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Child Custody Prep & Interrogatories

Updated on May 18, 2013

noun in•ter•rog•a•to•ry
plural in•ter•rog•a•to•ries
A formal question or inquiry; especially
A written question required to be answered under direction of a court

Interrogatories (also known as requests for further information) are a formal set of written questions propounded by one litigant and required to be answered by an adversary, in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case. They are an important key in a custody challenge.


This issue is the most emotional and traumatic part of most divorce cases. There is sole, joint legal, joint physical, and "bird nest" custody. The basis for determining child custody is "what is in the best interests of the child." Due to the extensive nature of custody disputes and the laws involved, this subject is best left to an in-depth discussion with your attorney.

You are advised to read and study the child custody law. A party involved in a child custody matter should become acquainted with their state's Child Custody Act. This can be found in your state's statute books, which can be found at most public libraries. It will take a little research, so ask the librarian to help if you have trouble finding the statute. You should it and be prepared to give their reasons for wanting custody pursuant to the following factors:

This information packet has been provided to assist you in establishing whether or not custody should be changed and, if so, the criteria followed and the information needed to help make your quest for custody possible.

Should you decide to pursue an action to change custody, please ask for a similar fact finding sheet to complete for office purposes.

Information provided to your attorney should include incidents and behaviors pertaining to both parents and any other parties directly involved in the case. As in all other matters connected with your divorce or a petition to change custody, you should always provide your attorney with all the facts, so he/she can determine how and when to use the information you provide.

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The following questions may be used in two ways.

  1. To give the attorney and his staff background of your case (even though you may have verbally provided much of this information, it is now in writing and readily accessible by anyone else in the office working on your case).
  2. As interrogatories to be presented to the other party. In interrogatories (question s) are used as the first form of discovery.

Please remember that the questions asked may not necessarily be applicable to you exactly as worded. If the question says child and you have children or if it says wife and you were not married, the question still needs to be answered. Just provide the Information requested as it applies to you in general terms.

You should print or type your answers. Many libraries have computers you can use for this purpose. Hand printing your answers and then typing them from your notes allows you to go over your notes and add something you may not have thought about the first time you wrote the answer.

    1. When did you meet the other party in this matter?

  • What was the length of your courtship?
  • When did you marry, begin living together or commence a sexual relationship with this person?
  • What were the circumstances surrounding the marriage/relationship?
  • What attracted you to him/her?
  • The age of the parties at the time of the commencement of this relationship:

