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Domestic Relations Pretrial Questionnaire (Paternity)


    [Case caption]          )            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. Have all presumed or putative fathers been named as parties and served? (See K.S.A. 38-1114.) If not, please state whether any further parties should be joined.

4. Is paternity a contested issue? If so,

a. Please state whether genetic paternity testing is being requested.

b. If genetic paternity testing is requested, state whether a hearing as contemplated by In re Marriage of Ross, 245 Kan. 591 (1989), is requested or required? (See also Ferguson v. Winston, 27 Kan. App. 2d 34 (2000).)

c. Has a guardian ad litem been appointed to represent the child? If not, should one be appointed? See K.S.A. 38-1125(b) ("The court shall appoint a guardian ad litem to represent the minor child if the court finds that the interests of the child and the interests of the petitioner differ."); Ferguson v. Winston, 27 Kan. App. 2d 34 (2000).

5. 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.)

6. 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.

7. Are any sums being requested to reimburse a party for past expenses of support and education of the child? If so, please state what amounts are being requested? (See K.S.A. 38-1121(e).) [If you are the party against whom such a request is being made, please state your position regarding that request.]

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. If child support is in issue, have you provided the opposing party a Domestic Relations? 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 ________________________, 20___.