<BR>In my mail is this thick stack of questions ... 53 of them, many multi-part, and 18 pages thick ... stuff I am required to answer!??!! Regarding financials dating from BEFORE we were married, jobs, inheritances, personal property, living expenses, liabilities, loans, contributions to the marital estate, family history including divorces and drug use, current relationships, mental and physical health, religion and morality, and then some.<P>Where the h!!! did this come from, and WHY do I have to answer these questions ... I understand the ones that may have SOMETHING to do with division of assets and of course those dealing with custody, but there is just so much here that is asinine!!!<P>My STBX is the plaintiff, is this why he is allowed to do this to me?! Can I make him answer all of these questions as well!? I'm in Michigan and I have never heard of this kind of ... oh, I am so angry. Why do I have to provide documentation of HIS income and HIS taxes and HIS debts to cover MY behind!??<P>Please, if anyone can shed some light on this ... I've already got a call in to my atty but it is going to be a looooong wait to hear from her.<BR>

You're looking at a part of the process that occurs in <I>many</I> cases. Whether it's standard in your state, I don't know. The purpose is to narrow the issues that need to be explored in an in-person deposition, and the issues that need to be addressed at trial. To the extent thing's aren't in dispute and don't need proving, the attorneys stipulate to the facts before trial to save the court time.<P>There are things there you likely <I>must</I> answer. But there may also be plenty that's in there just to harrass or annoy, and your attorney can object. Or fire back a heavy set of her own. Then the attorneys can either agree to what will or won't be in there, unilaterally furnish less than requested, or object and go before the judge. If an attorney gets less than he or she expects, he or she can ask the court to compel more disclosure.<P>Bottom line: your attorney strategizes, opposing counsel may have something to say about that, and the judge may be called upon to call it a ball or a strike. <P>Whatever you do answer, be sure to tell the truth.

Some of these are going to be completely IMPOSSIBLE!! I have gone through and <B>bolded</B> some that I found particularly asinine.<P><BR>1. What is your full name, your present residential address, your social<BR>security number, your birthdate, your birthplace, number of times you were<BR>married prior to this marriage, your present employer(s) name, address,<BR>telephone number, and a description of your occupation(s)?<BR>2. For each place of employment within the last five years please state the<BR>following:<BR>a. The name and address of each of your employers. If self-employed please<BR>indicate:<BR>b. The inclusive dates of employment.<BR>c. Type of work performed.<BR>d. Form and amount of compensation received.<BR>Please attach copies of your three (3) most recent paystubs.<BR>Please attach the last 5 years of tax statements.<BR>3. Do you own or have you <B>during the last 9 years</B> owned any interest in any<BR>real property? <I>(I haven't even known him nine years!)</I><BR>4. If so, for each period of real property state:<BR>a. The address.<BR>b. A legal description.<BR>c. Your interest in the property.<BR>d. The date of purchase or date obtained.<BR>e. Financial details of how you paid for your interest in the property.<BR>Please attach any/all documentation for same.<BR>f. Financial details of how you paid for the taxes in the property. Please<BR>attach any/all documentation for same.<BR>g. The amount of purchase price.<BR>h. Identity of each other person who you acknowledge as having an interest<BR>in the property and description of the person's interest.<BR>i. The present value attributed to said real estate.<BR>j. If an appraisal was done, state:<BR>i. appraisal date<BR>ii. amount of appraisal<BR>iii. attach a copy of appraisal<BR>k. Attach a copy of each and every Deed and/or Land Contract for each parcel<BR>of property.<BR>4. <B>Identify each document you have removed from the marital home in the last<BR>twelve months. Attach a copy of each such document.</B> <I>(Impossible, unreasonable!)</I><BR>5. <B>Please give a complete description of any and all furniture, household<BR>goods, appliances, antiques, paintings, etc. acquired during the marriage<BR>and the present location for each item.</B> <I>(Can this be serious?!)</I><BR>6. Please provide a written inventory of each item of personal property<BR>having a replacement value of $50.00 or more you either removed from the<BR>marital home or retain in the marital home during and following the date of<BR>separation set forth in the complaint.<BR>7. Please provide a written inventory of each item of personal property<BR>having a replacement value of $50.00 or more you may have removed from the<BR>marital home prior to the date of separation set forth in the complaint.