Dave Jensen on Leadership: Five Tips Leaders Use to Manage Ambiguity

Dave Jensen on Leadership: Five Tips Leaders Use to Manage Ambiguity: Accept criticism as learning. Leaders who manage ambiguity well understand that they will make mistakes. They adopt the attitude that there is no failure only feedback. It's only failure if they choose not to learn from the experience. Even when they are being criticized by others, they choose to interpret the criticism as learning.

UPL

UPL? Watch For These Red Flags
By Vicki Voisin, ACP

Generally, the practice of law is defined as giving legal advice or opinions to others or representing others in legal matters. However, there is no single complete definition of the practice of law. 

Every state defines the practice of law by statute. These statutes, as well as the rules and cases that define the practice of law, are continually changing and evolving.

It's interesting to note that an ABA task force specifically directed to prepare a model definition of the practice of law abandoned its task in March 2003. The members of the task force could not come to an agreement on the definition.

While the actual definition is difficult to pin down, one thing is certain: the unauthorized practice of law is a criminal offense and usually a misdemeanor. UPL does not apply only to nonlawyers who deliver legal services directly to the public. Attorneys can commit UPL. Paralegals working under the supervision of an attorney can commit UPL as well if they are not properly supervised, set fees, give legal advice or appear in court. 

Attorneys must be licensed by the state where they practice law. An attorney who practices law outside the jurisdiction where he or she is licensed is committing UPL. Thus, if a client wants to transfer title to real property in Florida but the attorney is licensed to practice only in Minnesota, you should seek assistance from counsel in Florida.

Only attorneys may represent clients in court. While some administrative agencies allow nonlawyers to represent persons before them, this is not so with most courts. 

There was a New Jersey case involving a New Jersey attorney who actually sent his paralegal to a court hearing where she advocated for a client. The Disciplinary Review Board is urging censure for this attorney. This paralegal committed UPL while working under the supervision of an attorney. (See In the Matter of Neal M. Pomper, Docket No. DRB 08-237) 

Only attorneys may set fees. Setting fees is an important step in establishing the attorney-client relationship. For this reason, only the attorney may decide what the client will be charged for his or her services. Even if there is a standard fee schedule, it is still up to the attorney to evaluate the case and set the fee. Nonlawyers may relay the information about the fees once the attorney provides that information. 

Only attorneys may sign pleadings or correspondence that offers legal advice.Nonlawyers may sign correspondence that relays procedural information. An exception is the State of North Carolina where nonlawyers may sign pleadings in emergency situations.

Only attorneys may give legal advice. This includes directing or recommending a course of action with legal consequences (such as 'You should accept the offer of $1500 offered by the cruise ship for your broken tooth.'); evaluating the probable outcome of a legal matter (such as 'Your claim against XYZ corporation will probably net you a seven figure settlement.') or interpreting statutes, decisions and legal documents.

Your challenge: Know that you may relieve the attorney of many duties. You may relay the attorney's advice to the client, draft pleadings and do legal research that requires legal interpretation. In these situations, it is the attorney who makes the legal judgment. Your are involved only in the assessment of the situation and implementing the attorney's decisions.

Be sure to study case law in your jurisdiction and become familiar with the Rules of Professional Conduct, Ethics Opinions, and case law. Also, attend ethics courses annually so that you will be up to date on the latest ethics education. All of this knowledge will help prevent you from being involved in the unauthorized practice of law.

==========================>
©2011 Vicki Voisin, Inc.

Do you want to use this article in your newsletter, ezine or Web site? You can so long as you include this entire blurb with it: Vicki Voisin, "The Paralegal Mentor", delivers simple strategies for paralegals and other professionals to create success and satisfaction by achieving goals and determining the direction they will take their careers. Vicki spotlights resources, organizational tips, ethics issues, and other areas of continuing education to help paralegals and others reach their full potential. She publishes a weekly ezine titled Paralegal Strategies and co-hosts The Paralegal Voice, a monthly podcast produced by Legal Talk Network. More information is available at http://www.paralegalmentor.com. 

