Interrogatories are part of the discovery process of divorce.  They allow you and your soon-to-be/already ex spouse to ask questions that must be responded to in writing under oath.

These answer are then used to determine facts in the case, as well as to question each side if/when the case goes to trial.

I issued these interrogatories myself.  

I went online and found some and assembled others based on what I thought I could prove about Mr. Ex's hidden income.

​​​Something I didn't know at the time was that according to Rule 33 (this is a Federal Law regarding Interrogatories), I was only allowed to serve 25 discreet interrogatories, including the sub-parts.  

This is important because I put all the really specific and valuable interrogatories at the end of the document.  

Interestingly, Mr. ​Ex skipped over the questions he didn't want to answer (#21) claiming that I had exceeded the 25 allowed by law.

But he answered all the interrogatories before and after #21, which was way beyond the 25 allowed.   ​

​Later in our court process, the Judge compelled​ Mr. Ex to answer all the interrogatories, including #21.

​My goal with the interrogatories was to either get Mr. Ex to admit that ABC Gear was his, or else force him to lie and purger himself so as to discredit himself to the Judge.  This is what he ultimately did.  ​

Something I didn't know was that according to Rule 33 (this is a Federal Law regarding Interrogatories), I was only allowed to serve 25 discreet interrogatories, including the subparts.  This is important because I put all the really specific and valuable interrogatories at the end of the document.  Interestingly, Mr. X skipped over the questions he didn't want to answer (#21) claiming that I had exceeded the 25 allowed by law.  He answered all the interrogatories before and after #21, which was way beyond the 25 allowed.   Then he tried to evade the most important one using Rule 33 as his defense.  At that point, the Judge compelled him to answer all the interrogatories.
While people can and do lie on interrogatories, the goal is to catch them with proof.  

Divorce ​Checklist Lessons:

  1. ​​​​Use the interrogatories strategically.
  2. Be aware of the laws governing divorce discovery in your state. Better still hire a good divorce lawyer to manage this for you.  
Judgement for the Dissolution of Marriage

IN THE CIRCUIT COURT OF XXXXXXXXXX COUNTY, XXXXXXXXXX COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

INTERROGATORIES TO PETITIONER

​​Rachel Beck, Pro Se, requests that the following interrogatories be answered by petitioner Mr. ​Ex within 28 days from the date hereof:

1.  State your full name, current address and date of birth.

2. List all employment/independent contractor position held by you during the preceding four years and with regard to each employment state:

(a) The name and address of each employer and/or client;

(b) Your position, job title or description;

(c) If you had an employment contract;

(d) The date on which you commenced your employment and, if applicable, the date and reason for the termination of your employment;

(e) Your current gross and net income per pay period;

(f) Your gross income as shown on the last W-2 tax and wage statement received by you, your social security wages as shown on the last W-2 tax and wage statement received by you, and the amounts of all deductions shown thereon;

(g) All additional benefits or perquisites received from your employment stating the type and value thereof; and

(h) The number of days that you work a year.

3. During the preceding three years, have you had any source of income other than from your employment listed above? If so, with regard to each source of income, state the following:

(a) The source of income, including the type of income and name and address of the source;

(b) The frequency in which you receive income from the source;

(c) The amount of income received by you from the source during the immediately preceding three years; and

(d) The amount of income received by you from the source for each month during the immediately preceding three years.

4. Do you own any interest in real estate? If so, with regard to each such interest state the following:

(a) The size and description of the parcel of real estate, including improvements thereon;

(b) The name, address and interest of each person who has or claims to have an ownership interest in the parcel of real estate;

(c) The date your interest in the parcel of real estate was acquired;

(d) The consideration you transferred or paid for your interest in the parcel of real estate;

(e) Your estimate of the current fair market value of the parcel of real estate and your interest therein; and

(f) The amount of any indebtedness owed on the parcel of real estate and to whom.

5. For the preceding 10 years, list the names and addresses of all assumed names, associations, partnerships, corporations, enterprises or entities in which you have an interest or claim any interest, the nature of your interest or claim of interest therein, the amount of percentage of your interest or claim of interest therein, and an estimate of the value of your interest therein.

6. During the preceding three years, have you had any account or investment in any type of financial institution, individually or with another or in the name of another, including checking accounts, savings accounts, certificates of deposit and money market accounts? If so, with regard to each such account or investment, state the following:

(a) The type of account or investment;

(b) The name and address of the financial institution;

(c) The name and address of each person in whose name the account is held; and

(d) Both the high and the low balance of the account or investment, stating the date of the high balance and the date of the low balance.

7. During the preceding five years, have you sold, transferred, conveyed, encumbered, concealed, damaged or otherwise disposed of any property owned by you:

(a) A description of the property;

(b) The current location of the property;

(c) The purpose or reason for the action taken by you with regard to the property;

(d) The approximate fair market value of the property;

(e) Whether or not there is written evidence of any such transaction; and

(f) A description of the written evidence.

8. During the preceding five years, have you made any gift of cash or property, real or personal, to any person or entity? If so, with regard to each such transaction state:

(a) A description of the gift;

(b) The value of the gift;

(c) The date of the gift;

(d) The name and address of the person or entity receiving the gift;

(e) Whether or not there is written evidence of the existence of a gift; and

(f) A description of the written evidence.

9. During the preceding three years, have you made any loans to any person or entity and, if so, with regard to each such loan state:

(a) A description of the loan;

(b) The value of the loan;

(c) The date of the loan;

(d) The name and address of the person or entity receiving the loan;

(e) Whether or not there is written evidence of the existence of a loan; and

(f) A description of the written evidence.

