STANLEY LEON GARFIELD
AND
CAROL PAULSEN GARFIELD

To: STANLEY LEON GARFIELD, Petitioner, Greetings:

Respondent, Carol Paulsen Garfield, wife of Stanley Leon Garfield, requests that you, Stanley Leon Garfield, petitioner, answer the following interrogatories in writing under oath within the applicable delays under the Texas Code of Civil Procedure article, and produce the documents requested the offices of the undersigned attorney on Tuesday, the twenty-third day of April, 1994, and respond to the following requests for admission pursuant to the Texas Code of Civil Procedure, for purposes of discovery and for such other purposes as may be authorized by law. These interrogatories, requests for production and requests for admission are continuing, and if any relevant information or documents come to your knowledge or into your possession after your initial response which are called for herein, you are notified to supplement your response forthwith to disclose and produce same.

1. State your full legal name and any other names by which you are or have been known within the last three (3) years, your social security number, and your present residence address, and all past home addresses at which you have lived at any time since 1983. For each address, please state the complete address, whether premises are or were rented or owned, the dates you lived at that address, the names of all other persons who lived with you, with dates, and the number of bedrooms and number of bathrooms.

2. Is Stanley Leon Garfield presently employed or working on commission, or has he been employed at any time since 1983? If so, state for each employment (including work on commission) since 1983 the name and address of Mr. Garfield's employer, the type of work Mr. Garfield performs, Mr. Garfield's gross income and net taxable income for each such employer, itemized by calendar year; Mr. Garfield's rate of pay, dates worked for such employer, number of hours per week worked for such employer, reason for termination, if not still employed, for each year; the names and number of dependents claimed by you, the amounts and items withheld from your pay, including but not limited to federal, state and local taxes, social security, union dues, bonds, insurance, and savings, for each employer, any income in addition to salary or wages, including but not limited to bonuses, commissions, dividends and tips.

3. Does Stanley Leon Garfield have any interest in real or immovable property in Louisiana, Texas or elsewhere? If so, for each such parcel of property state the address and legal description of the property, the date of purchase and purchase price, the name and address of each person or business with an ownership interest in the property, the ownership of the property as stated in the acts of sale or donation, and the location of each such document, the present value of the property and equity interest in the property.

4. Is any of the real or immovable property owned by Stanley Leon Garfield, individually or otherwise, mortgaged? If so, for each such item of property state a description of the property mortgaged, the nature of the encumbrance, the date of the mortgage, and the name and address of the mortgagee.

5. Does Stanley Leon Garfield maintain any personal or business checking or savings account, bank accounts, credit union accounts, savings and loan or homestead accounts, money market accounts or other financial deposits either alone or with someone else? If so, for each account on which he has a signature or in which he has an interest state the name and address of the bank or institution, the name under which each account is held, the account number, the balance of each account as of 1 February 1994, and the maximum amount in each account at any time from 1992 to the present.

6. Set forth all Stanley Leon Garfield's assets, liabilities and net worth as of the time of answering these interrogatories.

7. Has Stanley Leon Garfield furnished financial statements to any bank, savings and loan, homestead, credit union, broker, other financial institution or taxing authority at any time since August 1990? If so, for each such statement please state the name and address of the institution to which such statement was furnished, the name of the officer or other person with whom dealings were had, the date of each financial statement, the reason for each submission.

8. Has Stanley Leon Garfield at any time since August 1983 conveyed or transferred any movable or real or immovable property or given consideration for any property which has been conveyed or transferred and which is now being held for Stanley Leon Garfield in the name of some other person than Stanley Leon Garfield? If so, state the name and address of each title holder or owner, the date of each conveyance or transfer, a description of each item or piece of property, and the amount of consideration given for such property.

9. Does Stanley Leon Garfield keep any books, checkbooks, or written memoranda of Stanley Leon Garfield's income, personal expenses, or business affairs? If so, state in what form the books or memoranda are kept, when the books or memoranda were first maintained, the names and addresses of any person, firm or corporation who prepared same, and the present location of all such books or memoranda.

10. Did Stanley Leon Garfield file a federal income tax return for any year since 1990? If so, state for each such return the year for which it was filed, the amount of gross and adjusted gross income reported, the name and address of each person who prepared the return, whether the return was joint, and if so the name and social security number of the person you listed thereon as your spouse.

