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Interrogatories from Crystal's Attorney (Martha J. Harris) on 6-5-2014 to Emmett Beam

Interrogatories

24 Interrogatories and 20 Requests for Production of Documents from Crystal’s Attorney Martha Harris on 6-5-2014 .

Request for Production of Documents  from Crystal's Attorney (Martha J. Harris) on 6-5-2014

Production of Documents

Emmett, I am attaching a copy of Interrogatories and Request for Production of Documents

from Crystal's Attorney (Martha J. Harris). {on 6-5-2014}

Please attempt to answer the Interrogatories and to gather the requested documents

within the next two weeks.    Armanda Beal Day, Esq., Attorney at Law

1. Complete copies of your W-2 forms from 2010, through the date the documents are produced and complete copies of your federal and state income tax returns, 1099 forms, K-1 forms and all other attachments from 2010, through the date the documents are produced.

2. Any and all other documents that show all of your income (whether taxable or not) from January 1, 2010, to the date the documents are produced, including but not limited to. sales commissions, bonuses, wages, salary, severance pay, pensions, unemployment, disability, workers' compensation, social security, interest, dividends, rentals, royalties, the proceeds of sale of assets, and income of any nature from any and all securities.

3. All documents, including but not limited to, all statements of account, plan summaries, statement of accrued benefit, annual statement of benefits, personal earnings and benefit statement from Social Security, qualified domestic relations order procedures, qualified domestic relations order proposed form, calculation of benefit, and savings and security plan quarterly statements for the last year, with respect to any retirement source, pension, savings, and/or profit sharing plan or trust.

4. If you allege or will allege that any physical or mental impairment effects your employability or earning capacity, provide all health records (both physical and mental health) for the last three years.

5. All deeds, deeds of trust, escrow agreements, escrow statements, installment sales contracts, contracts of purchase or sale, leases and other documents that reflect and show all real estate transactions in your name individually or jointly with others for all real property in which you acquired, held or sold any interest.

6. All records indicating any interest of any kind held by you or on your behalf in any and all corporations, banks, or other institutions, foreign and domestic, or any other entities not evidenced by certificates or other instruments.

7. All records, agreements, or options for the purchase or transfer of any interest in any corporation or other business entity, including the purchase of the stock of any such corporation or entity made by you or in your behalf.

8. All records for all accounts of any type at any bank or other financial institution, whether held jointly or separately, or if not held in your name on which you are authorized to draw, including without limitation, monthly, quarterly and/or yearly statements, checks, whether or not canceled, check stubs, check registers, passbooks, certificates of deposit, money market accounts, loan documents, or other like assets covering the period from January 1, 2010 to the date the documents are produced.

9. Any documents which evidence any gift or inheritance received by you since July 24, 2010.

10. All documents of any description evidencing a loan in which you acted as borrower, lender, or guarantor for any personal or business loans.

11. All documents of any description outlining the collateral used to secure any personal or business loans in which you acted as borrower, lender or guarantor.

12. All documents, including, without limitation, statements of account and stock certificates relating to any stocks, investments or other securities of Plaintiff and/or Defendant from January 1, 2010 to the date the documents are produced.

13. All documents relating to any trust(s) created by, or for the benefit of you, whether you are the trust maker, trustee, beneficiary, or administrator of such trust. All of your credit card account records either personal or business for the period from January 1, 2010 to the date the documents are produced.

14. Any and all financial statements prepared by you or on your behalf, whether presented or not to any banking or other financial institution.

15. Any documents of any description pertaining to any life insurance or annuity policies insuring the life of Plaintiff and/or Defendant, along with an executed beneficiary election form.

16. For any business enterprise the following documents: All tax returns of said business enterprise for the last five (5)years; all profit and loss statements of said business enterprise for the last five (5)years; all balance sheets of said business enterprise for the last five (5) years; all year end financial statements of said business enterprise for the last five (5)years; any balance sheets, financial statements or profit and loss statements for said business enterprise for any part of the present calendar or fiscal year.

17. Any reports, memos or notes disclosed by any expert witness.

18. All exhibits you intend to introduce into evidence.

19. All documents identified in your Answers and/or Supplemental Answers to interrogatories.
1. If you have been employed or self-employed at any time in the past five (5) years to the present, provide: the name and address of each employer; the dates of employment for each employer; your job title and a description of your duties and responsibilities for each employer; hourly and total compensation received from each employer; list all fringe benefits in detail with the value of each and if you have left employment, please state whether the termination was voluntary or involuntary and the reason for termination.

2. State any and all applications for employment you have made in the past five years. State any offers of employment you have received in the past five years, including the name and address of the person making the offer, the job title, job description and compensation level offered.

3. State the general state of your personal health and describe with particularity any physical or mental impairments which affect your earning capacity or employability and state the name and address of each and every person with whom you have treated with respect to your physical or mental health within the last five (5) years and the dates of all treatments. In addition, please list all prescription medication you are presently taking, who prescribed it, and the amount of said medication you are to take on a daily basis.

4. For all accounts that you have/had or are/were authorized to draw on in the past five (5) years please state the name and address of the bank or financial institution; the account numbers and type of accounts; the names of persons authorized to draw on the account and the names under which the account appears if different from those authorized to draw; the date(s) that the account was opened and closed, if now closed; the present balance, balance as of the date of your separation and last balance for the account when it was closed (if applicable).

5. For any accounts in a bank/financial institution not listed above in which you or others at your request have deposited any money please state the name and address of the bank/financial institution; the name under which the account stands, and your relationship to that person; the account number; the approximate date and amount of each deposit made by you or by others at your direction; the source of the funds and deposits made.

