IN THE CIRCUIT COURT OF CLAY COUNTY, MISSOURI
SEVENTH JUDICIAL CIRCUIT OF MISSOURI
In Re The Marriage Of: )
) Case No:
) Division No.:
FIRST INTERROGATORIES OF
COMES NOW ___________________________, and propounds the following
Interrogatories to be answered by _______________________________, in the
manner provided by Missouri Supreme Court Rule 57.01.
These Interrogatories are intended to be of a continuing nature, requiring
you to serve timely supplemental answers setting forth any information, within
the scope of these Interrogatories, which may be acquired by you following the
A. As used herein, the phrase “the date of your marriage” shall mean the
___________ day of __________________________, 20_______.
B. As used herein, the term “your spouse” shall mean
________________________________, in this cause.
C. As used herein, the term “minor child born of this marriage” shall
apply to all children which have your spouse and you as parents, whether
natural born or adopted.
Type your answers to the following Interrogatories in the space following the
Interrogatory on this form where possible. If the space is not sufficient to
answer the Interrogatory completely, type your answer on a separate sheet of
paper and attach same as an appendix hereto noting on this form which
appendix contains your answer to said Interrogatory and noting on the
appendix reference to the Interrogatory being answered.
1. State your full name, the date of your birth, your social security
number, your present place of residence and the date you began your
residency at such place.
2. Attached to these Interrogatories is a Statement Of Marital And Non-
Marital Property And Liabilities and a Statement Of Income And Expenses.
Please answer the items requested in said statements as if fully set out in these
3. With respect to each place you have been employed during the
preceding five (5) years (or since the date of your marriage, whichever period of
time is lesser), please state:
(a) The name and address of each person, firm or corporation by whom
you were employed.
(b) The inclusive dates of your employment.
(c) Your rate of pay.
(d) Your annual gross earnings for each year of employment (or your
total gross earnings if employed for less than one year).
(e) The reasons for and circumstances of the termination of your
4. Please state whether or not you are now employed and, if so, state:
(a) The name, address and telephone number of your present employer
or, if self-employed, the name and address and telephone number of your
(b) Your present occupation or business with such employer or type of
business in which you are engaged.
(c) The name, address and telephone number of your payroll records
(d) Your rate of pay or income, how it is calculated, your base gross
earnings or income per pay period and how frequently you are paid.
(e) The length of time you have been with your present employer or
(f) All economic benefits or assets in addition to cash income which you
receive or have access to from any source, including, but not limited to such
things as company cars, club memberships and expense accounts.
(g) Do you expect any material increase or decrease in wages or benefits
and, if so, when and why?
5. Is there any program or plan for retirement, profit-sharing, pension or
thrift plan in which you are entitled to participate as a result of past or present
employment (including membership in a union)? If so, please execute the
attached Authorization before a notary public and return same with your
answers to these Interrogatories.
6. Do you have any interest in an individual retirement account (IRA)? If
so, please state:
(a) The location of each IRA.
(b) The present value of each IRA.
7. Have you in the last five (5) years (or since the date of your marriage,
whichever period of time is lesser) hired any accountant or accounting firm for
the purpose of preparing or maintaining financial books, records or statements
for you? If so, please state:
(a) The name and address of the accountant or accounting firm.
(b) The inclusive dates of employment.
(c) A description of the books or records prepared or maintained.
(d) The present custodian and location of such books and records.
8. Please state whether or not you have had any income during the
preceding five (5) years other than what has been set forth in the preceding
9. If your answer to the preceding Interrogatory is in the affirmative,
(a) The name and address of the person, firm or corporation who paid
your earning or income.
(b) The purpose for which the earnings were paid or the income was
(c) The amount of weekly or monthly wage, salary, commission or other
means of payment for each such earnings or income.
(d) The total amount paid to you by such person, firm or corporation
during each of the preceding five (5) years.
10. Please state all present sources of income and the amounts thereof
not otherwise disclosed in your answers to these Interrogatories.
11. Have you in the last three (3) years (or since the date of your
marriage, whichever period of time is lesser) filed a state and federal income tax
return? If so, for each such return, please, state:
(a) Whether it was joint or separate filing.
(b) The address of the office in which it was filed.
(c) The amount of your adjusted taxable income reported thereon.
NOTE: In lieu of answering subparts (a) through (c) above, you may
attach your state and federal income tax returns with all schedules for such
period of time.
(d) The name and address of the person or entity who prepared the
(e) Who received the refund, if any, from the return most recently filed,
who endorsed the refund check and what has been done with the money
12. Have you during the twelve (12) month period immediately preceding
the date of service of these Interrogatories, maintained an account or fund,
either singularly or jointly, in any credit union, bank, savings and loan
association or other financial institution?
13. If your answer to the preceding Interrogatory is in the affirmative,
please state for each such account or fund:
(a) The name and address of the bank or financial institution.