    Man: _____ Woman: _____

  • Describe your family history: (your mother, father, siblings, alcoholism or drug usage, abuse, stars, black sheep)
  • Describe the family history of your (former) mate:
  • How did the children come about? (planned, unplanned, etc.)
  • Children's names and birth dates: (Names, Birth dates, Grades, Schoolteacher's names)
  • Children of prior marriages/relationships: (Names, Ages, with whom does the child(ren) reside) Man: _____ Woman: _____
  • Describe the deterioration of the relationship:
    1. Date of marriage (or commencement of the sexual relationship or cohabitation, date of separation/divorce).
    2. Who left the marital home? (circle one) Man Woman
    3. Who had the children at the time of separation? (circle one) Man Woman
    4. Who filed for divorce and when?
    5. If this is a paternity/custody action, please provide the appropriate history (suit filed, blood tests, and acknowledgment of paternity)
    6. Were there other known relationships at the time of the divorce/separation? Man: _____ Woman: _____
    7. What was the date of the Judgment of Divorce (provide copy)?
    8. What has the arrangement (custody/visitation) been with the children (provide copies of all custody/visitation/ support orders)?
    9. When was the last visit with the children by the non-custodial parent?
    10. If visitation has ceased, please provide explanation:
    11. Do you attend church? (circle one) Yes No
      If yes, what is the name of the church?
      What type of religion is this church?
      How long have you been a member of this church?
      Were there prior church affiliations during your marriage?
      If so, what was the name of the church and how long were you a member with that church?
      Do your children attend church with you? (circle one) Yes No
      If yes, what activities are they involved in with the church?
      How often do the children attend church?
      With you?
      With the other parent?
    1. List all residences since separation/judgment of divorce: (Addresses, Dates Lived In, and Reasons Moved) Man: _____ Woman: _____
    2. Who is residing in your home? (include adults and children in the home. Provide names, ages, occupations and person's relationship to you)
    3. Describe your residence and explain why it is suitable housing for the children.
    4. Describe your spouse's/mate's residence and explain why it is not suitable housing for the children.
    5. Have you remarried since the judgment of divorce? If so when and to whom?
    6. If not married, are you currently dating or involved in a relationship with someone else? If so, please provide the name, address and phone number of this person.
    7. Please provide your former spouse/mate's current marital status or ongoing relationships, if any:
    1. Do you have a history of alcohol/substance abuse or incidents of spousal abuse/stalking, phone harassment charges? Yes No
      If yes, list the dates of arrest(s), sentence(s) and treatment(s): (dates charged, sentences, types/ places of treatment, dates completed)
    2. Please provide any other pertinent information as to the previous question (provide copies of police reports, if possible)
    3. Does your (former) spouse/mate have a history of alcohol/substance abuse or incidents of spousal abuse/stalking, phone harassment charges? Yes No
      If yes, list the dates of arrest(s), sentence(s) and treatment(s): (dates charged, sentences, types/places of treatment, dates completed)
    4. Please provide any other pertinent information as to the above question (provide copies of police reports, If possible)
      Have you ever been involved in counseling? If so, when, where, why and with whom? List the counselor's name, agency and address:
    5. Has your (former) spouse/mate ever been involved in counseling? If so, when, where, why and with whom? List the counselor's name, agency and address:
    6. Have any of the children even been involved in counseling?
      If so, when, where, why and with whom?
      List the counselor's name, agency and address:
    7. Do you feel that you have emotional problems?
      Please describe.
    8. Do you feel that your (former) spouse has emotional problems?
      Please describe.
    9. Do you have physical health problems?
      If so, describe what conditions, how long have you had the condition, the treatment for the condition, the name, address and phone number of the physician responsible for care of this condition.
    10. Does your (former) spouse/mate have physical health problems?
      If so, describe what conditions, how long he/she has had the condition, the treatment for the condition, the name, address and phone number of the physician responsible for the care of this condition.
    1. Please list each child living in the home (note their relationship to you) and briefly describe:
      a. The personality of each child.
      b. The school activities and interests of each child.
    2. Do any of the children have special educational or emotional needs, that is, have they been placed in a program through the schools to receive special services?
      If so, describe the disability and the length of time they have received services. If possible, provide the name and address (school) of the person providing the service or the name of the school counselor or administrator
    3. How have you participated in the educational development of your child since the separation and judgment of divorce?
      (Please be specific)
    4. Would there be a significant difference in the education opportunities offered by either parent?
      If so, describe with specifics.
    5. Do any of the Children have physical health problems?
      If so, describe.
    6. How do you discipline your children?
      What methods do you use?
      Are they effective?
    7. How does your (former) spouse/mate discipline your children?
      What methods does he/she use?
      Are they effective?
    8. List each child individually and list the most difficult behavior for you to handle?
    9. What are your faults or weaknesses as they pertain to the children?
