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Best of Philadelphia: Interrogatories in Aid of Execution

Once you have a judgment, your task turns to collecting on that judgment.  Below are a sample set of questions that you can use to attempt to discovery where the defendant’s assets are located.  Happy hunting.  If you need help, call me at 610 642 7676.

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EVAN K. AIDMAN, ESQUIRE                              ATTORNEY FOR PLAINTIFFS

Identification Number 38746

1420 Walnut Street

Suite 808

Philadelphia, PA  19102

(215) 563-7088

_____________________________________________________________________________

JOHN SMITH                                                                       COURT OF COMMON PLEAS

and

JANE DOE                                                                             CIVIL DIVISION

v.

CITY OF PHILADELPHIA                                               PHILADELPHIACOUNTY

MARCH TERM, 1999 NO.  252

PLAINTIFF’S INTERROGATORIES IN AID OF EXECUTION DIRECTED TO DEFENDANT

INTRUCTIONS

            A.  You are required to file answers under oath to the following interrogatories within 30 days after service upon you, pursuant to Rule 3117 of the Pennsylvania Rules of Civil Procedure.

B.  As used herein, the words “you” and “your” refer to Defendant and Defendant’s agents, representatives, attorneys and all other persons acting or purporting to act on behalf of Defendant.

C.  As used herein, “identify” or identity,” when used in reference to an individual person or entity, means to state his or its name and address.

D.  If a precise value, amount or date cannot be supplied in responses to an Interrogatory, an approximate value, amount or date should be provided.

INTERROGATORIES

            1.  Do you own any interest in real estate?

If so, as to each such interest, state:

(a) The location of the real estate;

(b) The nature of your interest in the real estate;

(c) The date you acquired such interest;

(d) The amount which you paid to acquire such interest; and

(e) Whether there are any mortgages on such real estate.  If there are any such mortgages, as to each mortgage, state:

(i) The identity of the mortgage;

(ii) The amount of the original mortgage obligation; and

(iii) The outstanding obligations of the mortgage.

2.  Have you conveyed any interest in any real estate to anyone within the last 12 months?

If so, as to each such conveyance, state:

(a) The description of the real estate;

(b) The interest that you conveyed;

(c) The identity of the person to whom you conveyed that interest; and

(d) The consideration that you received.

3.  Do you hold as mortgagee a mortgage in any real estate?

If so, as to each such mortgage state:

(a) The description of the real estate;

(b) The date on which you acquired the mortgage;

(c) The original principal amount of the mortgage;

(d) The outstanding balance due on the mortgage; and

(e) The identity of the mortgagor.

4. Do you own any automobiles, trucks, vessels, aircraft, or other vehicles?

If so, as to each such vehicle state:

(a) The make, model and year of the vehicle;

(b) The identity of the registered owner of the vehicle;

(c) The governmental agency registering the vehicle and the registration number; and

(d) The location of the vehicle.

5.  Is anyone indebted to you in an amount in excess of $100.00?

If so, for each such indebtedness state:

(a) The identity of the individual or entity that is indebted to you;

(b) The amount of such indebtedness; and

(c) The date on which such indebtedness is due.

6.  Do you have own any savings, money market or checking accounts or certificates of deposit?

If so, as to each such account or certificate of deposit state:

(a) The identity of the depository institution for the account or certificate of deposit;

(b) The title and registered owner or holder of the account or certificate of deposit;

(c) The account number;

(d) A full and complete description of the nature of the account or certificate of deposit; and

(e) The current balance of the account or certificate of deposit.

7.  Do you have or use any safe deposit box or other similar storage facility?

If so, as to each such facility state:

(a) The identity of the institution in which you rent, lease or use such facility;

(b) The box or other identifying number for such facility;

(c) The name under which such facility is rented, leased or used; and

(d) The contents of such facility.

8.  Do you own or have any interest in any stocks, bonds, mutual funds, money market funds, or other securities or negotiable instruments?

