IN THE CIRCUIT COURT OF CLAY COUNTY, MISSOURI
SEVENTH JUDICIAL CIRCUIT OF MISSOURI
LIBERTY, MISSOURI
In Re The Marriage Of:)
)
______)
______,)
)Case No:
______,)
)Division No.:
Petitioner,)
)
and)
)
______,)
)
Respondent.)
FIRST INTERROGATORIES OF
PROPOUNDED UPONCOMES NOW ______, and propounds the following Interrogatories to be answered by ______, in the manner provided by Missouri Supreme Court Rule 57.01.
These Interrogatories are intended to be of a continuing nature, requiring you to serve timely supplemental answers setting forth any information, within the scope of these Interrogatories, which may be acquired by you following the original answers.
DEFINITIONS
A. As used herein, the phrase “the date of your marriage” shall mean the ______day of ______, 20______.
B. As used herein, the term “your spouse” shall mean ______, in this cause.
C. As used herein, the term “minor child born of this marriage” shall apply to all children which have your spouse and you as parents, whether natural born or adopted.
INSTRUCTIONS
Type your answers to the following Interrogatories in the space following the Interrogatory on this form where possible. If the space is not sufficient to answer the Interrogatory completely, type your answer on a separate sheet of paper and attach same as an appendix hereto noting on this form which appendix contains your answer to said Interrogatory and noting on the appendix reference to the Interrogatory being answered.
1. State your full name, the date of your birth, your social security number, your present place of residence and the date you began your residency at such place.
ANSWER:
2. Attached to these Interrogatories is a Statement Of Marital And Non-Marital Property And Liabilities and a Statement Of Income And Expenses. Please answer the items requested in said statements as if fully set out in these Interrogatories.
ANSWER:
3. With respect to each place you have been employed during the preceding five (5) years (or since the date of your marriage, whichever period of time is lesser), please state:
(a) The name and address of each person, firm or corporation by whom you were employed.
(b) The inclusive dates of your employment.
(c) Your rate of pay.
(d) Your annual gross earnings for each year of employment (or your total gross earnings if employed for less than one year).
(e) The reasons for and circumstances of the termination of your employment.
ANSWER:
4. Please state whether or not you are now employed and, if so, state:
(a) The name, address and telephone number of your present employer or, if self-employed, the name and address and telephone number of your business location.
(b) Your present occupation or business with such employer or type of business in which you are engaged.
(c) The name, address and telephone number of your payroll records clerk.
(d) Your rate of pay or income, how it is calculated, your base gross earnings or income per pay period and how frequently you are paid.
(e) The length of time you have been with your present employer or occupation.
(f) All economic benefits or assets in addition to cash income which you receive or have access to from any source, including, but not limited to such things as company cars, club memberships and expense accounts.
(g) Do you expect any material increase or decrease in wages or benefits and, if so, when and why?
ANSWER:
5. Is there any program or plan for retirement, profit-sharing, pension or thrift plan in which you are entitled to participate as a result of past or present employment (including membership in a union)? If so, please execute the attached Authorization before a notary public and return same with your answers to these Interrogatories.
ANSWER:
6. Do you have any interest in an individual retirement account (IRA)? If so, please state:
(a) The location of each IRA.
(b) The present value of each IRA.
ANSWER:
7. Have you in the last five (5) years (or since the date of your marriage, whichever period of time is lesser) hired any accountant or accounting firm for the purpose of preparing or maintaining financial books, records or statements for you? If so, please state:
(a) The name and address of the accountant or accounting firm.
(b) The inclusive dates of employment.
(c) A description of the books or records prepared or maintained.
(d) The present custodian and location of such books and records.
ANSWER:
8. Please state whether or not you have had any income during the preceding five (5) years other than what has been set forth in the preceding Interrogatories.
ANSWER:
9. If your answer to the preceding Interrogatory is in the affirmative, please state:
(a) The name and address of the person, firm or corporation who paid your earning or income.
(b) The purpose for which the earnings were paid or the income was received.
(c) The amount of weekly or monthly wage, salary, commission or other means of payment for each such earnings or income.
(d) The total amount paid to you by such person, firm or corporation during each of the preceding five (5) years.
ANSWER:
10. Please state all present sources of income and the amounts thereof not otherwise disclosed in your answers to these Interrogatories.
ANSWER:
11. Have you in the last three (3) years (or since the date of your marriage, whichever period of time is lesser) filed a state and federal income tax return? If so, for each such return, please, state:
(a) Whether it was joint or separate filing.
(b) The address of the office in which it was filed.
(c) The amount of your adjusted taxable income reported thereon.
NOTE: In lieu of answering subparts (a) through (c) above, you may attach your state and federal income tax returns with all schedules for such period of time.
(d) The name and address of the person or entity who prepared the return.
(e) Who received the refund, if any, from the return most recently filed, who endorsed the refund check and what has been done with the money refunded.
ANSWER:
12. Have you during the twelve (12) month period immediately preceding the date of service of these Interrogatories, maintained an account or fund, either singularly or jointly, in any credit union, bank, savings and loan association or other financial institution?
ANSWER:
13. If your answer to the preceding Interrogatory is in the affirmative, please state for each such account or fund:
(a) The name and address of the bank or financial institution.
