COMMONWEALTH OF KENTUCKY
HOPKINS CIRCUIT COURT
CIVIL ACTION NO. 92-CI-00444
IN RE THE MARRIAGE OF:
LAURA VANNOY PADGETT PETITIONER
RESPONDENT'S ANSWERS TO THIRD SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION
OF DOCUMENTS
THOMAS CARTER PADGETT RESPONDENT
***** ***** ***** *****
Comes now the Respondent, by counsel, and for his answers to
the Petitioner's Third Set of Interrogatories and Requests for
Production of Documents states as follows:
Interroqatory No. 1: Please state your name, present address
and Social Security number.
Answer: Thomas C. Padgett, 25376 Lyncastle Lane, Farmington
Hills, Michigan 48336, 152-38-9332.
Interroqatory No. 2: With respect to your employment in the
past ten (10) years, please state:
(a) The name and address of the employer;
(b) Your annual salary or wages, and other benefits received
from such employment;
(c) Your specific job qualification or description;
(d) The term of each employment, and;
(e) With respect to all except your current employment, the
reason for termination of employment.
Answer: A through E.
Radisson Plaza Hotel Town Center, General Manager, 1500 Town
Center, Southfield Michigan 48075; August 1991 to present;
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$85,000.00. Responsible for 385 room Commercial hotel, 250
employees and managers.
Radisson Plaza Hotel Lexington, General Manager, Lexington,
Kentucky; November 1989 - August 1991; $77,000.00. Responsible for
367 room, Active Convention Hotel, 250 employees, responsible for
all operational and $10,000,000 plus in sales. Reason for leaving:
Raise and bonuses not fulfilled by owners of hotel; Home mortgage
poor, Radisson wanted me in more challenging position and I needed
additional salary because spouse could not help with expenses due
to her committments.
Radisson Hotel International, Director of National Sales,
National Sales Office, Washington, D.C.; May 1985 - November 1989;
$53,000 - $67,000. Represented Mid-Atlantic and S.E. US Hotels,
staff of six, sales, marketing, and administrative support staff.
Reason for leaving: Wanted general manager position, lower cost of
living, opportunity to get out of larger city and closer to one set
of the grandparents.
Radisson Hotels International, Lexington, Kentucky, Regional
Director of Sales, Responsible for sales efforts in St. Louis,
Kansas City, Indianapolis, Louisville (Seelbach) and Lexington
Hotels, Lexington, Kentucky; August 1984 - May 1985; $43,000.00.
Reason for leaving: Promotion, higher salary and opportunity to
live in Washington, D.C.
Radisson Hotels International, Director of Sales, Plaza Hotel,
Lexington, Kentucky; June 1982 - August 1984; $33,000.00 -
$36,000.00.
Host/Marriott Hotels, Director of Sales and Marketing, Tampa
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Marriott Hotel-Airport formerly Host International Hotels, Tampa,
Florida; June 1981 - June 1982. Assistant Director of Sales, 300
room, 4-star hotel, June 1980 - June 1981.
Omni Hotels (formerly Dunfey Hotel Corp.), Assistant Director
of Sales, Capitol House Hotel, 325 renovated old classic hotel,
National Accounts; Baton Rouge, Louisiana; January 1980 - June
1980.
Sales Manager, state and regional accounts; Baton Route, LA;
June 1979 - January 1980.
Catering Director; Baton Rouge, LA; February 1979 - June 1979.
Account Executive, local corporate accounts; Baton Route, LA;
April 1978 - February 1979.
Conference Service Manager, Convention service and
coordination for extremely active Cape Cod Golf Resort, Spa and
Conference Center; Hyannis, MA; April 1976 - April 1978.
Manager Trainee, Dunfey Hotels, Comprehensive program with
exposure to all operating areas of the Hotel, Hyannis, MA September
1975 - April 1976.
Interroqatory No. 3: Please identify and describe each and
every item of personal property which you have in your possession
or control and with respect thereto, please state:
(a) The present location thereof, and;
(b) The present fair market value (including the basis of the
answer, i.e., your estimate., professional appraisal, etc.).
Answer: This list, will be submitted separately within the
next ten (10) days.
Interrogatory No. 4: Please itemize and describe or otherwise
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identify each item of personal property which you claim to be
entitled to be restored to you by reason of its having been
acquired by gift, bequest, devise or descent during your marriage
to Laura Padgett or by reason of its having been acquired by you
prior to your marriage to Laura Padgett. With respect to each
item, please state:
(a) The date acquired;
(b) From whom acquired;
(c) Value at time of marriage (if owned at time of marriage)
or value at time of acquisition (if acquired during marriage), and;
(d) The reason why you claim the property to be non-marital.
Answer: One-half of all wedding gifts or equivilent cash
value, i.e., silverware, dinnerware, glassware, flatware, china,
crystal, serving pieces, misc., etc.