<BR>8. Please provide a written inventory of each item of personal property<BR>having a replacement value of $50.00 or more currently in the possession of<BR>your spouse that you intend to claim as your separate property at trial.<BR>9. Please indicate the source of funds used in the purchase of the items<BR>listed in your answer to question number 8 hereinabove and the estimated<BR>present value of these items of personal property.<BR>10. Does any person, firm or business entity hold any property for your<BR>benefit in trust or otherwise?<BR>11. If so, for each item of property please state:<BR>a. The name and identity of such person.<BR>b. A description of the property held for your benefit.<BR>c. The approximate value of that property.<BR>12. Please list in detail any and all other assets in which you have an<BR>interest, with a value in excess of $100 not listed above, and for each item<BR>please state:<BR>a. An exact description of the item.<BR>b. The purchase price.<BR>c. The approximate current value.<BR>13. List in detail your monthly living expenses for the last 12 months<BR>including: -- <I>(What does this have to do with anything?!)</I><BR>a. Rent. If so, attach a copy of the lease.<BR>b. Purchase or mortgage payments. If so, attach a copy of any documentation<BR>regarding same.<BR>c. Utilities<BR>d. Clothing<BR>e. Food<BR>f. Laundry and cleaning<BR>g. Transportation<BR>h. Medical and dental care<BR>i. Education<BR>j. Insurance. If so, please attach a copy of any and all statements.<BR>k. Recreation<BR>l. Drugs and personal grooming expenses<BR>m. Organization fees. If so, please attach any and all invoices for same.<BR>n. Other regular expenses<BR>14. Are your total monthly living expenses at the time of answering these<BR>interrogatories different from those listed above?<BR>15. If so, please indicate in detail how your expenses differ.<BR>16. Please list in detail all of your current debts or liabilities and for<BR>each state:<BR>a. The nature or type of liability. Please attach copies of any and all<BR>documentation regarding current debts and liabilities.<BR>b. The total amount of liability when incurred and the date incurred.<BR>c. The current balance due on each liability.<BR>d. The amount of monthly payment for each liability.<BR>e. The purpose for which each liability was incurred.<BR>17. Are you making a claim that any assets owned by you are separate<BR>property and not subject to division for purposes of property settlement?<BR>18. If your answer is yes, please list specifically the items of property<BR>you believe to be your separate property and the value of that property on<BR>the date of your marriage.<BR>19. Please state any and all educational or other degrees which were<BR>acquired by you during the marriage, and state the date each degree was<BR>acquired.<BR>20. Have you obtained any loans (including any with your spouse) during the<BR>marriage in excess of $1,000? If so, please state:<BR>a. The purpose of the loan. Please attach copies of any and all loan<BR>agreements.<BR>b. The name of the institution making the loan.<BR>c. Security, if any, used for the loan.<BR>d. Has the loan been re-paid in full?<BR>e. If not, please state the current balance?<BR>21. <B>If you claim you have made specific contributions to the marital estate<BR>and that those contributions should be considered in determining a division<BR>of the marital estate, for each specific contribution, state:</B> <I>(Again, bordering on impossible - documentation of every cent I've put into our home!?)</I><BR>a. The contribution;<BR>b. The value of the contribution at the time you made it;<BR>c. The date or dates on which you made the contribution;<BR>d. If the contribution no longer exists in its original form (having been<BR>sold, traded, or disposed of in some other manner as consideration for some<BR>other asset of value), state the present form of the contribution and trace<BR>all transactions between the original contribution and the present form of<BR>the contribution;<BR>e. The present value of the contribution and your basis (appraisal or<BR>otherwise) for claiming that value;<BR>f. Any specific asset you claim you should be awarded because of your<BR>contribution.<BR>g. Please attach any and all supporting documentation for said<BR>contributions.<BR>22. <B>If you acknowledge that your spouse has made specific contributions to<BR>the marital estate and that those contributions should be considered in<BR>determining a division of the marital estate, for each specific<BR>contribution, state:</B> <I>(Oh great, now I'm required to prove HIS contributions TOO!!?)