Chapter one review questions. Family law for the paralegal by Wilson

REVIEW QUESTIONS

1. Describe five of the ways in which the nature of family law practice has changed over the past fifty years.
   You do not have to have a reason to divorce now i. e. "No Fault Divorce". It used to be the biological parents had all the rights to the children even if somebody else like a grandparent was raising them but now there are grandparent rights and "psychological parents" have rights that can be addressed in Divorce or custody cases. The Ability of same sex couples to marry in some states it was not to long ago when different races could not marry. The sexes are treated more uniformly now it is not always the mother who gets custody of the children and the father might even get spousal support. Reproductive technological advances have made it possible for same sex couples to have children using just their shared DNA now the law must catch up and redefine what a mother and father is and how to deal with that custody issue.
   
2. Define family law and identify the kinds of issues that are addressed in a family law practice. Family law deals with the forming and dissolution of a family or marriage. Some of the things other than marriage and divorce are deciding custody of minor children, spousal support, prenuptial agreements, cohabitation agreements and adoption.
   
3. Describe the role of a paralegal in a family law practice. Depending on the size of the practice the role can be doing everything secretarial interviewing clients to drafting appellate briefs
   
4. Identify the primary purposes of an initial client interview. To screen for conflicts of interest, to see if the matter to be handled is in the scope of the attorneys knowledge and if the client is a good fit.
   
5. Describe the characteristics of effective fee agreements, and identify the various types of fee agreements that may be used in divorce cases. The agreements plainly state the responsibilities of the lawyer and the client and how the fee will be determined. It might be a flat rate for something a lawyer does commonly like an uncontested divorce without children. Or an hourly rate depending on the whose services are utilized such as a paralegal or lawyer. Also all other costs to be borne by the client. It is common for the Lawyer to collect payment up front in the form of a retainer and the fees will be deducted from that amount and the difference returned or more collected.
   
6. Define unbundled legal services. When the lawyer only does part of the work and the client acts for themselves or "pro se' or "pro per" Latin for "for ones self" It takes a special fee agreement outlining the limited scope of the attorneys work.
   
7. Identify the kinds of resources included in a basic family law library. It should consist of the State statutory code, court rules, case law, Practice Manuals like the ICLE guides, Form books, legal dictionary, citation manual and legal newspapers.
   
8. Define jurisdiction in both of its basic meanings. 1 the geographical area in which the court has jurisdiction over. Like the Supreme court of Michigan has jurisdiction over things that occur in Michigan. 2 What people, type of legal matter or things. Like Wills are handled by the probate court.
   

1. Define and distinguish among subject matter, personal, and in rem jurisdiction.
   An example of Subject matter would be like are circuit courts ability to hear Civil and Criminal cases. An example of personal jurisdiction would be the courts ability to force an individual to pay child support and if they do not, then to put them into jail. The court must first notify the person of the pending action usually using a process server but can also be by the mail or posting in a newspaper. In Rem jurisdiction applies to State of Michigan's power over property inside of it borders,
   

Identify at least ten ethical "dos" that should guide the professional conduct of paralegals.
Do: Communicating with client

Do: Researching legal issues with attorney supervision

Do: Let client know from start you are not a lawyer and can not give advice

Do: Give client factual information

Do: Recognizing and avoiding conflicts of interest

Do: Protecting client secrets

Do: Observing ethical guidelines

Do: Join Paralegal organizations

Do: Continuing education

Do: Become certified.

 

1. Define and give an example of the unauthorized practice of law. If you give any advice on what to do in or on a legal matter. An example would be telling someone to file a certain form with the court.
   
2. Describe at least three kinds of conflicts of interest that paralegals encounter in the family law setting. Someone in the law firm has handled a matter opposing this particular client. If you have such a strong bias or aversion to some one you can not objectively represent them ( I could not represent some one I thought to be a pedophile for instance).
   

   Where you have a financial interest in the matter
   

3. Describe the nature and purpose of an "ethical wall." If someone in the firm has a conflict of interest from a previous job you put up an ethical wall where that person does not talk about anything they know and are not allowed to know or see anything
   
4. Distinguish between the attorney-client privilege and the ethical rule of attorney-client confidentiality. In the attorney-client privilege the client has to give permission for the attorney to give evidence about what they talked about with few exceptions.
   