10. State the year, make and model of each motor or motorized vehicle, boat, motor or mobile home and farm machinery or equipment in which you have had an ownership, estate, interest or claim of interest, whether individually or with another, and with regard to each item state within the past 3 years:

(a) The date the item was acquired;

(b) The consideration paid for the item;

(c) The name and address of each other person who has a right, title, claim or interest in or to the item;

(d) The approximate fair market value of the item; and

(e) The amount of any indebtedness on the item and the name and address of the creditor.

11. Have you purchased or contributed towards the payment for or provided other consideration or improvement with regard to any real estate, motorized vehicle, financial account or securities, or other property, real or personal, on behalf of another person or entity other than your spouse during the preceding three years. If so, with regard to each such transaction state:

(a) The name and address of the person or entity to which you contributed;

(b) The type of contribution made by you;

(c) The type of property to which the contribution was made;

(d) The location of the property to which the contribution was made;

(e) Whether or not there is written evidence of the existence of a loan; and

(f) A description of the written evidence.

12. During the preceding three years, have you been the holder of or had access to any safety deposit boxes? If so, state the following:

(a) The name of the bank or institution where such box is located;

(b) The number of each box;

(c) A description of the contents of each box during the immediately preceding three years and as of the date of the answer; and

(d) The name and address of any joint or co-owners of such safety deposit box or any trustees holding the box for your benefit.

13. During the immediately preceding three years, has any person or entity held cash or property on your behalf? If so, state:

(a) The name and address of the person or entity holding the cash or property; and

(b) The type of cash or property held and the value thereof.

14. During the preceding three years, have you owned any stocks, bonds, securities or other investments, including savings bonds? If so, with regard to each such stock, bond, security or investment state:

(a) A description of the stock, bond, security or investment;

(b) The name and address of the entity issuing the stock, bond, security or investment;

(c) The present value of such stock, bond, security or investment;

(d) The date of acquisition of the stock, bond, security or investment;

(e) The cost of the stock, bond, security or investment;

(f) The name and address of any other owner or owners in such stock, bond, security or investment; and

(g) If applicable, the date sold and the amount realized therefrom.

15. Do you own or have any incidents of ownership in any life, annuity or endowment insurance policies? If so, with regard to each such policy state:

(a) The name of the company;

(b) The number of the policy;

(c) The face value of the policy;

(d) The present value of the policy;

(e) The amount of any loan or encumbrance on the policy;

(f) The date of acquisition of the policy; and

(g) With regard to each policy, the beneficiary or beneficiaries.

16. Do you have any right, title, claim or interest in or to a pension plan, retirement plan or profit sharing plan, including, but not limited to, individual retirement accounts, 401(k) plans and deferred compensation plans? If so, with regard to each such plan state:

(a) The name and address of the entity providing the plan;

(b) The date of your initial participation in the plan; and

(c) The amount of funds currently held on your behalf under the plan.

17. Do you have any outstanding indebtedness or financial obligations, including mortgages, promissory notes, or other oral or written contracts? If so, with regard to each obligation state the following:

(a) The name and address of the creditor;

(b) The form of the obligation;

(c) The date the obligation was initially incurred;

(d) The amount of the original obligation;

(e) The purpose or consideration for which the obligation was incurred;

(f) A description of any security connected with the obligation;

(g) The rate of interest on the obligation;

(h) The present unpaid balance of the obligation;

(i) The dates and amounts of installment payments; and

(j) The date of maturity of the obligation.

18. Are you owed any money or property? If so, state:

(a) The name and address of the debtor;

(b) The form of the obligation;

(c) The date the obligation was initially incurred;

(d) The amount of the original obligation;

(e) The purpose or consideration for which the obligation was incurred;

(f) The description of any security connected with the obligation;

(g) The rate of interest on the obligation;

(h) The present unpaid balance of the obligation;

(i) The dates and amounts of installment payments; and

(j) The date of maturity of the obligation.

19.  Please list all school, lessons, extracurricular activities, childcare, or summer camps that you have contributed to for our Son for the past five years.

(a)The name and address of payee;

(b)Form of payment;

(c)The class, lesson, school, organization for which fees were paid; and

(d)The dates of said activity

20.  How much have you paid to retain your attorney to present date?  In what form was he paid (cash, check, credit card)?  From what account did you pay your attorney?

21. List all jobs and contracts that you worked between January 21, 2014 and February 21, 2014?  Please answer the following for each such job and contract:

(a) Production company name and contact;

(b) The name of the job or contract;

(c) The product or client;

(d) The job or contract number;

(e) The job or contract dates;

(f) Job title and description of the work/services/items;

(g) Pay amount of each job or contract;

(h) Name and/or entity under which you billed for job/contract along with any invoice numbers issued for such pay; and

(i) Name and address of the payroll company or other issuer of payment for the job or contract.

22.      Pursuant to Illinois Supreme Court Rule 213(f), provide the name and address of each witness who will testify at trial and all other information required for each witness.

23.      Pursuant to Supreme Court Rule 213(f)(3), identify the name and address of every controlled expert witness who will testify at trial, identifying

(a)  The subject matter on which the witness will testify;

(b)  The conclusions and opinions of the witness and the bases therefore;

(c)  The qualifications of the witness; and

(d)  Any and all reports prepared by the witness about the case.

24.      Identify any statements, information, and/or documents known to you and requested by any of the foregoing interrogatories which you claim to be work product or subject to any common law or statutory privilege, and with respect to each interrogatory, specify the legal basis for the claim as required by Illinois Supreme Court Rule 201(n).