What is the name of your state? WI
Below I have copied my interrogatories and request for production of documents.....I think I covered all my bases, did I miss anything? is this overkill?
INTERROGATORIES AND REQUEST FOR DOCUMENTS TO JOINT PETITIONER -HUSBAND
The Joint Petitioner- Wife, (Mom), submits the following interrogatories pursuant to
Wis. Stat. 804.08, Rule 804.12, Wisconsin Rules of Civil Procedure, and request that they
be answered under oath.
INSTRUCTIONS:
1. Answer each interrogatory separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection must be stated in lieu of answer. If additional space is required for an answer, additional sheets of paper should be added and numbered separately.
2. An evasive or incomplete answer is deemed to be a failure to answer under Wis. Stat. 804.08, Rule 804.12, Wisconsin Rules of Civil Procedure.
3. You are under a continuing duty to supplement your response with respect to any question directly addressed to the identity and location of persons having knowledge of discoverable matters, and the identity of each person expected to be called as an expert witness at trial and the subject matter in which s/he is expected to testify. Furthermore, you are under a similar duty to correct any incorrect response if and when you later learn that it is incorrect.
4. The following terms are defined as follows for the purpose of these interrogatories: “You” or “Your” means the answering, and any successors or agents acting on the behalf of the answering party; to “identify” a person means to state his/her full name, address, phone number, employer’s name and address.
INTERROGATORIES
INTERROGATORY NO. 1: State your present residence address, home and cell phone numbers, and identify all other persons residing at your residence address.
INTERROGATORY NO. 2: Describe in detail the parenting responsibilities relating to (KIDDO) assumed by each party since the issuance of the most recent court order.
INTERROGATORY NO. 3: State the permanent legal and physical custody arrangements that you believe are in the best interests of the above mentioned minor child, and specifically address the parenting time each parent should have with him during the school year, summer, holidays and on special occasion days. Why do you believe custody should be arranged his way?
INTERROGATORY NO. 4: If you or any member of your household have been seen, tested, evaluated, or treated by any professional person such as a psychiatrist, psychologist, sociologist, social worker, family counselor, or other professional, since the issuance of the most recent court order, identify the professional by name, address and area of practice, state the date of each contact with the professional, explain the purpose of each contact, and indicate whether the contacts are continuing.
INTERROGATORY NO. 5: Identify the name, address and telephone number of all persons you intend to call as witnesses, expert or otherwise, in the hearing regarding modification of physical placement for the above mentioned minor child.
INTERROGATORY NO. 6: For each of the witnesses identified in INTERROGATORY NO
5 state:
a. The substance of the facts and opinions to which the witness is expected to testify;
b. Any assumed facts upon which the witness will rely;
c. A summary of the grounds for each opinion;
d. The contents of any documents upon which the witness will rely.
INTERROGATORY NO. 7: Describe with particularity any medical care or treatment that you or members of your household receive or have received on a regular basis, identify the person rendering such treatment.
INTERROGATORY NO. 8: For each criminal, civil, domestic abuse, incident reported to the police, or any other incident requiring police contact involving you, members of your household or your residence address since the issuance of the most recent court order, state the:
a. The nature and substance of the complaint or incident;
b. The county and state in which the complaint or incident occurred; and
c. The disposition of the complaint or incident.
d. Identify any persons who were witnesses to the incident.
INTERROGATORY NO. 9: If you, or any member of your household have been cited for any offense or charged with any crime since the issuance of the most recent court order, for each matter state the:
a. The date and who was charged or cited;
b. The offense or violation for which you or a member of your household was charged or cited;
c. The date of the alleged offense or violation;
d. The names of any persons who were witnesses to the alleged offense or violation;
e. The disposition or outcome of the charge or citation;
f. The dates of any incarceration or treatment;
g. The county and state in which you or a member of your household were charged or cited; and
h. The name and location of the court in which proceedings occurred as a result of the charge or citation.
INTERROGATORY NO. 10 Describe in detail, your efforts to encourage a loving relationship between the above mentioned minor child and his Mother.
INTERROGATORY NO. 11 Describe in detail, your efforts at co-parenting and communicating with the above mentioned minor child’s Mother.
REQUEST FOR PRODUCTION OF DOCUMENTS
You are hereby requested to produce copies of the following documents to the Petitioner pursuant to Wis Stat 804.09.
REQUEST NO 1: All documents that support or form the factual basis for what you intend to request the court to order.