   The ethical rule of attorney – client confidentiality is outlined in professional codes of ethics the codes say the attorney may not ethically reveal any information about the case, client or preparation of the case if the information was given while seeking legal advice. There are some exceptions such as if they spoke in front of a third person when talking to the lawyer. Or if the lawyer needed to use the information to defend himself in a legal action. Or if not telling will cause great bodily harm to someone.

Transmittal for 234-01

2/2/2011

 

Via Hand Delivery

 

 

Kellogg Community College

Paralegal Course 234 section 01

Instructor Susan M. McCabe, J.D.

450 North Avenue

Battle Creek, Michigan 49017-3397

 

Re: Assignment: Chapter 1 Review questions

 

Dear Ms. McCabe:

 

    As requested by the Course Materials Packet for PARA 234 Section 01, please find enclosed a copy of The Chapter 1 review questions and answers. That is due on today's date Wednesday, February 02, 2011 at the beginning of class.

 

Please review the assignment at your convenience and return it to me at a future class session.

 

If any additional information is required I would be pleased if you would contact me at 269-580-8889 or by email at k0018598@kellogg.edu.

 

 

Sincerely

 

 

----------------------------------------------

Paralegal Student ID # 7676

 

 

Enclosure

 

 

 

 

 

12/13/2010

 

Via Hand Delivery

 

 

Kellogg Community College

Paralegal Course 110 - section 01

Instructor Susan M. McCabe, J.D.

450 North Avenue

Battle Creek, Michigan 49017-3397

 

Re: Assignment #5: Professional Portfolio

 

    Dear Ms. McCabe:

 

    As requested by the Course Materials Packet for PARA 110 Section 01, please find enclosed a copy of assignment #5. That is due on today's date Monday December 13^th 2010 at the beginning of class

 

Please review the assignment at your convenience and return it to me at a future class session.

 

If any additional information is required I would be pleased if you would contact me at 269-580-8889 or by email at k0018598@kellogg.edu.

 

 

Sincerely

 

 

----------------------------------------------

Paralegal Student ID # 7676

Assignment 12 PARA 110-01 Fall 2010

 

 

 

12/6/2010

·
·
·

Student 7676

The Law Office of Snidley Whiplash

450 North Ave

Battle Creek, MI 49017

Nichole Marie Bosworth

427 East Blair

Hastings , Mi,49058

Dear Mrs. Bosworth:

 

    Mrs. Bosworth I am writing this letter to follow up on our interview. If you would read and make any corrections or additions you see fit and return it to me no later than 1 week from today it would be greatly beneficial in the preparation of your case. I would like to thank you for the time and to let you know how helpful and important your answers are.

FACTS

    Nichole and Matthew Bosworth were married in May of 2008. Matthew is now 26 years old and works for the Viking Corporation in Hastings, Michigan as a Quality control inspector of fire sprinklers for the past three years. He makes 42,000 dollars a year. They both still reside with their child at 427 East Blair, Hasting, Mi. 49058.

    Last month Nichole was looking at her husbands emails and found sexually charged emails from her husband to the neighbor that lives across the street from the family home leading Nichole to believe that her husband had committed adultery. Nichole confronted the neighbor Ms. Brandi Hammond about the emails and Brandi admitted to the affair with Matthew. Nichole also talked with her other neighbor Margret Smith who said she had seen Brandi entering the home with Matthew when Nichole was not home. Her husband when confronted denies the allegations of adultery. Nichole believes that Brandi would testify about the adultery. Nichole then called for the appointment with the firm.