    10. What are your strengths as they pertain to the children?
    11. Is the children's medical care current? Yes No
      If no, please explain.
    12. Does either parent object to medical care in general?
    13. Which parent has been most involved in obtaining medical care for the children?
    14. Has there ever been any complaint registered that the children have no t received the necessary or needed medical care? Yes No
      If yes, please explain:
    15. Has child protective services ever been contacted regarding the care/control of your children? Yes No
      If yes, describe when, who and why and the disposition of each incident?
    16. What is the most rewarding thing for you as a parent in parenting each child?
    17. In your opinion, what are the most important lessons you want your children to learn in life?
      How are you teaching them this lesson?
    18. Please describe your childcare plan or proposed childcare plan, Include the name and address of the baby-sitter or day care center.
    19. Describe your relationship with your children:
    20. Describe the relationship of the other parent to your children:
    21. What are the changes in circumstances since the separation/judgment of divorce that has lead to this change of custody petition?
    22. What have you told your children about the pending (change of) custody petition or divorce?
    23. How do you discuss divorce/custody issues with the children?
    24. What are you hoping will be the outcome of this litigation?
    25. What type of involvement would you like your children to have with the other parent and the relatives of the other parent?
      How would you facilitate the relationship?
      (Please describe with specifics.)
    26. What activities doe s the child share with each parent?
    27. What is each parent's perception of the children's attachment to all family members?
    28. What evidence do you offer to justify your perception?
    29. Do the children experience privileges with one parent that they do not with the other?
    30. Who do the children go to for attention, affection, and advice?
    31. Who initiates affection or interaction? How is it displayed?
    32. Do the children demonstrate any conflicts of loyalty when with one parent?
    33. How does each parent demonstrate their love and affection for the children and how consistent is it?
    34. Has either parent been abusive to the children? In what ways?
    35. What is the current environment with regard to housing, location, cleanliness, household furnishings, play area, etc.?
    36. What is the pro posed environment?
    37. Are there influences in either home that might induce delinquent or criminal associations? If so, please explain.
    38. Has the other parent attempted to remove or destroy the relationship between the children and you? If so, please explain.
  • Please provide any other information pertaining to you, the child's other parent, and the other children in the family/home that may have an impact on this case. Of great interest to the courts in is the determination of the primary parent. The following is the Michigan Child Custody Act (MC LA 722.23). It uses the following provisions to assist the Court in determining the best interest of the minor child. (Your state may have some differences, and it is suggested that you go to the local library to look them up. A reference librarian can help to locate the state statute books.) Please provide information under each point as it pertains to both parties (good and bad).
    1. The love, affections and other emotional ties existing between the parties and the child.
    2. The capacity and disposition of the parties involved to give the child love, affection, guidance, and continuation of the educating and raising of the child in its religion or creed, if any.
    3. The capacity and disposition of the parties involved to provide the child with food, clothing, medical care or other medical care recognized and permitted under the laws of this State in place of medical care and other material needs.
    4. The length of time the child has lived in a stable, satisfactory environment, and the desirability of maintaining continuity.
    5. The permanence, as a family unit, of the existing or proposed custodial home or homes.
    6. The moral fitness of the parties involved.
    7. The mental and physical health of the parties involved.
    8. The home, school and community record of the child.
    9. The reasonable preference of the child, if the Court deems the child to be of sufficient age to express preference.
    10. The willingness and ability of each of the parents to facilitate and encourage a close and continuing parent-child relationship between the child and the other parent.
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In establishing which parent is the primary caretaker, the trial court shall determine which parent has taken primary responsibility for, among other things, the performance of the following caring and nurturing duties of a parent:

  • preparing and planning of meals;
  • bathing, grooming and dressing;
  • purchasing, cleaning, and care of clothes;
  • medical care, including nursing and trips to physicians;
  • arranging for social interaction among peers after school, i.e., transporting to friend's houses or, for example, to girl or boy scout meetings;
  • arranging alternative care, i.e. baby-sitting, day-care, etc.;
  • putting child to bed at night, attending to child in the middle of the night, waking child in the morning;
  • disciplining, i.e. teaching general manners and toilet training;
  • educating, i.e. religious, cultural, social, etc.; and,
  • teaching elementary skills, i.e. reading, writing and arithmetic.

You should also give great consideration to the witnesses you can provide. You will need witnesses that can testify for you. You will also need witnesses that can testify that your (former) spouse/mate should not have the custody of the children.

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      6 years ago

      Great lens, enjoyed reading it. Keep up squidooing :)


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