REQUEST NO 2: All forms, communications, disciplinary notes, counselor notes and other
documents contained in the school file of (KIDDO) since his enrollment in X School District.
REQUEST NO 3: All forms completed by you, or a representative of yours, in the process of obtaining medical care for the above mentioned minor child.
REQUEST NO 4: All forms, doctor’s notes, and other documents contained in the medical files of the above mentioned minor child.
REQUEST NO 5: All forms completed by you, or a representative of yours, in the process of obtaining dental care for the above mentioned minor child.
REQUEST NO 6: All forms, doctor’s notes, and other documents contained in the dental file of the above mentioned minor child.
REQUEST NO 7: All forms completed by you, or a representative of yours, in the process of obtaining psychiatric or psychological care for the above mentioned minor child.
REQUEST NO 8: All forms, doctor’s notes, and other documents contained in the
psychiatric/psychological file of the above mentioned minor child.
REQUEST NO 9: All forms completed by you, or a representative of yours, in the process of enrolling the above mentioned minor child in sports, extracurricular activities, instructional classes or religious instruction.
REQUEST NO 10: All documents upon which you or any witness will rely or base their testimony.
REQUEST NO 11: All police reports, witness statements and other related documents for any incidents in which the police were involved with you, any member of your household or at the place of your residence.
REQUEST NO 12: All police reports, witness statements and other related documents for any incidents where you, or a member of your household has been cited for any offense or charged with any crime.
REQUEST NO 13: All documents including letters, notes, emails or other written communications indicating notification to the above mentioned minor child’s Mother in reference to medical, dental and other care appointments for the above mentioned minor child.
REQUEST NO 14: All documents including letters, notes, emails or other written communications indicating notification to the above mentioned minor child’s Mother in reference to school events or other educational appointments for the above mentioned minor child.
REQUEST NO 15: All documents including letters, notes, emails or other written communications indicating notification to the above mentioned minor child’s Mother in reference to other important events in the day to day life of above mentioned minor child.
REQUEST NO 16: All documents including letters, notes, emails or other written communications exemplifying your efforts, intent, history or willingness to have a productive co-parenting relationship with the above mentioned minor child’s Mother.
Dated: September 8, 2007
Below I have copied my interrogatories and request for production of documents.....I think I covered all my bases, did I miss anything? is this overkill?
INTERROGATORIES AND REQUEST FOR DOCUMENTS TO JOINT PETITIONER -HUSBAND
The Joint Petitioner- Wife, (Mom), submits the following interrogatories pursuant to
Wis. Stat. 804.08, Rule 804.12, Wisconsin Rules of Civil Procedure, and request that they
be answered under oath.
INSTRUCTIONS:
1. Answer each interrogatory separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection must be stated in lieu of answer. If additional space is required for an answer, additional sheets of paper should be added and numbered separately.
2. An evasive or incomplete answer is deemed to be a failure to answer under Wis. Stat. 804.08, Rule 804.12, Wisconsin Rules of Civil Procedure.
3. You are under a continuing duty to supplement your response with respect to any question directly addressed to the identity and location of persons having knowledge of discoverable matters, and the identity of each person expected to be called as an expert witness at trial and the subject matter in which s/he is expected to testify. Furthermore, you are under a similar duty to correct any incorrect response if and when you later learn that it is incorrect.
4. The following terms are defined as follows for the purpose of these interrogatories: “You” or “Your” means the answering, and any successors or agents acting on the behalf of the answering party; to “identify” a person means to state his/her full name, address, phone number, employer’s name and address.
INTERROGATORIES
INTERROGATORY NO. 1: State your present residence address, home and cell phone numbers, and identify all other persons residing at your residence address.
INTERROGATORY NO. 2: Describe in detail the parenting responsibilities relating to (KIDDO) assumed by each party since the issuance of the most recent court order.
INTERROGATORY NO. 3: State the permanent legal and physical custody arrangements that you believe are in the best interests of the above mentioned minor child, and specifically address the parenting time each parent should have with him during the school year, summer, holidays and on special occasion days. Why do you believe custody should be arranged his way?
INTERROGATORY NO. 4: If you or any member of your household have been seen, tested, evaluated, or treated by any professional person such as a psychiatrist, psychologist, sociologist, social worker, family counselor, or other professional, since the issuance of the most recent court order, identify the professional by name, address and area of practice, state the date of each contact with the professional, explain the purpose of each contact, and indicate whether the contacts are continuing.
