How to Draft Interrogatories About Marriages and Children?

Question from Bey, How to Draft Interrogatories About Marriages and Children?

Answer from AI:

Interrogatory No. 1 – Marital History

Please state the total number of times the responding party has been married, and for each marriage provide the following information:

1. Full name of the spouse (including any maiden or prior‑marriage names).
2. Date of marriage (month, day, year).
3. Place of marriage (city, state, and country).
4. Date of termination of the marriage, if applicable (including divorce, annulment, or death).
5. Grounds for divorce or annulment, if any (e.g., irreconcilable differences, fault‑based grounds).
6. Current marital status with respect to that spouse (e.g., still married, divorced, widowed).
7. Personal circumstances surrounding each marriage and its termination, including:
   • Any legal agreements (prenuptial, postnuptial, separation agreements).
   • Whether community‑property or equitable‑distribution issues were raised.
   • Any pending or resolved litigation related to the marriage (e.g., property disputes, spousal support).

If the responding party was never married, state “None” and attach a declaration to that effect.

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Interrogatory No. 2 – Children

Please identify each child of the responding party and provide the following details for each child:

1. Full legal name (including any aliases).
2. Date of birth (month, day, year).
3. Current age.
4. Current residence (city, state, and whether the child lives with the responding party, the other parent, or a third party).
5. Living arrangements (e.g., primary custodial parent, shared custody, foster care).
6. Personal circumstances that may be relevant, including:
   • Health status (any disabilities, chronic conditions, or special medical needs).
   • Educational status (school grade, special education services, college enrollment).
   • Financial dependency (whether the child is claimed as a dependent on the responding party’s tax returns for any year).
   • Existing court orders or agreements concerning custody, visitation, child support, or guardianship.

If the responding party has no children, state “None” and attach a declaration to that effect.

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Instructions for Responding Party

1. Answer each interrogatory fully and separately; do not combine answers to different interrogatories.
2. Provide all information to the best of your knowledge. If any portion of a request is unknown, state “Unknown” and describe the steps taken to obtain the information.
3. Attach any supporting documents (e.g., marriage certificates, divorce decrees, birth certificates, custody orders) that verify the answers.
4. Verify and sign the responses under oath in accordance with the applicable rules of civil procedure.

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Disclaimer

The foregoing interrogatories are provided for general informational purposes and may need to be adapted to the specific procedural rules of the court in which the case is pending (e.g., Federal Rule of Civil Procedure 33 or the corresponding state rule). For tailored drafting and to ensure compliance with local filing requirements, you should consult a licensed attorney.

Helpful References

• Federal Rule of Civil Procedure 33 – Governs the use of interrogatories in federal courts.
• State civil‑procedure rules – Each state has its own rules; see the National Conference of State Legislatures’ summary of state civil‑procedure rules for guidance.