IN THE CIRCUIT COURT FOR
                               COUNTY,                               (STATE)

TO:                                          
          YOU WILL PLEASE TAKE NOTICE that the undersigned, as attorney for the Petitioner herein, demands answers to the following Interrogatories, under oath, and within the time allowed by the Rules of Civil Procedure. You are further informed that these Interrogatories are continuing so that should you obtain information subsequent to answering these Interrogatories, which will supplement, complement, add to, or change your answers in any way you are required to promptly provide such information to the undersigned, under oath.

1. Set forth the details of any present employment, giving as to each:
   a) The name, address and telephone number of the employer;
   b) The date you commenced the employment;
   c) Your job title or position;
   d) The name and position of your immediate supervisor;
   e) Your gross salary per hour, week or month, and the number of payroll deductions claimed;
   f) The number of hours per week that you are required to work by the employer;
   g) The rate of pay received for overtime work and the average number of hours of overtime worked per week or month;
   h) The amount of your gross earnings from employer from January 1,         to the present;
   i) The exact amount of your present take-home pay per week or month, excluding overtime;
   j) An itemized list of all amounts presently deducted from your gross salary per week or month;
   k) Any other compensation from the employer, other than wages and overtime, such as meals, discounts, free transportation, medical insurance or services, uniforms or clothing, profit sharing or any other employment benefits, and state the value thereof;

l) Attach a copy of any employment contract you now have in effect;
m) Attach copies of your three most recent wage slips or a written statement from your employer to verify your earnings and all deductions there from for the current year-to-date.

2. Set forth your employment since your marriage to your present spouse, giving, with respect to each such employment, the following information:
   a) The inclusive dates of each such employment;
   b) Your gross and net income from each such employment on an annual basis;
   c) Any and all additional compensation received there from in each such instance, including fringe benefits, expense account payments, insurance, and any and all other compensation;
   d) Your reason for leaving each such position in each instance.

3. Set forth the names and addresses of all high schools, colleges or universities, vocational schools, trade schools, or other educational institutions attended by you, giving the inclusive dates of the attendance at each, the type of degree or training, date degree received, institution from which received, and whether such degree or training has been productive of income or increased your earning capacity and, if so, in what way.

4. State the details of any savings accounts, certificates of deposit or checking accounts that you have, giving the names and addresses of the banks, the numbers of the accounts, the stated ownership of the accounts, and the present balances. Also state the balances in said accounts or certificates as of the date this  action was commenced.

5. State the details of any savings accounts, certificates of deposit or checking accounts that you have closed or otherwise terminated since January 1,         , giving the names and addresses of the banks, the numbers of the accounts, the stated ownership of the accounts, and the use made of such amounts after any such accounts were closed.

6. Do you have a safety deposit box? If the answer is in the affirmative, give the name and address of the bank at which the box is held, the number of the box, and itemize the contents thereof.

7. Set forth in detail each and all of your assets including all real and personal property, furnishing as to each such asset the following information:
   a) A complete description of each asset (if real property, set forth the common address and the full legal description, and, if securities, set forth the name of the issuer, the date of issue, the certificate number, and the number of shares or other type of denomination);
   b) The exact name or names of the record and/or registered owners thereof;
   c) The date of acquisition;
   d) The original cost, if any (and, if the same was acquired in any other manner than by purchase on your part, describe the manner of such acquisition);
   e) The current fair market value as of the date of the Answers to these Interrogatories of any asset that you would value over $100; and,
   f) The encumbrances, if any, against the asset, setting forth the name and address of the encumbrance, the date of the encumbrance, the original amount thereof, the present balance, and the nature of the payoff.

8. Submit a schedule of all life, health, and disability insurance presently held by you, giving for each policy the name of the insurance company, the policy number, the face value of the policy, the cash value of the policy, the amount of the premium, the status of any policy loans, and the names of the beneficiaries.

9. State the ownership, year, make, and model of any motor vehicles you own or currently have in your possession, as well as the current values thereof and the nature and amounts of any encumbrances.

10. Have you furnished to any bank or lending institution or to anyone else from January 1,         , to the current date, a personal net worth or financial statement? If the answer is in the affirmative, state the names of all banks or persons to whom said statements have been given, the dates of said statements, and attach copies thereof.

11. Do you currently hold any promissory notes from other persons, or are there any outstanding loans receivable by you from any person? If the answer is in the affirmative, attach copies of any notes and state the details of each loan, including the amount owed and the method of payment.

12. Are there any outstanding debts as to which you are the obligor to any banks, financial or lending institutions or other entities or persons? If the answer is in the affirmative, state the names of each such creditor, the current balance of each such debt, the method of payments, the security, if any, given for each such debt, the date each such debt was taken out, and the reason for each such debt in each case, and the payments made by you, on each, since January 1,         .

