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Domestic Relations Pretrial Questionnaire (Divorce, Separate Maintenance, Annulment)


In the Matter of the Marriage of:  )
                                                           )       Case No.________
                                                           )       Div. No.________
                                                           )       Chap. 60
_________________________ )



This questionnaire must be completed by each attorney of record or pro se party. You need only complete those portions that are relevant to issues in controversy. All answers must be typed. If the space provided is not sufficient for your answers, you may type your own questionnaire and answers in accordance with this format.

Note: Unless otherwise ordered by the judge, you are required to file proposed Findings of Fact and Conclusions of Law by the start of trial.

1. Present date:

2. Attorney's name and party represented:

3. Is child custody or residential placement a contested issue?

a. If so, specify your proposed custodial/residential arrangements:

b. Set forth a concise statement of the facts and/or law on which you intend to rely to support the proposed arrangement set forth above as being in the child(ren)'s best interests.

c. Describe your proposed parental access schedule or arrangements:

d. Set forth a concise description of any issues regarding restriction of parental access:

e. Have the parties attempted mediation?

f. Has your client attended the GRASP class? (See Johnson County District Court Local Rule 24.)

4. Is there an issue concerning the payment of child support?

a. If so, attach an updated copy of your child support worksheet.

b. Specify below with particularity any child support adjustments on your worksheet that you want the Court to consider.

5. Is there an issue as to property that should not be subject to division? If so, identify it and provide a concise justification for its exclusion from the divisible marital estate:

6. Is there a controversy regarding division of marital assets and/or debts? If so, complete the following:

a. Age of parties: Husband _____ Wife _____

b. Length of marriage: _____ years prior to filing of this action. Comment below if there were substantial periods of separation or other factors that should be considered regarding the length of marriage:

c. Provide a brief description of your allegations regarding the present and future earning capacities of each party:

d. Provide a summary of any significant facts you will be asking the Court to consider concerning time, source and manner of acquisition of property; dissipation of assets; family ties and obligations; the allowance of maintenance or lack thereof; or other relevant factors in making a just and reasonable division of property (see K.S.A. 60-1610(b)(1)):

e. If there are issues regarding the value of marital assets, identify any appraisers who will be testifying:

7. Is there an issue regarding spousal maintenance?

a. If so, describe the amount, period and manner of payment suggested (including any relevant calculations):

b. Provide a concise statement supporting (or opposing) the amount and manner of any maintenance payment requested:

c. Describe any provisions you intend to propose regarding termination or modification of maintenance:

8. List all witnesses you intend to call at trial. (NOTE: You must list all witnesses known to you at the time of the Pretrial Conference.)

9. List all exhibits you intend to offer at trial. (NOTE: You must list all exhibits known to you at the time of the Pretrial Conference.)

10. List discovery you have completed:

11. Specify further discovery contemplated (if complete, state, "None."):

12. Have you provided the opposing party a Domestic Relations Affidavit as required by Supreme Court Rule 164? If not, state the date by which you will provide it to the opposing party:

13. Identify any procedural or other problems that should be addressed at the Pretrial Conference:


Certificate of Service

I hereby certify that a copy of the foregoing Pretrial Questionnaire was served upon opposing counsel by depositing a copy in the United States mail addressed to counsel, postage prepaid, on the ____ day of ________________________, ______.