INTERROGATORY NO. 5: Identify the name, address and telephone number of all persons you intend to call as witnesses, expert or otherwise, in the hearing regarding modification of physical placement for the above mentioned minor child.
INTERROGATORY NO. 6: For each of the witnesses identified in INTERROGATORY NO
5 state:
a. The substance of the facts and opinions to which the witness is expected to testify;
b. Any assumed facts upon which the witness will rely;
c. A summary of the grounds for each opinion;
d. The contents of any documents upon which the witness will rely.
INTERROGATORY NO. 7: Describe with particularity any medical care or treatment that you or members of your household receive or have received on a regular basis, identify the person rendering such treatment.
INTERROGATORY NO. 8: For each criminal, civil, domestic abuse, incident reported to the police, or any other incident requiring police contact involving you, members of your household or your residence address since the issuance of the most recent court order, state the:
a. The nature and substance of the complaint or incident;
b. The county and state in which the complaint or incident occurred; and
c. The disposition of the complaint or incident.
d. Identify any persons who were witnesses to the incident.
INTERROGATORY NO. 9: If you, or any member of your household have been cited for any offense or charged with any crime since the issuance of the most recent court order, for each matter state the:
a. The date and who was charged or cited;
b. The offense or violation for which you or a member of your household was charged or cited;
c. The date of the alleged offense or violation;
d. The names of any persons who were witnesses to the alleged offense or violation;
e. The disposition or outcome of the charge or citation;
f. The dates of any incarceration or treatment;
g. The county and state in which you or a member of your household were charged or cited; and
h. The name and location of the court in which proceedings occurred as a result of the charge or citation.
INTERROGATORY NO. 10 Describe in detail, your efforts to encourage a loving relationship between the above mentioned minor child and his Mother.
INTERROGATORY NO. 11 Describe in detail, your efforts at co-parenting and communicating with the above mentioned minor child’s Mother.
REQUEST FOR PRODUCTION OF DOCUMENTS
You are hereby requested to produce copies of the following documents to the Petitioner pursuant to Wis Stat 804.09.
REQUEST NO 1: All documents that support or form the factual basis for what you intend to request the court to order.
REQUEST NO 2: All forms, communications, disciplinary notes, counselor notes and other
documents contained in the school file of (KIDDO) since his enrollment in X School District.
REQUEST NO 3: All forms completed by you, or a representative of yours, in the process of obtaining medical care for the above mentioned minor child.
REQUEST NO 4: All forms, doctor’s notes, and other documents contained in the medical files of the above mentioned minor child.
REQUEST NO 5: All forms completed by you, or a representative of yours, in the process of obtaining dental care for the above mentioned minor child.
REQUEST NO 6: All forms, doctor’s notes, and other documents contained in the dental file of the above mentioned minor child.
REQUEST NO 7: All forms completed by you, or a representative of yours, in the process of obtaining psychiatric or psychological care for the above mentioned minor child.
REQUEST NO 8: All forms, doctor’s notes, and other documents contained in the
psychiatric/psychological file of the above mentioned minor child.
REQUEST NO 9: All forms completed by you, or a representative of yours, in the process of enrolling the above mentioned minor child in sports, extracurricular activities, instructional classes or religious instruction.
REQUEST NO 10: All documents upon which you or any witness will rely or base their testimony.
REQUEST NO 11: All police reports, witness statements and other related documents for any incidents in which the police were involved with you, any member of your household or at the place of your residence.
REQUEST NO 12: All police reports, witness statements and other related documents for any incidents where you, or a member of your household has been cited for any offense or charged with any crime.
REQUEST NO 13: All documents including letters, notes, emails or other written communications indicating notification to the above mentioned minor child’s Mother in reference to medical, dental and other care appointments for the above mentioned minor child.
REQUEST NO 14: All documents including letters, notes, emails or other written communications indicating notification to the above mentioned minor child’s Mother in reference to school events or other educational appointments for the above mentioned minor child.
REQUEST NO 15: All documents including letters, notes, emails or other written communications indicating notification to the above mentioned minor child’s Mother in reference to other important events in the day to day life of above mentioned minor child.
REQUEST NO 16: All documents including letters, notes, emails or other written communications exemplifying your efforts, intent, history or willingness to have a productive co-parenting relationship with the above mentioned minor child’s Mother.
Dated: September 8, 2007
