VS. INTERROGATORIES

Respondent. Docket No.

SIRS:

PLEASE TAKE NOTICE, that the LAW GUARDIAN, requests that the anser, under oath, in accordance with Article 31 of the CPLR and Section 236 (B) (4) of the Domestic Relations Law, the following Interrogatories:

NOTE: Questions concerning marriage and children are with relation to the other party to the suit, unless otherwise indicated. Where a question is inapplicable, indicate the same.

INTERROGATORY NO. 1

State your full name, age, residence and post office address, home telephone number, social security number and business address.

INTERROGATORY NO. 2

State whether any child of the marriage is in need of unusual or extraordinary medical or mental care or has special needs, giving a description of the condition which requires such care.

INTERROGATORY NO. 3

As to yourself, state:

(a) your present health;

(b) whether you have any need of any unusual or extraordinary medical care or special financial needs;

(c) educational background, giving all schools attended and years of attendance, any degrees conferred, as well as any special training courses and employment skills, and

(d) if you were married at the time you attended school or any special training course, indicate whether your spouse contributed to the cost of your education and/or support and living expenses and the amount thereof.

INTERROGATORY NO. 4

If you have any disability which at any time renders you unable to perform work or limits your ability to perform work, now or in the future, state:

(a) the nature of the disability;

(b) the name and address of each treating physician for the past ten years for said disability;

(c) the frequency of said treatment;

(d) the cost of said treatment; and

(e) the nature of said treatment.

Attach any medical reports concerning this disability rendered during the past three years.

INTERROGATORY NO. 5

State your residence addresses for the past five years up to the present time, indicating periods of residence at each address.

INTERROGATORY NO. 6

State the number of people with whom you currently reside. If you are not currently residing with your spouse, state the names, ages and relationship to you of those persons with whom you reside at the above address, either on a permanent or periodic basis.

INTERROGATORY NO. 7

If your residence is rented or leased, state:

(a) the monthly rental and term of the lease or agreement;

(b) to whom the rental is paid, including name and address;

(c) whether any other persons are contributing to the rental, the amount of the contributions, and the names of any such person.

Attached copies of canceled rent checks for the pas six months and a copy of your lease or rental agreement.

INTERROGATORY NO. 8

If there are any non-income producing properties which have not been listed in any previous interrogatory, give the same information for each non-income producing property.

Attach copies of the closing statement of purchase, deeds and a copy of any appraisals obtained.

INTERROGATORY NO. 9

If you have sold or otherwise disposed of any real property in which you have had an interest within the last three years, state for each property, in detail.

Attach copies of each closing statement of purchase and deed.

INTERROGATORY NO. 10

If you are or have been the grantor or grantee within the past five years of any options to purchase real estate, state for each option:

(a) the name of the grantee if you are the grantor;

(b) the name of the grantor if you are the grantee;

(c) the price paid or received;

(d) the period during which the option is in force and effect.

INTERROGATORY NO 11.

If you have executed any contracts to buy or sell real property on your own behalf, on behalf of any other individual, partnership, form, or other entity within the last three years, indicate the location of the property, the term so the sale, and whether you are the purchaser or seller, and the name of the other parties or party. Attach a copy of each such contract.

INTERROGATORY NO 12.

If you are the holder of any rental property not disclosed in a previous interrogatory, state for each:

(a) the type of such property (whether real or personal);

(b) the location of such property;

(c) the date acquired;

(d) the net monthly rental to you from each piece of property; and

(e) the gross monthly rental to you from each piece of property;

(f) list all expenses incurred within past year.

INTERROGATORY NO 13.

State the names, addresses, and telephone numbers of all employers for the past three years and give the dates of such employment, position held, reason for termination, and salary.

INTERROGATORY NO 14.

As to your present employment, state:

(a) name and address of each and every partnership, corporation, firm, or other entity from which you receive compensation of whatever sort;

(b) type of work performed, position held, and nature of work or business for which you receive compensation;

(c) amount of time devoted to such compensation-earning activities over the past three years;

(d) hours of employment; and

(e) rate of pay or earnings, setting forth specifically your gross and net average weekly salary, wages, draws, commissions, overtime pay, bonuses and gratuities.

INTERROGATORY NO 15.

State in which bank, savings or checking account, your salary or other compensation is deposited, giving the name of the bank, branch and account number. If said salary, bonus, or other compensation checks or cash are negotiated other than deposited, indicate the name and branch of the bank where said checks are regularly cashed or negotiated.

INTERROGATORY NO 16.

Itemize all income benefits and other emoluments not already included in your answers to any preceding interrogatories, including but not limited to, any other sources of income such as pensions, annuities, inheritances, retirement plans, social security benefits, military and/or veterans benefits, lottery prizes, bank interest, dividends, showing the source, amount and frequence of payment of each. Indicate whether each income benefit and/or other emolument is taxable or non-taxable income.

