<p>Notes for use of form interrogatories:</p><p>These instructions, definitions, and the first 25 interrogatories are taken from the Maryland Rules Form Interrogatories; the others are designed to get more detailed information. There are more than 30 interrogatories here; only some will be relevant to the case at hand. (Formatted for red line paper.)</p><p>______, * IN THE PLAINTIFF * CIRCUIT COURT VS. * FOR ______, * ______COUNTY DEFENDANT * CASE NO: ______* * * * *</p><p>* *</p><p>* * </p><p>* * [Party]’S INTERROGATORIES TO [Party] </p><p>Instructions </p><p>Pursuant to Rule 2-421, you are required to answer the following interrogatories within 30 days or within the time otherwise required by court order or by the Maryland Rules:</p><p> a) In accordance with Rule 2-421(b), your response shall set forth the interrogatory, and shall set forth the answer to the interrogatory "separately and fully in writing under oath" or "shall state fully the grounds for refusal to answer any interrogatory." The response shall be signed by you. (Standard Instruction (a).)</p><p> b) Also in accordance with Rule 2-421(b), your answers "shall include all information available" to you "directly or through agents, representatives, or attorneys." (Standard Instruction (b).)</p><p> c) Pursuant to Rule 2-401(e), these interrogatories are continuing. If you obtain further material information before trial you are required to supplement your answers promptly. (Standard Instruction (c).)</p><p> d) If pursuant to Rule 2-421(c), if you elect to specify and produce business records in answer to any interrogatory, your specification shall be in sufficient detail to enable the</p><p>[Party’s] Interrogatories to [Party] Page 1 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 interrogating party to locate and identify the records from which the answer may be ascertained. (Standard Instruction (d).)</p><p> e) If you perceive any ambiguities in a question, instruction, or definition, set forth the matter deemed ambiguous and the construction used in answering. (Standard Instruction (e).)</p><p>Definitions </p><p>In these Interrogatories, the following definitions apply: a) Document includes a writing, drawing, graph, chart, photograph, recording, and other data compilation from which information can be obtained, translated, if necessary, through detection devices into reasonably usable form. (Standard General Definition (a).) b) Identify, identity, or identification, (1) when used in reference to a natural person, means that person’s full name, last known address, home and business telephone numbers, and present occupation or business affiliation; (2) when used in reference to a person other than a natural person, includes a description of the nature of the person (that is, whether it is a corporation, partnership, etc. under the definition of person below), and the person’s last known address, telephone number, and principal place of business; (3) when used in reference to any person after the person has been properly identified previously means the person’s name; and (4) when used in reference to a document, requires you to state the date, the author (or, if different, the signer or signers), the addressee, and the type of document (e.g. letter, memorandum, telegram, chart, etc.) or to attach an accurate copy of the document to your answer, appropriately labeled to correspond to the interrogatory. (Standard General Definition (b).) c) Person includes an individual, general or limited partnership, joint stock company, unincorporated association or society, municipal or other corporation, incorporated association, limited liability partnership, limited liability company, the State, an agency or political subdivision of the State, a court, and any other governmental entity. (Standard General Definition (c).) d) Employer means any person that has compensated, or is obligated to compensate, you for services. (Standard Domestic Relations Definition (a).) e) Fringe benefits include: (1) contributions made by your employer to health insurance, life insurance, disability insurance, pension, profit sharing, or retirement plans; and (2) employer reimbursements or payments that reduce your personal living expenses such as use of a company car, expense accounts, and housing. (Standard Domestic Relations Definition (b).) f) Property includes:</p><p>[Party’s] Interrogatories to [Party] Page 2 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 1) accounts in any financial institution or brokerage, including certificates of deposit;</p><p>2) cash;</p><p>3) debts owed to you, secured or unsecured, actual or contingent;</p><p>4) home furnishings, jewelry, furs, stamp or coin collections, antiques, and works of art;</p><p>5) intellectual property, including patents, royalties, and copyrights;</p><p>6) interests in any entity, including partnerships, joint ventures, and corporations;</p><p>7) interests in improved or unimproved real property, including leaseholds, condominiums, and time share interests;</p><p>8) life insurance and annuities;</p><p>9) military or federal retirement benefits;</p><p>10) pension plans, profit sharing plans, individual retirement accounts, and retirement plans;</p><p>11) securities, including stocks, bonds, mutual funds, United States Government obligations, options, and debentures;</p><p>12) vehicles, boats, aircraft, equipment, machinery, crops, livestock, and poultry;</p><p>13) workers' compensation claims and tort or contract claims against another; and</p><p>14) any other interest or asset. (Standard Domestic Relations Definition (c).) g) Wages include hourly wages, salary, bonuses, tips, incentive awards, fees, commissions, self-employment income, and overtime pay. (Standard Domestic Relations Definition (d).)