Information & Instructions: Master Interrogatories 1. The interrogatories in this form are designed for selection to fit the case. 2. The questions are intended to show the range of questions that may be selected within the limitation of the number of interrogatories. Please note that there are more interrogatories listed in this form than are allowed in one submission, therefore you will have to limit some of the questions. 3. Varied interrogatory questions may be selected according to the categories listed. Form: Master Interrogatories NO: [Cause Number] IN THE MATTER OF THE MARRIAGE OF [Petitioner Name], Petitioner v. [Respondent Name], Respondent AND IN THE INTEREST OF: [CHILD NAME] IN THE DISTRICT COURT [District] JUDICIAL DISTRICT [SUIT COUNTY] COUNTY, TEXAS [PARTY NAME]'S FIRST SET OF INTERROGATORIES TO: [Other Party Name], by and through [Other Party Attorney],[Other Party Address], attorney of record. [Submitting Party Name] submits the following First Set Of Interrogatories. The written Interrogatories are attached hereto and marked as "EXHIBIT A" and are made a part hereof for all purposes. The Interrogatories shall be answered or objected to separately and fully in writing under oath. Each answer shall be preceded by the interrogatory to which the answer pertains. The answers shall be signed and verified by the person making them. A copy of the answers shall be served on the party submitting this request for discovery within thirty-one (31) days after the service of the Interrogatories but in no event later than
[Deadline to File Response], by 5:00 p.m., OR you must FILE A WRITTEN RESPONSE WITH THE COURT objecting to said interrogatories within said 31 days. Answers shall be supplemented not less than thirty (31) days prior to the beginning of trial in accordance with the Texas Rules of Civil Procedure. CERTIFICATE OF SERVICE Respectfully Submitted, [Law Firm Name] By [Attorney s Name] [Attorney for Client Role] [Attorney s Address] [Telephone Number] [Facsimile Number] [Bar Card Number] I certify that a true and correct copy of the foregoing has been served upon all attorneys of record and any parties who are not represented by an attorney on. Attorney for: Attorney s name: Attorney s address Other attorney s client s name Other attorney s name Other attorney s address Type of Service: U.S. Mail, certified return receipt requested no.. U.S. Mail, first class. Hand delivery by [name of delivery service]:. Facsimile transmission to [fax number] before 5 p.m. [Attorney s name] INSTRUCTIONS
For the purpose of completing these interrogatories, the term "comparison date" where used refers to the date of any order which is presently in existence. The "present date" refers to the date on which you complete your answers to this request. ATTORNEY FEES 1. Please state the following matters regarding any employment agreement or other relationship with your attorney, [Other Attorney Name], or any other attorney employed by you in connection with this case: a. Terms of the contract or agreement. b. Amounts paid by you to the date of these answers, including the retainer, if any. c. Hourly billing rates quoted to you for the lead attorney, associate attorneys, paralegals, legal assistants and clerical personnel. d. Amounts billed but not yet paid. e. Amounts paid to the date of these answers. 2. Please state whether or not any funds described in the question above have been transferred, assigned or acquired by you or anyone else, including relatives and if so, please identify the other persons who have made or received such transfers or assignments, including their names, addresses and telephone numbers. BACKGROUND 3. Please state the full legal name by which you are known or have ever been known and list your driver's license number, all addresses which refer to your residence or place of employment. 4. Please identify all of the persons who have provided answers or any other form of assistance to you in answering the interrogatories which have been asked of you, other than any assistance you may have received from your attorney in formulating the wording to answers which you have already provided. 5. At which Internal Revenue Service office do you file your taxes. State the date of filing of your last two returns, and general information as to the total income reported therein and the sources and amounts of income. 6. Using the attached financial information sheet, identify the major categories of living expenses and list monthly average expenditures for a time period of the last six months, and please list your present outstanding debts as outlined in the exhibit.