13. State who has possession of bank statements, canceled checks, deposit slips and other indicia relating to any checking account of yours or of any entity in which you have any interest, from                          to the current date.

14. Attach copies of your personal federal and state income tax returns filed for the calendar years         and         as well as for the current year, if filed; if not filed for the current year, furnish the data that you will use as the basis for filing your federal and state income tax returns for the current year. In addition, attach copies of returns filed for all of said above years by any entity in which you have an interest as hereinabove set forth.

15. Set forth with particularity a breakdown of the items comprising your present claimed monthly personal living expenses. Be specific.

16. Set forth all current sources of income in full detail, the amounts there from realized in each instance on a monthly basis (or other periodic basis as applicable), and any and all other details relevant and concerning your present sources of income, whether taxable or not.

17. State with respect to any transfers of property since January 1,         , in which you had an interest, of whatever kind and wherever situated, the details of all such transfers, sales, or other dispositions thereof, giving all dates of each such transfer, the property transferred, the source of said property in the first instance, the compensation received in transfer, and the disposition made of all the compensation in each such instance, and the names and address of the transferee.

18. State the details of any pension, retirement, deferred compensation, profit sharing or employee stock purchase plans in which you participate, including the name and nature of the plan, the number of years you or your employer have contributed to the plan, the total amount contributed by each, the date your rights become vested, the amount, frequency, and duration of payments under the plan after vesting; attach a copy of any such plan.

19. With regard to your present residence address, set forth the following information:
    a) The address;
    b) A description of the premises; that is, whether the same is a single family dwelling, an apartment, duplex, or other entity;
    c) Name and address of the owner of said premises;
    d) The names, ages, marital status, employer, and sources of income of all occupants thereof.

20. In the event you claim any of your assets are directly traceable to any gift, injury claim, or inheritance, describe the asset and state the date received, name of the donor or source, and whether you claim your spouse has any interest in the property.

21. State the name and address of each and every corporation, partnership, limited partnership, joint venture, sole proprietorship, joint tenancy and tenancy in common in which you have an interest, either as owner, general partner, limited partner, shareholder, joint tenant, tenant in common, or otherwise, and the nature and current value of your interest therein.

22. To the extent that you have not in previous answers to these Interrogatories described fully any asset in which you have any interest, vested or contingent, including an interest as beneficiary under any and all trusts created by any other person or by yourself, and whether that interest in property be personal, real or mixed, and whether the interest be held by you alone or jointly or in any other manner with any person or entity, set forth in the answer to this Interrogatory the identity, nature, value and location of each and every item of such property and if any of said property is encumbered in any manner, set forth the encumbrance thereon and full details with regard to each such encumbrance.

23. State names and address of all doctors, psychiatrists, psychologists, or other medical personnel you have consulted or from which you have received treatment since your marriage during the last five years, as well as the nature of the physical or psychological problem for which said treatment or consultations were received and the dates thereof, as well as whether                                      claims he/she is under a temporary or permanent physical or mental disability, giving the exact details.

24. State whether or not you have created any trust, either revocable or irrevocable. If the answer is in the affirmative, attach a copy of each to your answers to these Interrogatories.

25. State the names and addresses of all experts who have been retained or specially employed by you or your attorneys in anticipation of this litigation.

26. With respect to all witnesses whom you will or may call as experts to give opinion testimony in the trial of this matter, state the following:
    a) Name and address;
    b) Name and address of said witness' employer or the organization with whom he/she is associated in any professional capacity;
    c) The field in which he/she is to be offered as an expert;
    d) A summary of his/her qualifications within the field in which he/she is expected to testify;
    e) The substance of the facts to which he/she is expected to testify;
    f) The substance of the opinions to which he/she is expected to testify;
    g) The name and date of any treatises, books, articles or other writings, published or unpublished, by the expert, relating in any way to the subject matter on which the expert is expected to testify. For each published article, state the title of the book, journal, or other work in which it can be found and the name of the publisher;
    h) The type of each case, the Court, docket or file number, and date of each decision of each lawsuit in which the expert has testified as an expert witness; and i) State the dates and address of all reports, appraisals, or other documents rendered by such expert.

27. State whether or not you believe that your spouse is a fit person to have legal and/or physical custody of your minor child.

28. If you do not believe that your spouse is a fit or proper person to have legal and/or physical custody of the minor child of the parties, state in detail the facts upon which your conclusion is founded.

29. What restrictions, if any, should be placed upon either party's relationship with or access to the minor child.

30. State the name and address of each witness that you intend to call on your behalf in this proceeding, and for each such witness, state:
    a) The substance of the facts and opinions to which the witness is expected to testify;
    b) A summary of the grounds for each opinion; and,
    c) The contents of any documents that the witness will rely upon.