</p><p>Interrogatories </p><p>1. Identify yourself and all individuals with whom you reside. For each individual other than</p><p> yourself, state that individual's age, relationship to you, and marital status. State your own</p><p> birth date and social security number. (Standard Domestic Relations Interrogatory No. 1.)</p><p>[Party’s] Interrogatories to [Party] Page 3 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 2. Describe your educational background. Include in your answer the highest grade you</p><p> completed; the name and date of any degree, diploma, or certificate you received, and the</p><p> name of the institution conferring the degree, diploma, or certificate; and any specialized</p><p> training you have received. (Standard Domestic Relations Interrogatory No. 2.)</p><p>3. If you are currently employed in any capacity, identify each current employer and, for each</p><p> employment, state: (a) your job title, (b) your duties, (c) the number of hours in your</p><p> average work week, (d) your regular pay period, (e) your gross wages per pay period, and</p><p>(f) the deductions per pay period made by your employer from your wages. If overtime</p><p> work was available to you during the past twelve months, state: (a) the number of overtime</p><p> hours you worked during the twelve months and your rate of pay for those hours and (b) the</p><p> number of overtime hours that were available to you during the twelve months but that you</p><p> did not work and the rate of pay you would have received if you had worked those hours.</p><p>(Standard Domestic Relations Interrogatory No. 3.)</p><p>4. Describe the nature and amount of any fringe benefits that you receive as a result of your</p><p> employment. (Standard Domestic Relations Interrogatory No. 4.)</p><p>5. If you are unemployed, describe your efforts to obtain employment since you became</p><p> unemployed, identify each prospective employer and employment agency you have</p><p> contacted while seeking employment and state the date of each contact. (Standard Domestic</p><p>Relations Interrogatory No. 5.)</p><p>6. If you claim you are physically or mentally unable to work or your capacity to work is</p><p> limited, state the facts upon which your claim is based and identify all persons with</p><p> personal knowledge of those facts. (Standard Domestic Relations Interrogatory No. 6.)</p><p>[Party’s] Interrogatories to [Party] Page 4 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 7. For each employment that you have had during the past five years other than any current</p><p> employment, identify each employer and for each employment state: (a) the dates of</p><p> employment, (b) your duties, (c) your wages, and (d) your reason for leaving the job. If you</p><p> were unemployed for any period of time, specify the amount and source of any income that</p><p> you received while unemployed. (Standard Domestic Relations Interrogatory No. 7.)</p><p>8. Identify the sources and amounts of all taxable and non-taxable income you received during</p><p> the past five years. (Standard Domestic Relations Interrogatory No. 8.)</p><p>9. Identify the sources and amounts of any other monies and credit(s) you received during the</p><p> past five years with an aggregate value in excess of $250.00 in any one year, including gifts,</p><p> loans from others, loans repaid to you by others, sales of assets, and untaxed distributions.</p><p>(Standard Domestic Relations Interrogatory No. 9.)</p><p>10. List each item of property in which you have any interest. For each item listed, state how it</p><p> is titled, its value, the amount of any present lien or mortgage on the property, the date of</p><p> acquisition of the property, and the identity of any other person with an interest in the</p><p> property. If you claim that any property listed is not marital property, state the facts upon</p><p> which you base your claim, including all sources of funds used for the acquisition of the</p><p> property and identify all persons with personal knowledge of those facts. (Standard</p><p>Domestic Relations Interrogatory No. 10.)</p><p>11. If you, either alone or with anyone other than your spouse, transferred property during the</p><p> last five years of your marriage with a value in excess of $250.00 to any person other than</p><p> your spouse without receiving full consideration in money or money's worth for the</p><p> property transferred, identify each person to whom a transfer was made and the property</p><p>[Party’s] Interrogatories to [Party] Page 5 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 transferred, giving the date and method of transfer and the value of the property at the time</p><p> of transfer. (Standard Domestic Relations Interrogatory No. 11).</p><p>12. If the information contained on your Financial Statement submitted pursuant to MD. RULE 9-</p><p>202 has changed, describe each change. (Standard Domestic Relations Interrogatory No.</p><p>12.)