7. Identify your present basic schedule of work days and hours. 8. List the names, ages, and relationships of all the persons who are living or residing with you at your present address; state the address and the employers, if any, of those persons who are not children below the age of 18 years. 9. Identify your educational background from the date of completion of your last grade in secondary school through college or postgraduate education, including the name and location of schools attended, the dates during which you attended, and the year and specification of any degree, certificate or diploma. 10. Please identify a chronology of your employment for the past the last five years, and list the names of all employers, the nature and duties of your employment, the location and the basis of your wage per hour, month or year, and the average of your monthly income for the specified period. 11. Please identify the name, address, location and type of health care providers which have been seen by you for any purpose, including diagnostic, treatment, consultation or examination, during the past five years, including, but not limited to medical, psychological, psychiatric, dental, or other treatment or counseling professional. Identify the reasons for which you saw the provider. 12. Please identify the name, address, location and type of health care providers which have been seen by the children for any purpose, including diagnostic, treatment, consultation or examination, during the past five years, including, but not limited to medical, psychological, psychiatric, dental, or other treatment or counseling professional. Identify the reasons for which you saw the provider. WITNESSES 13. For each person with knowledge of any facts which may be relevant to this case, identify their names, addresses, and telephone numbers, with the nature of the facts which are known to each person. 14. For each person with knowledge of any facts which may be relevant to this case, identify their names, addresses, and telephone numbers, with the nature of the facts which are known to each person. The knowledge is requested regardless of its admissibility into evidence or whether the person you identify has personal knowledge of the fact asserted. This relevant knowledge includes specific reference to any of the topics which are listed in this question of the interrogatories. 1. Fault by either party in the breakup of the marriage. 2. Relevant conduct by either party as it contributes to the breakup. 3. Knowledge which refers to the nature of the property which is being divided in this proceeding.
4. Knowledge which refers to any business operation of either member of the community. 5. Knowledge which relates to any matters of the financial debts of the parties. 6. Knowledge tending to indicate whether a party was wronged during the divorce and might be due a disproportionate division of the property of the community. 7. Knowledge of facts that any property is owned free and clearly of any possible claim of the other party. 8. Knowledge of facts tending to prove the existence of separate property. 9. Knowledge of facts tending to prove whether either party has broken any fiduciary responsibilities to the other party. 10. Conservatorship of the children. 15. With respect to any person identified in W2, please identify any document or tangible thing in the possession of that person which tends to provide confirmation of the facts which you believe to be in the knowledge of that person and which is relevant to the knowledge asserted by your answer. The tangible things should refer to items which are in the possession, custody or control of that person. Please explain why the tangible thing is relevant to the subject of the knowledge which is asserted by your answer. 16. With respect to any expert witness testimony, please identify the name, address, and telephone number of any person who may be called with reference to any of the issues which may arise in this cause and answer the following information regarding each such person: a. Identification of the subject matter of the expert's testimony, including impressions and opinions of the expert. b. Identify the facts known to each of the experts that may form the basis of their conclusions, impressions or opinions. c. Identify all of the documents, reports, or other tangible forms of any nature including all drawings, photographs, models, or exhibits, which have been used by the expert, prepared by the expert or furnished to another in any anticipation of the expert's testimony at trial or otherwise, specifically including the results of any tests utilized by that expert in reaching the conclusions, opinions or testimony. 17. With respect to any expert witness testimony, please identify the name, address, and telephone number of any person who may be consulted, but not expected to testify, reference to any of the issues which may arise in this cause and answer the following information regarding each such person:
a. Identification of the subject matter of the expert's testimony, including impressions and opinions of the expert. b. Identify the facts known to each of the experts that may form the basis of their conclusions, mental impressions or opinions. c. Identify all of the documents, reports, or other tangible forms of any nature including all drawings, photographs, models, or exhibits, which have been used by the expert, prepared by the expert or furnished to another in any anticipation of the expert's testimony at trial or otherwise, specifically including the results of any tests utilized by that expert in reaching the conclusions, opinions or testimony. 19. State the identity of all the persons who might be called to testify as an expert witness at trial, including any professionals. Identify the general basis of their testimony and list their names, telephone numbers and addresses. 20. Identify the names, addresses and telephone numbers, including identification of their agency or other employing entity, of those persons who were engaged by you in any investigative capacity in this cause. State the reason for their employment, the nature of the investigative topic and the facts which have become known or investigated which form the basis of this person's employment. If there has been any written report or other documentation including audio, video, photographic, or electronic rendition of any fact or observance, please identify if and produce a copy of such tangible evidence. EVIDENCE 21. Are there any graphic or electronic records in existence that relate in any way to the subject matter of the following, whether they are computer-generated or stored, or depicted by any drawing, chart, graphic design, photograph or tape recording of any kind: 1. Fault by either party in the breakup of the marriage. 2. Relevant conduct by either party as it contributes to the breakup. 3. Knowledge which refers to the nature of the property which is being divided in this proceeding. 4. Knowledge which refers to any business operation of either member of the community. 5. Knowledge which relates to any matters of the financial debts of the parties. 6. Knowledge tending to indicate whether a party was wronged during the divorce and might be due a disproportionate division of the property of the community.
