Sample Deposition
If you ever wondered what the attorneys would ask you at a financial deposition, we believe that the following questions will be pretty close!!!
Sample Interrogatories for Judgment Debtor
Give your name, including any nicknames or other names used.
Give your present residence address.
Give your residence telephone number.
Give your social security number.
Give your age and the date of your birth.
State where you were born.
State your marital status and, if married, state your spouse's full name, social security number, and date of birth.
State whether your spouse is presently employed, and if so, give your spouse's employer and state how long your spouse has been so employed.
State your spouse's present residence address.
Do you have any children? If so, state each child's full name, residence address, and date of birth.
List all the places where you have lived in the past year by stating the street address, any post office address, city, state, zip code, and for each place, give the dates during which you lived there.
Give your occupation.
Who is your employer?
What is the address where you work?
What is the telephone number where you work?
Do you work part-time anywhere?
Give the dates during which you have been employed by your present employer.
State all business ventures you have engaged in during the past year and for each give:
The name of the business.
Its address.
The beginning and ending dates of your association with said business.
Identify other persons associated with the business.
Describe the purpose of the business.
State whether you still own any interest in the business.
State all partnerships in which you have been engaged in during the past year and for each give:
The name of the partnership.
The partnership address.
Beginning and ending dates of the partnership business.
Identify the partners.
The purpose of the partnership business.
State whether you still own any interest in the partnership.
Give the amount of income you received from your trade or profession for the past year.
Give the amount of the income your spouse received for the previous year.
List income from other sources, including but not limited to investments, interest, dividends, pension funds, profit sharing plans, and trust funds by identifying each source and the amount of money received for the past year.
Give the date and place of filing of your last state income tax returns and federal income tax return.
List all accounts you have with any banks, credit unions, savings and loan associations, or other financial institutions you have maintained either in your name or together with any person for the past year, and for each account, state:
The name of the financial institution.
Its address.
The name on the account.
The account number.
The average balance in the account for the previous year.
The current balance of the account.
Whether any IRA accounts exist.
The location of the IRA account.
The amount in the account.
Give all safe deposit boxes you have kept since one year prior to the entry of the judgment and give-.
The bank or other institution where it is located.
The address of that institution.
'Me name or names on the box.
Describe in detail the contents of the box.
Identify each person who has possession or custody of any financial records reflecting your financial condition during the past year.
List anything you have in your possession which belongs to someone else.
Have you ever filed bankruptcy, and if so, state the date of filing, the name of the bankruptcy court, the location of the bankruptcy court, the nature of the proceed, proceedings, and the name of the attorney who represented you.
List all outstanding obligations, the name of the creditor, address of the creditor, amount due, and the amount of payments.
Have you ever been a defendant or a plaintiff in a lawsuit in the past five years? if so, for each action, state:
Name of the court.
The location of the court.
The case number.
The type of proceeding.
The result or outcome.
Identify the attorney who represented you.
List all of your properties that have been taken by a court order, -attached, executed, or foreclosed since the entry of the judgment against you, and for each item of. property state:
Its description.
The name and location of the court that ordered seizure of the property.
The type of the case and case number.
The date the property was seized.
Have you paid off any accounts within the past year and if so, what was the collateral or security?
If you have cosigned with any person to repay a debt, list the following for each debt:
The identity of the person to whom the debt is owed.
The place the debt was incurred.
The nature of the debt.
The identity of the person with whom you co-signed.
The amount due.
List any loan you have made to any of you relatives since the entry of the judgment against you and for each such loan:
Identify the relative's name and address.
State the relative's relationship to you.
State the amount of the loan.
State when the relative received the proceeds of the loan.
State the amount repaid and the date of repayment, if repaid.
State the present balance.
State the consideration for any loan.
List any loans that you have received from any relatives in the past year and for each such loan, state:
The name and address of the relative.
The relative's relationship to you.
The amount of the loan.
The date you received the proceeds of the loan.
The amount you have repaid and the date of repayment, if repaid.
The present balance.
Whether any relative - holds a perfected security interest in any of your property.
List all losses you have suffered from fire, theft, or gambling within the last year and for each such loss:
Describe the property.
State how it was lost.
Give the date of loss.
State the value of the property.
State whether an insurance claim for the loss has been filed and if so, identify the insurance company.
State whether an insurance claim has been paid and if so, identify the insurance company making the payment and the amount of the payment
Has the property been recovered.
List all of your real estate and personal property you have sold, traded, pawned or given away since the entry of the judgment against you and for each item of property. state,.
Description of the property
The date of the transfer.
The identity of the person whom it was transferred.
'Me relationship to you of the person to whom it was transferred.
'Me consideration you received in return for the property.
List any of your property that has been returned to or repossessed by a creditor or secured party during the past year and for each item of property, state-.
The name of the creditor or secured party.
A description of the property.
The value of the property.
The date it was returned or repossessed.