</p><p>13. State by type and amount all support provided by you for your spouse and children since the</p><p> date of your separation. (Standard Domestic Relations Interrogatory No. 13.)</p><p>14. State the date on which you separated from the Plaintiff and describe the circumstances of</p><p> the separation. (Standard Domestic Relations Interrogatory No. 14.)</p><p>15. If you contend that your spouse's conduct was excessively vicious or that your spouse acted</p><p> with extreme cruelty or constructively deserted you, describe your spouse's conduct and</p><p> state the date and nature of any injuries sustained by you and the date, nature, and provider</p><p> of health care services rendered to you. Identify all persons with personal knowledge of</p><p> your spouse's conduct and all persons with knowledge of any injuries you sustained as a</p><p> result of that conduct. (Standard Domestic Relations Interrogatory No. 15.)</p><p>16. State the date on which you and your spouse last had sexual relations with each other.</p><p>(Standard Domestic Relations Interrogatory No. 16.)</p><p>17. If you have had sexual relations with a person other than your spouse during your marriage,</p><p> identify the person(s) with whom you have had sexual relations, state the date of each act</p><p> of sexual relations, and state the location where each act took place. If you refuse to answer</p><p> this interrogatory as framed because the answer would tend to incriminate you, so state and</p><p>[Party’s] Interrogatories to [Party] Page 6 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 answer for the period ending one year prior to the date of your answers. (Standard Domestic</p><p>Relations Interrogatory No. 17.)</p><p>18. If you have had sexual relations with a person other than your spouse during the marriage</p><p> and you contend that your spouse has forgiven or condoned your actions, state the facts</p><p> upon which your contention is based. (Standard Domestic Relations Interrogatory No. 18.)</p><p>19. If you contend that the Plaintiff is unfit to have custody of the children, state the facts upon</p><p> which your contention is based and identify all persons having personal knowledge of</p><p> these facts. If your contention is based on the use of controlled dangerous substances or the</p><p> abuse of alcohol on specific occasions, identify the substance used, the other persons</p><p> present at the time of the use, and the date, time, and place of the use. If your contention is</p><p> based on the repeated use of controlled dangerous substances or the repeated abuse of</p><p> alcohol, identify the substance and all persons with personal knowledge of the repeated use</p><p> or abuse. (Standard Domestic Relations Interrogatory No. 19.)</p><p>20. If you have sought or received treatment or therapy at any time during the past 10 years for</p><p> any physical, mental, or emotional condition, including drug addiction or alcoholism,</p><p> describe the condition and the treatment or therapy provided, state the date or dates of</p><p> treatment or therapy, and identify all persons providing treatment or therapy. (Standard</p><p>Domestic Relations Interrogatory No. 20.)</p><p>21. If you contend that placing the children in your sole, shared, or joint custody will be in their</p><p> best interests, specify the facts and circumstances upon which you rely. (Standard Domestic</p><p>Relations Interrogatory No. 21.)</p><p>[Party’s] Interrogatories to [Party] Page 7 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 22. Describe the child-care plan you intend to follow when your children are with you. Include</p><p> in your answer a description of the place where the children will reside, specifying the</p><p> number of bedrooms, bathrooms, and other rooms, the distance to the schools the children</p><p> will attend, and the identity of all other persons who will be residing in that household.</p><p>Identify all persons who will care for or supervise the children in your absence, state the</p><p> hours during which they will care for them, and the location where the care will be</p><p> provided. (Standard Domestic Relations Interrogatory No. 22.)</p><p>23. Identify each person, other than a person intended to be called as an expert witness at trial,</p><p> having discoverable information that tends to support a position that you have taken or</p><p> intend to take in this action, including any claim for damages, and state the subject matter of</p><p> the information possessed by that person. (Standard General Interrogatory No. 1.)</p><p>24. Identify each person whom you expect to call as an expert witness at trial, state the subject</p><p> matter on which the expert is expected to testify, state the substance of the findings and</p><p> opinions to which the expert is expected to testify and a summary of the grounds for each</p><p> opinion, and attach to your answers any written report made by the expert concerning those</p><p> findings and opinions. (Standard General Interrogatory No. 2.)</p><p>25. If you intend to rely upon any documents or other tangible things to support a position that</p><p> you have taken or intend to take in the action, including any claim for damages, provide a</p><p> brief description, by category and location, of all such documents and other tangible things,</p><p> and identify all persons having possession, custody, or control of them. (Standard General</p><p>Interrogatory No. 3.)