What are interrogatories and which ones should you expect during a divorce?

Answer 1

Written questions about facts in a civil suit, which are submitted by one party to the other party or witnesses. These questions are asked under oath, with the questions and sworn answers being used as evidence in the trial. The court may submit questions and answers to the jury as part of the evidence. Court time is saved by the use of interrogatories. ---- == == == == ----

* submits the following interrogatories to be answered by ** . These interrogatories are submitted pursuant to MCR 2.309, and the information sought must be given under oath whether that information is in the possession of or secured by you, your attorney, an investigator retained by your or on your behalf, your insurer, or any other agent or representative, whether personally to you or not.

The answers must be served on the undersigned attorney within 28 days after these interrogatories are served on you, These interrogatories are continuing in nature, pursuant to MCR 2.302 (E)(1), and supplemental answers are required on the receipt of additional or further information by you , either directly or indirectly, up to the time of trial.

These interrogatories include requests to produce documents. * requests that copies of the requested documents be attached to these interrogatories. Alternatively, pursuant to MCR 2.310, * requests that ** produce these documents for inspection and copying at the law offices of ******* on *date* ( 28 days), 20**, or another time, date, and place as may be agreed on. ** may produce them as they are kept in the usual course of business or organize them and label them to correspond with the categories in this request.

1. What is your complete name, address, and social security number?

2. Please state the name(s), address(es) and current telephone number(s) of the child(ren)'s pediatrician(s) or physician(s).

3. Please list any regular medical treatment received by the child(ren) including, but not limited to, treatment for Allergies, treatment for behavior or learning disorders, speech therapy, etc.

4. If the child(ren) have undergone any surgery, please state the nature of the illness or medical problem treated surgically, the name(s) of the surgeon(s) performing the surgery, the date(s) of said surgery(ies), and the outcome(s).

5. If you have consulted a child psychologist regarding the custody action and have had the child(ren) interviewed by said, please state the psychologist's name, address, and current telephone number, and the date(s) consulted.

6. If your answer to paragraph _______above was yes, please provide with these answer a copy of any records and reports and attached a signed authorization for the release of any records not in your possession.

7. Will you permit and encourage communication by the other parent with doctors and other medical personnel? ______ If no, why not?

8. Do you agree that the other parent should have the ability to make medical decisions in emergencies when you are not available?_________ If no, why not?

9. Would you provide advance notification to the other parent about proposed and forthcoming medical care? _______ If no, why not?

10. Do you plan on continuing the child(ren)'s education within the same school systems? __________ If not, please state what school system the child(ren) will attend and why you are proposing a change in school systems.

11. Would you exchange information of educational strength or weakness?

12. Would you assist the other parent's ability to visit teachers? ________ If not, why?

13. Would you pass on school information, such as dates for school activities? _________ If not, why?

14. Are you interest in and willing to assume a religious education responsibility? _____ ___ If not, why?

15. Do you have a religious preference for the child? _______ If so, what is your religious preference?

16. If you and the child's father are not of the same faith, how do you plan to facilitate the child(ren)'s knowledge or involvement in both religions?

17. If the parents live more than an hours drive from one another, please describe how you would facilitate transportation (logistically and economically) for shared parenting time (visitation).

18. In regards to preference and proposal for parenting time:

In general, how would you prefer to divide:

The school year?

The summer vacation?

The Christmas/Winter holiday break?

The Easter/Spring break?

19. What are the days that are important in your scheduling? (See Link Below for Form)

20. Are there events, club meetings, obligations or opportunities you would like to accommodate on behalf of the child(ren)? _______ If so, what?

21. Would you facilitate the other parent attending club meetings, obligations or opportunities with the child(ren) during times the child(ren) is normally with you? ________ If not, why?

22. Do you feel that yours is the only acceptable and satisfactory way to raise child(ren)? _______ If yes, why?

23. Do you agree that shared parental responsibility establishes two balanced homes for the child(ren)? _________ If not, why?

