Edward R. Weinstein, Esq.Edward R. Weinstein, Esq.

What is a “Notice to Produce Documents” in a New Jersey Divorce?

In a divorce action in the state of New Jersey, all seasoned lawyers understand that discovery of evidence is essential. This rings true if you are successful in reaching a global settlement outside of a family courthouse or heading to a trial. What particular documents that are required are contingent upon what I, as an attorney, deem to be both relevant and probative in order to prove my client’s case. Below, please find a same of a “Notice to Produce,” which you shall find to be extremely comprehensive.

___________________, Esq. N.J. No.:_______________

LAW OFFICES OF EDWARD R. WEINSTEIN, L.L.C.

Weinstein Professional Building

214 Highway 18 North, Suite 2A

East Brunswick, New Jersey 08816

Telephone: 732-246-0909

Facsimile: 732-246-2888

Attorney for _____________________

__________________________,

Plaintiff,

v.

___________________________,

Defendant.

SUPERIOR COURT OF NEW JERSEY

____________COUNTY

CHANCERY DIVISION: FAMILY PART

DOCKET NO. FM-

CIVIL ACTION

NOTICE TO PRODUCE

TO: (Husband/Wife)

PLEASE TAKE NOTICE that Plaintiff/ Defendant, ___________________________, demands that Plaintiff/Defendant produce and permit inspection and copying of the following documents listed in “Schedule A” attached hereto and made apart hereof, at the Law Offices of Edward R. Weinstein, LLC, located at 214 Highway 18, Suite 2A, East Brunswick, NJ 08816 in accordance with R. 4:10-2, R. 4:18-1 and the instructions below

LAW OFFICES OF EDWARD R. WEINSTEIN, LLC

______________________________________

EDWARD R. WEINSTEIN, ESQ.

Dated:


INSTRUCTIONS

  1. Pursuant to R. 4:18-1 produce all documents which are responsive to the specific demands set forth in Schedule A, within thirty-five (35) days. Produce all responsive documents within your possession, custody or control or in the possession custody or control of your attorneys, accountants or other agents or trustees, wherever located.
  2. The time frame for the purpose of this demand shall be from the date of the marriage until the present day unless otherwise noted.
  3. Produce each document required herein with an indication of the particular paragraph or subparagraph of this Demand for Documents to which the document is responsive.
  4. Pursuant to R. 4:18-1(b), produce all documents as they are kept in the usual course of business, or organize and label them to correspond to the categories in this request.
  5. If you contend that any request for documents calls for the production or privileged or work product materials and such privilege or work product is asserted, identify in writing each document so withheld and provide the following information with respect thereto:
    1. the reason for withholding the document;
    2. a statement of the basis for the claim of privilege, work product or other grounds for non-disclosure;
    3. a brief description of the document, including:
      1. the date of the document;
      2. the number of pages, attachments and appendices;
      3. the names of its author(s) or preparer(s) and an identification by employment and title of each such person;
      4. the name of each person who was sent, shown or copied on the document or has access to or custody of the document, together with an identification of each such person;
      5. the present custodian; and
      6. the subject matter of the document, and in the case of any document relating or referring to a meeting or conversation, and identification of such meeting or conversation.
  6. With respect to any responsive document which was formerly in your possession, custody or control and has been lost or destroyed, state the following:
    1. the type of document;
    2. the subject matter and contents of the document;
    3. the author of the document;
    4. each person to whom the original or a copy of the document was sent,
    5. the date on which the document was prepared or transmitted;
    6. the date on which the document was lost or destroyed;
    7. the condition of and reason for such destruction and the persons requesting and performing the destruction.
  7. This request shall be deemed a continuing one, so as to require prompt, further and supplemental production without further request if you locate or obtain possession, custody or control of additional responsive documents at any time prior to trial of this action.
Definitions

As used herein:

  1. “Plaintiff” means __________________________, including all predecessors in interest, directors, affiliates, subsidiaries, directors, officers, managers, and employees, as well as every agent or any other person or representatives acting on behalf of plaintiff.
  2. “Defendant” means ______________________, including all predecessors in interest, directors, affiliates, subsidiaries, directors, officers, managers, and employees, as well as every agent or any other person or representatives acting on behalf of defendant.
  3. “Person(s)” means a natural person, firm, proprietorship, association, partnership, corporation, estate or any other type of organization or entity.
  4. “Address(es)” means the present or last known street name and number, city or town, state and zip code, and country if other than the United States.
  5. “Complaint” means both the earliest complaint attempted to be filed by the plaintiff and the Complaint accepted for filing thereby commencing the instant action or any Amended or Supplemental Complaint(s) filed thereafter.
  6. “Oral Communication(s)” means any verbal conversation or other statements from one person to another, including, but not limited to, any interview, conference, meeting, or telephone conversation.
  7. “Document(s)” means the original and any identical or non-identical copy, regardless of origin or location, or any book, pamphlet, periodical, letter, memorandum, telegram, report, record, study, handwritten or other note, working paper, chart, paper, graph, index, tape, diskette, data sheet, or data processing card, correspondence, table analysis, schedule, diary, journal, message (including, but not limited to, inter-office or intra-office communications, e-mails or other electronically stored information), purchase order, bill of lading, bid of tabulation, questionnaire, survey, contract, option to purchase, memorandum of agreement, assignment, license, book of account, order, invoice, statement, bill (including, but not limited to, telephone bills), check, voucher, notebook, film, photograph, photographic negative, tape recording, wire recording, transcript of recording, drawing, catalogue, brochure, any other electronically stored information or data compilations from which information can be obtained and translated if necessary, or any other written, recorded, transcribed, punched, taped, filed or graphic matter, however produced or reproduced, to which the party answering these requests has or has had access, or of which the party answering these requests has knowledge.
  8. “Identify,” “identity,” or “identification” means, when used in reference to:
    1. A natural person, his or her:
      1. full name
      2. home address and/or business address
      3. present or last known position, business affiliation and job description.
    2. A company, corporation, association, partnership or entity other than a natural person:
      1. its full name
      2. a description of the type of organization or entity
      3. the address of its principal place of business
      4. the jurisdiction of incorporation or organization
      5. the date of its incorporation or organization.
    3. A document:
      1. its description (for example, letter, memorandum, reports, etc.)
      2. its title
      3. its date
      4. number of pages thereof
      5. its subject matter
      6. the identity of its author, signer and any person who participated in its preparation
      7. the identity of its addressee or recipient
      8. the identity of each person to whom copies were sent and each person by whom copies were received
      9. its present location and
      10. the identity of its custodian (If any such document was, but no longer is, in the possession of or subject to the control of the party answering these interrogatories, state what disposition was made of it and when).
    4. An oral communication:
      1. the date and time when it occurred
      2. the place where it occurred
      3. the complete substance of communication
      4. the identity of each person
        1. to whom such communication was made
        2. by whom such communication was made
        3. who was present when such communication was made,
      5. if by telephone:
        1. the identity of each person
        2. who initiated each phone call
        3. who participated in each call
      6. The identity of all documents memorializing, referring or relating in any way to the subject matter of the communication.
  9. “Electronic Communication” means any exchange of information by means of email or other internet exchange, including, but not limited to, instant messaging or any digital communication.
  10. “And” as well as “or” shall be construed either disjunctively or conjunctively, as necessary to bring within the scope of the specification or responses that which might otherwise be construed to be outside the scope thereof. “Each” shall be construed to include the word “every.“ “Every” shall be construed to include the word “each”. “Any” shall be construed to include the word “all”; “ and “all” shall be construed to include the word “any”.
  11. The use of a verb in any tense shall be construed as the use of the verb in any other tenses, as necessary to bring within the scope of the specification or responses that which might otherwise be construed to be outside of its scope.
  12. A plural noun shall be construed as a singular noun and a singular noun shall be construed as a plural noun, as necessary to bring within the scope of the specification or responses that which might be otherwise construed to be outside the scope thereof.
Demand For Production Of Documents “Schedule A”DOCUMENTS TO BE PRODUCED
  1. Produce leases and/or rental agreements for any and all properties in which you have an interest.
  2. All records pertaining to real estate in which you have held, acquired or may have acquired an interest from the date of the marriage to the present, including but not limited to the following:
    1. Mortgage documents (including monthly payments and present outstanding balance of principal and interest)
    2. Evidence showing all contributions in cash or otherwise made by you to the acquisition of such real estate, whether as owner, co-owner, fiduciary, trust beneficiary (vested or contingent), partner, limited partner, shareholder, joint venture, mortgagee, developer or otherwise
    3. Deed
    4. Closing statement
    5. Sales agreement
    6. Option agreements
    7. Leasehold agreements
  3. Copies of all sales agreements and/or options for any real estate owned by you and those held by you in your name or in your name jointly with any other person or in your name in trust or in your name as guardian for any other person.
  4. Documentation showing all repairs, capital improvements and landscaping relative to any property owned by you, which documentation should show the nature of all such items, the dates, canceled checks, substitute checks, image replacement documents, receipts, bills, bank books and who paid for all such items.
  5. A copy of all leases covering residential premises in which you are now a tenant.
  6. All checking account statements in your name individually, with another, as trustee or guardian, or in which you may have an interest, whether foreign or domestic, including checkbooks and check registers, deposit slips, monthly statements and canceled checks, substitute checks and/or image replacement documents (regardless of whether or not the account or accounts have been closed) for the past five (5) years.
  7. All statements from all savings accounts, credit union, cash management account, money market fund and other passbooks of yours, including those held by you in your name or in your name jointly with any person or entity, or in your name as trustee for any other person, whether foreign or domestic, during the last five (5) years (regardless of whether or not the account or accounts have been closed), including any such accounts in your name as custodian for any minor under the Uniform Gift to Minors Act or otherwise, and showing any and all savings deposits of every kind and nature.
  8. Any and all evidence of your ownership of any interest in any stocks, tax-free securities, annuities, bond funds, mutual funds, money market funds or any other security or investment of any kind. If you maintain an account with a stockbroker, investment company or other financial institutions, please produce all monthly, quarterly, annual or other statements from the stockbroker, investment counselor or financial institution relating to your account(s).
  9. Copies of any and all securities and investments owned by you and not reflected in any brokerage account records or statements.
  10. All records pertaining to stock options in any corporation or other entity, exercised or not yet exercised.
  11. Produce all records of any interest-bearing assets such as bonds, municipal bonds, other tax-free bonds, negotiable instruments, notes receivable, treasury bills, certificates of deposit, savings books, savings accounts, or any other such asset in which you have or have had an interest but not otherwise.
  12. All records, statements, notices of account and other tangible evidence of your interest in any profit-sharing plans, pension plans, Keogh plans, 401K plans, individual retirement accounts and any other deferred compensation or retirement plans of any nature, whether or not qualified pursuant to the Internal Revenue Code of 1954, as amended, including, but not limited to, the following:
    1. Any quarterly, semi-annual and annual statements of your interest and account as a participant in any such plans;
    2. Any forms in the Form 5500 Series, and annual return/report of Employee Benefit Plan filed by the trustee or administrator of such plan with the Internal Revenue Service;
    3. The Summary Plan Description or similar document containing the terms and conditions under which the Plan is maintained;
    4. Any statements showing the assets held in or purchased or sold by each of the plans in which you have an interest in any; and
    5. Any documents reflecting the past and present beneficiaries of your interest in any and all such plans.
  13. All partnership tax returns and corporate tax returns filed with federal and state governments for any partnership, corporation, company or association of which you are a partner or stockholder, or claim any interest whatsoever.
  14. Any and all monthly, quarterly, or annual cash flow summaries, profit and loss statements, or income statements of any nature for any partnership, corporation, company or association of which you are a partner or stockholder, or in which you claim any interest whatsoever, or in which you had any interest during the course of your marriage.
  15. Any and all balance sheets or statements of assets and liabilities for any partnership, corporation, company or association in which you claim any interest whatsoever, or in which you had any interest during the course of your marriage.
  16. Any partnership agreements, stockholders agreements, buy-sell agreements, or other agreements of any nature relating to any partnership, corporation, company or other business entity in which you claim any interest whatsoever, or in which you had any interest during the course of your marriage.
  17. Any and all checking and savings account records, and records of any money market accounts or other investment accounts maintained in connection with any company, partnership, corporation or other business entity in which you claimed any interest whatsoever during the course of your marriage.
  18. Any and all minute books of any corporation, partnership, company or association in which you claimed any interest whatsoever during the course of your marriage.
  19. Copies of all corporate records (articles of organization, by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest, or in which you had any interest during the course of the marriage.
  20. Copies of any and all buy out agreements that may be outstanding in any business enterprise and/or venture which you have or had an interest.
  21. All insurance policies and respective applications made by business entities in which you have held any interest during the course of your marriage.
  22. A list of all loans made from all business or business ventures to you. For each loan list the date of the loan, principal, interest, terms of repayment and current balance outstanding. Furnish a copy of all notes.
  23. A list of all monies borrowed by the respective entities. For each loan, list the lender, date of the loan, principal, interest, terms of repayment and balance. Provide copies of the loan application and note.
  24. For every business entity in which you have held any interest, copies of the following from one year prior to the marriage to date:
    1. Sales journals;
    2. Accounts receivable journals;
    3. Schedule of accounts receivable as reflected on the income tax returns;
    4. Accounts payable journal;
    5. Petty cash journals;
    6. Inventory records;
    7. A list of suppliers or vendors with whom your annual business exceeds $500.00;
    8. Cash receipts journals;
    9. Cash disbursement journals;
    10. List of all customers, sales representatives or agents with whom your annual business exceeds $500.00;
    11. Any lease for real estate or major equipment or machinery;
    12. Purchase journals;
    13. For capitalized items:
      1. produce evidence of the expenditures
      2. purchase journals
      3. any other journal or books of record [if you do not maintain a general ledger, your accountant’s year- end work papers, journal entries, and summary worksheets constitute your general ledger];
    14. Bank statements and canceled checks, substitute checks, and/or image replacement documents;
    15. Bank deposit slips to checking or savings accounts;
    16. All sales invoices;
    17. All purchase invoices for goods for sale and for expenses;
    18. Employee payroll cards;
    19. All corporation income, sales, personal property, payroll tax returns or any other tax or information return required to be filed by the Internal Revenue Service or the State of New Jersey;
    20. Sales order and delivery books;
    21. Purchase order books;
    22. Inventory of merchandise as shown on the income tax returns;
    23. Any financial statements prepared by your accountant whether certified, unaudited or in worksheet form;
    24. Supporting data for any loan or notes payable or receivable, check stub register or equivalent;
    25. Any other supporting documents that will substantiate any of the transactions as reflected on the books during said period of time.
  25. For each business venture in which you are involved in, please provide the following:
    1. A complete transcript of any loan account with any business venture or its subsidiaries, including but not limited to, records identifying the source of any and all charges and/or credits made by you;
    2. Any and all blue prints or other documents showing the number of square feet occupied by each entity;
    3. The minutes of the meetings of the board of directors for each entity;
    4. The minutes of the stockholder meetings of each entity;
    5. The by-laws currently in existence including any amendments thereto to each entity;
    6. The stock register of each entity.
  26. All records that relate to any secured or unsecured personal loans made to you for the last five (5) years.
  27. Copies of all mortgages, notes receivable and other evidence of debts due you individually or otherwise, executed or payable in the future or within the past five (5) years.
  28. Please produce all titles, receipts, sales or purchase notices or other documents reflecting your purchase or sale of any tangible personal property including, but not limited to, any gold, silver, watches, furs, automobiles, boats, motorcycles, stereo equipment, televisions, cameras, video equipment, appliances or other valuable tangible assets (cost exceeding $499.00) of any nature.
  29. Provide a list of all automobiles that you or any company you are affiliated with lease, or automobiles provided for your use that you do not own.
  30. All registrations to motor vehicles currently being used by you.
  31. List all household furniture, furnishings and antiques owned by you individually or jointly with any other person or entity; such list to include the purchase price of each item, the source of the funds used to purchase each item, and the current fair market value of each item. If no appraisal figures are available, include your opinion of the fair market value.
  32. All records pertaining to the transfer by sale or gift or otherwise of any personal property during the past five (5) years.
  33. An inventory of all precious metals, diamonds, gems, art work or other similar investments that you currently own, or have an interest in or which you have owned, or which you have had an interest in during the past five (5) years, including any and all records you possess concerning tile acquisition of any silver or gold by you or any of your relatives.
  34. A list of the location and box number and the contents of all safe deposit boxes maintained by you, individually and jointly with others, as of the date of service of this Demand for Documents.
  35. An inventory of all jewelry, clothes and art work which you have owned from the date of the marriage down to the present date, setting forth tile date acquired, and, if so, the date upon which you sold, to whom sold, and the sale price.
  36. Appraisals as to all jewelry and furs purchased by you or for you for the last five (5) years to the present time including any insurance policies whether or not still in force which would reflect evaluation of such, jewelry and furs. Proof of any proceeds you received from any insurance company resulting from stolen or lost jewelry, furs or other personal items, being certain to include a photocopy of the settlement check, documents showing items which were lost or stolen, documentation showing the funds from which these items had been originally purchased, such as canceled checks, substitute checks, image replacement documents, bank books, etc.
  37. All life insurance policies and certificates on your life as well as all premium notices, beneficiary designation forms and other records and documents received or completed by you in connection with any life insurance of which you are the owner and/or the insured person. If you have changed the beneficiary of any of your life insurance policies during the time in question, produce all forms reflecting these changes.
  38. Copies of any and all wills and/or trusts wherein you are named as a beneficiary and/or named as trustee and/or executor.
  39. Copies of all trusts in which you may have a present or contingent interest, including the certificates, if any, indicating such interests, together with copies of all statements, receipts, disbursements, investments and other transactions.
  40. All records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or irrevocable.
  41. All records of all estates of decedents from which you have received, are receiving or will receive any inheritance in either personal property, real property, assets, in trust or otherwise, or monetary assets of any kind since one year prior to the marriage to date.
  42. A list of all of the employers who have employed you from one year prior to the marriage to date and include a list of any and all remuneration or compensation that you have received from these employers.
  43. Any pay stubs, statement of earnings, W2 forms, 1099 forms, K1 forms, and any other documents given to you by your employer and any other person, partnership, corporation or other entity showing your income from any source.
  44. Any and all copies of income tax returns filed by you individually and/or jointly with any other person with Federal and State governments.
  45. With respect to federal, state and local income tax returns filed by you either individually or jointly with your spouse, produce all accompanying worksheets and documents including W-2, copies of W-4 forms, 1099 forms, and any other attachments provided to the taxation authority.
  46. All records indicating any and all income received by you from any and all sources for the last five (5) years.
  47. All employment information, including, without limitation, wages, salaries, bonuses, stock options, commissions, earnings, income, employment, contracts, pay raises, promotions, payroll deductions, other deductions of any kind, credit union accounts, pension plan, pension fund, retirement plan, retirement fund, stock plan and stock fund and other benefits or deductions of any kind which are, were previously, or may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future at any time for the last five (5) years.
  48. All books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, auto expenses, travel expenses, personal living and entertainment expenses, life insurance, bonuses, health, accident and hospital insurance.
  49. Copies of any and all examinations of revenue agents made pursuant to any and all audits of federal and state income tax returns filed by you singly or jointly.
  50. Any and all documents, booklets, notices, memoranda or other tangible evidence or reflecting the benefits and prerequisites of employment provided to you, directly or indirectly, by your employer.
  51. Any and all documents, receipts, or vouchers reflecting the funds provided to you directly or indirectly, for reimbursement or otherwise by your employer or company as an expense account or reimbursed expense.
  52. Copies of any and all employment contracts between you and your present employer for the period from which you first became employed to date.
  53. Produce all W4 forms you have submitted to your current employer or employers for purposes of federal income tax withholding showing the number of withholding exemptions you are declaring. If you have changed your withholding exemptions from 1980 to the present, submit all W4 forms signed by you during this period to show all such changes you have made.
  54. All records, statements, entire file, from its inception to the present date, relative to the payment of Social Security benefits to the Plaintiff, including, but not limited to:
    1. Any and all correspondence between the Social Security Administration and any other individual or attorney involved in this matter;
    2. Copies of any and all applications for benefits completed by or on behalf of you;
    3. Copies of any and all benefits statements; and
    4. Copies of any and all documentation pertaining to this matter.
  55. Copies of all real estate mortgages held by you, or by any entity (including but not limited to realty trusts, partnerships or corporations) in which you have or had a present or contingent interest during the last five (5) years.
  56. Documentation of the current mortgage balances on any and all real estate owned by you individually, corporately, in partnership, or jointly as well as the balance of same on title date of the trial.
  57. Copies of all statements and year end summaries for all credit cards, business and personal, utilized from the past five (5) years to the present.
  58. Copies of all loan applications and statements of loan accounts for all loans applied for by you, whether or not taken or approved during the past five (5) years.
  59. All records that relate to any secured or unsecured personal loans made by you for the last five (5) years.
  60. Any and all documents pertaining to or being evidence of any current outstanding indebtedness, including any suits now pending or previously pending in any court whatsoever and all cases resolved without litigation or presently being negotiated.