</p><p>[Party’s] Interrogatories to [Party] Page 8 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 26. If you have been arrested for or convicted of any crime in the past 10 years, please state</p><p> all details concerning said arrest or conviction, including, but not limited to, the</p><p> jurisdiction and case number, the nature of the crime, the current status of the case, and</p><p> the disposition, if any, of the case.</p><p>27. List separately each bank account, building and loan account or other account of money</p><p> on deposit in which you now have (or in the last three years, have had) any interest, either</p><p> alone or together with others, or in another name, giving the type and number of the</p><p> account, the name and address of the depository, and the names and addresses of any</p><p> other person or persons who have had or now have any interest in the same, specifying</p><p> the nature and extent of that interest, and state the present balance therein.</p><p>28. After each item listed in your answer to the preceding interrogatory, give the date the</p><p> account was opened, the date the account was closed, the balance on deposit as of the date</p><p> of your Answer to these Interrogatories, and the highest and lowest balance during the last</p><p> three years.</p><p>29. Identify all life insurance policies that you now have or have had in the past ten years upon</p><p> your life, and include in your answer: the name of the company; the number of the policy;</p><p> the face value of the policy; the amount of accumulated dividends; whether or not the</p><p> insurance is term or whole; whether there are any loans against any policy; the date any loan</p><p> was incurred; the cash surrender value; the present status of each policy; the beneficiary of</p><p> each policy; and whether or not each policy contains a right to change the beneficiary.</p><p>30. If you have any interest in any type of retirement, pension, profit-sharing, Individual</p><p>Retirement Account, or Keogh plan or fund, state with particularity the nature and extent of</p><p>[Party’s] Interrogatories to [Party] Page 9 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 your interest, including but not limited to the following: the name of the plan or fund; the</p><p> full name and address of the custodian; the full name and address of any employer</p><p> contributing to the plan or fund; the total amount of your contribution to the plan or fund as</p><p> of the date of your answers; the present balance of your interest in the plan or fund; the date</p><p> upon which you are entitled to receive actual benefits from the plan or fund; the amount of</p><p> benefits and the method of payment to you; the amount of any funds available to you at the</p><p> present date; and the method of obtaining funds without retirement.</p><p>31. State the names and addresses of all business entities in which you have any interest. If such</p><p> business entity is a corporation, state for each the number of shares of stock you own; the</p><p> percentage of stock you hold in comparison with all other outstanding stock; the date(s) you</p><p> acquired your stock; your cost and purchase price of the stock; the method by which you</p><p> financed the purchase of the stock; the terms of such financing; the name and address of the</p><p> person or entity which provided the financing; and the name and address of any person who</p><p> may be liable for said financing.</p><p>32. If you are a stockholder in a closely held corporation or professional association, state the</p><p> exact name of said corporation and its place and date of incorporation; the total number of</p><p> its shareholders; the number of shares of stock issued by the corporation; the number of</p><p> shares of stock owned by you; the fiscal year of the corporation; the exact amount of any</p><p> undistributed earnings held by the corporation as of the end of each of the last two fiscal</p><p> years and as of the date of your preparation of this answer.</p><p>33. If you were an officer and/or director of a corporation at any time during the last three years,</p><p> state the name and address of the corporation; the dates(s) on which you became an officer</p><p>[Party’s] Interrogatories to [Party] Page 10 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 and/or director; the nature and extent of your duties as an officer and/or director; and the</p><p> amount of compensation which you receive, if any.</p><p>34. With respect to any partnership (which is defined for the purposes of this interrogatory as</p><p>"any unincorporated association for a business purpose") in which you presently have any</p><p> interest, or in which you had an interest during the last two years, state the name and address</p><p> of each partnership and for each calendar year, state separately your percentage share of the</p><p> partnership earnings and losses, the gross income of the partnership for each year, and</p><p> itemize all business expenses, assets, and liabilities of the partnership for each year.</p><p>35. If you are presently self-employed, or were self-employed during the last three years, state</p><p> the following: the exact name and address of the business conducted by you in each year for</p><p> the past three years; the gross receipts of your business for each of the last three years and</p><p> for the current year through the date of your answer; and itemize all business expenses for</p><p> each of the past three years and for the present year through the date of your answer.