(b) The type of account or fund.
(c) The names on the account or fund.
(d) The date the account or fund was closed, if applicable.
(e) The account or fund number.
(f) The amount of the balance as shown on your last statement and the date of such statement; or, if the account or fund is closed, the amount of the last balance before the account or fund was closed.
(g) The names of all persons whose names have appeared on said accounts or funds.
ANSWER:
14. Since the date of your marriage, have you made any deposits with any credit union, bank, savings and loan association or other financial institution to an account or fund on which your name did not appear?
ANSWER:
15. Please list all the safe deposit boxes, vaults, safes or other places of deposit and safekeeping in which you have deposited any money, documents or other items of personal property at any time during your marriage. For each, please state the following:
(a) The name of the depository institution.
(b) The box number, letter or other identifying designation for the place of deposit.
(c) The name and address of each person authorized to enter the safe deposit boxes, vaults, safes or other places of deposit.
(d) The date on which said safe deposit boxes, vaults, safes or other places of deposit were opened.
(e) The present inventory of the contents.
(f) The date on which said safe deposit boxes, vaults, safes or other places of deposits were closed or entry rights terminated.
ANSWER:
16. If you are in possession of any cash money which is not deposited in any type of account or within any depository institution, then please state the amount of such money and its present location.
ANSWER:
17. Are there in effect any policies of insurance providing hospitalization and/or major medical, dental or vision health care protection to you, your spouse or any minor child born of this marriage? If so, state:
(a) The identity of the insurance company.
(b) The number of the policy and your identification number.
(c) Details of the coverage and benefits provided.
(d) The names of the persons covered under each policy.
(e) The total monthly premium charged for such coverage.
(f) The amount of the monthly premium which is attributable to coverage for any minor child born of this marriage.
ANSWER:
18. If you have paid or incurred any attorney fees with respect to any attorney who is or has represented you in this action for dissolution of marriage, then for each such attorney please state:
(a) The name, address and telephone number of the attorney.
(b) The amount paid on account.
(c) The dates of the payments.
(d) The amount now owed, but unpaid, with respect to legal services rendered to the present.
ANSWER:
19. Do you claim that your spouse engaged in any form of misconduct since the date of your marriage?
ANSWER:
20. Are you presently in good health? If not, please state:
(a) The cause of your physical, emotional or mental condition or the occasion giving rise to such condition.
(b) The date or duration of each such condition.
(c) The nature of your physical, emotional or mental condition.
(d) The name and address of the treating doctor or hospital.
(e) The dates or duration of any treatment received by a doctor or hospital.
ANSWER:
21. Do you claim that you are entitled to maintenance?
ANSWER:
22. Please state the name and address of each person you expect to call as an expert witness at the hearing on your dissolution of marriage in the above-captioned cause and the general nature of the subject matter on which such expert is expected to testify.
ANSWER:
23. Do you claim that it is in the best interest of any unemancipated child born of this marriage that you be awarded primary physical custody of such child?
ANSWER:
24. Do you claim that your spouse is unfit as a parent to have primary physical custody of any unemancipated child born of this marriage?
ANSWER:
25. Do you believe that joint legal custody is in the best interest of any unemancipated child born of this marriage?
ANSWER:
26. Please state the periods of time during each calendar year that you believe the unemancipated children born of this marriage should be in the physical custody of each parent.
ANSWER:
27. Please complete all portions of Civil Procedure Form No. 14 based upon information currently available to you and return same with your answers to these Interrogatories.
ANSWER:
28. Do you believe the child support amount for the unemancipated minor children born of this marriage as calculated under Civil Procedure Form No. 14 is inappropriate or unjust?
ANSWER:
29. Do you claim that any child born of this marriage is emancipated and, if so, please state the name of such child and the facts and circumstances which you believe substantiate your claim?
ANSWER:
30. Since the date you and your spouse separated, have you paid any sums to your spouse or anyone on your spouse’s behalf for the support of any child born of this marriage?
ANSWER:
31. If your answer to the preceding Interrogatory is in the affirmative, for each such payment please state:
(a) The date of such payment.
(b) The amount of such payment.
(c) The form of payment, e.g. cash, check, money order, etc.
(d) To whom the payment was made.
(e) The particular purpose of the payment.
ANSWER:
By: ______
MO. Bar Enrollment # ______
Telephone: ______
Fax: ______
ATTORNEYS FOR ______
______’S SWORN SIGNATURE
STATE OF ______)
) SS.
COUNTY OF ______)
The below named ______, being duly sworn upon ______oath, states that ______read the foregoing Interrogatories and the answers given are true to the best of ______belief and knowledge.
______
The foregoing Answers to Interrogatories were subscribed and sworn to before me this ______day of ______, 20______.
______
Notary Public
(Seal)
My Commission Expires: ______
CERTIFICATE OF MAILING
I hereby certify that the original copy of the completed Interrogatories was mailed, U.S. Mail, postage prepaid, to: ______,
this ______day of ______, 20____, attorney for ______.
______
I hereby certify that the foregoing Interrogatories was ______this ______day of ______,
20 _____, to: ______,
Attorney for ______.
______
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