Personal details of Mrs. Bosworth

Born: 4/30/1986

Address: 427 East Blair, Hasting, Mi., 49058

Home phone: (269)945-3020

Cell phone (269) 908-8248 Please only use this number to contact Mrs. Bosworth

SSN: 123-45-6789

E-Mail: nbos04@hotmail.com

Work Details for Mrs. Bosworth

Employer: Viking Corporation

Employer Address: 210 North Industrial Park drive, Hastings, Mi., 49058

Work Telephone: (269) 945-9501

Length of Employment: 6 years

Yearly income: 30,000

Personal details of Mr. Bosworth

Born: 08/09/1985

Address: 427 East Blair, Hasting, Mi., 49058

Home phone: (269)945-3020

Cell phone:

SSN: 987-65-4321

 

Work Details for Mr. Bosworth

Employer: Viking Corporation

Employer Address: 210 North Industrial Park drive, Hastings, Mi., 49058

Work Telephone: (269) 945-9501

Length of Employment: 3 years

Yearly income: 42,000 dollars

Assets

A home at 427 East Blair, Hasting, Mi.49058 approximate value 100,000 dollars

Vehicle's: Nicholes 2003 Ford Explorer and Matthews 2005 Chevrolet Impala.

They also own a boat.

    They have a Joint account at Comerica Bank in Hastings and both have individual accounts at the Commercial Bank in Hastings, Michigan with a total combined balance of 10,000 dollars. They both have 401k's Nicholes balance is 4,000 dollars and Matthews is 14,000 dollars. They also have whole life insurance policies on each person. Nichole has whole life policy of 100,000 dollars, Matthew 150,000 dollars and daughter 100,000 dollars.

 

Liabilities

Home mortgage of 80,000 dollars

Car loan on Ford Explorer of 8,000 dollars

Matthew has an 8,000 dollar school loan

Again Thanks for double checking the accuracy of these facts If you have any questions or concerns please give me a call at (269) 123-4567

 

Sincerely,

Student 7676

Paralegal

The Law Office of Snidley Whiplash

 

S7:xx

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR CALHOUN COUNTY

FAMILY DIVISON

------------------------------

                                                            

 

 

 

 

 

 

 

 

 

 

 

 

NOW COMES the Plaintiff, WILMA JEAN FLINTSTONE, who first being duly sworn, states:

1. There is no other pending or resolved action within the jurisdiction of the Circuit Court's Family Division involving the family or any family members of the person who is subject of the Complaint.
   
2. There is no other pending or resolved civil action arising out of the transaction or occurrence alleged in the Complaint.
   
3. The Plaintiff and Defendant have been residents of Michigan for at least 180 days and of Calhoun_. County for at least ten (10) days immediately preceding the filing of this Complaint.
   
4. On May 29, 1995, the parties were legally married in the City of Sandstone, Calhoun County, Michigan by a priest at St. Paul's Cathedral.
   

1. Prior to the marriage, the Plaintiff's name was Wilma Jean Lightrock and is Wilma Jean Flintstone; that prior to this marriage the Defendant's name was Frederick Flint Flintstone and is Frederick Flint Flintstone. There was one child born of this marriage: Pebbles Alecia Flintstone, born March 15, 2002, Social Security Number 371-04-5589.
   
   1. During the past five years, the minor child, Pebbles Alecia Flintstone, has resided with both parents at 711 South Gravel Drive in the City of Sandstone, Calhoun County, Michigan.
      
   2. That although Defendant has participated in raising the minor child, Plaintiff has been the primary caretaker for the parties' minor child since her birth.
      
   3. Plaintiff has not participated in any capacity in any litigation in this or any other jurisdiction concerning the custody of said minor child.
      
   4. Plaintiff has no knowledge of any person not a party to this proceeding who has physical custody, claims to have physical custody, or has visitation rights with respect to the parties' minor child.
      
   5. The Plaintiff is not pregnant.
      
   6. The parties have acquired martial assets and debts during this marriage to be divided by this Court.
      
   7. There has been a breakdown in the marriage relationship to the extent that the objects of matrimony have been destroyed and there remains no reasonable likelihood that the marriage can be preserved.
      

   WHEREFORE, Plaintiff requests this Court to:
   

   1. grant a judgment of divorce;
      
   1. grant both parties joint legal custody of the minor child;
      
   2. grant Plaintiff physical custody of the minor child;
      
   3. grant an equitable division of martial assets;
      
   4. grant an equitable division of martial debts; and
      
      1. grant Plaintiff any such other and further relief in the premises as is agreeable to equity and good conscience.
         

