STATE OF WISCONSINCIRCUIT COURTOUTAGAMIE COUNTY

In the Interst of:Case No. XXXXXX

XXXXXXXX

a person under the age of 18

(d/o/b): XX/XX/XXXX

PETITIONER’S FIRST SET OF WRITTEN INTERROGATORIES TO RESPONDENT AND REQUESTS FOR PRODUCTION OF DOCUMENTS

TO:XXXXXX

c/o Attorney XXXXXX

Wisconsin State Public Defender’s Office

XXXXXX

XXXXXX

PLEASE TAKE NOTICE that Petitioner, XXXXX, by her attorneys, XXXXXX, herby request [Birth father] to answer the following Interrogatories in writing and under oath within thirty (30) days hereof, in accordance with Wis. Stats. §804.08, and to produce documents in accordance with Wis. Stats. §804.09.

Answer each Interrogatory separately and fully, in writing, under oath, unless it is objected to, in which event the reasons for objection muse be stated in lieu of your answer. Invasive or incomplete answers deemed to be failure to answer under Wis. Stats. §804.12.

You are under continuing duty to reasonably supplement your responses with respect to any questions directly addressed to the identity and location of persons having knowledge of discoverable matters, and the identity of each person expected to be called a witness. Furthermore, you’re under a similar duty to correct any incorrect responses when you later learn that it is incorrect.

DEFINITIONS AND INSTRUCTIONS

  1. “Document” is used in the broadest possible sense and refers, without limitation, to the originals (or any copies when originals are not available), and any non-identical copies (whether different from the originals or otherwise) of any written printed, typed, photostatic, photographed, recorded or otherwise reproduced communications or representation of every kind and description, and including, but not limited to correspondence, notes, minutes, records, messages and internal memoranda, diaries, reports contracts, invoices, compilations, studies, summaries, analyses, tables and tabulations, account records, financial statements, invoices, ledgers, accounts receivable ledger, accounts payable ledger, working papers, tallies, maps, diagrams, charts, plans, pictures, facsimile, computer-stored or computer-readable data, computer printouts, teletype messages and other communications can be obtained, and any preliminary versions, drafts, or revisions of any of the foregoing. Any document that contains any comment, notation, addition, signature, insertion, or marking of any kind, so that it is different from the original, is a separate document.
  2. “Document” includes the file and folder tabs associated with each such aforesaid original and/or copy, all correspondence transmitting such document or explaining or commenting on the contents thereof, and all working supporting papers. “Document” also includes the file and folder tabs, etc.
  3. “You” or “your” includes, and without limitation, any counsel, consultants, experts, investigators, special administrators, agents, or other person acting on your behalf.
  4. “Identify” has the following meanings:
  5. When used in reference to a document, it means to state:
  6. The date and description of the document;
  7. The document’s present location and the name and address of its custodian;
  8. The name and address of the person who drafted, prepared, and signed the documents, along with the name and address of his or her current employer; and
  9. Any other descriptive information necessary to adequately describe the document.
  10. When used in reference to an individual person, it means to state:
  11. The person’s full name;
  12. The person’s last know residential address and telephone number; and
  13. The person’s last known employer, business address, and business telephone number.
  14. When used in reference to communication that is not a document, it means to state:
  15. The date of the communication;
  16. The place where the communication occurred;
  17. The type of communication occurred;
  18. The content of the communication;
  19. The name and address of the parties to the communication; and
  20. The name and address of all others who participated in or witnessed the communication.
  21. “Person” or “persons” refers to any natural person or any entity other than a natural person, sole proprietorship, partnerships, limited partnerships, corporations, associations, joint ventures, co-ventures, and any other entity of any description or nature whatever, as well as all divisions, departments, affiliates, subsidiaries, or other subunits of the foregoing entities.
  22. If you object to any interrogatory of document requires, state the following:
  23. The nature of the privilege or doctrine you claim;
  24. If a document:
  25. Identify if and state the date on which and the purpose for which it was prepared; and
  26. Identify all persons to whom the substance of the document has been disclosed.
  27. If any oral communications:
  28. Identify all persons to whom the substance of the oral communication has been disclosed (including all personal present when the oral communication was made).
  29. The discovery requests to which these definitions and instructions may apply are continuing and require supplemental responses pursuant to Wis. Stats. §804.01(5).

INTERROGATORIES

INTERROGATORY NO. 1:

State the full name of the person preparing the answer to these interrogatories and the name of any person assisting in the preparation of the answers?

INTERROGATOY NO. 2:

State whether you have in your possession, custody or control, any written or recorded statements made by or attributed to the Petitioner, XXXXXX, concerning the allegations contained in the Petition for Termination of Parental Rights (hereinafter TPR petition), and the name, address and phone numbers of witnesses to the Petitioner’s, XXXXXX, statements.

INTERROGATORY NO. 3:

State all names, occupations, addresses and telephone numbers of all witnesses, including expert witnesses, you intend to call at the trial.

INTERROGATORY NO. 4:

Set forth a synopsis of testimony from each witness, including expert witnesses, listed above, including their educational background, reports and conclusions, if any.

INTERROGATORY NO. 5:

State all physical evidence that you intend to offer in evidence at the trial, as well as all other physical evidence within you possession, custody, or control or within the possession, custody or control of you investigative agencies or agents.

REQUESTS FOR PRODUCTION OF DOCUMENTS

You are required to send to [attorney] within (30) days of the date herein the documents requested below or a statement that you do not have and cannot locate such documents. If you have or can obtain the documents, if must be furnished.

REQUEST NO. 1:

Produce a copy of your driver’s license.

REQUEST NO. 2:

Produce copies of all wage statements from January 1, 2016 to date.

REQUEST NO. 3:

Furnish a full copy of your state and federal tax returns from 2014 and 2015.

REQUEST NO. 4:

Furnish copies of any photos, notes, records, emails, faxes, text messages, Skype messages, memos, diaries, records in anyway related to communications between you and [birth mother].

Dated this ____ of XXXXX, 20XX.

XXXXXX

Attorneys for Petitioner

By: ______

XXXXXX

State Bar Number: #XXXXXXX