More from the words of Jeb Abraham
You will be struck by the interrogatories, the pages of pesky questions peering impertinently into your private life:
List all persons (of the same or opposite sex) with whom you had sexual intercourse during the past five years. Include in your answer the time(s) and place(s) of such intercourse.
List all persons (of the same or opposite sex and exclusive of those mentioned in your response to the preceding interrogatory) the flesh of whose bodies you have touched (other than by way of salutation, such as by shaking hands) during the past five years. Include in your answer the time(s) and place(s) of such touching.
List all persons with whom you have discussed your wife, your marriage, or your children during the past five years. Include in your answer the time(s) and place(s) of such discussions and precise of there of.
List all personal writings and papers, such as diaries, journals, calendars, and letters that may relate to the subject matter of the preceding interrogatories. Include in your answer the precise location(s) of such writings and papers.
List every fact that may tend to prove that you are, or are not, fit to have the sole or joint custody of your children.
List every document that may tend to prove that you are, or are not fit to have the sole or joint custody of your children.
List all persons who may have any knowledge concerning your fitness, or your lack thereof, to be have the sole or joint custody of your children. Include in your answer the current address(es) and telephone number(s) of such persons.
List all medical and mental health practitioners (including practitioners of alternative forms of health care such as faith healers and card readers) you have consulted during the past five years. Include in your answer the current address(es) and telephone number(s) of such professionals.
List all pharmacies that filled your medical prescriptions during the past five years. Include in your answer the current address(es) and telephone number(s) of such pharmacies.
List all controlled substances (i.e., “drugs,” such as cocaine, heroin, and marijuana) that you have used during the past five years. Include in your answer the date(s) and place(s) of such use.
List all sources of wage income you have had during the past five years. Include in your answer the name and address of each employer, your position with each, your length of employment with each, your rate pay with each, and your yearly before-tax income with each.
List all sources of non-wage income or revenue (including, but not limited to, non-wage business or professional income, capital gains, rents, royalties, barter interest, gratuities, gifts, pensions, inheritances, insurance proceeds, judgments, and workman’s compensation) as well as lottery, gambling, or other wagering winnings (and losses) you have had during the past five years. Include in your answer the date(s) and amount(s) for each source.
List all personal checks you have written during the past five years. Include in your answer the drawee bank, the date, payee, amount, and purpose of each check. (You may satisfactory answer this interrogatory by supplying a legible photocopy of each such check-unaltered, front and rear-or a legible photocopy of the unaltered, original check register pertaining to each and such check.)
List all credit card, debit card, and charge card transactions you executed during the past five years. Include in your answer the card issuer, date, payee, and purpose of each transaction. (You may satisfactorily answer this interrogatory by supplying a legible photocopy of the unaltered, original monthly statement pertaining to each such transaction.)
List the location of each safe deposit box held by you directly or indirectly or that you otherwise had use of during the past five years. Include in your answer the name(s) in which the box was held, the name, address an telephone number of the bank or other institution where the box was located, and the nature and contents of the box (indicating dates of placement and removal).
List and describe on the attached Property Disclosure Form all property owned by you. For all such property claimed by you to be non-marital, complete the detailed Non-Marital Property Tracing Schedule attached to said form.
In accordance with state law, you have an affirmative duty to timely supplement any answer hereto whenever new or additional information becomes known to you.