         
          

The statements made herein are true to the best of my knowledge, information and belief.

Dated: November 29^th 2010

Wilma Jean Flintstone

STATE OF MICHIGAN

COUNTY OF CALHOUN

Subscribed and sworn to before me on this 29th day of November, 2010 by

 

WILMA JEAN FLINTSTONE, Plaintiff herein.

 

 

Eddie D. Egghead Jr.

Notary Public, Calhoun County

My commission expires: 10/25/2012

Prepared by:

Chrinchutton Cheeturn (P01010)

Attorney for Plaintiff

1500 Sabortooth Tiger Boulevard

Sandstone, MI 49099-7990

(269) 777-1111

 

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR CALHOUN COUNTY

FAMILY DIVISON

------------------------------

                                                            

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FIRST INTERROGATORIES AND

REQUESTS FOR THE PRODUCTION OF DOCUMENTS.

Pursuant to MCR 2.309 and MCR 2.310, WILMA JEAN FLINTSTONE, by and through her attorneys, requests that FREDERICK FLINT FLINTSTONE prepare answers separately and fully in writing and under oath to the following interrogatories, produce the requested documents, and serve a copy of the answers and documents on attorneys for WILMA JEAN FLINTSTONE within the time frame allowed by applicable court rules.

Each of the following interrogatories and requests for the production of documents is deemed continuing in accordance with the parameters in MCR 2.302(E).

DEFINITIONS

As used in these interrogatories, the following terms have the following meanings:

1. Plaintiff refers to WILMA JEAN FLINTSTONE
   
2. Defendant refers to FREDERICK FLINT FLINTSTONE.
   

   C.'    Document means, without limitation, any written, printed, typed, or other graphic matter of any kind or nature or any writing, drawing, graph, chart, photograph, photo record, tape recording, or other data compilation from which information can be or could have been obtained and also means all copies of documents by whatever means made.
   

   D.    Person includes, without limitation, any natural person, proprietorship, firm, association, partnership, corporation, joint venture, government, or other entity and all affiliates, present or former agents, sureties, indemnitors, servants, employees, representatives, and all other persons acting on behalf or in the interest of the person.
   

   E.    Identify means the following:
   

   1. when used in reference to a natural person, to state his or her full name, address, business address, employer, and position
      
   2. when used in reference to someone other than a natural person, to state its full name, type of entity, address, nature of business, and the person in charge of the principal office
      
   1. when used in reference to a document, to state the type of document, its date, its author, its addressee, and the person who presently has possession or control of it (As an alternative to such identification, you may produce documents for inspection and copying when you file answers to these interrogatories; however, all documents produced will be segregated and identified by the interrogatory to which they are primarily responsive.)
      
      1. when used in reference to an event or occurrence, to state the date and location, a description, and the names and addresses of those involved, if known.
         

   F.    When requested to state the factual basis of any allegation, identify each occurrence,
   

   incident, or fact on which you rely to support the allegation, including the date, place, and substance of each occurrence, incident, and fact and the source of your knowledge.
   

   G.
   If any of these interrogatories or requests for production cannot be answered in full, you are to answer to the extent and in the manner possible; estimates should be identified as such.
   

   
    

   INTERROGATORIES
   

   1.    For each and every employment of any kind you have had during the past five years, state:
   

   1. THE
      name and last known address of each employer;
      
   1. the inclusive dates of each employment;
      
      1. gross annual income from each employment in each year (including income of any kind, whether wage, commission, bonus, or other);
         
      2. monthly gross income from each employment this year, itemizing the amount and nature of deductions;
         
      3. commissions and bonuses anticipated in the next 12 months, specifying whether the compensation is earned or unearned at this time; and
         
      4. a brief description of your duties.
         

      Attach to your answers all proof of income you received to date this year from any source (for example, pay stubs for the last three months).
      

