Fill and Sign the Discovery Request Production Documents Form

STATE OF MINNESOTA DISTRICT COURT COUNTY OF JUDICIAL DISTRICT FAMILY COURT DIVISION In Re the Marriage of: Court File No. , Petitioner, REQUEST FOR PRODUCTION OF DOCUMENTS AND , Respondent, TO: _______________ , _______________ ABOVE-NAMED, BY AND THROUGH (HIS) (HER) ATTORNEY, _______________ . YOU ARE HEREBY REQUESTED, pursuant to Minn. R. Civ. P. 26 and 34 to produce and permit Attorney's Name of , and agents, as attorneys for _______________ herein, to inspect and copy the following documents: DEFINITIONS "Document" means any writing, record, or other graphic matter of any type or description, including but not limited to originals or copies of correspondence, letters, telegrams, communications, memoranda, reports, records, instructions, notes, scrapbooks, diaries, appointment books, photographs, photocopies, recordings, transcripts of telephone conversations, and any other retrievable data in your possession, custody or control, however produced or reproduced, including any identical or nonidentical copy, and whether a draft or final version. 1 . All documents relating to the conception, pregnancy, and birth that is the subject matter of this suit, including but not limited to: a. All medical documents relating to _______________ . In lieu of producing these documents, _______________ may provide authorizations to permit _______________ to obtain all requested documents; b. All medical documents relating to the child, _______________ . In lieu of - 1 - producing these documents, _______________ may provide authorizations to permit _______________ to obtain all requested documents; c. All documents of any agency, unit or department, governmental or otherwise; and d. All personal documents of _______________ or the child, _______________ . 2 . All documents indicative of or relating in any way to the relationship between Plaintiff and Defendant, including but not limited to: a. All personal documents of _______________ or the child, _______________ . b. All documents of any persons other than _______________ , whether relative, friend, acquaintance or other; c. All medical documents. In lieu of producing these documents, _______________ may provide authorizations to permit _______________ to obtain all requested documents; and d. The documents of any agency, unit or department, governmental or otherwise. 3 . All documents indicative of or relating in any way to the parentage of the child, _______________ , including but not limited to: a. Birth certificate; b. All medical documents. In lieu of producing these documents, _______________ may provide authorizations to permit _______________ to obtain all requested documents; c. School/daycare records; d. All documents of any agency, unit or department, governmental or otherwise; e. All personal documents of _______________ , or the child, _______________ ; and f. All documents of any persons other than _______________ , whether relative, friend, acquaintance or other. g. All documents relating to the marriage or dissolution of marriage of _______________ between _______________ , 20 ___ , and the present. 4 . Complete copies of all personal Federal and State Income Tax Returns signed by you, including all schedules and forms attached thereto, for tax years 20 ___ to the present. 5 . All documents which will be used to prepare your tax returns for the current year. 6 . All documents that reflect any income received by you from _______________ to the present including, but not limited to: - 2 - a. IRS Forms W-2, 1099, and K-1; b. paycheck stubs; c. bonus check stubs; d. income receipts or vouchers; e. expense reimbursement records; f. dividend or interest statements; g. rental income records; h. copies of checks or check stubs; and i. deposit records. 7 . All documents that detail or reflect any interest that you have or have had in any vested and unvested employment benefits since _______________ , including, but not limited to: a. bonus or incentive plans; b. benefit booklets; c. medical, dental, disability, health and life insurance coverage; d. stock option plans; e. deferred compensation plans; f. profit sharing plans or statements of account; g. any other retirement plans or statements of account; and h. summary plan descriptions. 8 . Complete copies of all Federal and State Income Tax Returns, including all schedules and forms attached thereto, for tax years 20 __ to the present for each and every business or enterprise in which you have or have had an ownership interest (that is greater than _______________ percent (__%)) since _______________ . 9 . All financial statements prepared from _______________ to the present by you or on your behalf and for or on behalf of each and every business or enterprise in which you have or have had an ownership interest (that is greater than _______________ percent (__%)) since _______________ . 10 . All personal checking account records for any joint or separate account used by you, or in which you have or have had any interest, from _______________ to the present, specifically including: a. account statements; b. cancelled checks; c. check registers; and d. deposit tickets. 11 . All statements from _______________ to the present for each bank account, savings account, money market account, liquid asset account, credit union account, insurance account, brokerage firm account, and depository in which you have or have had any interest. 12 . All documents relating to any joint and/or separate interest you have or have had in and to any stock, bonds, debentures, Treasury Bills, notes, or other investments from - 3 - _______________ to the present. 13 . All documents relating to any real property in which you have or have had any interest since _______________ , jointly or individually, specifically including: a. purchase agreements; b. closing documents; c. warranty deeds; d. mortgage applications; e. mortgage statements; g. appraisals; and g. market analyses. 14 . All documents relating to insurance assets in which you have or have had any interest since _______________ , jointly or individually, specifically including: a. copies of each policy; b. loan statement; c. premium statement; and d. statements of actual or projected cash value. 15 . All documents pertaining to motor vehicles, boats, or other recreational vehicles in which you have any interest. 16 . All documents relating to any contingent assets or expectancies, such as annuities, trusts, wills, probate and estate records and evidence of distributions. 17 . All documents, records, notes and files, not already provided in response to any of the foregoing requests, relating to any assets worth more than $ _______________ that you have owned from _______________ to the present. 18 . All documents evidencing any debts that you have incurred, jointly or individually, since _______________ , specifically including: a. promissory notes; b. invoices; c. bills; d. credit card statements; and e. other account statements. 19 . All pleadings relating to any litigation or Court proceedings in which you or the child are or have been involved, other than this proceeding. 20 . Copies of all expert reports and any documents, records, notes and files that served as a basis for the expert's opinion. 21 . Copies of all exhibits that you intend to offer at trial. 22 . All resumes, transcripts, diplomas, certificates or other evidence of your academic - 4 - accomplishments and employability, including evidence of any job offers or efforts to obtain employment. 23 . All documents or records that evidence your inability to obtain or maintain employment, including but not limited to medical records, school records and assessments. 24 . All records or reports relating to any medical or mental health care or treatment that you or the child have received since _______________ . Said inspection and copying shall take place at on _______________ , 20 __ , at the offices of , Address_________ , City, ST Zip , or at such other time and place as the parties may mutually agree. Dated: _______________ By____________________________ _______________________________ __________________ Attorney for Petitioner #1 Address #2 Address City, State Zip Telephone ( ____ ) __________ Attorney Reg. No.: ______ - 5 -