7. Knowledge of facts that any property is owned free and clearly of any possible claim of the other party. 8. Knowledge of facts tending to prove the existence of separate property. 9. Knowledge of facts tending to prove whether either party has broken any fiduciary responsibilities to the other party. 10. Conservatorship of the children. 22. If you have answered yes for any item listed in E1, for each depiction identify the following a. The type of graphic or recording and the subject to which it relates. b. State the names, addresses, and photograph number of any person portrayed or identifiable within the graphic or recording. c. State the name, address and telephone number of the person who produced the graphic or recording by use of the equipment, tool or other device which reduced the subject of the graphic or recording to tangible form. 23. Are you in possession of any recording of any kind, particularly as it may be related to the children subject of this suit, or conversation of whatever nature in which you are recorded, particularly as it may be related to the children subject of this suit? If you do, please identify particulars about the recording include its date of origin, place and the general nature of the conversation. 24. Are you in possession of any letters or written communications of any kind, any recording of any kind, particularly as it may be related to the children subject of this suit, or conversation of whatever nature in which you are recorded, particularly as it may be related to the children subject of this suit? If you do, please identify particulars about the recording including its date of origin, place and the general nature of the conversation. 25. Are you in possession of any videotapes, recording, motion pictures or photographs, particularly as it may be related to the children subject of this suit, or may have any depicting your image, your spouse's image or that of your children or conversation of whatever nature in which you are recorded. If you do, please identify particulars about the recording include its date of origin, place and the general nature of the conversation. 26. Do you have any documents or other tangible things, including videotapes, recordings, motion pictures, photographs, portraits, or other reproductions, made within the past 10 years, containing the voice or image of you, your spouse, or your children? If so, describe each such document or other tangible thing, its present location, and its contents. 27. Do you have any documents or other tangible things, including videotapes, recordings, motion pictures, photographs, portraits, or other reproductions, made within the past ten years,
containing any item of property in which you may assert an interest? If so, describe each such document or other tangible thing, its present location, and its contents. CHILDREN AND CONSERVATORSHIP 28. Which parent should have the primary residential conservatorship of the children who are the subject of this suit, and state your reasons for that opinion. 29. What indications do you have which have permitted you to make any assertion about the feelings of the children subject of this suit, as those feelings may relate toward the other parent in this suit? If there have been any statements or indications to that effect, please identify the time, place and circumstances of such statement, a general depiction of the wording of the statement. 30. If there are assertions that your spouse should be appointed the primary residential conservator of the children, [Child Name1] and [Child Name2], state whether you agree and the basis in facts for your agreeing or disagreeing with such assertions. 31. If you assert that it is in the best interest of the children, [Child Name1] and [Child Name2], that you be appointed sole managing conservator or residential managing conservator, state the basis in facts for your making that assertion. 32. If you assert that you should be appointed a possessory conservator of the children or a party not having primary possession of the children, specify the visitation you believe should be awarded to you. 33. Identify the frequency or regularity which you have in attending any religious services and if you do have such attendance, identify the specific frequency and location of your attendance and the frequency of times at which the children accompany you. 34. Specify the date and length of time for each visitation with the children from the Date to the date of your answers to these interrogatories. 35. Child support will be paid by one party for the use and benefit of the children who are the subject of this suit. The parent awarded the primary residential possession of the children will receive the support. What amount of child support is reasonable for you to pay if you are not the parent with primary residential conservatorship? 36 If you are contending that our spouse be appointed a conservator with possessory rights to the children but should not be awarded statutory standard visitation with the children specify the visitation schedule which you believe to be appropriate and state the facts whereby you believe that your suggested schedule is appropriate. 37. If you are contending that you should be appointed residential managing conservator of the children, what is the amount of child support per month which you contend should be ordered by the Court for your spouse to pay?
