• FreeAdvice has a new Terms of Service and Privacy Policy, effective May 25, 2018.
    By continuing to use this site, you are consenting to our Terms of Service and use of cookies.

Proofreading needed PLEASE!

Accident - Bankruptcy - Criminal Law / DUI - Business - Consumer - Employment - Family - Immigration - Real Estate - Tax - Traffic - Wills   Please click a topic or scroll down for more.

CJane

Senior Member
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.

I would change 'party' to 'parent' and include a question relating to 'other members of your household' that is similar.

And a follow-up question something like "Please describe, in detail, with supporting documentation your efforts to support and encourage Mother's involvement in these activities."

I know it seems a repetitious question, but since I think of interrogatories as a written deposition, I'd ask the same question a couple of different ways. Especially the important questions. I know when I've been deposed, I've been asked the same questions a billion ways over 8 or 9 hours... it's like the SAT if the SAT was an entrance exam for Hell.
 


Zephyr

Senior Member
I would change 'party' to 'parent' and include a question relating to 'other members of your household' that is similar.

And a follow-up question something like "Please describe, in detail, with supporting documentation your efforts to support and encourage Mother's involvement in these activities."

I know it seems a repetitious question, but since I think of interrogatories as a written deposition, I'd ask the same question a couple of different ways. Especially the important questions. I know when I've been deposed, I've been asked the same questions a billion ways over 8 or 9 hours... it's like the SAT if the SAT was an entrance exam for Hell.

I asked specifically what Skeletors role in KIDDOs life is regarding parenting duties assigned by dad, discipline, education, extracurriculars etc

the second one I already added previously


it's my understanding that I only have 25 questions to ask, I'm now up to 19, so well see if anything can be repeated with different wording or if there are items I haven't even addressed yet
 

CJane

Senior Member
I asked specifically what Skeletors role in KIDDOs life is regarding parenting duties assigned by dad, discipline, education, extracurriculars etc

the second one I already added previously


it's my understanding that I only have 25 questions to ask, I'm now up to 19, so well see if anything can be repeated with different wording or if there are items I haven't even addressed yet

Ohhh... didn't realize it was so limited. Durn it.

I'll read through again...
 

Zephyr

Senior Member
In respect for CJane's need for me to keep all my threads together :p;) I am resurrecting this one....I received ex's answers to interrogatories, and have some question's. I have copied part of my original thread so that I may update the info- ex's answers in bold


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.

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.

The parties have followed the current court order and Father has the child insured under his health insurance policy No mention of the fact that I also have the child insured, and I don't like this evasive answer

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?

It is in the best interests of the child to be primarily placed with his father and to be placed with his mother every other weekend on a year round basis. It is in the best interests of the child to divide equally the holiday and vacation time he spends with each parent by alternating which parent has placement on Christmas and Thanksgiving and by alternating or dividing in half the Christmas break holiday. This schedule is in the best interests of the child because it is consistent with the child's wishes, it promotes stability for the child and it allows the child to in close proximity to the majority of his relatives. I thought we weren't supposed to ask kids what they want

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.

Child sees "school guidance counselor"

#3 (messed up on the cut/paste)Describe the role in the life of the child you think his Mother should play. What should her level of involvement be in all aspects of the child's life. Why?

The mother should cooperate with the father to promote the best interests of the minor child. The mother should cooperate in transporting the child to activities and should support the child's interests. The mother should be a consistent factor in the child's life and maintain a stable residence. The mother should cooperate with the father during those times that he is placed with the mother; as the mother expects the father to do the same. Am I wrong in reading that he basically just wants me to do whatever he says but not really be a "parent"? I don't know maybe I am being oversensitive


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.

Ex, School Employees and any other witnesses that would support the father's position or rebut an allegation of the mother


INTERROGATORY NO. 6: For each of the witnesses identified in INTERROGATORY NO
6 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.

All witnesses will testify that KIDDO is adjusting well to the placement schedule and that he is excelling at school both academically and socially All B's, 1 C, and 1 A- does not say excelling to me

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.


For this one he neglected to list where Skeletor got into a huge fight with the neighbor and it turned physical to the point the neighbor got in her car and drove into Skeletor



INTERROGATORY NO. 10 Describe in detail, your efforts to encourage a loving relationship between the above mentioned minor child and his Mother.