6. State the name, location and number of any safe deposit boxes in your name or in the name of others to which you have access or have had access to for the last three years, including the contents of each box as of one year ago, as of date of the Complaint in this action and at the present time.

7. For any life insurance or annuity policies you own, have an interest in or are a beneficiary of please state the name and address of the insurance company; the type of policy and its policy number; the date the policy was issued; the face amount and annual premium of the policy; the name and address of each owner, insured and beneficiary of/under the policy; the amount and date of each loan made on the policy; the accumulated dividends; the present cash surrender value; whether the policy contains the right to change beneficiaries.

8. For each and every firm or business entity that holds any property of any kind for your benefit such as, but not limited to, trust funds, custodian accounts or life estates, please state the name and address of each such person, firm or business entity, a description of the property held for your benefit, the condition under which the property is held for your benefit, and the approximate value of the property.

9. Describe in full detail each and every retirement plan, pension plan and/or similar plan, insured plans, group deferred annuities, salary deferment plans, group deposit, administration insured plans, trust funds, individual contract pensions, pension trusts, group permanent insurance, split dollar insurance plans, defined benefit plans, profit sharing plans, HR10 plans, 401k plans, and individual retirement accounts, etc., including a description of such plan(s), identification of all documents pertaining to such plan and the entity through which it is administered; your contingent and vested interest in said plan, including the value and amounts of anticipated benefits as well as the time or contingency at which, or upon which, the same are to be paid.

10. For any and all property that you claim is non-marital property (either whole or in part) of either you or your spouse as that term is explained in 19-A M.R.S.A. Section 953, please provide for the property involved a description, location, present value, date and method of acquisition, value at time of acquisition, source of funds used to acquire, and facts that you base your claim that the property is non-marital.

11. For each person or organization that owes you money, please state the name and address of the debtor, the amount owed, the form of the obligation, the date the obligation becomes due and owing, the date the obligation was incurred, the conditions for payment of the obligation, the consideration for payment of the obligation, the amount of arrearage, if any, now due, and any amount which has been deducted on any of your tax returns as "bad debt" and the date on which said amount was deemed to be a "bad debt."

12. For each person or organization that you or your spouse owe money to, please state the name and address of the debtor, the amount owed, the form of the obligation, the date the obligation becomes due and owing, the date the obligation was incurred, the conditions for payment of the obligation, the consideration for payment of the obligation, the amount of arrearage, if any, now due.

13. Please state whether you have received during your marriage or expect to receive any gift or inheritance and indicate the property, both real and personal, already or to be received, the value of such property, the name and address of the person from whom it has been or will be received and the disposition and present whereabouts of said property.

14. List all items of value over Five Hundred Dollars ($500.00) which you have purchased since July 24, 2010, and include the name and address of the person from whom each item was bought, the sale price, whether any financing was involved and to what extent, and the present location of each item.

15. Please describe all real or personal property that you have disposed of or conveyed your interest in at any time since your marriage, including the date and method of transfer, the consideration received from the transfer, the name and address of each recipient of the property; the amount of profit or loss realized, the reason for the sale, gift, disposal, the use to which the proceeds of the sale were put, the present whereabouts of the proceeds of the sale, the value of the property, and the property's present whereabouts.

16. For all monies or property that you have loaned or given with a value in excess of five hundred dollars ($500.00) to relatives, friends or anyone else during your marriage, please state the name and address of the recipient, the total amount or the type of property loaned or given, the date each loan or gift was made, the date the loan becomes due, the reason for each loan or gift, a description of any consideration or evidence of indebtedness received in exchange for such loan or gift.

17. For each and every pending claim or potential claim for worker's compensation, personal injury, claims for benefits, or any other causes of action, with any court, agency, commission, other tribunal from any source anywhere involving any possible action which you now have, or expect to have please describe in detail the substance of said claim, the tribunal, date of action and/or injury, status thereof, docket or file number, name of opposing party and their representative and address, and name, and address of your representative.

18. Itemize all shares of stock or other securities that you own in your name or jointly with another or as a member of an investment group or that are held in trust for you by any other person or business entity and itemize the cost or other basis and the present fair market value.

19. Please describe fully anything of value not reflected in IRS filings that you have received within the past five (5) years in exchange for any services rendered or to be rendered by you or in exchange for anything of value provided by you.

20. For all business enterprises you have engaged in at any time during your marriage, either solely or jointly with others, whether incorporated or not, please state for each the name, address, nature and form of the business organization; the name of each officer, partner or other principal; your capital contribution; your proportionate share in the ownership and profits; the number of shares you own, the number of shares owned by others, and the number of shares outstanding (if applicable); the date of incorporation (if applicable); the dates on which your interest commenced and ended.

21. For any intellectual property or software you have produced at any time in the past five (5) years, describe in detail what each is, when it was produced, whether there is a copyright or patent or other protection, and what you have earned through its rise.

22. Identify by name, address, occupation and telephone number each person whom you intend to call or reserve the right to call as an expert witness in connection with any of the matters presently pending before the Court and with respect to each such witness, state the subject matter on which the expert is to testify, a summary of the grounds for each opinion, and identify the data or other information considered by the witness in forming the opinions, any exhibits to be used as a summary of or support for the opinions, the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten years, and the compensation to be paid for the study and testimony.

23. Identify by name, address, occupation and telephone number each witness other than expert witnesses whom you intend to call or reserve the right to call in these proceedings and with respect to each person identified, state the relationship, if any, between yourself and said person, the subject matter on which said person will testify, and a summary of what you expect said person to say.

24. Identify by date, title and author each and every document which you reserve the right or may use as an exhibit at the trial of this matter.

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