List any other creditors, including wages, commissions, or funds that you may owe any employee or other person and for each such employee or other person, state:
The name of the employee or other person.
The amount due.
When contracted.
The nature of the work or reason for the debt.
Name any person or business that owes you money or is indebted to you in some manner.
Do you owe any federal, state or local taxes and if so, state:
The identity of the government branch to which it is owed.
The amount due.
The type of tax.
The place incurred.
The place assessed.
Do you make any alimony or child support payments in connection with a divorce, dissolution of marriage, or separation agreement, and if so, state:
The name of the person to whom it is paid.
The amount of payment.
The name of the court.
The date of the decree.
The type and the case number.
List any inheritances that you have received within the past year and for each such instance, state:
The source of the inheritance.
The monetary amount received and description of any property 'and its value.
The date you received the proceeds.
If you owe any debts for which you have pledged any of your property as a guarantee for payment, list the following for each debt:
The name of the person or business to whom the debt is owed.
A full and complete description of the pledged property.
The value of the property.
The date the debt was incurred.
Identify the document you signed in pledging the property.
The amount due on the debt.
Where any lien is recorded or filed.
Have you made any written statements or completed any applications or financial affidavits concerning your financial situation within the past year? If so, state:
'The name of the person or business receiving the statement, application, or financial affidavit.
The date made.
With respect to any parcel of real property which you may own or in which you may have an interest, including a leasehold interest, state:
Its address.
Its legal description.
The original purchase price.
The balance on each mortgage-e on the property.
The identity of the mortgage holder.
The date of each mortgage.
The market value of the property.
Identify the person in possession of the property.
Identify any leases on the property.
Book and page number and where recorded.
Identify any stocks, bonds, annuities, negotiable instruments and securities that you own either individually or with someone else, and if jointly owned, identify each other owner and state that owner's interest in the property.
List the jewelry, watches, rings, artworks, stamp collections, coin collections, artifacts and antiques that you own and the estimated value of each.
List all the household appliances that you own and for each item, state:
The year, make, and model including the serial number.
The value.
Identify all co-owners.
Whether any liens exist.
List all the household furniture that you own and for each item, state:
A full and complete description.
The value.
Identify all co-owners.
Whether any liens exist.
List any livestock that you may own and state for each:
The description.
The address where it is located.
The market value.
Identify all documents pertaining to its registration, certification, or lineage.
Identify any joint owner.
List all the automobiles or other motor vehicles including mobile homes and trailers that you own or are presently buying and for each item, state:
The year, make, model, identification number, and certificate of title number.
Its location.
Identify any co-owners.
The market value.
Whether any liens exist.
List any farming equipment that you own and for each item, state:
The description, including the year, make, model, and identification number.
The address of its location.
Identify any co-owners.
The market value.
Whether any liens exist.
List all machinery, equipment, and tools of business or other tools that you own or have an interest in and for each, state:
The description.
The address of its location.
The identity of all co-owners.
The market value.
Whether any liens exist.
List all office equipment, furnishings, and supplies which you own and for each item, state:
The description.
The address of its location.
The identity of all co-owners.
The market value.
Whether any liens exist.
Do you own a personal computer or other computer hardware or software and if so, state:
The description.
The address of its location.
The identity of all co-owners.
The market value.
Whether any liens exist.
List all other personal property owned by you not previously listed including but not limited to: ships, boats, motorcycles, airplanes, cameras, guns, campers, golf clubs, sporting equipment, stereo systems, video cassette recorders, and musical instruments and for each item, state:
The description, including year, make, model, identification or serial number, certificate of title number.
The address of its location.
The value.
The identity of any co-owners.
Whether any liens exist.
Identify each patent, copyright or trademark in which you have an interest and state its value.
List any interest you have in property now being held by someone else, including but not limited to interest in land, money, stocks, bonds, bequests, or other personal property and for each item, state:
The identity of the person holding the interest.
The description of the property.
The address of the location of the property.
The nature of your interest in the property.
The value of your interest in the property.
List any insurance policies you own and for each such policy, state:
The identity of the insurance company.
The cash value of the policy.
The type of insurance.
The face value.
The item or person insured.
The annual premium.
Do you have money in any pension or retirement fund where you now work or have worked previously and if so, state:
The name and address of employer.
The name of the fund.
the amount due you.
The terms and provisions upon which it will be paid -to you or your beneficiaries.
Do you have any money or security now posted as a bond? If so, state:
The amount of the bond.
The reason for the bond.
Identify all books, papers, and deeds relating to your estate, business, trade or property which you have not previously disclosed in your answers to these interrogatories and for each identify the person who has possession of it, if not in your possession.
Are you the beneficiary of any trust? If so, state the circumstances of the trust.
Do you have deposits with any utility or telephone companies? If so, state:
The name and address of the entity.
Amount of deposit.
When such deposit is due to be returned to you.
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