   2    Attach a complete copy of each income tax return you filed during the past five years.
   

   Do you have any passive carryover that you are cur^rently claiming or to which you will be entitled in the foreseeable future?
   

   3.    For each interest you have in any annuity, pension, profit-sharing, retirement, stock purchase, individual retirement account, 401 K, or other deferred benefit plan, state
   

   1. The type of plan (for example, annuity, stock savings, etc.);
      
   1. the date your interest began;
      
      1. your total contributions in each plan as of the date of these interrogatories (list each separately);
         
      2. as of the date of these interrogatories, all contributions to each plan made on your behalf other than those listed in your preceding answer;
         
      3. a current inventory of all assets in your account in each plan;
         
      1. the present-value of your interest in each plan and the method used to ascertain present value;
         
      2. the name, last known address, and telephone number of the plan administrator of each plan;
         
         1. your vested percentage in each plan;
            
            1. your years of credited service in each plan; and
               

      j.    the total amount of accrued benefits in each plan.
      

   Attach a written copy of each plan, a summary plan description, and a copy of the most recent statement relating to your interest in each plan.
   

   
    

       4.    For each debtor who owes you money on any notes, mortgages, land contracts, loans, or otherwise, state
   

   1. the debtor's name and last known address;
      
   2. the current amount owed;
      
   3. the original amount of the obligation;
      
   4. the form of the obligation;
      
   5. the date the obligation was incurred;
      
   6. the date the obligation becomes due and owing;
      
   7. the conditions for payment of the obligation; and
      
   8. the consideration given for the obligation.
      

   Attach copies of all documentation in your possession regarding each indebtedness.
   

       5.    For each motor vehicle you have an interest in, state
   

   1. its year, make, model, and vehicle identification number;
      
   1. the name and address of the registered owner;
      
   2. the name of the primary driver;
      
   3. the value of the vehicle; and
      
      1. the amount owing on the vehicle, to whom, account number, balance due, and the minimum monthly payment.
         

          6.    For any equipment, machines, furniture, furnishings, or other personal property you have had an interest in during the past year with a value in excess of $500, including the personal property located at [Plaintiff's (Defendant's] residence, state
      

   4. a complete description;
      
   5. the date of purchase;
      
   6. the estimated present market value;
      
   7. the amount owed on the property and to whom it is owed;
      
   8. the property's present location; and
      
   9. if the property has been sold or otherwise disposed of,
      

      i    the date of the sale,
      

      1. the name and last known address of the recipient,
         
      1. how it was disposed of, and
         
         1. what you received in exchange for the property (for example, money, other property, services, etc.).
            

          7.    Give a complete description and state the present value of any collections you own such
      as stamps, coins, paintings, antiques, etc.
      

       8.    If, during the past four years, you have been an officer, a director, or a consultant to any
   corporation, partnership, joint venture, or other entity, identify that relationship.
   

       9.    If, during the past four years, you purchased or had an ownership interest in any securities, including stocks, bonds, debentures, or mortgages, state
   

   1. the name of the corporation or entity,
      
   2. the type and number of shares,
      
   3. the type of ownership,
      
   4. the date of acquisition,
      
   5. the purchase price,
      
   6. the present market value, and
      
   7. the amount owed, if any.
      

       10.    If, during the past four years, you have sold any securities, state
   

   1. the type and number of securities sold,
      
   2. the name of the security,
      
   3. the date of the sale,
      
   4. the sale price,
      
   5. the net gain or loss resulting from the sale, and
      
   6. the name and last known address of the purchaser.
      

          11.    If, during the past four years, you have had any savings or checking accounts in your name, solely or jointly with others, with any bank, stock broker, or other financial institution, state
      

   7. the name and address of the institution,
      
   8. the type of account,
      
   9. the names on the account and the type of ownership,
      
   10. the persons authorized to draw on the account,
       
   11. the date the account was opened,
       
   12. the date the account was closed,
       

       g,    the account number,
       

   13. the balance on deposit 30 days before this lawsuit was commenced,
       
   14. the balance on the date of these interrogatories, and
       

       j,    the present balance, if any, or the balance when the account was closed.
       