11. Does Stanley Leon Garfield own any vehicles, or has Stanley Leon Garfield owned or purchased any vehicles since August 1990? If so, for each vehicle state the year, make, model and license number of the vehicle, the name and address of the legal owner, the name and address of the registered owner, date of purchase, purchase price, if the vehicle has been sold, date of sale, name and address of vendee, and sale price.

12. Does Stanley Leon Garfield presently own or have any interest in any life insurance or annuity policy? If so, for each policy state the name and address of the insurance company, the number of the policy, the type of policy (i.e. term, straight life, etc.), the date the policy was issued, the amount of the annual premium, the total amount of premiums paid on the policy to date, the name and address of each beneficiary, the name and address of each owner of the policy, the date of each change of beneficiary since inception, and the name of each beneficiary added or deleted, the name and address of the agent or broker, the face value of the policy, and the present cash surrender value of the policy.

13. Since August 1990, has Stanley Leon Garfield contributed to or is Stanley Leon Garfield a beneficiary under any investment plans, stock options, retirement plans from employment, inter vivos or testamentary trusts, wills, or otherwise? If so, set forth types of plans or trusts, method of funding, amount invested by Stanley Leon Garfield and amount contributed by Mr. Garfield's employer, when invested and under what terms, amount currently invested, and a description of the trust document, will, or other document creating the interest, with identification of the trustee's or administrator's name and address.

14. State with particularity any fringe benefits that Stanley Leon Garfield receives from any business or agency by which he is employed or in which he has an interest, including but not limited to country club dues, automobile expenses, travel expenses, entertainment expenses, insurance, bonuses, health, accident, and hospitalization insurance.

15. Is Stanley Leon Garfield living with another adult or sharing housing with another adult? If so, please state the full name, age and sex of such person and state when the living arrangement commenced.

16. Has Stanley Leon Garfield ever been charged with or convicted of any felony, misdemeanor, petty offense or municipal ordinance violation, including but not limited to reckless driving or driving under the influence or while impaired? If so, for each such charge state the date, name and address of court, docket number, and disposition.

17. Has Stanley Leon Garfield taken any psychological tests (including but not limited to the Minnesota Multiphasic Personality Inventory, the Millon Clinical Multiaxial Inventory, the Thematic Apperception Test, the Rohrschach Test, or any other tests, projective or otherwise) for any purpose at any time within the past five years? If so, for each such test please state date of administration, type of test, name and address of person administering, reason for administration, and the present whereabouts of the test results and scoring data.

18. Has Stanley Leon Garfield consulted any psychiatrist, psychologist or mental health professional for any reason (whether for diagnosis, for treatment as a patient, for possibile consideration as a potential expert witness, or for advice as to psychological issues in litigation) at any time within the past five years? If so, for each such consultation please state the date of each visit, the reason for each visit, the name and address of the psychiatrist, psychologist or mental health professional, whether psychological tests were discussed or administered, and if so which ones, and the amount if any paid for each such visit or consultation.

19. Please state the name, business address, and residence address of the bookkeeper for the company where Stanley Leon Garfield is presently employed.

20. Please state the name, business address, and residence address of the principal certified public accountant who is most familiar with the books of the company where Stanley Leon Garfield is presently employed.

21. Has Stanley Leon Garfield been married before? If so, for each marriage state the name of his former spouse, the date and place of marriage, the date and place of divorce, case number, and present address of such former spouse. If you do not know the address with particularity, state the last known address and last known employment of such former spouse.

22. Does Stanley Leon Garfield have any children? If so, for each child state name and date of birth, name and present address of custodian, your monthly child support obligation and the amount of any arrearage owing, the name and address of each court that has decided any matter pertaining to custody or support, and the docket number of the case.

23. Has Stanley Leon Garfield received any funds from his parents or either of them at any time since 1983? If so, for each such amount over $500, state the date of each payment to you, the amount of each payment, and the reason for each payment.

24. Is Patricia Hill-Garfield presently employed or working on commission, or has he been employed at any time since 1983? If so, state for each employment (including work on commission) since 1983 the name and address of Mr. Garfield's employer, the type of work Mr. Garfield performs, Mr. Garfield's gross income and net taxable income for each such employer, itemized by calendar year; Mr. Garfield's rate of pay, dates worked for such employer, number of hours per week worked for such employer, reason for termination, if not still employed, for each year; the names and number of dependents claimed by you, the amounts and items withheld from your pay, including but not limited to federal, state and local taxes, social security, union dues, bonds, insurance, and savings, for each employer, any income in addition to salary or wages, including but not limited to bonuses, commissions, dividends and tips.

