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How to answer Discovery?


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I am being SUED by Citibank, and was properly served in my state of Texas (Sheriff came and all)....well I answered the summons, but apparently not in time, ......well months went by and nothing, until i received the Discovery papers in Aid of Judgment....so now I will answer but I don't know the legal jargon.....For the most part, I just have to verify and state my name and any other names I am known by, list all accounts (bank) that I have or share with hubby. But what about the questions that don't pertain to me such as #2 & #4, but then I don't know how to properly answer the ones that do #5 & #7.....

INTERROGATORIES

2. Are you self-employed (either full time or part time)? If you are, please state:

a. The nature of your occupation, in detail.

b. How long you have been self-employed in the business

c. The full name under which your business is operated

d. The complete address and telephone number of your place of business

e. Your annual income for each of the last five years or for any portion thereof that you have been self-employed

f. Your average monthly income for the last six months

g. Whether any money is presently owed you and, if it is, from whom and in what amount it is owed

ANSWER: I am not self employed...how do I answer this?

4. Do you receive income or benefits from any source other than your employement or family contributions listed above? If you do, for each source please state:

a. The full name and complete address of the source

b. The amount of the income or benefits

c. etc..

d. etc

ANSWER: I don't.....again, how should I answer

5. Do you have an ownership interest in, option to purchase, contract to sell leasehold in, contract to exchange, or other interest in any real estate? If so, for each property pleast state:

a. The legal and common descriptions and the location of the property...etc....etc...

ANSWER: Again, I do not have any onwership in any real estate......

7. Do you claim that any real estate or personal property of you is exempt from the claims of creditors? If so, for each piece of property claimed to be exempt please state:

a. The legal and common descriptions of the property

b. The present value of the property

c. Your reason for claiming property is exempt: cause it's my home and I am current on payments?

d. The nature of the property (describing it is either "rural" or "urban" if it is real estate): it's a home in a neighborhood.....urban

e. address....

f. Amount paid...$$$$

g. The name of the person (you, your spouse, or both) owning or having an interest in the property....both of us do...

Anyways, I just don't know the proper way to anwer these and want to do this ASAP so that I can send this letter back....any help is greatly appreciated.

thank you!!

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These really aren't all that difficult to answer. It doesn't have to be legal jargon, just the facts. This is just like being in a deposition, you offer NOTHING extra, JUST the short and sweet FACTS ;)

#2: I am not self-employed.

#4: I do not receive income or benefits from any source other than my employment or family contributions listed above.

#5: Yes, you do, you live in a community property state, so your ownership interest 50/50 with your DH.

#7: YES - Homestead exemption in TX is 100% of the value of your home and personal property is something like 30K. You need to list the applicable TX statutes for item "c".

Keep your answers short and sweet and to the point. Don't elaborate unless its necessary.

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