INTERROGATORY NO 17.

Itemize all bank and savings and loan association accounts, time deposits, certificates of deposit, savings clubs, Christmas clubs, and checking accounts in you name, or in the name in conjunction with any other individual, or in your name as custodian for any other firm, corporation, or other entity, presently or during the past three years stating for each:

(a) name and address of each depository;

(b) the balance in those accounts as of the date of the services of the Summons in this action;

(c) the present balance;

(d) the balance for four months prior to the service of the Summons in this action;

(e) if there is any difference between your answers to (b), (c), and (d) above, specify when the withdrawals were made, who received the benefit of the withdrawals, who made the withdrawal and where the proceeds of the withdrawals went;

(f) the name and address in which each account is registered, account numbers, and the present location and custodia of all of the deposit books, check registers, and/or certificates.

Attach copies of the monthly statement of such accounts for the past twelve months, together with copies of all savings account books, check registers, and/or certificates.

INTERROGATORY NO. 18

For each vehicle of any nature in which you have any interest, or have the use of by virtue of any agreement or understanding, including but not limited to automobiles, trucks, campers, mobile homes, motorcycles, snowmobiles, boats and/or airplanes, state:

(a) the nature of each vehicle.

(b) your interest therein;

(c) the name in which the vehicle is registered;

(d) the make, model and year of each;

(e) the price paid and the date acquired;

(f) the principal operator or operators of the vehicle since its purchase, if any

(g) the present location of the vehicle;

(h) the name and address of co-owners, or any owner other than yourself of any vehicle of which you have the use;

(i) the present value of said asset.

Your answers to the above should include any and all vehicles presently owned or owned and transferred within the past three years.

INTERROGATORY NO. 19

State whether you have any legal actions pending for money damages. State whether your are a plaintiff or a defendant in any such action, or whether you are entitled to receive any legal settlements or insurance recoveries. If so, state:

(a) the amount of money which is demanded in the pleadings.

(b) the court in which the action is or was pending, the caption of the case, and the index or docket number;

(c) whether any person has an interest in the recovery, legal settlement, or pending action, or is named as a co-defendant with you in any such legal action, and if so, the nature of their interest, or liability, name and address;

(d) the circumstances resulting in your becoming entitled to the insurance recovery or legal settlement, or commencing legal action, which resulted in the legal action being commenced against you;

INTERROGATORY NO. 20

If, during the course of your marriage, you have received any inheritances, state:

(a) from whom you inherited;

(b) the nature and the amount of the inheritance;

(c) the disposition of any of the assets of the inheritance, tracing, if possible, to the same of the service of the Summons of this action;

(d) the value of the inheritance at the time of the services of the Summons in this action; and

(e) the present value of the inheritance.

INTERROGATORY NO. 21

List any and all property assets, or things of a value in excess of $250.00 which you hold in trust for anyone, stating as to each:

(a) a description of the property, its location, and the name and address of the person for whom you are holding same;

(b) the condition of terms of the trust; and

(c) how such property was acquired by you and whether you paid any part of the consideration thereof. If there is a trust instrument, attach a copy hereto.

INTERROGATORY NO. 22

If you are entitled to any disability benefits, state:

(a) the nature of the disability

(b) the dollar amount of the award;

(c) the date of payment of the award;

(d) whether there are survivor benefits, giving a brief description thereof;

(e) whether any benefits or awards are presently being claimed by you, litigated, or being reviewed, indicating the amount thereof if not included above.

INTERROGATORY NO. 23

State whether anyone contributes to your support, income, and/or living expenses who has not been included in a previous interrogatory. If so, state:

(a) their names and addresses;

(b) their relationship to you;

(c) the amount of support, income and/or living expenses received by you during the last three (3) years and the frequency of said support, income and/or living expenses;

(d) the reason for said support;

(e) the nature of said support.

INTERROGATORY NO. 24

List all judgments outstanding against you and/or your spouse, not included in your anser to a previous interrogatory, and for each, state:

(a) the name of the parties and their respective attorneys;

(b) the courts in which same were entered and the index or docket number assigned to each case;

(c) the amounts of each judgment.

INTERROGATORY NO. 25

With respect to all capital contributions consisting of property other than cash which were made by you and identified in your previous Interrogatories, provide the following information:

(a) the date you acquired the property.

(b) the consideration given by you for such property.

(c) the account from which you withdrew funds to acquire such property.

BE ADVISED that the LAW GUARDIAN specifically reserves the right to demand answers to any and all such additional Interrogatories as may from time to time become necessary.

PLEASE TAKE NOTICE, that a copy of such answers must be served upon the undersigned within fifteen days after the service of these Interrogatories.

DATED: , New York

Yours, etc.

_______________________, ESQ.

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