38. If you contend or allege physical or mental abuse of the children by their other parent, state the specific nature of the abuse and upon which dates it occurred. Further, state any actions which you took to report the abuse to anyone or to obtain treatment therefor. 39. If there are contentions of changed behavior by the children when the children have been in the possession of their other parent, detail the changes that you have observed and identify specific incidents during which you have made such observations. 40. If you contend that the children should or should not attend public schools until graduation from high school, state the reasons why you make such contention, particularly as to the desirability or undesirability of the children's attendance at private school. If private school is a desirable option by you, state the means whereby you will contribute to such expense. 41. Do you intend and are you willing to purchase and maintain the health insurance necessary to permit the children to be covered in this manner? 42. What percentage of uninsured medical expenses for the children do you contend is fair and equitable for you to incur? State further what percentage you are willing to provide. 43. Are there any graphic depictions or electronic media that contain drawings, charts, photographs, or any electronic, video, or computer recordings in existence that relate to conservatorship issues in this case? For each depiction or recording state its identity and its subject matter; further identify the person whose voice or image is contained in the depiction and identify the person responsible for the recording or production of the depiction. MODIFICATION OF CONSERVATORSHIP 44. You have contended that there is a material and substantial change in circumstances of the children. Identify the circumstances which you believed to have changed, and state the differences between the comparison date and the present. State your contention as to the relevance of such change. 45. State the particular facts known to you which support your contention of materially changed circumstances and state the name, address, and telephone number of each person with possession of a fact which is material to that contention. 46. You contend that the appointment of a new residential managing conservator would be a positive improvement for the circumstances of the children. State the particular facts known to you or reported by other persons that support your contention, and list the names, addresses, and telephone numbers of each person with possession of a fact which is material to that contention. 47. Identify the names, addresses and telephone numbers of all persons who have any personal knowledge relating to any material fact in this suit, whether or not the facts are discoverable, and whether or not such facts are protected by any privilege.
48. If you have reported knowledge by any person in Interrogatory MC4, state if such person has possession, control or custody of any documentary thing which is relevant to the subject matter of the knowledge. If there is any such thing, documentary, written, recorded or otherwise preserved, identify and describe each such thing and state its relevance to the subject matter of this suit. CONDUCT OF PARTIES 50. Have you alleged that you have been physically or mentally abused by the other party in this case? If you make such a contention, stated the dates upon which such abuse may have occurred, the nature of the abuse which you claim and whether you took any actions to treat, report or document such abuse. 51. Have you ever used or taken any illegal drug ingested or taken any illegal (not prescribed) drug since your relationship began with the other party to this suit? If you have done so, identity the date and place of each occurrence during which you utilized the illegal drug and identify the name of the drug, your source to obtain the drug and the source and amount of money used to obtain the drug. 52. There are allegations that you have had sexual intercourse with another person other than your spouse. If that is the case, identify the person, or persons and appropriate addresses and work and home telephone numbers for each such person. Relate the specific incidents in which you did have intercourse as to location, date and time. 53. On any occasion in which adults of the opposite sex have spent the night with you from the Date until these answers are filed, relate the date and occasion for each such incident and include the name, address, work and home telephone numbers of such person. 54. In the past 5 years, identify each and every gift in excess of a $50 value to any person other than your spouse or your two or more children, including the value of the gift, the recipient, that person's name, address, work and home telephone number and identify the date for each such gift and the relationship of the recipient to you. 55. If you have any letters or other written communications between you and your spouse, and your spouse and any other person, identify the following information for each such communication, the date, and occasions for each such memorandum, its subject matter and its relevant value to any matter at issue in this cause. PROPERTY 56. Detail each item of real or personal property, whether tangible or not, that you assert is separate property. State the property's location, the title owner if applicable, and your statement as to its fair market value and any amount of debt which is held against the property.
57. Relate facts supporting your contentions that each item described in Item 56 is separate property and attach, if applicable any documents supporting your statement including, but not limited to deeds, wills, trust documents, checks, titles or other such documents. 58. Detail each item of real or personal property, whether tangible or not, that you assert is community property. State the property's location, the title owner if applicable, and your statement as to its fair market value. 59. For each item in P3, identify the nature of any debt against a particular item of property, and identify the basis for consideration given for the property and the date of each debt. Include the amount of debt for each item, terms or method of repayment and maturity date of any obligation. 60. If you have possessed any interest in any trust during the term of your marriage to, then for each respective trust give: a. the names of each trust and trustee; b. the trustor or persons establishing the trust; c. its date of establishment; d. the place where the trust is physically located; e. the trust value; f. identity of any person having access to the particular trust; g. the trust purposes as stated in the trust documents; h. statement of trust assets, including real and personal property or whether the property is tangible or intangible; i. identify all disbursements made from the trust to you during the marriage; j. list and produce all documents which identify assets of the trust or relate to the trust in any way; and k. in your words describe any interest you have in the trust or entitlement to benefits; l. identify all persons with relevant knowledge of trust matters, including their names, addresses and telephone numbers. 61. Identify all bank accounts or accounts in any financial institution in which you or the other party have an interest or to which you have access, including checking accounts, savings accounts, certificates of deposit or money market accounts. For each such account or institution, list the
