STATE OF _______________ ) ) SS COUNTY OF ______________ ) IN THE CIRCUIT COURT OF ______________________ COUNTY JUVENILE COURT DIVISION In The Interest of: _______________________, AGE ______ _______________________, AGE ______ ) ) ) ) ) ) ) ) ) Cause No.: No._______________ No._______________ FIRST SET OF INTERROGATORIES PROPOUNDED TO THE JUVINILE OFFICE AND TO THE DIVISION OF FAMILY SERVICES COMES NOW, _______________________________________________________, the natural/common parents of the children in above caption matter, and propound the following Interrogatories to be answer under oath and in accordance with (insert your state) Rules of Civil Procedure by the JUVENILE OFFICE, the (insert your state) DIVISION OF FAMILY SERVICES 1. State the name, address, telephone number, and title of each and every person answering these Interrogatories or providing information for the answers to these Interrogatories and identify each Interrogatory answered or in which information was provided by each person. ANSWER: 2. State the precise acts with which have been alleged to have been perpetrated or committed by MR. JOHN DOE and/or MRS. JANE DOE with regard to each child and the following; A. Date and time of act B. Place where the act occurred C. Name of the child involved D. Complete description of an act E. Names and addresses and telephone numbers of all persons witnessing the act F. Describe how JOHN DOE and/or JANE DOE were involved and/or what acts they participated in or Failed to participated in with regard to each ANSWER: 3. State whether or not the Juvenile office expects to or may call any expert witness and if so the following: A. Name, home address and home telephone number of the expert B. Name, employment address and employment telephone number of the expert C. Name of the expert's employer D. Complete description of the qualifications, background and credentials of any expert E. Whether or not the expert is retained or non-retained F. Hourly deposition rate of each expert G. Complete summary of the facts and opinions about which the expert is expected to testify ANSWER: 4. State whether or not any statements have been made or given by JOHN DOE or JANE DOE, individually or jointly, and if so the following A. Name of Person making the statement B. Name and address of the person taking the statement C. Whether or not it was recorded, transcribed or otherwise memorialized D. Names, addresses and telephone numbers of all persons witnessing the statement E. Date and time of statement F. Place where the statement was made G. Complete description and transcript of the statement ANSWER: 5. State whether or not any statement have been made or given by Son, or daughter1 and daughter 2,individually or jointly, and if so the following A. Name of person making the statement B. Name and address of the person taking the statement C. Whether or not it was recorded, transcribed or otherwise memorialized D. Names, addresses and telephone numbers of all persons witnessing the statement E. Date and time of the statement F. Place where the statement was made G. Complete description and transcript of the statement ANSWER: 6. State whether or not there were any video tapes, recording, pictures, photographs or other renderings, audio tapes, stenographic recordings or other mechanical recordings made with regard to any of the actions or conclusions of any action set forth in the Petition filed by the Juvenile Office and if so the following: A. Date and time it was taken B. Complete description of what is shown or portrayed C. Name, address and telephone of person taking, recording or photographing each D. Name, address and telephone number of person who has custody of each ANSWER: 7. State whether or not there has been meeting in which John Doe or Jane Doe attended, jointly or individually, with regard to the disposition of this matter and if so the following: A. Date and time of meeting B. Place of meeting C. Name, addresses, telephone numbers and employment of all persons in attendance D. Whether or not tape, transcript, recording or notes were made of the meeting E. Names, addresses, telephone numbers and employment of all persons making any such tape, transcript, recording or notes F. Complete description of all tapes, transcripts, recordings or notes. ANSWER: 8. State whether or not there has been any correspondence or delivery of any writings or letters of any kind between John Doe or Jane Doe and the Juvenile Office or any of its representatives, the Missouri Division of Family Services and any of its representatives, Son or daughter1 and daughter 2 and if so the following: A. Date and time of delivery or receipt correspondence, writing or letter B. Place where delivered C. Names, addresses, telephone numbers and employment of all persons witnessing the writing, letter or correspondence D. Complete description of all writings, letters .and correspondence ANSWER: 9. Please state whether or not JOHN DOE and/or JANE DOE have made any requests for accommodations under the Americans with Disabilities Act and if so, the following: ANSWER: A. Date and time of the request B. Name and address of the person making the request C. Complete description of the request made D. Complete description of all accommodations made or provide to John Doe and/or Jane Doe ANSWER: 10. Please state whether or not there have been any meetings during the pendency of this action in which John Doe and/or Jane Doe have participated with the Juvenile Office, the Missouri Division of Family Services, son and daughter1and daughter 2 and if so, the following: ANSWER A. Date and time of meeting B. Place of meeting C. Names, addresses and telephone numbers of all persons in attendance D. Complete description of what was said by each person or representative of any party. ANSWER: 11. Please State whether or not any investigation reports or supplemental reports pursuant to rule 118.03 of the Missouri Rules of Court and any social or home studies or evaluations have been made or any reports have been made with regard to the family and/or home environment and/or living conditions about and/or where John Doe and/or Jane Doe and/or son and/or daughter1 and daughter 2 have resided and if so the following : A. Name address and employer of the person making the report or study B. Date of the report or study C. Complete description of the report or study ANSWER: CERTIFICATE OF SERVICE A copy of the above and foregoing Interrogatories was mailed postage prepaid by first class mail this date of _____/______/2002 to: (You must list All Parties involved (DFS, Juvenile Officer, All Lawyers on the case here) _______________________ (your signature) Together for the Cause Brother Cletus A Note To Our Supporters: "FAMILIES AT RISK of AMERICA is a sane prescription for what ails our children, our schools and our communities. It's a no-nonsense, say-it-the-way-that-it-is, type of group. I hope that every parent and teacher will continue to have access to FAMILIES AT RISK'S outstanding up-to-date factual data. I also hope that every parent and teacher takes FAMILIES AT RISK'S superb advice to heart. Do not allow harmful CPS psychiatric diagnoses, treatments and drugs to ruin another child's life, another child's future." "I am only one, but I am one. I cannot do everything, but I can do something and because I cannot do everything, I will not refuse to do the something that I can do. What I do, I should do and what I should do, by the grace of God, I will do." ~ Edward Everett Hale United You Bargain! Divided You Beg! You can make a difference today! FAMILIES AT RISK of AMERICA needs your support to continue its work fighting for the right of Americans to be free of government tyranny at all levels and for restoration of the US Constitution as America's guiding charter. Come Join the cause! Please contact Families At Risk of America to see how you can support us. familiesatrisk@aol.com