A common misconception that many business owners have about litigating a dispute is the belief that just because a party wins at trial, the money won in the judgment automatically is transferred to the winner.  Usually, that is far from the case.  While it is never easy to go to trial and win a money judgment against another party, sometimes winning is actually easier than collecting on the money judgment won.  A judgment is simply a piece of paper from the Court stating who won and who lost.  However, if the losing party is not financially ready and willing to pay you, a judgment holder has to be prepared to continue to work. Maryland law permits a judgment holder to take certain steps to collect.  One of these steps is the use of post-judgment interrogatories, which are questions the winner may ask of the losing party, known as the debtor, about the amount and location of his/her/its wages, assets, bank accounts and property.  Here is a sample of some of the questions I ask.  Once the amount and location of the debtor’s assets are revealed, an experienced collections attorney will be able to pursue the amounts you are owed.

1. Provide the address and fair market value of all real estate owned by Defendant either individually or jointly with another person or entity.
2. Provide Defendant’s federal and state income tax returns for the years x, y and z, including any Schedules thereto, whether such returns were filed individually or jointly.
3. Detail Defendant’s net worth, including all such assets owned jointly.
4. Provide the year, make, model, mileage, blue book value, and VIN number of all vehicles owned by Defendant.
5. Detail the name and address of each financial institution where Defendant has an account, including the routing number and the account number for each.
6. Detail the balances for each account detailed in your response to Interrogatory #5.
7. Provide Defendant’s bank statements for each account specified in your response to Interrogatories #5 from x through the present.
8. Detail all other assets owned by Defendant not yet mentioned and the fair market value for each.
9. Detail whether Defendant has disposed of or transferred any asset within the last 180 days. If yes, give the name and address of each person or entity who received any asset and describe each asset.
10. Detail any ownership interest Defendant has in any corporation, partnership, or limited liability company. In so doing, identify the name of the corporation, partnership, or limited liability company, the state of incorporation or organization, the amount or percentage of the ownership interest, and the fair market value of the ownership interest.
11. For any corporation, partnership or limited liability company named in your response to Interrogatory #10, provide any shareholder, partnership or operating agreement to which Defendant is a party.
12. Detail all income, wages, or other compensation of any kind received by Defendant within the last 180 days.