Embezzlement Discovery Document Requests

Yes, ****, you can request documents like taxes, payroll slips, and expenses during trips as part of the discovery process. These documents can provide relevant information about the embezzlement. Have you discussed these specific requests with your attorney?

****, in New Mexico, you can indeed request those documents during the discovery phase. You might want to file a formal request for production of documents.
Have you filed any specific discovery requests yet, or do you need guidance on how to proceed with that?

****, here are some potential questions you can use to request the documents during the discovery phase:
- Please provide copies of your tax returns for the past 7 years.
- Provide all payroll slips from your employment during the last 7 years.
- Submit detailed expense reports for all trips taken in the past 7 years, including receipts and invoices.
Would you like more guidance on filing these requests?

Sure, ****! Here are some steps to help you file these requests:
*. Draft Requests:
- "Please provide copies of your tax returns for the past 7 years."
- "Provide all payroll slips from your employment during the last 7 years."
- "Submit detailed expense reports for all trips taken in the past 7 years, including receipts and invoices."
*. Format Properly: Ensure each request is clearly numbered and specific.
*. File with Court: Submit the requests as part of your discovery motion with the court.
Do you need further details on filing the motions?

****, here are some additional questions you can consider for your discovery requests:
- Please provide any records of wire transfers or electronic fund transfers made in the past 7 years.
- Submit all bank statements for the past 7 years.
- Provide all documents related to any offshore accounts or foreign transactions.
Would you like more specific guidance on any of these questions?

****, here are some more specific questions you can add to your discovery requests:
- "Please provide records of any wire transfers or electronic fund transfers made in the past 7 years."
- "Submit all bank statements from the past 7 years."
- "Provide all documents related to any offshore accounts or foreign transactions in the past 7 years."
- "Submit any records of income not reported to the IRS."
Would you like more details on how to format and file these requests?

****, here are steps to format and file your discovery requests:
*. Draft Requests:
- "Please provide records of any wire transfers or electronic fund transfers made in the past 7 years."
- "Submit all bank statements from the past 7 years."
- "Provide all documents related to any offshore accounts or foreign transactions in the past 7 years."
- "Submit any records of income not reported to the IRS."
*. Format Properly:
- Number each request clearly.
- Use clear and specific language.

*. File with Court:
- Prepare a formal discovery motion.
- Attach your numbered and formatted requests.
- Submit the motion to the court handling your case.
Would you need more details on how to prepare the formal discovery motion?

****, you should request detailed statements for all her bank accounts, focusing on transactions that could show the embezzlement. Here's a question you can add:
- "Please provide detailed statements for all bank accounts held in the past 7 years, including account numbers, transaction dates, amounts, and descriptions."
Would you like more guidance on how to present this to the court?

****, here's a step-by-step on how to present your discovery requests to the court:
*. Draft Requests:
- "Please provide detailed statements for all bank accounts held in the past 7 years, including account numbers, transaction dates, amounts, and descriptions."
- "Please provide records of any wire transfers or electronic fund transfers made in the past 7 years."
- "Submit all bank statements from the past 7 years."
- "Provide all documents related to any offshore accounts or foreign transactions in the past 7 years."
- "Submit any records of income not reported to the IRS."
*. Format Properly:
- Number each request clearly.
- Use clear and specific language.
*. File with Court:
- Prepare a formal discovery motion.
- Attach your numbered and formatted requests.
- Submit the motion to the court handling your case.
Do you need help with any specific part of preparing the formal discovery motion?

Sure, ****! Here’s a sample of a formal discovery motion you can use to guide you:
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STATE OF NEW MEXICO
COUNTY OF [Your County]
[Your Court's Name]
[Your Name],
Plaintiff,
v.
[Your Ex-Partner's Name],
Defendant.
Case No. [Your Case Number]
---
PLAINTIFF'S FORMAL DISCOVERY MOTION
TO: [Defendant's Name]
FROM: [Your Name], Plaintiff Pro Se
COMES NOW, the Plaintiff, [Your Name], to respectfully request the Defendant, [Defendant's Name], to produce the following documents within thirty (*) days from the date of service of this request, pursuant to Rule *-* of the New Mexico Rules of Civil Procedure:
*. Tax Returns: Please provide copies of your federal and state tax returns for the past seven years.
*. Payroll Slips: Provide all payroll slips from your employment during the last seven years.
*. Expense Reports: Submit detailed expense reports for all trips taken in the past seven years,including receipts and invoices.
*. Wire Transfers: Please provide records of any wire transfers or electronic fund transfers made in the past seven years.
*. Bank Statements: Submit all bank statements from the past seven years.
*. Offshore Accounts: Provide all documents related to any offshore accounts or foreign transactions in the past seven years.
*. Unreported Income: Submit any records of income not reported to the IRS.
*. Bank Account Statements: Please provide detailed statements for all bank accounts held in the past seven years, including account numbers, transaction dates, amounts, and descriptions.
Respectfully submitted,
[Your Name]
Plaintiff Pro Se
[Your Address]
[Your Phone Number]
[Your Email Address]
Date: [Date]
---
Would you like any further assistance with this?