24. Do you agree not to emotionally distance your child(ren) from the other parent?

25. Will you respect the other parent's choice to his or her opinions and reasonable leeway of action when with the child(ren)? ____________ If not, why?

26. Do you recognize that other people have different ways of raising children and that it is permissible for a child experience and evaluate those differences for themselves?

27. If brothers and sisters are also involved, how would you prefer the relationship, residence and other activities be coordinated?

28. How would you approach situations that traditional families usually attend together, such as graduation, recitals, athletic performances, school activities, etc?

29. Will you facilitate the child(ren)'s contact with the other parent's parents? ________ If not, why?

30. Describe the level of involvement you can accept with the other parent.

31. Do you anticipate that your level of acceptance with the other parent will change, and under what circumstances?

32. Is verbal communication between parents satisfactory for you? ________ If not, how would you prefer to communication with the other parent and why?

33. Will you require written confirmation of verbal agreements?

34. Will you facilitate telephone calls or chats by the child(ren) with the other parent during those times when the child(ren) is a resident with you? ________ If no, why?

35. Which parenting tasks do you believe you do the best and why do think that?

36. Which tasks do you perform least well and why do you think that?

37. Which parenting responsibilities would you most like to assume and why?

38. Which parenting responsibilities would you like least to do and why?

39. In making shared parental responsibility work, which task(s) would you most like the other parent to do and why?

40. If babysitting or equivalent service is needed, will you give the other parent the first opportunity to do so before selecting or engaging an individual other than the parent? _________ If no, why not?

41. Will you, or can you, pick up and deliver the child(ren) to the other parent as frequently as the same is done for you? ________ If not why not?

42. Do you have opinions about the child(ren)'s safety that you would like to communicate to the other parent? _______ If yes, please elaborate.

43. Do you have preferences and opinions about manners and how the child(ren) behave(s) that you wish to communicate to the other parent?

44. Do you have proposals or preferences regarding punishment?

45. If you and the child(ren)'s other parent agree on a custody/shared parenting time arrangement, will you honor the plan even if you and the child(ren) dislike the conditions of that agreement? _________ If no, why not?

46. Will you agree that if you or the child(ren) are upset with the agreed upon plan, that you cannot merely modify the plan without a mutual agreement or order of the court? _______ If no, why not?

47. Will you agree that the parent who has care of the child(ren) at any given time can make minor decisions of the moment? ________ If no, why not?

48. Will you permit input about the plan from the child(ren), even if the child(ren)'s observations are critical of your options? ___________ If no, why not?

49. Do you believe that the custodial/shared parenting time agreement should be reviewed periodically without necessitating one or the other parent from having to petition for a change in custody? __________ If no, why not?

50. Have you ever discussed the custody action with the child(ren)? _____ If yes, please describe those discussions.

51. Please state the precise words you use to describe the other parent.

52. What are your estimated monthly living expenses? (See Link Below For Form)

51. If your answer to the above interrogatory includes the support of any person other than yourself and the child(ren), state the name of each person, the relationship to the child(ren) and the monthly expenses attributable to each person.

54. If your answer to the above interrogatory includes the support of any person other than yourself, state the name of each person, the relationship to the child(ren) and the monthly expenses attributable to each person.

55. Do you believe the other parent should share in the decision making when it comes to the expenses attributable to the child(ren)?______ If not, why not?

56. Do you have preference or intentions about financial savings for the child(ren)? _______ Please explain your response.

57. Please indicate (subject to your attorney's approval and without binding yourself in any way) what you would consider a fair resolution of the custody/share parenting time issue.

58. Identify by name, work address and telephone number, and home address and telephone number, each person you intend to call as a witness in this action and describe their anticipated testimony.

59. Identify each person expected to be called as an expert witness at trial, their phone number and address, the subject matter on which the expert is expected to testify, the substance of the expert's testimony and the basis upon which their opinion is formed.

Attorney Name

Attorney for

Dated: