(i) Admissions - where you or your spouse are required to admit or deny specific written statements within a specified time; if you do not respond it may be deemed admitted and the court accepts it as fact.
(iii) Production of Documents - a written request to the opposing party for a specific list of documents to be produced at a specific time and date; again you may be sanctioned by the court for non-compliance.
If you encounter difficulty securing past joint tax returns, you may get them directly from the Internal Revenue Service by completing I.R.S. Form 4506.
(iv) Deposition - the most common form of discovery, a deposition generally takes place in a lawyers office, where you, your spouse or other witnesses give oral testimony under oath. Listen to the question and answer only the question. Never volunteer information. Never state facts that you do not know. Depositions are used not only to gather information but also to assess the deponents credibility and to document inconsistencies which may later occur if the deponent is called as a witness at trial. Most of your attorneys objections available at a trial do not apply here. Questions may be broad, but must focus on relevant case information.
If subpoenaed for a deposition, we strongly suggest that, prior to your testimony, you have your attorney prepare you for questions which may be asked by the opposing party at the deposition.
(vi) Requests for Entry onto Land - It may be necessary for your attorney to formally request access to property to appraise a house or business or value their contents. The request will specify when and why access is necessary.
(vii) Requests for Vocational Evaluation - This permits a trained evaluator to assess earning potential by interviewing and testing the person to find out what career choices might be appropriate and what training is necessary to achieve career goals. A court considering spousal support will want this information. The court generally gives considerable weight to such testimony.