Any and all items listed in Laura Padgett's 10/9/92 inventory
as:
*"gift to Laura from..."
*"given to Laura by..."
*"loaned to Laura by..."
as they were in fact gifts (no loans) to Laura, Tom and family, but
were erroneously labeled as above. These were all clearly conveyed
by Grantor or Grantors as gifts to Tom and Laura and/or Padgett
family. At the time they were granted, given, or gifted.
Sewing machine (Singer) purchased by Tom and Tom did all the
family sewing and alterations including Laura's garments and
things.
Diamond mounted in wedding ring: Heirloom of Shirley Padgett
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loaned to Tom and Laura Padgett - value $5,000.00.
Extension ladder and 1991 Eagle Summit automobile.
See attached list prepared by Laura Padgett for other discrepancies.
Interroqatory No. 5: Itemize all property, including cash or
cash equivalent, (other than gifts to your wife and children)
having a value in excess of $100.00, which you have transferred to
others during the past five years for less than full consideration
and with respect to each, please state:
(a) A description/amount of the property;
(b) The name and address of the person or organization to
whom transferred, and;
(c) The consideration received.
Answer: None other than what was submitted on joint tax
returns or sold in family garage or yard sales.
Interroqatory No. 6: Please identify any IRA, Keogh, 401K, or
any other pension or profit sharing or retirement plans or accounts
in which you have an interest, and with respect to each such
account or plan, please provide:
(a) The present balance, and;
(b) The name and address of the administrator of the plan or
account.
Answer: This information was previously noted on an earlier
Interrogatory.
Interrogatory No. 7: Please itemize all debts of you and/or
Laura Padgett and with respect thereto, please provide:
(a) The name and address of the creditor;
(b) The repayment plan, if any;
(c) The purpose of incurring the debt, and;
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(d) The identity of any security therefor.
Answer: Visa Card (Tom), Sioux Falls, S.D., $2,819.83, family
purchases.
Central Bank (Tom), Lexington, Kentucky, personal line
account, $1,570.46, family purchases or payment of family incurred
debt.
Mother (Shirley T. Padgett), S. Orleans, MA, and Boca Raton,
FL, $23,350.00 (Tom & Laura) remaining balance on home loans
secured by demand note and promises by Tom and Laura.
$20,000.00 (Tom), borrowed to replace some of the belongings
taken by Laura and her mom in August of 1991, to pay for debts
incurred by Laura, Tom and family, to rent and/or purchase a home
in Michigan. To pay excessive litigation instigated by Petitioner
and her counsel, including the additional costs associated with the
venue of the litigation, additional transportation, and excessive
state and federal tax burden created by Laura's desire to file
individually. Secured by title to boat motor and trailor, and
attachment to IRA account. Must be paid back in four years, no
interest.
Sister (Gail E. Padgett), S. Orleans, MA, $6,000.00, borrowed
for same reasons as above. Secured by title to 1991 Eagle Summitt,
must be paid back in 2 years 8% interest.
Interrogatory No. 8: Please state the amount of cash, or cash
equivalent, which you brought with you when you moved from Fayette
County, Kentucky, to Oakland County, Michigan.
Answer: Approximatly $700.00
Interrogatory No. 9: Please provide the date of which you
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transferred your residency from Fayette County, Kentucky, to
Oakland County, Michigan.
Answer: Wednesday, September 16, 1992.
Interrogatory No. 10: With respect to your financial
condition, please state:
(a) The name of each banking, savings, or other financial
institution where you have an account or investment;
(b) The address of said institution;
(c) The account/investment number assigned by the
institution;
(d) The amount in each account/investment as of September 1,
1991, and;
(e) The amount in each account/investment on the date of your
response to these interrogatories.
Answer: This information has previously been identified in
earlier interrogatories.
RESPONSE TO REOUEST FOR PRODUCTION
Request No. 11: All cancelled checks and monthly statements
on all accounts with any financial institution in your name, either
individually or jointly with others, issued after January 1, 1990.
Response: These documents have already been supplied for
reviewing by opposing counsel in Madisonville, Kentucky.
Request No. 12: Statement of any credit card account
reflecting all activities with respect to each account from and
after January 1, 1990.
Response: These documents have already been supplied for
reviewing by opposing counsel in Madisonville, Kentucky.
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[signature]
THOMAS CARTER PADGETT
STATE OF Michgan
COUNTY OF Oakland
Subscribed and sworn to before me by Thomas Carter Padgett on
this the 11th day of December, 1992
[signature]
Notary Public, State at Large
My Commission Expires: [stamp]
[signature]
LOLA PHILPOT LEWIS
177 N. Limestone
Lexington, Kentucky 40507
Telephone: (606) 281-1313
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the
foregoing has been duly mailed, postage prepaid to:
Michael D. Hallyburton
54 South Main Street
Madisonville, Kentucky 424
on this,the 11th day or December, 1992.
[signature]
LOLA PHILPOT LEWIS
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