</I><BR>a. The contribution;<BR>b. The value of the contribution at the time your spouse made it;<BR>c. The date or dates on which your spouse made the contribution;<BR>d. If the contribution no longer exists in its original form (having been<BR>sold, traded, or disposed of in some other manner as consideration for some<BR>other asset of value), state the present form of the contribution and trace<BR>all transactions between the original contribution and the present form of<BR>contribution;<BR>e. The present value of the contribution and your basis (appraisal or<BR>otherwise) for claiming that value;<BR>f. Any specific asset you claim your spouse should be awarded because of<BR>your spouse's contribution.<BR>g. Please attach any and all supporting documentation for said<BR>contributions.<BR>23. If you claim that your health is a factor, which should be considered in<BR>determining a division of the marital estate, for each reason you claim your<BR>health should be a factor, state:<BR>a. The precise reason;<BR>b. The name, address, telephone number, and a brief description of the<BR>professional credentials of each person who diagnosed or treated you<BR>concerning the reason;<BR>c. The date you first experienced the reason;<BR>d. Any treatment currently prescribed to treat the reason;<BR>e. The percentage, dollar amount, or specific item by which your share of<BR>the marital estate should be increased (or decreased) because of your<BR>health.<BR>f. Please attach any and all supporting documentation for said claim.<BR>24. Describe your family history: (Your mother, father, siblings, alcoholism<BR>or drug usage, abuse, stars, black sheep)<BR>25. <B>Please list each of your parents and siblings individually. Please<BR>address the following: Age, married (how many times) ever divorced. How many<BR>children, highest level of education completed, where employed, any drug or<BR>alcohol use, any criminal history, and whether or not you are close to<BR>him/her.</B> <I>(What does this have to do with anything?! Where my sister works, and if my brother was ever divorced ... why!?)</I><BR>26. Was there anything significant/extraordinary about your family?<BR>27. Describe the family history of the other parent: (father, mother,<BR>siblings, alcoholism, drug usage, abuse, stars, black sheep.<BR>28. <B>Describe the marital deterioration:</B> <I>(In 10,000 words or less? Whatever ... let's see his answers!)</I><BR>29. What have you told your children about the pending divorce?<BR>30. What is your perception of the children's attachment to your family and why?<BR>31. What is your perception of the children's attachment to the other parent's family and why?<BR>32. Do the children have close relationships with friends in the area you live in? If so, what are the children's names and ages?<BR>33. <B>Are you currently involved in a relationship or have you had a relationship with someone else during this marriage?</B> <I>(This takes the cake - what does this have to do with anything?! What defines a 'relationship' here ... he has already accused me of being a lesbian because I spent a lot of time with my girlfriend!!)</I><BR>34. If so, please provide the name, address and phone number of this person and the date you began seeing each other?<BR>35. Do you see your relationship with that person continuing?<BR>36. Have you ever been involved in counseling? If so, when, where and with whom? List all the counselor's name, agency and address.<BR>37. Do you feel that you have any emotional problems? Please describe:<BR>38. Has either parent or current significant other ever been hospitalized for a mental health problem? If yes, please explain:<BR>39. <B>Do you have any physical or mental health problems?</B> <I>(No, I left him!)</I> Please describe what conditions, how long you have had the condition, the treatment for the condition, the name and address and phone number of the physician responsible for the care of this condition.<P>IF YOU CLAIM THAT THE "BEST INTEREST OF THE CHILD" AS DEFINED BY MCLA 722.23 (A COPY OF WHICH IS ATTACHED HERETO) FAVOR YOUR BEING AWARDED THE PHYSICAL CUSTODY OF THE MINOR CHILDREN, ANSWER THE FOLLOWING INTERROGATORIES.<BR>40. "The love, affection, and other emotional ties existing between the parties involved and the child."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. Who assists the child with tasks, homework, hobbies, etc.?<BR>c. What activities does the child share with each parent?<BR>d. Does the child experience privileges with one parent than he/she does not with the other?<BR>e. Who does the child go to for attention, affection, and advice?<BR>f. Who initiates affection or interaction? How is it displayed? What is the response?<BR>g. Does the child demonstrate any conflicts or loyalty when with one parent?<BR>41. "The capacity and disposition of the parties to give the child love, affection and guidance and continuation of the educating and raising of the child in its religion or creed, if any."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. How does each parent demonstrate his/her love and affection for the child and how consistent is it?<BR>c. What are each parent's child management techniques? Are these consistent and within the understanding of the child's development and age?<BR>d. Is either parent prone to be punitive in disciplinary efforts?