name, address and telephone number for the entity or institution holding such account, and give the account number or other identifying mark for any such account. Identify the balance in the account as of the date of your answer, and the exact name or names on any withdrawal card or account title. If applicable, list the balance in each account as of the Date from your spouse. 62. If you are making contentions that you should be reimbursed for funds spent by your separate estate for any debts or real property of your community estate, identify each claim you may have for such recovery and include the amount which you claim to have spent, the source from which you obtained the funds which you claim to be separate and the name, address and telephone number of any person or entity having documentary evidence which supports your contention. 63. If you are making contentions that you should be reimbursed for funds spent by your separate estate for any improvements to real property of your community estate, identify each claim you may have for such recovery and include the amount which you claim to have spent, the source from which you obtained the funds which you claim to be separate and the name, address and telephone number of any person or entity having documentary evidence which supports your contention. 64. If you are making contentions that you should be reimbursed for funds spent by your separate estate for payment of life insurance premiums on any policy which is owned by your community estate, identify each claim you may have for such recovery and include the amount which you claim to have spent, the source from which you obtained the funds which you claim to be separate and the name, address and telephone number of any person or entity having documentary evidence which supports your contention. 65. If you are making contentions that you or the community should be reimbursed for funds lost as a result of your spouse's time, toil or talent expended or lack thereof, identify each claim you may have for such recovery and include the amount which you claim to have lost by yourself or the community, and the name, address and telephone number of any person or entity having documentary evidence which supports your contention. 66. If you are making contentions that you should be reimbursed for funds in favor of your separate estate against your spouse's separate estate, identify each claim you may have for such recovery and include the amount which you claim to have lost by yourself or the community, and the name, address and telephone number of any person or entity having documentary evidence which supports your contention. 67. If there are contentions that either you or the other party owe any member of your family who is related by blood or marriage, identify the circumstances which gave rise to the debt, the person owed money and the amount. Identify the date or dates on each such occasion. 68. If you are seeking an unequal division of the community property and you are a claiming a greater share of the property, by invoking provisions for a disproportionate division or property or the court's use of "equitable devices," state the precise reasons for each such claim, including the amounts which you believe are appropriate to compensate you for such item.
69. If you have not done so in any other document, relate the precise division of property for which you will ask the court. Identify specific assets and any reason for the court's allocation of that asset in your favor. Identify any factual matter which supports your contentions. BUSINESS 70. For any interest which you have held in any business entity, identify its full name and address, its form of organization and the amount of any holding you have had, its present value, the date upon which you acquired the interest and the names and locations of all present offices or places of business. 71. For each leasehold or ownership interest in real estate, identify its specific location, and the nature of the document whereby the interest in held or leased. Provide copies of all documents relating to the ownership or lease of such interest. Give the name and address of others holding an interest in the property and note the recording information of any deed or instrument identifying its record ownership, including page and volume of title recording. If you have any equity in such real estate, describe its extent. 72. Identify any motor vehicle, boat or aircraft owned or operated by the business, and identify its serial or other identifying number, its location and value. Identify any lease on equipment utilized by the business and state the extent of remaining obligations, liabilities or values which may apply to the lease. Identify the purpose of the lease, its primary property, and the location of any property. Identify the name, address, and telephone number of any leasing company, together with any identifying account number. 73. For the past five years, identify the name by which you have been engaged in business, and state the type of business, whether proprietorship, partnership or corporation, and give the dates of operation, the name and address of each business, and the names, addresses and telephone numbers of those persons who have been involved with you in such business. 74. Identify financial institutions with which you have done business, including the maintenance of bank accounts, loans, letters of credit or other financial transactions, and identity the name of the accounts, the names of each person with whom you have dealt at such institution and the address and telephone number of such institution. List any authorizations for signature and the present balance in any account. 75. For any claim by your business against another, identify the claim, its nature, and any instrument evidencing the claim. List the name, address, and telephone number of any person who is indebted to the business. 76. If you or the business in which you are involved hold property, money or any other asset for another, identify the item, and the name, address and telephone number of any person having knowledge or documentation which evidences such arrangement.
77. Identify any accounts receivable held by you or your business and list the names, addresses and telephone number of any person having knowledge or documentation of the item. Describe any action which may have been taken in regard to such account. 78. Identify the conveyance by your business of any property by sale, gift or otherwise, and identify the consideration received and the disposition of any receipt of funds or consideration. Identify any interests retained by the business in such receipt. 79. As to any books or written documentation of any transaction within the business for the past five years, provide copies of such documentation or identify a time and place where the records can be examined. 80. Identify the names, address and telephone number of any accountants employed or utilized by the business for the past five years.