****, you can request information on how she managed to block your access to the business account. Here’s a question you can add to your discovery requests:
- "Please provide any communications or documents related to actions taken to restrict the Plaintiff's access to the business bank account."
Would you like more details on how to include this in your formal motion?

****, here's how you can include the question about restricting access to the business account in your formal discovery motion:
---
STATE OF NEW MEXICO
COUNTY OF [Your County]
[Your Court's Name]
[Your Name],
Plaintiff,
v.
[Your Ex-Partner's Name],
Defendant.
Case No. [Your Case Number]
---
PLAINTIFF'S FORMAL DISCOVERY MOTION
TO: [Defendant's Name]
FROM: [Your Name], Plaintiff Pro Se
COMES NOW, the Plaintiff, [Your Name], to respectfully request the Defendant, [Defendant's Name], to produce the following documents within thirty (*) days from the date of service of this request, pursuant to Rule *-* of the New Mexico Rules of Civil Procedure:
*. Tax Returns: Please provide copies of your federal and state tax returns for the past seven years.
*. Payroll Slips: Provide all payroll slips from your employment during the last seven years.
*. Expense Reports: Submit detailed expense reports for alltrips taken in the past seven years, including receipts and invoices.
*. Wire Transfers: Please provide records of any wire transfers or electronic fund transfers made in the past seven years.
*. Bank Statements: Submit all bank statements from the past seven years.
*. Offshore Accounts: Provide all documents related to any offshore accounts or foreign transactions in the past seven years.
*. Unreported Income: Submit any records of income not reported to the IRS.
*. Bank Account Statements: Please provide detailed statements for all bank accounts held in the past seven years, including account numbers, transaction dates, amounts, and descriptions.
*. Business Account Restrictions: Please provide any communications or documents related to actions taken to restrict the Plaintiff's access to the business bank account.
Respectfully submitted,
[Your Name]
Plaintiff Pro Se
[Your Address]
[Your Phone Number]
[Your Email Address]
Date: [Date]
---
Would you like any further assistance with this?

****, here's how you can include the new request in your formal discovery motion:
---
STATE OF NEW MEXICO
COUNTY OF [Your County]
[Your Court's Name]
[Your Name],
Plaintiff,
v.
[Your Ex-Partner's Name],
Defendant.
Case No. [Your Case Number]
---
PLAINTIFF'S FORMAL DISCOVERY MOTION
TO: [Defendant's Name]
FROM: [Your Name], Plaintiff Pro Se
COMES NOW, the Plaintiff, [Your Name], to respectfully request the Defendant, [Defendant's Name], to produce the following documents within thirty (*) days from the date of service of this request, pursuant to Rule *-* of the New Mexico Rules of Civil Procedure:
*. Tax Returns: Please provide copies of your federal and state tax returns for the past seven years.
*. Payroll Slips: Provide all payroll slips from your employment during the last seven years.
*. Expense Reports: Submit detailed expense reports for all trips taken in the past seven years, including receipts and invoices.
*. Wire Transfers: Please provide records of any wire transfers or electronic fund transfers made in the past seven years.
*. Bank Statements: Submit all bank statements from the past seven years.
*. Offshore Accounts: Provide all documents related to any offshore accounts or foreign transactions in the past seven years.
*. Unreported Income: Submit any records of income not reported to the IRS.
*. Bank Account Statements: Please provide detailed statements for all bank accounts held in the past seven years, including account numbers, transaction dates, amounts, and descriptions.
*. Account Access Restriction: Please provide any communications or documents related to actions taken to restrict the Plaintiff's access to the business bank account.
Respectfully submitted,
[Your Name]
Plaintiff Pro Se
[Your Address]
[Your Phone Number]
[Your Email Address]
Date: [Date]
---
Would you need any more assistance with this motion or anything else related to your case?

In New Mexico, you can potentially subpoena the husband of the defendant if you believe he possesses relevant information or documents related to your case. You’ll need to demonstrate the relevance of his testimony or documents to the case.
Would you like guidance on how to draft a subpoena?

****, you can subpoena the husband if he has relevant information. Here's a basic guide for drafting a subpoena:
*. Identify the Court:
- State of New Mexico
- County of [Your County]
- [Your Court's Name]
*. Case Information:
- Plaintiff: [Your Name]
- Defendant: [Your Ex-Partner's Name]
- Case No.: [Your Case Number]
*. Subpoena Text:
- "To: [Husband's Name]
- You are commanded to appear and testify in the above-stated case, or produce the following documents: [List specific documents you need]."
*. Details: Include the date, time, and place for the testimony or document production.
Would you like more details on filling out this subpoena?

****, you can subpoena the husband if he has relevant information about the embezzled money used for the house down payment. Here’s a sample subpoena request:
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