       Please provide copies of the monthly statements for each account for six months preceding the filing of this lawsuit and for every month after the suit was filed.
       

       
        

       12.    If, during the past four years, there have been any bank accounts on which your name did not appear in which you either deposited or withdrew any money, state
       

       1. the name and address of the bank,
          
       2. the name on the account at the time of each deposit or withdrawal,
          
       3. the account number,
          
       4. the date and amount of each deposit and withdrawal you made, and
          
       5. the reason for the deposit or withdrawal.
          

   13.    If there are any safe deposit boxes, vaults, safes, or other places of deposit and safekeeping in which you deposited or had on deposit any money, documents, or other items of personal property during the past three years, or to which you have a right of access, state
   

   1. the name and address of the location,
      
   2. the number or other means of identification,
      
   3. the name and last known address of each person authorized to enter it,
      
   4. the date you obtained rights to deposit assets at the location,
      
   5. the contents presently contained there, and
      
   6. an inventory of all contents removed since this lawsuit commenced.
      

      
       

       14.    If you have had any interest in any real property during the past four years (including
   property in which your interest is a reversion, remainder, or contingent), state
   

   1. the address and legal description,
      
   2. a description of the property,
      
   3. the conditions and terms tinder which it is held,
      
   4. the present market value of the property and your interest in it, and
      
   5. the date that interest began.
      

      Attach all agreements that contain any of the terms by which the property is being held for your. benefit.
      

       15.    If you hold property for the benefit of another person in trust or otherwise, state
   

   1. the name and last known address of the beneficial owner,
      
   2. a description of the property,
      
   3. the present market value of the property,
      
   4. the current amount of any liens or encumbrances on it,
      
   5. the conditions and terms under which it is held, and
      
   1. the date the interest began.
      

      
      Attach all agreements that contain any of the terms by which you are holding the property
      for the benefit of another.
      

   16 If, during the past four years, you owned or had an interest in any life insurance or
   
   

   1. the name and address of the insurance company,
      
   2. the number of the policy,
      
   3. the type of the policy (for example, term, whole life, etc.),
      
   4. the, face value of the policy,
      
   5. the amount of the annual premium,
      
   6. the name and last known address of each beneficiary named in the policy,
      
   7. the name and last known address of each owner of the policy,
      
   8. the amount and date of each loan on the policy during the past three years,
      
   9. the current loan balance, and
      
   10. the present cash surrender value including dividends.
       
   1. List in detail any benefits that you receive or to which you
      are entitled, together with their actual or estimated value, from any association, employer (past or present), or other entity, including but not limited to automobile, travel, and entertainment expenses; bonuses; and health, accident, and hospitalization insurance.
      
   2. List all sources of income you have had during the last four years not referred to in the
      

      preceding interrogatories, together with the gross amount received from each source and the approximate dates you received them.
      

   1. If you own or have an interest in any personal property, real property, or stun of money that you claim your spouse has no interest in, state
      
      1. A description of the property,
         
      2. the location of the property,
         
      3. the present value of the property,
         
      4. the date and method of acquisition of the property,
         
      5. the source of funds used to acquire the property,
         
      6. the name of each owner of the property and his or her ownership interest, and
         
      7. the reason you claim that your spouse has no interest in the property.
         
      1. If you have any outstanding obligations (not referred to above), including but not limited to mortgages, conditional sales contract obligations, promissory notes, or charge or credit
         
         1. accounts, state
            
         2. the name and address of the creditor,
            
         3. the form of the obligation,
            
         4. the date the obligation was incurred,
            
         5. what you received in exchange for the obligation,
            
         6. a description of any security given for the obligation,
            
         7. the amount of the original obligation,
            
         8. the rate of interest on the obligation,
            
         9. the present unpaid balance on the obligation,
            
         10. the date and amount of installment repayment,
             
         11. whether each obligation is current or delinquent and, if delinquent, for how long, and
             
         12. the names and addresses of any codebtors,
             

       21.    What loans have been repaid by you or on your behalf during the past year?
   

       22.    If you transferred property of any nature to others in trust, by gift, by loan, or otherwise during the past four years having an aggregate value in excess of $500, state
   

   1. a description of the property,
      
   2. the name and last known address of the party to whom a transfer was made,
      
   3. what you received in exchange for the transfer,
      
   4. the value of the property at the time of the transfer,
      
   5. the present value of the property,
      
   6. the present Location of the property, and
      
   7. the exact details of the transfer. Attach copies of any writing that contains information regarding the transaction.
      

