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  1. #1
    Mom3434 is offline Junior Member
    Join Date
    Sep 2011
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    Default ALL this for a downward modification?

    Yesterday I received, through the mail, “Father’s First Request for Production of Documents” “pursuant to Rule 1.350 of the Florida Rules of Civil Procedure”.
    The father/father’s lawyer is requesting as “Exhibit A” specific info from the list below (I summarized)-
    1-Long Form Family Law Financial Affidavit
    2-2010 tax returns
    3-2010-present Records of all income
    4-2010-present Employment info
    5-2010-present saving account or other passbooks (what’s a passbook?)
    6-2010-present checking account
    7-2010-present records of all bank accounts
    8-2010-present brokerage accounts
    9-2010-present securities/investments
    10-2010-present lease agreements
    11- 2010-present credit cards
    12- 2010-present outstanding debts
    13- 2010-present personal loan
    14- 2010-present loan application
    15- 2010-present life insurance
    16- proposed parentingicon plan

    This request seems over to top. It was not sent to the courthouse, only me and Tangle-Rod and Associates.
    Is it a scare tactic or do I need to respond in writing w/i 30 days?
    If I need to respond, can I reply to all but 1 & 16 by simply saying, “contested”?
    In regards to number 1- if the father’s attorney was handed a copy of my long form in our meeting last month do I need to supply another one?
    In regards to number 16 – we don’t currently have a plan; do we have to have one in writing?
    It never says why the docs are needed.
    They are obviously because he's preparing to lower his support amount but this is over kill and an invasion of my privacy especially when I’ve already sent him the financial affidavit, a couple times.

  2. #2
    Attorney Cheri Hobbs's Avatar
    Attorney Cheri Hobbs is offline Super Moderator
    Join Date
    Oct 2009
    Location
    The Orlando office covers cases in the Central Florida area.
    Posts
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    Default

    The Request to Produce is a typical list of requested documents for an original or modificationicon of support. If something has already been provided to the other side then you can list "previously provided" in your Response to Request to Produce. You will NOT file the requested documents with the courthouse but rather send copies to the other side. You will need to file a sworn to Response to Request to Produce. If something is not applicable you can state that or if you do not have something you can state that.

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