(b) The type of account or fund.
(c) The names on the account or fund.
(d) The date the account or fund was closed, if applicable.
(e) The account or fund number.
(f) The amount of the balance as shown on your last statement and the
date of such statement; or, if the account or fund is closed, the amount of the
last balance before the account or fund was closed.
(g) The names of all persons whose names have appeared on said
accounts or funds.
14. Since the date of your marriage, have you made any deposits with
any credit union, bank, savings and loan association or other financial
institution to an account or fund on which your name did not appear?
15. Please list all the safe deposit boxes, vaults, safes or other places of
deposit and safekeeping in which you have deposited any money, documents or
other items of personal property at any time during your marriage. For each,
please state the following:
(a) The name of the depository institution.
(b) The box number, letter or other identifying designation for the place
(c) The name and address of each person authorized to enter the safe
deposit boxes, vaults, safes or other places of deposit.
(d) The date on which said safe deposit boxes, vaults, safes or other
places of deposit were opened.
(e) The present inventory of the contents.
(f) The date on which said safe deposit boxes, vaults, safes or other
places of deposits were closed or entry rights terminated.
16. If you are in possession of any cash money which is not deposited in
any type of account or within any depository institution, then please state the
amount of such money and its present location.
17. Are there in effect any policies of insurance providing hospitalization
and/or major medical, dental or vision health care protection to you, your
spouse or any minor child born of this marriage? If so, state:
(a) The identity of the insurance company.
(b) The number of the policy and your identification number.
(c) Details of the coverage and benefits provided.
(d) The names of the persons covered under each policy.
(e) The total monthly premium charged for such coverage.
(f) The amount of the monthly premium which is attributable to coverage
for any minor child born of this marriage.
18. If you have paid or incurred any attorney fees with respect to any
attorney who is or has represented you in this action for dissolution of
marriage, then for each such attorney please state:
(a) The name, address and telephone number of the attorney.
(b) The amount paid on account.
(c) The dates of the payments.
(d) The amount now owed, but unpaid, with respect to legal services
rendered to the present.
19. Do you claim that your spouse engaged in any form of misconduct
since the date of your marriage?
20. Are you presently in good health? If not, please state:
(a) The cause of your physical, emotional or mental condition or the
occasion giving rise to such condition.
(b) The date or duration of each such condition.
(c) The nature of your physical, emotional or mental condition.
(d) The name and address of the treating doctor or hospital.
(e) The dates or duration of any treatment received by a doctor or
21. Do you claim that you are entitled to maintenance?
22. Please state the name and address of each person you expect to call
as an expert witness at the hearing on your dissolution of marriage in the
above-captioned cause and the general nature of the subject matter on which
such expert is expected to testify.
23. Do you claim that it is in the best interest of any unemancipated
child born of this marriage that you be awarded primary physical custody of
24. Do you claim that your spouse is unfit as a parent to have primary
physical custody of any unemancipated child born of this marriage?
25. Do you believe that joint legal custody is in the best interest of any
unemancipated child born of this marriage?
26. Please state the periods of time during each calendar year that you
believe the unemancipated children born of this marriage should be in the
physical custody of each parent.
27. Please complete all portions of Civil Procedure Form No. 14 based
upon information currently available to you and return same with your
answers to these Interrogatories.
28. Do you believe the child support amount for the unemancipated
minor children born of this marriage as calculated under Civil Procedure Form
No. 14 is inappropriate or unjust?
29. Do you claim that any child born of this marriage is emancipated
and, if so, please state the name of such child and the facts and circumstances
which you believe substantiate your claim?
30. Since the date you and your spouse separated, have you paid any
sums to your spouse or anyone on your spouse’s behalf for the support of any
child born of this marriage?
31. If your answer to the preceding Interrogatory is in the affirmative, for
each such payment please state:
(a) The date of such payment.
(b) The amount of such payment.
(c) The form of payment, e.g. cash, check, money order, etc.
(d) To whom the payment was made.
(e) The particular purpose of the payment.
MO. Bar Enrollment # _____________
ATTORNEYS FOR _________________
_________________________’S SWORN SIGNATURE
STATE OF ____________________ )
COUNTY OF __________________ )
The below named __________________________________ , being duly sworn
upon _________________ oath, states that __________________ read the foregoing
Interrogatories and the answers given are true to the best of __________________
belief and knowledge.
The foregoing Answers to Interrogatories were subscribed and sworn to
before me this ________________ day of ___________________, 20___________.
My Commission Expires: _____________________________
CERTIFICATE OF MAILING
I hereby certify that the original copy of the completed Interrogatories
was mailed, U.S. Mail, postage prepaid, to: __________________________________,
this ______ day of _________________, 20____, attorney for
I hereby certify that the foregoing Interrogatories was
___________________________________ this _______________ day of _______________,
20 _____, to: ________________________________________________________________,
Attorney for _________________________________.