SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
FAMILY COURT
Domestic Relations Branch

PLAINTIFF'S INTERROGATORIES TO DEFENDANT

Plaintiff, Oksana Shemet Shaddock, by and through her counsel, Robert Case Liotta, hereby propounds the following Interrogatories to Defendant, Frederick Shaddock:

Definitions and Instructions

(a) Pursuant to the provisions of the D.C. SCR-Dom. Rel. 33, Defendant must file a response to these Interrogatories within thirty (30) days, and answer each interrogatory separately and fully in writing under oath.  These Answers to these Interrogatories must include all information available to the Defendant either directly or through his agents, representatives, or attorneys.

(b) These Interrogatories are continuing in character and, therefore, require you to timely file Supplementary Answers if you obtain further or different information before trial.

(c) Where the name or identify of a person is requested, please state the full name, home address and telephone number, and business address and telephone number, if known.

(d) If you object to an Interrogatory and/or assert that a matter is privileged, you must state with specificity the reasons for your objection and/or the basis for your claim of privilege.

(e) The pronoun "you" refers to the party to whom these Interrogatories are addressed and the persons mentioned in clause (a).

(f) "Employer" means any person that has compensated, or is obligated to compensate, you for your services.

(g) "Fringe benefits" include: (1) contributions made by your employer to health insurance, life insurance, disability insurance, pension, profit sharing, or retirement plans; and (2) employer reimbursements or payments that reduce your personal living expenses such as use of a company car, expenses accounts, and housing.

(h) "Wages" include hourly wages, salary, bonuses, tips, incentive awards, fees, commissions, self-employment income, and overtime pay.

Interrogatories

1. Identify yourself and all individuals with whom you reside, including for each individual, that person's age, relationship to you, marital status, and specify the period of time that each individual has resided with you.  State your own birth date and social security number as well as those for any aliases you may go by.

2. State all addresses at which you have resided from 2001 to the present, specifying whether you rent or own, and whether anyone else has contributed to the rent and/or mortgage payments,  including in your answer any and all amounts received from others and identify those individuals.

3. State the city and state where you lived when you met your husband.

4. It is agreed and understood that you are a native in the country of Russia.  Please state when you came to the USA, how and why you came to the small town of Fairfield, Iowa, and describe in detail the circumstances which led you to come to the USA.  By way of example, whether someone else provided the money for your air travel and costs, and the circumstances of how you came to know that person or groups.

5. Describe your educational background, including any specialized training, and state in your answer the highest grade you completed; the name and date of any degree, diploma, license or certificate you received, the name of the institution conferring the degree, diploma, license or certificate.

6. Please identify your current employer, including in your answer your job title, duties, the number of hours in your average work week,  your regular pay period, your gross wages per pay period, and the deductions per pay period made by your employer from your wages.

I am unemployed, but looking, so none of the above apply.

7. Identify the sources and amounts of all taxable and non-taxable income you received during the past five years.

8. List each item of property in which you have any interest, including in your answer, how each property is titled, its value, the amount of any present lien or mortgage on the property, the date of acquisition of the property, and the identity of any other person with an interest in the property.    This specifically includes any interest in any real property in Russia, or any other foreign nation.

9. If you claim that any property listed in your answer to Interrogatory No. 6 is non-marital, please specify why you claim the property is non-marital and the facts upon which you base your claim, including all sources of funds used to acquire the property and identify all persons with knowledge of those facts.

10. Please specify which property listed in your answer to Interrogatory No. 6 is marital, and please state the facts upon which you base your claim, including all sources of funds, if any, you used to acquire the property and identify all persons with knowledge of those facts.

11. Does any person (including relatives) or firm owe you a debt of more than $1000?  If so, state the name of the person or firm, the nature and the amount of the debt and the date on which the debt is due.

12. Do you owe any debts to any person, real or corporate?  If so, state the name of the person or corporation, the nature and amount of the debt, the date on which the debt is due and the amounts paid in reduction of the debt.

13. Please identify any and all checking, savings, credit union, money market, IRA, Keogh and 401-K accounts or CDs held in your name individually or with someone else subsequent to January 1, 2001, and include in your answer the name of the institution, the type of account, the account number, how it is titled, the balance on January 1, 2001 and the present balance.

14. Please state whether you have any life insurance policies and/or annuities, and if so, please identify the company, the type of policy, the present value of the account, and name each beneficiary.

15. Identify all major items of household furnishings/personal effects owned by either you or the Plaintiff having an estimated resale value in excess of $500.

16. State the date on which you and your spouse last had sexual relations.

17. If you have had sexual relations with a person other than your spouse during your marriage, identify the person(s) with whom you have had sexual relations, state the date of each act of sexual relations, and state the location where each act took place.

18. Please state the true date on which you separated from your spouse and describe the circumstances of the separation.

19. Please specify your monetary, as well as non-monetary, contributions to the well-being of your family throughout your marriage.

Respectfully Submitted,

___________________________
Robert R. Stone, Esq.
PO Box 10041
Arlington, VA  22202
202-744-2618
DC Bar No. 139-032

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 2nd of June 2008, a copy of the foregoing PLAINTIFF'S INTERROGATORIES TO DEFENDANT was sent via first-class postage prepaid to Robert Case Liotta, Esq. PO Box 100411, Arlington, VA  22201.

____________________
 

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
FAMILY COURT
Domestic Relations Branch

CERTIFICATE OF DISCOVERY

I HEREBY CERTIFY, that on this 2nd day of June 2008, a copy of Plaintiff's Interrogatories and Request for Production of Documents was sent via first-class, postage pre-paid mail to Robert Stone, Esq., PO Box 100411, Arlington, VA  22201.  I will retain the original in my possession, without alteration, until the case is concluded in this Court.

Respectfully Submitted,

___________________________
Robert R. Stone, Esq.
PO Box 10041
Arlington, VA  22202
202-744-2618
DC Bar No. 139-032

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 2nd of June 2008, a copy of the foregoing PLAINTIFF'S INTERROGATORIES TO DEFENDANT was sent via first-class postage prepaid to Robert Case Liotta, Esq. PO Box 100411, Arlington, VA  22201.