      
       

      23.    If, during the past five years, you have prepared, signed, or submitted any financial statement for any purpose whatsoever, state
      

      1. the date of each statement;
         
      2. the name, last known address, and telephone number of the person or entity who prepared each statement;
         

         c,    the name, last known address, and telephone number of the person or entity to whom each statement was submitted;
         

      3. the purpose of preparation; and
         
      4. the name, last known address, and telephone number of each person or entity that has a copy of the statement.
         

   Attach a copy of each statement.
   

   24.    If, other than this lawsuit, you have any interest in or are a party to any other action now pending or in which there is an unsatisfied judgment in any court, administrative agency, etc., state
   

   1. the nature of the interest;
      
   2. the nature of the case
      
   3. the court, the title, and the docket number; and
      

      d.    the amount of any unsatisfied judgment, together with the name and address of the obligor and the obligee.
      

   25.    If you own or have an interest in any property of any nature not referred to above, state
   

   a.    a complete description of the property;
   

   b.    the present Location of the property;
   

   c.    the estimated present market value of the property;
   

   1. the indebtedness now owing on the property and the name and address of the party to whom it is owed; and
      
   2. the name, last known address, and telephone number of every other person with an ownership interest in the property, indicating the nature and extent of each person's interest.
      

       26.    Have you been a party to any agreement in which you granted an option to anyone to purchase any of your assets during the past five years? If so, please specify the terms of that option agreement.
   

       27.    If, during the past three years, you offered to sell or anyone offered to purchase any of the property in which you currently have an interest, state
   

   1. the name and last known address of the offerer,
      
   1. the name and last known address of the offeree,
      
   2. the property subject to the offer,
      
   3. the date of the offer,
      
   4. the amount of the offer,
      
   5. the offeree's
      response to the offer,
      
   6. whether the offer was oral or written, and
      
      1. the name and last known address of each party who has a copy of the offer or the reply to it.
         

      Attach a copy of the offer and responses to the offer,
      

          28.    If any of the assets mentioned in your answers to interrogatories have been appraised or evaluated during the past three years, state
      

      1. the name, last known address, and telephone number of the party who made the appraisal or evaluation;
         
      2. the name, last known address, and telephone number of the employer of each person mentioned in your answer to the prior interrogatory;
         
      3. the purpose for which it was made;
         
      4. the date it was made; and
         
      5. the appraised value.
         

         
          

   29.    What is your date of birth?
   

   1. What is your Social Security number?
      
   1. What is you driver's license number?
      
   2. State the name, last known address, and telephone number of each person you may call on to testify at the trial of this cause and indicate the specific nature of each person's anticipated testimony.
      
3. Attach to your answers to these interrogatories copies of anything you may introduce as an exhibit at the trial.
   
4. Identify each and every educational institution you attended since and including high school and for each such institution state
   
   1. its name and address,
      
   2. your dates of attendance,
      
   3. your areas of study, and
      
   4. the degree or certificate you acquired.
      

      
       

   1.     Do you have any cash
      in excess of $500 in your custody, or does anyone else hold any cash for you? If so, specify the amount of the cash in U.S. currency equivalent and its location. If someone else has custody of this money, state the name, address, and telephone number of this person.
      

   
    

   Cheetum, Dewey & Howe
   

   
   By ____________________________________
   

   
    

   CHRINCHUTTON CHEETUM (P01010)
   

   Attorney for Plaintiff
   

   1500 Sabertooth Tiger Boulevard
   

   Sandstone, MI 49099
   

   (269) 777-1111
   

   
    

   
    

   
    

   
    

   Dated:__________________________________