Interrogatories – Asking questions in a Michigan divorce

Interrogatories – Asking questions in a Michigan divorce

By: Daniel Findling

In preparing a divorce case in Michigan, your Michigan divorce attorney should conduct discovery on your behalf.  Discovery is the process by which lawyers obtain answers to questions under oath and subject to the penalty of perjury.   The three major types of discovery are interrogatories, depositions and a subpoena.  We produced a video presentation on discovery which can be viewed here. This article will discuss Interrogatories.   The term interrogatory comes from the root to interrogate which means conveying the force of a question.  In the movies an interrogation is often portrayed by a police officer rattling questions to a suspect in a dimly lit cell, a chair and a table.   Interrogatories in a Michigan divorce or custody case are far less dramatic.  Interrogatories are simply written questions asked under oath.  Interrogatories often include a request to produce documents in support of an answer. The purpose of Interrogatories are to prepare a case for settlement or trial.  Questions are asked to address issues relevant to a particular case, such as the parties’ finances, custody considerations and even extra-marital affairs. I have provided some sample Interrogatories and production of documents below:


  • Question:  Have you filed a federal and state income tax return for the years 2009, 2010, 2011, 2012, and 2013?
  • Production of document request:  Please attach a copy of the above state and federal income tax returns to your Answers to these Interrogatories, including all amendments, attachments, schedules, K-1’s, partnership form 1065’s, Form 1120’s, 1099’s, cost basis statements and W-2’s and draft returns for 2010 if not yet prepared.  Attach all the above K-1’s, 1065’s, W-2’s, 1120’s, 1099’s and all other tax documents regarding your income (joint and sole) for 2009 through 2013.
  • Question:  Identify each employment-related and/or employer-provided pension, profit-sharing, annuity plan, savings plan, IRA, 401(K), Keogh, SKEPP, SERP, PRA, benefit continuation plan, gross up payment plan, ESAP, SRP and pension plan, or other deferred compensation plan or account, or accrued leave with pay plan in which you now have and/or have had, in the last 5 years whether vested, non-vested, qualified, non-qualified, contingent or otherwise for all employers and entities.
  • Question:  During the course of your marriage to Defendant, did you engage in or have extra-marital sexual contacts or an affair?   If yes, please provide the name, address and telephone number of the person(s) you are engaged in an affair or extra-marital contacts with.
  • Question:  What parenting time would you propose to foster and encourage a good parent child relationship with your spouse?

Interrogatories are a tool used by Michigan divorce attorneys in almost every divorce and custody case.  A properly prepared case insures that you understand the nature and extent of the marital estate and custody considerations before you settle your case or go to trial. We want to help you manage your situation.  Let our Michigan divorce attorneys help.

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I have been exclusively practicing divorce and family law in Michigan for over two decades.  The attorneys at Findling Law all share the core value of practicing law to help people navigate change in their lives, without compromising principles.  We specialize in high socio-economic, high-profile and high-conflict cases, while also working with clients of all backgrounds. We recognize that the most important aspect of the practice of law is the application of the law to your specific circumstances.

That is why we provide more free information on divorce and family law than any other Michigan law firm. We want to help you manage your situation. Allow our exceptional legal team to help you navigate the change in your life, without compromising principles.

We want to help you manage your situation. Let our exceptional legal team help you . . .


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By:  Daniel Findling

(c) 2014 Findling Law The Divorce Guy, Michigan Divorce Attorneys and Specialists. 877-YOUR FIRM Daniel

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