Interrogatories

[Tennessee Dad]

Background:  I am NCP of 6yo daughter, and have filed for change in custody.  Our basis is the fact that I have had daughter 60% or more of the time on average the last 3 years.  BM and I divorced when daughter was only 3 months old.  The original MDA stated custody subject to modification when the child was 3.  

We have received a set of interrogatories from BM's attorney.  It looks like the standard questions from a divorce proceeding, i.e., regarding debts, assets, money transfers the last three years, etc.  I understand the importance of income, but debt?  I will have to spend hours trying to locate all this information.  My attorney is out of town, or I would be asking her this question.  

1.  Will I be required to answer all these questions, or can they be objected to as irrelevant?  

Thanks, as always, for your reponse.

[socrateaser]

>1.  Will I be required to answer all these questions, or can
>they be objected to as irrelevant?  

If the only issue before the court is custody, and neither party has filed a motion to modify support, then any question about assets, liabilities, income, expense or equity is probably objectionable as "not reasonably calculated to lead to the discovery of admissible evidence."

If there is a motion to modify support before the court, then income is "reasonably calculated," and debt may be.

[Tennessee Dad]

Thank you; that's what we thought!

The only petition filed is for change of custody to Father.  Mother has not filed anything re: child support.