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Messages - TJRodolph

#41
Dear Socrateaser / RE: Interrogatories UPDATE
Mar 01, 2006, 10:06:46 AM
OOOO YOU ARE GOOD! Thanks for the empowerment...I will do EXACTLY as you suggest....in fact I am writing it down and memorizing it so I can recite it word for word.  I'll update you on March 24th! Thanks again.
#42
Dear Socrateaser / RE: Interrogatories UPDATE
Mar 01, 2006, 08:57:51 AM
Ok, I filed my Motion to Compel Discovery today....and the clerk let me have the same date/time as my 1st hearing for the change of custody, which is March 23rd. I figure it will show that I was doing my ex a favor by not making her have to buy 2 plane tickets for 2 diff hearings. I am serving her (via mail) her copy tomorrow.

I am positive the Referee will order her to provide me that info as I am entitled to it. I am quite sure ex will not bring with her any of the doctor's names, addresses, phone numbers, or school info, all her employer's info, etc.

Questions

1. Will the Referee give the ex X amount of days to provide it to me in writing?

2. What is the standard amount of time Referees/Judges give for a deadline?

2. What would be my next step if/when ex does not send it to me in writing by the deadline?

3. Or will the Referee order her to get the info that day, one way or another and provide it to me immediately?
#43
Dear Socrateaser / RE: Interrogatories UPDATE
Mar 01, 2006, 12:43:10 PM
I just thought of something...

Question:

1. If it got to the point where I needed to file contempt for ex not providing me the info, and I also wanted to file for temporary sole custody simultaneously....How would I get the court to approve that since my ex and son live in OH and I am in MN?
#44
Dear Socrateaser / RE: Interrogatories UPDATE
Mar 01, 2006, 10:06:46 AM
OOOO YOU ARE GOOD! Thanks for the empowerment...I will do EXACTLY as you suggest....in fact I am writing it down and memorizing it so I can recite it word for word.  I'll update you on March 24th! Thanks again.
#45
Dear Socrateaser / RE: Interrogatories UPDATE
Mar 01, 2006, 08:57:51 AM
Ok, I filed my Motion to Compel Discovery today....and the clerk let me have the same date/time as my 1st hearing for the change of custody, which is March 23rd. I figure it will show that I was doing my ex a favor by not making her have to buy 2 plane tickets for 2 diff hearings. I am serving her (via mail) her copy tomorrow.

I am positive the Referee will order her to provide me that info as I am entitled to it. I am quite sure ex will not bring with her any of the doctor's names, addresses, phone numbers, or school info, all her employer's info, etc.

Questions

1. Will the Referee give the ex X amount of days to provide it to me in writing?

2. What is the standard amount of time Referees/Judges give for a deadline?

2. What would be my next step if/when ex does not send it to me in writing by the deadline?

3. Or will the Referee order her to get the info that day, one way or another and provide it to me immediately?
#46
Dear Socrateaser / RE: Interrogatories
Feb 27, 2006, 02:51:56 PM
PERFECT! thanks! I also plan on submitting a supplemental affidavit to my motion to change custody, so the judge can have a chance to read all the interrogatories and her response before we even get there. Our 1st hearing is March 23rd. Tomorrow I will file the Motion to Compel.
#47
Dear Socrateaser / Interrogatories
Feb 27, 2006, 11:56:05 AM
Hi again Soc,

I have sent a 2nd request telling the custodial mom to respond to my interrogatory or I will file a Motion to Compel. She finally responded. But she didn't give me the info.

I asked what the name of her various employers, address and work schedule has been for past 2 years, and her answer was : This is not your concern.

I asked how many hours a week my son spends at his grandfathers house. Her answer was: This is not your concern.

I asked for my son's school address and teacher. Her response was: will be discussed in court.

I asked what health insurance our son was covered under since she doesn't use my insurance that I provide. Her answer was: Will be discussed in court.

I asked how many times our son has been to see the therapist in the past year. Her answer was: he does not see a therapist, he attends group therapy at school.

She further states in her letter that she does not appreciate me making false allegations against her, that I am being vindictive because she won't pay her 1/2 of the airfare and that I should spend all my time, energy and money into working overtime to pay for my son's airfare rather than harassing her.

Questions

1. Since she did send a response to my interrogatory, does this mean I cannot file a Motion to Compel since she refuses to answer the majority of the questions?

2. Considering her defensiveness, unwillingness to cooperate, and trying to blame me for her actions, could I bring up in the 1st hearing that I want her psych tested for some sort of Borderline Personality Disorder and or High Conflict Personality Disorder?

#48
Dear Socrateaser / RE: Interrogatories
Feb 06, 2006, 05:14:48 PM
Thanks again!!
#49
Dear Socrateaser / RE: Interrogatories
Feb 06, 2006, 02:38:36 PM
Questions:

1.  When I go to file a Motion to Compel Discovery since the CP has not responded to my 2nd request....what sanctions could she be hit with?

2. Can she be charged with contempt for not responding to the Interrogatory?

#50
I will probably just wait and see what the judge does with her letter, as I do not want the judge to think I am just trifling or being unreasonable. I just dont feel she should be allowed any leniency.

However, her reason for requesting a later date is to suit her own agenda, to accomodate HER work schedule, and HER finances. She is the one that has violated a few different issues in the court order. She comes up with an excuse for every single thing I have voiced concerns about. I have not violated one thing in the order.

The only thing I feel really good about is that the judge was on my side during the parenting time hearing, and it showed in the order she signed. I am hoping she is on my side again.

questions

1. So what would be the proper way to let the court know that I think the other parties communication is improper and that I want to keep the current date?

2. Wouldnt it look bad on the other party for requesting a different date just to suit her personal agenda?