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Specially prepared interrogatories

Chula Vista, CA |

This was served to me by my exhusbands attorney. The paperwork states that I have to submit my responses to his attorney in person. I cant afford an attorney and im not comfortable seeing his attorney by myself. Why cant these documents be given to the judge at the child support mod hearing which is BEFORE this deadline? If the judge rules on the support issue, wouldnt this Special Interrogatories issue be voided? Seems like a lot of paperwork to ask me how come im a stay at home mom. How many ways can i NOT hide the fact that I dont have an income? Is this what attorneys do for their clients when the client has no grounds for a support mod? Bury the other party in paperwork.

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Attorney answers 5


You have 35 days from the date they were mailed to you to respond to them. If they were personally served, you have 30 days from the date you were personally served. You do not have to personally deliver the responses. You can mail them when they are due, with a proper proof of service by mail signed by someone other than you, over 18, and not a party. Have a friend put them in the mail, and sign the proof. Your answers must be verified under penalty of perjury. if the hearing is set for a time before the responses are due, the other side may ask for a continuance to get the responses. I would not assume they are moot if the hearing goes forward. Instead, I would ask the judge and opposing counsel in open court at the end of the hearing, if you still need to respond. If they say no, make sure that is included in the court order.



You have been very helpful. Thank you for your thoughtful response.

Donald Frederick Conviser

Donald Frederick Conviser


There could be serious consequences if you fail to timely and/or properly respond to the interrogatories. However, how you answer the questions (or properly object to any of them) is critically important. Get assistance from an experienced Family Law Attorney in responding and/or objecting to the interrogatories. Objections are highly technical, requiring somebody who knows the evidentiary rules to make proper objections. Good luck.


You should see if your local court has a pro se assistance program or if there is some other program that helps people with low income in this type of case - otherwise an attorney is what you need.

Under the rules governing the conduct of attorneys in New York it may be necessary to remind you that this answer could be considered attorney advertising.


The special interrogatory is designed to trap you into a position that can be used against you in front of the judge, perhaps at trial or hearing.

Since you aren't using an attorney you should take some hours of your own time to study up on the meaning of what the trap is and then avoid it.

Good luck. It will take you a while to learn what is needed to know so do no delay in starting.


The intended purpose of interrogatories is to obtain information necessary to assist the Judge in making a proper decision. Counselor Brinkmeier is correct, often opposing attorneys attempt to "trap" or get a competitive advantage over you through your failure to timely respond, failure to follow the local rules or to illicit/trick you into giving incomplete or even inaccurate information they then will use against you. That is why you must seek the assistance of competent counsel. In Illinois, the statute allows parties who cannot afford counsel to seek to have their attorney's fees paid by the other party. You should make an appointment today with an attorney who regularly practices in contested child support matters in your county to see if California law allows you to seek have the other party pay to "even the playing field".

Of course, as always this answer is general in nature, applies only to Illinois law, assumes certain facts omitted from the question and does not take into account any facts specific to any person’s particular circumstances. No attorney/client relation is created hereunder and I highly recommend you seek first the counsel and advice of an experienced contested civil litigator prior to taking any actions relating to this matter, as seemingly insignificant actions may have unintended consequences.


You do not have to serve the attorney in person, have them mailed by someone over the age of 18 who is not a party to the case and fill out a proof of service. The time for response should be before the date of hearing, so you may want to double check the due date. Provide honest answers and the requested documentation. It is a stressful thing to deal with, but you could seek help from the facilitators office at the family court. You could also have an attorney review those questions on a limited scope basis if you are afraid of being caught in the traps the other attorneys have referenced. Support is based mainly upon income and percentage of time share that the judge inputs into a computer program. The specials (without seeing them) seem to be used as an attempt to alter the base amount that the computer comes up with and/or to prove you have income or assets that you have not disclosed. You may be asked to diligently look for work or have minimum wage imputed to you. I would at very least consult with an attorney. Good luck.



Thank you for your answers. I already agreed to impute my income at min wage in my response which is what they were asking for. During the child support mod hearing, his attorney decided to try and impute me at a much higher income. For a job ive never had. I disagreed and asked for a continuance. I received the spec interrogs two days later. Yes, the date for submitting the interrogs is 2 weeks after our support hearing. Go figure

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