25. Does Patricia Hill-Garfield have any interest in real or immovable property in Louisiana, Texas or elsewhere? If so, for each such parcel of property state the address and legal description of the property, the date of purchase and purchase price, the name and address of each person or business with an ownership interest in the property, the ownership of the property as stated in the acts of sale or donation, and the location of each such document, the present value of the property and equity interest in the property.

26. Is any of the real or immovable property owned by Patricia Hill-Garfield, individually or otherwise, mortgaged? If so, for each such item of property state a description of the property mortgaged, the nature of the encumbrance, the date of the mortgage, and the name and address of the mortgagee.

27. Does Patricia Hill-Garfield maintain any personal or business checking or savings account, bank accounts, credit union accounts, savings and loan or homestead accounts, money market accounts or other financial deposits either alone or with someone else? If so, for each account on which he has a signature or in which he has an interest state the name and address of the bank or institution, the name under which each account is held, the account number, the balance of each account as of 1 February 1994, and the maximum amount in each account at any time from 1992 to the present.

28. Set forth all Patricia Hill-Garfield's assets, liabilities and net worth as of the time of answering these interrogatories.

29. Has Patricia Hill-Garfield furnished financial statements to any bank, savings and loan, homestead, credit union, broker, other financial institution or taxing authority at any time since August 1990? If so, for each such statement please state the name and address of the institution to which such statement was furnished, the name of the officer or other person with whom dealings were had, the date of each financial statement, the reason for each submission.

30. Has Patricia Hill-Garfield at any time since August 1983 conveyed or transferred any movable or real or immovable property or given consideration for any property which has been conveyed or transferred and which is now being held for Patricia Hill-Garfield in the name of some other person than Patricia Hill-Garfield? If so, state the name and address of each title holder or owner, the date of each conveyance or transfer, a description of each item or piece of property, and the amount of consideration given for such property.

31. Does Patricia Hill-Garfield keep any books, checkbooks, or written memoranda of Patricia Hill-Garfield's income, personal expenses, or business affairs? If so, state in what form the books or memoranda are kept, when the books or memoranda were first maintained, the names and addresses of any person, firm or corporation who prepared same, and the present location of all such books or memoranda.

32. Did Patricia Hill-Garfield file a federal income tax return for any year since 1990? If so, state for each such return the year for which it was filed, the amount of gross and adjusted gross income reported, the name and address of each person who prepared the return, whether the return was joint, and if so the name and social security number of the person you listed thereon as your spouse.

33. Does Patricia Hill-Garfield own any vehicles, or has Patricia Hill-Garfield owned or purchased any vehicles since August 1990? If so, for each vehicle state the year, make, model and license number of the vehicle, the name and address of the legal owner, the name and address of the registered owner, date of purchase, purchase price, if the vehicle has been sold, date of sale, name and address of vendee, and sale price.

34. Does Patricia Hill-Garfield presently own or have any interest in any life insurance or annuity policy? If so, for each policy state the name and address of the insurance company, the number of the policy, the type of policy (i.e. term, straight life, etc.), the date the policy was issued, the amount of the annual premium, the total amount of premiums paid on the policy to date, the name and address of each beneficiary, the name and address of each owner of the policy, the date of each change of beneficiary since inception, and the name of each beneficiary added or deleted, the name and address of the agent or broker, the face value of the policy, and the present cash surrender value of the policy.

36. Since August 1990, has Patricia Hill-Garfield contributed to or is Patricia Hill-Garfield a beneficiary under any investment plans, stock options, retirement plans from employment, inter vivos or testamentary trusts, wills, or otherwise? If so, set forth types of plans or trusts, method of funding, amount invested by Patricia Hill-Garfield and amount contributed by Mr. Garfield's employer, when invested and under what terms, amount currently invested, and a description of the trust document, will, or other document creating the interest, with identification of the trustee's or administrator's name and address.

37. State with particularity any fringe benefits that Patricia Hill-Garfield receives from any business or agency by which he is employed or in which he has an interest, including but not limited to country club dues, automobile expenses, travel expenses, entertainment expenses, insurance, bonuses, health, accident, and hospitalization insurance.