I encourage telephone communication between KIDDO and his mother on a daily basis, always drop KIDDO off on time and abide by the court order.

INTERROGATORY NO. 11 Describe in detail, your efforts at co-parenting and communicating with the above mentioned minor child_s Mother.

Previous attempts to co-parent via telephone have not been successful. Email is now being utilized as the form of communication between the mother and I.


He also flat out lied in the interrogatories about how often he allows KIDDO to spend time with my mother

REQUEST FOR PRODUCTION OF DOCUMENTS




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.

No dental care, no dental problems.
soooooo no teeth cleaning in 3 years?!!?!?!? is that neglect?

Dated: September 8, 2007

He provided NO documents except for email conversations between he and I, duh I already have those....everything else said see doctor office, or see school office or see sheriff's dept**************..can he do that?

he is the custodial parent, he has easy access to all of this information, I am three hours away.....should I file motion to compel?

I will have more questions later I'm sure....
 
Last edited:

CJane

Senior Member
In respect for CJane's need for me to keep all my threads together :p;) I am resurrecting this one....I received ex's answers to interrogatories, and have some question's. I have copied part of my original thread so that I may update the info- ex's answers in bold


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.

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.

The parties have followed the current court order and Father has the child insured under his health insurance policy No mention of the fact that I also have the child insured, and I don't like this evasive answer

Well, this is a mod based on contempt right? So obviously the parties have NOT followed the 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?

It is in the best interests of the child to be primarily placed with his father and to be placed with his mother every other weekend on a year round basis. It is in the best interests of the child to divide equally the holiday and vacation time he spends with each parent by alternating which parent has placement on Christmas and Thanksgiving and by alternating or dividing in half the Christmas break holiday. This schedule is in the best interests of the child because it is consistent with the child's wishes, it promotes stability for the child and it allows the child to in close proximity to the majority of his relatives. I thought we weren't supposed to ask kids what they want

IMO this stance does NOT promote 'frequent, meaningful and continuing contact with the other parent. What's WI thought on this?

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.

Child sees "school guidance counselor"
Well, this is an evasive answer in that you asked for names and such and I'm betting his/her name is Mr. School Guidance Counselor.

#3 (messed up on the cut/paste)Describe the role in the life of the child you think his Mother should play. What should her level of involvement be in all aspects of the child's life. Why?

The mother should cooperate with the father to promote the best interests of the minor child. The mother should cooperate in transporting the child to activities and should support the child's interests. The mother should be a consistent factor in the child's life and maintain a stable residence. The mother should cooperate with the father during those times that he is placed with the mother; as the mother expects the father to do the same. Am I wrong in reading that he basically just wants me to do whatever he says but not really be a "parent"? I don't know maybe I am being oversensitive

The 'stable residence' is a dig at you... the rest I can't answer to because I would think it was him saying "I want mom to follow my rules"... but I'm kinda sensitive to that too.


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.

Ex, School Employees and any other witnesses that would support the father's position or rebut an allegation of the mother

Again... evasive answer.

INTERROGATORY NO. 6: For each of the witnesses identified in INTERROGATORY NO
6 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.

All witnesses will testify that KIDDO is adjusting well to the placement schedule and that he is excelling at school both academically and socially All B's, 1 C, and 1 A- does not say excelling to me

I don't think that's excelling either. I'm betting he's capable of much better, knowing his mom.

QUESTION: If he doesn't produce the documents requested in D is he allowed to submit them as evidence?

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.


For this one he neglected to list where Skeletor got into a huge fight with the neighbor and it turned physical to the point the neighbor got in her car and drove into Skeletor

Can you get the police report?


INTERROGATORY NO. 10 Describe in detail, your efforts to encourage a loving relationship between the above mentioned minor child and his Mother.

I encourage telephone communication between KIDDO and his mother on a daily basis, always drop KIDDO off on time and abide by the court order.

So he's basically saying that he'll do no MORE than actually required to do. And we all know he isn't really even doing that.

INTERROGATORY NO. 11 Describe in detail, your efforts at co-parenting and communicating with the above mentioned minor child_s Mother.

Previous attempts to co-parent via telephone have not been successful. Email is now being utilized as the form of communication between the mother and I.