  61. A list of all credit cards and charge accounts held by you and all statements and receipts received by you in connection with the use of such credit cards and charge accounts during the last five (5) years, together with a list of all businesses where you are authorized to charge purchases to the account of another person or entity.
  62. Copies of all records showing any collateral furnished by you in connection with any loan or financing obtained.
  63. Produce a complete copy of your current passport, as well as a copy of any expired passport that is in your possession.
  64. Copies of any and all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest during the last five (5) years.
  65. Copies of all financial statements or records containing financial information of any nature which have been submitted by you to banks or lending institutions or to any person or entities in connection with your application for credit or loans during the past five (5) years.
  66. Any and all books, receipts, records, checks, image replacement documents or other tangible evidence of charitable donations made by you or on your behalf.
  67. Originals of all diaries and ledgers that you have kept to account for travel and entertainment expenses throughout the marriage and in connection therewith, provide a list of all travel or vacations which you have done or taken outside the State of New Jersey from one year prior to the marriage to date.
  68. All records pertaining to your membership in any clubs, religious organizations, or social organizations, such records to include copies of all bills sent to you by such clubs or organizations and expenditures or donations made by you in connection with your membership in such clubs or organizations.
  69. All records pertaining to any frequent flier (or other incentive travel-related program) memberships that you maintain.
  70. All records pertaining to any incentive or “cash back” rewards program in which you participate pursuant to credit card use (e.g. American Express points or Discover cash back incentives) or repeat use of certain merchants or service providers (e.g. hotels or rental car) whether or not any annual fees are associated with participation.
  71. All records pertaining to gifts of any kind made by you to any person, firm, trust, corporation or other entity for the past five (5) years.
  72. A list of all gifts received by you from any person or entity including the amount and date of each such gift during the past five (5) years.
  73. Copies of your child’s federal and state income tax returns for the last five (5) years.
  74. Copies of financial account statements for any account maintained for the benefit of your child pursuant to the Uniform Gift to Minor’s Act, or otherwise.
  75. All documents relating to any monies received by you from any insurance carrier as reimbursement for any claim under a health, life, automobile, homeowner or any other casualty policy in effect for the benefit of yourself or any other covered person, including copies of the policies, claim forms, benefit statements and records reflecting the disposition of funds received.
  76. All documents and/or letters received by you from any real estate broker, appraiser or agent, as well as from any attorney, accountant, bank officer, stockbroker, appraiser or any other person, concerning the status of value of your interest in any corporation, trust, estate, reversionary interest, partnership, joint venture, syndicate, oil or gas royalty or interest, jewelry, furniture, art or any other real or personal property.
  77. A list setting forth the names and addresses of all persons who were witnesses to or have knowledge or information of any relevant facts relating to this action or who possess proof of the incidents or acts involved, their relationship to you and indicating which were eye witnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person; and all tape recordings or other evidence prepared from tape recordings made in connection with any wire-tapping or other electronic surveillance conducted by you or others on your behalf.
  78. A list of the names and addresses of any and all proposed expert witnesses; and certified copies of all written reports rendered to you or your attorney by any such proposed expert witness.
  79. All documents which purportedly support your claim that certain assets are immune from equitable distribution (if relevant).
  80. Copies of all complaints filed in which you seek damages, including those arising out of claims for personal injuries during the last five (5) years to date.
  81. Certified copies of all judgments in your favor for money damages, including those arising out of claims for personal injuries, from one (1) year prior to the marriage to date.
  82. All hospital records made as a result of any automobile accident in which you were involved in from one (1) year prior to the marriage to date.
  83. A copy of any calendar, date book, journal or diary that has been maintained by you and/or your spouse.
  84. A listing of all assets owned by you on the date prior to your marriage with a valuation as to each such asset and the necessary documentation such as brokerage statements, bank book, etc., to prove each and every asset and its valuation.
  85. A listing of all assets owned by you on the date you started this litigation with a valuation as to each such asset and the necessary documentation such as brokerage statements, bank books, etc., to prove each and every asset and its valuation.
  86. The exact and full copies of all detective reports or investigative reports relative to the activities of your spouse or which were prepared on any other matter involving this case.
  87. All the documentary evidence upon which you will rely at the time of the trial.
  88. All documents and other tangible evidence pertaining to the cause of the dissolution of your marriage.