38. Is Patricia Hill-Garfield living with another adult or sharing housing with another adult? If so, please state the full name, age and sex of such person and state when the living arrangement commenced.

39. Has Patricia Hill-Garfield ever been charged with or convicted of any felony, misdemeanor, petty offense or municipal ordinance violation, including but not limited to reckless driving or driving under the influence or while impaired? If so, for each such charge state the date, name and address of court, docket number, and disposition.

40. Has Patricia Hill-Garfield taken any psychological tests (including but not limited to the Minnesota Multiphasic Personality Inventory, the Millon Clinical Multiaxial Inventory, the Thematic Apperception Test, the Rohrschach Test, or any other tests, projective or otherwise) for any purpose at any time within the past five years? If so, for each such test please state date of administration, type of test, name and address of person administering, reason for administration, and the present whereabouts of the test results and scoring data.

41. Has Patricia Hill-Garfield consulted any psychiatrist, psychologist or mental health professional for any reason (whether for diagnosis, for treatment as a patient, for possibile consideration as a potential expert witness, or for advice as to psychological issues in litigation) at any time within the past five years? If so, for each such consultation please state the date of each visit, the reason for each visit, the name and address of the psychiatrist, psychologist or mental health professional, whether psychological tests were discussed or administered, and if so which ones, and the amount if any paid for each such visit or consultation.

42. Please state the name, business address, and residence address of the bookkeeper for the company where Patricia Hill-Garfield is presently employed.

43. Please state the name, business address, and residence address of the principal certified public accountant who is most familiar with the books of the company where Patricia Hill-Garfield is presently employed.

44. Has Patricia Hill-Garfield been married before? If so, for each marriage state the name of his former spouse, the date and place of marriage, the date and place of divorce, case number, and present address of such former spouse. If you do not know the address with particularity, state the last known address and last known employment of such former spouse.

45. Does Patricia Hill-Garfield have any children? If so, for each child state name and date of birth, name and present address of the custodian, her monthly child support and the amount of any arrearage owing, the name and address of each court that has decided any matter pertaining to custody or support, and the docket number of the case.

You are requested to produce each of the following:

1. Copies of all bank statements, savings account passbooks, cancelled checks and statements of account on all accounts, whether at banks, homesteads, savings and loans, thrifts, credit unions, brokerage houses or otherwise, standing in your name or that of your present spouse or on which you or your present spouse have or had a signature, whether the said accounts are open or closed at the present time, from August 1990 to and including the date of your production.

2. Copies of all policies or certificates of health or medical insurance in your name or that of your present spouse from August 1990 to and including the date of your production, whether the said insurance is now in effect or not.

3. Copies of your federal income tax returns, with all schedules, and of the federal income tax returns of your present spouse, with all schedules, for the years 1990, 1991, 1992, and 1993.

4. Copies trust documents, wills and other documents in which you or your present spouse are named as a beneficiary.

5. Invoices, retainer agreements and other documents pertaining to your legal representation in the instant case showing amounts paid, by whom said amounts were paid, amounts billed, and the fee agreement.

6. Copies of all loan applications and supporting documentation, including financial statements, submitted by you or your present spouse to any lender or prospective lender at any time since August 1990.

7. Copies of all bank statements, savings account passbooks, cancelled checks and statements of account on all accounts, whether at banks, homesteads, savings and loans, thrifts, credit unions, brokerage houses or otherwise, standing in your name or your present wife's name or on which you or she has or had a signature, whether the said accounts are open or closed at the present time, from August 1990 to and including the date of your production, including all statements received by you in the mails since your physical separation from your spouse and withheld from her by you.

8. Copies of all bills for medical services rendered for you, your present wife or her son Matthew at any time from the date of your most recent marriage, showing amounts paid, dates of payment, and by whom such payments were made.

9. Copies of your pension plan and that of your present spouse, together with a statement of accrued employer contributions to date, accrued employee contributions to date, and benefits to be received upon retirement.

1. You are requested to admit that you have an alcohol abuse problem.

Propounded this _______ day of ____________, 199___, at Houston, Texas.

_________________________________________
SUSAN JONES, Attorney for Respondent
Bar Registration 382265
6150 West Loop South, Suite 1000
Houston, Texas 77028
Telephone (713) 555-1212

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