Wasn't email YOUR idea and fought by him?

He also flat out lied in the interrogatories about how often he allows KIDDO to spend time with my mother

Get her booty on the stand.


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.

No dental care, no dental problems.
soooooo no teeth cleaning in 3 years?!!?!?!? is that neglect?

Maybe... could definitely be argued, anyway...

Dental neglect, as defined by the American Academy of Pediatric Dentistry,33 is "the willful failure of parent or guardian to seek and follow through with treatment necessary to ensure a level of oral health essential for adequate function and freedom from pain and infection." Dental caries, periodontal diseases, and other oral conditions, if left untreated, can lead to pain, infection, and loss of function. These undesirable outcomes can adversely affect learning, communication, nutrition, and other activities necessary for normal growth and development.33

Dated: September 8, 2007

He provided NO documents except for email conversations between he and I, duh I already have those....everything else said see doctor office, or see school office or see sheriff's dept**************..can he do that?

he is the custodial parent, he has easy access to all of this information, I am three hours away.....should I file motion to compel?

I will have more questions later I'm sure....

I think you should file a motion to compel. Absolutely.

Find the rules of discovery/evidence.
 

Zephyr

Senior Member
mod is based on on best interests of the child, COC- Skeletor's continuing criminal behavior, unclear portions of the court order, lack of co-parenting, etc.


Wisconsin has the position of maximizing the amount of time that a child spends with each parent

he put the name of the counselor, I editted it out, but he never informed me that kiddo was seeing him regularly

"QUESTION: If he doesn't produce the documents requested in D is he allowed to submit them as evidence?"


I don't know, as rebuttle, I think so but not as regular evidence


Yes email was my idea, and I have the emails to prove it....


yes I can get all the documents I requested myself, now that I actually know the doctors name, I was just hoping I could make him do it, he is in the town where all the documents are, as custodial parent- he should have almost all of the school related ones in his own files anyway..., I was hoping I could make him do it all as I am 3 hours away and would have to take a day of work to go get them all...but ya gotta do what you gotta do
 

CJane

Senior Member
yes I can get all the documents I requested myself, now that I actually know the doctors name, I was just hoping I could make him do it, he is in the town where all the documents are, as custodial parent- he should have almost all of the school related ones in his own files anyway..., I was hoping I could make him do it all as I am 3 hours away and would have to take a day of work to go get them all...but ya gotta do what you gotta do

No you don't.

Print the letter from delta bravo. Mail it out to each person, including a self addressed/postage paid envelope or fed ex pack for them to put the documents in when sending them back.

Call ahead to warn them that the request is coming.

Some docs/schools will let you fax permission and then mail the stuff to you.

You can get police reports/docket entries on Skeletor, yes?
 

Zephyr

Senior Member
No you don't.

Print the letter from delta bravo. Mail it out to each person, including a self addressed/postage paid envelope or fed ex pack for them to put the documents in when sending them back.

Call ahead to warn them that the request is coming.

Some docs/schools will let you fax permission and then mail the stuff to you.

You can get police reports/docket entries on Skeletor, yes?

true, although I am worried about not being there in person, when I have called or faxed requests before (to the school) that's when I have only gotten a copy of the emergency contact sheet....I kinda wanna watch them pull the folder out so I can "put my eyes on it" and see if I am getting everything..kwim?

yes I can get police reports, the docket stuff I can get on line, the police reports I have to go there....
 

CJane

Senior Member
true, although I am worried about not being there in person, when I have called or faxed requests before (to the school) that's when I have only gotten a copy of the emergency contact sheet....I kinda wanna watch them pull the folder out so I can "put my eyes on it" and see if I am getting everything..kwim?

yes I can get police reports, the docket stuff I can get on line, the police reports I have to go there....

Hey, if you have to go there anyway... call and make an appointment with the school counselor to discuss your son's progress. ;)
 

Zephyr

Senior Member
Question (told you there would be more!)...

can I through motion or by verbal request at the hearing request a word or incident that occured prior to the last court order not be used as it is unduly prejudicial or inflammatory given the court has, by virtue of the last court order (joint legal and physical custody) determined me to be a fit and proper parent?
 

Find the Right Lawyer for Your Legal Issue!

Fast, Free, and Confidential
Top