If so, as to each such interest state:

(a) A full description of the stock, bond, security or negotiable instrument;

(b) The par or face value of such stock, bond, security or negotiable instrument;

(c) The registered and beneficial holders of the stock certificate, bond, security or negotiable instrument;

(d) The dates on which interest or dividends are payable

(e) The maturity date of any bond;

(f) The identity of the custodian of any and all documents evidencing the interest; and

(g) The location of any and all such documents.

9.  Do you own any jewelry, furniture, office equipment, precious metals or stones, television sets, radios, record players, antiques or collectibles, electrical appliances, power or hand tools, photographic equipment, work of art, furs, musical instruments, rare books or maps, collections of coins or stamps, silver or china, or other personality with an individual or collective value exceeding $250.00?

If so, as to each such item state:

(a) A full and complete description of such item and its present condition;

(b) The location of such item;

(c) Whether or not such item is subject to any security interest; and

(d) The identity of the holder of any such security interest.

10.  Are you a beneficiary of any trust fund?

If so, as to each trust fund state:

(a) The nature of the trust;

(b) The nature of your interest therein; and

(c) The identity of each trustee.

11.  Do you own any patents, inventions, trade names, trade secrets, trademarks, service marks or copyrights?

If so, as to each such item state:

(a) A full and complete description of such item; and

(b) The number of any other identifying features of such item.

12.  Do you own any warehouse receipts, bills of lading or other documents of title?

If so, as to each such item state:

(a) The identity of such item;

(b) The location of such item;

(c) Whether or not such item is subject to any such security interest.

(d) The identity of the holder of any such security interest.

13.  Are you the plaintiff in any lawsuit, which is pending or in which a verdict of judgment has not been satisfied in whole or in part?

14.  Have you applied for a loan or mortgage within the last three years?

If so, as to each such loan or mortgage application state:

(a) Where you applied for such loan;

(b) Whether or not you were granted such loan;

(c) The amount granted for such loan; and

(d) What you did with the proceeds of such loan, if any.

15.  In the last three years, have you acted as co-maker, guarantor or endorser of any loan?

If so, provide full details as to each such loan and your relationship thereto, including the amount of the loan.

16.  Have you issued or furnished any financial statements within the last three years?

If so, as to each such financial statement state:

(a) The identity of such financial statement; and

(b) To whom such financial statement was issued.

17.  Are you a party to a contract of any kind?  If so, as to each such contract state:

(a) The identity of such contract;

(b) The nature of such contract; and

(c) The identity of the person or entity with which you entered into the contract.

18.  Does any governmental body owe you any money?

If so, provide full and complete details thereof.

19.  Have you made any claim under any policy of insurance within the last three years?

If so, as to each such claim state:

(a) The name of the insurer;

(b) The policy number;

(c) The facts given rise to such claim; and

(d) Whether or not such claim has been paid.

20.  Do you own or have any interest in any partnerships or limited partnerships?

If so, as to each such interest state:

(a) A full and complete description of the partnership or limited partnership, including but not limited to its name, purpose, assets, registered address, and the identity of each of its general partners;

(b) The identity of the agreement or agreements governing the affairs of the partnership;

(c) The nature and extent of the interest;

(d) The value of the interest, if any; and

(e) The name under which the interest is owned or otherwise held by you.

21.  Do you own or have any interest in any business, corporation, partnership or joint venture other than those identified in responses to the foregoing interrogatories?

If so, as to each, state:

(a) The identity of the business, corporation, partnership or joint venture; and

(b) A full and complete description of your interest in same.

22.  Do you own or have interest in any asset or item of value individually or collectively worth in excess of $500.00 other than those identified in response to the foregoing interrogatories?

If so, for each such asset or item state:

(a) A full and complete description of the asset or item;

(b) The nature of your interest in the assets or item; and

(c) The value of the asset or item.

23.  Are you unable to pay any of your debts or obligations?

If so, provide full and complete details thereof.

___________________________

EVAN K. AIDMAN, ESQUIRE

Attorney for Plaintiffs

 

If you need more information or think you need an attorney, please contact Evan Aidman, Esq..

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