</p><p>36. Set forth a complete description of any loan incurred by you or on your behalf during the</p><p> past three years specifying the date, amount, reason for the loan, unpaid balance, the</p><p> description of security, location of any written records, name and address of lender, name</p><p> and address of borrower, and amount of periodic payments.</p><p>37. Identify any entities, whether individual, corporate, or otherwise to which you have applied</p><p> within the last three years for credit, whether it be loan or otherwise, and to which you have</p><p> given a financial statement, including within your answer: the name and address of the</p><p> person or entity; the date the financial statement was prepared; the purpose for which it was</p><p> prepared; the name and address of each person or entity who has possession of the</p><p>[Party’s] Interrogatories to [Party] Page 11 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 statement (or an exact copy thereof); and a summary of the list of assets (and the value</p><p> attributed thereto) and liabilities (and the amount thereof) set forth on said statement.</p><p>38. Describe all of your business interests or investments not disclosed by your answers to</p><p> previous interrogatories, including any such business interests or investments in any</p><p> partnership, corporation, joint venture, syndication, or other entity in which you have any</p><p> interest.</p><p>39. State whether the residence at [address of family home] was used as the principal residence</p><p> of you and your spouse while you lived together.</p><p>40. State how the property at [address of family home or any other real property] is titled.</p><p>41. State the date on which the property at [address of family home or any other real property]</p><p> was acquired.</p><p>42. If you claim that the residence at [address of family home] is not the "family home," state</p><p> the facts upon which your claims is based, and list all persons having knowledge thereof.</p><p>43. If you claim that any tangible personal property presently located at [address of the family</p><p> home] is not "family use personal property," list each item with respect to which you make</p><p> such claim, state the facts upon which your claim is based, and list all persons having</p><p> knowledge thereof.</p><p>44. If you claim that the [year, make, model, and title of the family car] which is titled in your</p><p> name is not "family use personal property," state the facts upon which your claim is based</p><p> and the names of all persons having knowledge thereof.</p><p>45. If you contend that your spouse has committed adultery during the period of your marriage,</p><p> state when the adultery took place, the name and address of the person with whom it took</p><p>[Party’s] Interrogatories to [Party] Page 12 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 place, the location and address where such act occurred, and the name and address of any</p><p> person with personal knowledge thereof.</p><p>46. If you contend that your spouse has not been a kind, faithful and affectionate spouse</p><p> throughout your marriage, state the exact facts upon which you base your contention, and</p><p> state the name and address of any person who has personal knowledge of the facts with</p><p> reference to such contention.</p><p>47. Give a concise statement of the facts which support the allegations of Paragraph [any</p><p> paragraph of the complaint, counter-complaint, or answer] and the name and address of</p><p> any person having knowledge thereof.</p><p>48. List any deferred income, pension, or profit sharing due to you now or in the future as a</p><p> result of any plan in which you now, or at any time in the past, have participated, whether</p><p> said benefits are vested or contingent, and describe said plans and benefits in detail.</p><p>49. If you have any interest in any type of retirement or pension fund, for each state:</p><p> a. The name of the fund;</p><p> b. The full name and address of the plan administrator of the fund;</p><p> c. The full name of any employer contributing to the fund, whether or not the</p><p> benefits are vested;</p><p> d. The total amount of your contributions to the fund;</p><p> e. The present balance of your interest in the fund;</p><p> f. The date upon which you are entitled to receive benefits;</p><p> g. The amount of benefits and the method of payment to you upon retirement of any</p><p> funds from said retirement or pension fund; and</p><p>[Party’s] Interrogatories to [Party] Page 13 of 14</p><p>Plaintiff vs. Defendant C-00-0000000 h. The amount of any funds available to you and the method of obtaining said funds</p><p> without retirement.</p><p>Respectfully submitted,</p><p>Attorney Firm Address Address Phone Email</p><p>Attorneys for the </p><p>Certificate of Service</p><p>I hereby certify that on this day of , , a copy of the foregoing [name of document] was mailed, first class mail, postage prepaid, to [opposing counsel].</p><p>Attorney</p><p>[Party’s] Interrogatories to [Party] Page 14 of 14</p><p>Plaintiff vs. Defendant C-00-0000000</p>