Respondent Answer to Interrogatories - Home Page

12345CAROLE D. BALDWIN, SBN 213310Law Offices of LAURY M. BALDWIN9171 Towne Centre Drive, Suite 125San Diego, CA 92122Telephone: (858) 452-2898Attorney for Respondent,MICHAEL CALDWELL678SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO91011121314In Re the Marriage of:Petitioner: GINNY L. CALDWELLandRespondent: MICHAEL J. CALDWELLI, MICHAEL CALDWELL, declare as follows:Case Number ED 047912ANSWER TO REQUESTFOR SUPPLEMENTALINTERROGATORIES1516171819202122232425262728My answers to Petitioner's Supplemental Interrogatories are:1. Gross and Net Proceeds From Sale of Santee Home: The grossproceeds were $330,000.00. The net proceeds after all loans were paid off wereapproximately $827.00.2. Mortgages Paid Off From Sale of Santee Home: The first mortgageloan payoff was $145,878.47. The second mortgage loan payoffio Arthur Turner(Petitioner's father) was $96,674.39. The sales proceeds were also used to repayJay and Lea Caldwell for the original down payment of $83,112.97.3. Purchase Price of Ramona Home: According to the SettlementStatement dated August 6, 2002, the Contract Sales Price was $538,710.00.4. Appraised Value of Ramona Home at Time of Quit Claim Deed: Thequit claim was signed several days before the "settlement date." No appraisal wasperformed at that time.1

12345678910111213141516171819202122232425265. Equity in Ramona Home at Time of Quit Claim Deed: The equitywas $108,967.42, the amount of the downpayment made by Jay and Lea Caldwell.6. Any Payment of Monies to Respondent as a Result of Transaction: No.7. Any Payment of Monies to Petitioner as a Result of Transaction: No.8. Current Value of Ramona Home: Unknown.9. Any appraisals on Ramona Home in the Last 3 Years: Yes.10. Will Respondent Agree to Provide Appraisals Without a FormalDemand: I have no access to any appraisal information.11. Any Withdrawals From Retirement Accounts in the Last 4 Years: No.12. Not applicable.13. Amount of Down Payment for Ramona Home: The downpaymentwas $108,967.42.14. Source of Down Payment for Ramona Home: Jay and Lea Caldwell.15. Amount of Down Payment for Santee Home: According to theSettlement Statement dated December 18, 1991, the downpayment was$83,112.97.16. Source of Down Payment for Santee Home: Jay and Lea Caldwell.17. Real Estate Agent and Agent Fee For Sale of Santee Home: The salewas "sale by owner." We did not utilize a real estate agent, so no fees were paid.I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THESTATE OF CALIFORNIA THAT THE FOREGOING ANSWERS ARE TRUE ANDCORRECT.Date: //MICHAEL J. CALDWELL Respondent27282

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address):CAROLE D. BALDWIN, SBN 213310LAW OFFICE OF LAURY M. BALDWIN9171 TOWNE CENTRE DRIVE, SUITE 125SAN DIEGO, CA 92122FOR COURT USE ONLYTELEPHONE NO.: 858/452-2898 FAX NO.:ATTORNEY FOR (Name):SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGOCOUNTY COURTHOUSE, 220 W. BROADWAY, SAN DIEGO, CA 92101-3814HALL OF JUSTICE, 330 W. BROADWAY, SAN DIEGO, CA 92101-3827FAMILY COURT, 1555 6TH AVE., SAN DIEGO, CA 92101-3294MADGE BRADLEY BLDG., 1409 4TH AVE., SAN DIEGO, CA 92101-3105KEARNY MESA BRANCH, 8950 CLAIREMONT MESA BLVD., SAN DIEGO, CA 92123-1187JUVENILE COURT, 2851 MEADOW LARK DR., SAN DIEGO, CA 92123-2792NORTH COUNTY DIVISION, 325 S. MELROSE DR., VISTA, CA 92081-6643EAST COUNTY DIVISION, 250 E. MAIN ST., EL CAJON, CA 92020-3941RAMONA BRANCH, 1428 MONTECITO RD., RAMONA, CA 92065-5200SOUTH COUNTY DIVISION, 500 3RD AVE., CHULA VISTA, CA 91910-5649KSIPLAINTIFF(S)/PETITIONER(S)/IN THE MATTER OF GINNY L . CALDWELL JUDGE:DEFENDANT(S)/RESPONDENT(S) MICHAEL J. CALDWELLPROOF OF SERVICE BY MAIL(CCP 1013a(1) & (3) & Local Rules, Division 11, Rule 2.2C)DEPT:DATE:CASE NUMBERED 047912I, ALANA MERHA , declare that I am over the age of 18 years and nota party to the case; I am employed in, or am a resident of, Lxi the County of San Diego, California, where the mailing occurs; andmy business/M=1Mb address is: 9171 TOWNE CENTRE DRIVE, SUITE 125(No., Street)(City, State)SAN DIEGO, CA 92122X I further declare that I am readily familiar with the business' practice for collection and processing ofcorrespondence for mailing with the United States Postal Service; and that the correspondence shall be depositedwith the United States Postal Service this same day in the ordinary course of business.I caused to be served the following document(s): (SET FORTH THE EXACT TITLE OF THE DOCUMENT(S)SERVED AND FILED)ANSWER TO REQUEST FOR SUPPLEMENTAL INTERROGATORIESTIME:by placing a true copy of each document in a separate envelope addressed to each addressee, respectively, asfollows: (For civil cases, specify the name of the party so served, the nature and status of the party's involvementin the case, i.e. plaintiff, defendant, cross-complainant, etc.; and the name, address and phone number of theparty's counsel of record, if any)STEVEN R. LISSLAW OFFICES OF STEVEN R. LISS7472 LA JOLLA BOULEVARDLA JOLLA, CA 92037I then sealed each envelope and, with postage thereon fully prepaid,I deposited each in the United States Postal Service atX I placed each for deposit in the United States Postal Service, this same day, at my business address shown above,following ordinary business practices.I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.Date: 1/27/05ALANA MERHA(Signature)SDSC CIV-9A(Rev. 5-03)PROOF OF SERVICE BY MAIL SD-9A