<BR>e. What are each parent's set of values? How are these values taught to the child?<BR>f. Has there been a change or inconsistency in the value system as taught to the child since the parent's separation? If so, what is the child's perception of this change?<BR>g. Do the parents actively participate, encourage, or have an interest in religious training? Is the present situation consistent with the parent's past practices? Is there a history of difference in the parents' religious beliefs?<BR>h. Does either parent's religious convictions interfere with the child's relationship with the other parent?<BR>42. "The capacity and disposition of the parties to provide the child with food, clothing, medical care or other remedial care recognized and permitted under the laws of this state in lieu of medical care or other material needs."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. What are the financial resources of both parties?<BR>c. Is there a difference in the child's attire and grooming depending on who is responsible for the child's care?<BR>d. How was the child care responsibility negotiated and implemented during the marriage? Has the distribution changed? If so, how?<BR>43. "The length of time the child has lived in a stable, satisfactory environment and the desirability of maintaining continuity."<BR>a. If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>b. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>c. Has the child experienced a consistent living environment prior to the separation or divorce?<BR>d. To what degree has each parent been mobile since the separation and what are the explanations for such moves?<BR>e. What are the provisions for child care?<BR>44. The permanence, as a family unit, or the existing or proposed custodial home."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>45. "The moral fitness of the parties."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. Have there been changes in the social-sexual behaviors of either parent?<BR>c. How do each of the parents teach their belief system and values?<BR>d. How do each of the parents respond to a deviation from his/her personal code of ethics?<BR>e. Are the parents' moral teachings consistence with the child's developmental level?<BR>46. "The mental and physical health of the parties."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. Are there any evidences of emotional, mental or physical impairment? Do these incapacitate the parent? Is there a disability in either parent that may progressively put demands on the child to meet the parent's needs?<BR>c. Is there evidence or substance and/or drug abuse by either parent?<BR>47. "The home, school and community record of the child."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. How do the teachers view each parent with respect to the child's school progress?<BR>48. "The reasonable preference of the child."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>49. "Ability and willingness of the parties to facilitate and encourage a continuing relationship between the child and the other parent."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. What is the history of the parents' cooperation over visitation and contact between child and the other parent?<BR>50. "Any other factor considered by the Court to be relevant to a particular child custody dispute."<BR>If you claim the foregoing factor favors your being awarded physical custody of any minor child born to or adopted by you and your spouse, for each minor child,<BR>a. State your reasons for making such a claim. Cite specific supporting instances and identify all witnesses to such instances.<BR>b. Is there evidence that either parent is using issues concerning the child to disrupt or control the activities of the other parent?<BR>c. Is there any other information that appears relevant to the custody dispute by the parents not otherwise covered in the Child Custody Act?<BR>51. Do you or does anyone presently living in your household consume alcoholic beverages? If so, please state:<BR>a. The name of each person and your relationship to that person (include yourself);<BR>52. Have you ever been ordered by any Court or agency to the conditions of a domestic restraining order of no contact bond provision? If so, please describe.<BR>53. Have you ever struck, hit, pushed, or grabbed your spouse in an abusive manner without your spouse's consent? If so, please describe.<BR>I DECLARE THAT THE STATEMENTS ABOVE ARE TRUE TO THE BEST OF MY INFORMATION, KNOWLEDGE, AND BELIEF.<P><BR>I stopped highlighting stuff after question 39. I think he is trying to make me give up everything, or trying to drive me insane! I don't know what I'd do without my family and friends and church right now ... he and/or his mother have been telling the kids stuff that they shouldn't be subjected to ... where do I fit THAT in?!<BR><p>[This message has been edited by T-L-C (edited March 04, 2001).]