Drafting Legal Document Requests

Summary

In Floridas 14th Circuit, a Respondents Request for Production can include electronic communications, call records, tax returns, accounting documents, and household tax records for specified years. You can also request subpoenaed evidence, witness lists, correspondence, recordings, vehicle titles, and bank statements. Ensure all documents are requested within a reasonable timeline, typically covering the past 3 to 10 years, depending on the document type. Consider consulting with a legal professional to ensure compliance with local rules and to tailor the request to your specific case needs.

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What is an ideal timeline to ask for cell phone records, income tax, business taxes, for in divorce from your spouse
You can request cell phone records, income tax, and business tax records as part of discovery in a divorce case. Here are some key points:
- Cell Phone Records: Request for the past * to 5 years.
- Income Tax Returns: Typically requested for the past * to 5 years.
- Business Tax Records: Request for the past * to 5 years.
- Household Tax Records: Usually requested for the past * to 10 years.
Have you already discussed this with your attorney or need help in drafting the request?
yes I am requesting a draft
Here's a draft for your Respondent's Request for Production:
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IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT, IN AND FOR [COUNTY NAME], FLORIDA
Case No.: [Your Case Number]
[Your Name],
Petitioner,
vs.
[Spouse's Name],
Respondent.
---
RESPONDENT'S REQUEST FOR PRODUCTION
Respondent, [Your Name], requests that the Petitioner produce the following documents and electronic records within thirty (*) days from the date of service of this request:
*. Electronic Records:
- All electronic communications, including emails, text messages, and social media messages from the past five (*) years.
- All call records from the past five (*) years.
*. Income Tax Returns:
- Copies of federal and state income tax returns filed by the Petitioner for the past five (*) years.
*. Business Tax Returns:
- Copies of all business tax returns filed by the Petitioner for the past five (*) years.
*. Accounting Documents:
- All accounting documents and QuickBooks information related to any businesses owned or operated by the Petitioner for the past five (*) years.
*. Household Tax Records:
- All household tax records, including property tax records, for the past ten (*) years.
DATED this ___ day of [Month], [Year].
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, Zip Code]
[Your Phone Number]
[Your Email Address]
---
Would you like any additional information or assistance with this draft?
Yes, please. I need to modify to all evidence and witness that is subpena
To modify your Respondent's Request for Production to include subpoenaed evidence and witnesses, you can add the following sections:
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RESPONDENT'S REQUEST FOR PRODUCTION
Respondent, [Your Name], requests that the Petitioner produce the following documents and electronic records within thirty (*) days from the date of service of this request:
*. Electronic Records:
- All electronic communications, including emails, text messages, and social media messages from the past five (*) years.
- All call records from the past five (*) years.
*. Income Tax Returns:
- Copies of federal and state income tax returns filed by the Petitioner for the past five (*) years.
*. Business Tax Returns:
- Copies of all business tax returns filed by the Petitioner for the past five (*) years.
*. Accounting Documents:
- All accounting documents and QuickBooks information related to any businesses owned or operated by the Petitioner for the past five (*) years.
*. Household Tax Records:
- All household tax records, including property tax records, for the past ten (*) years.
*. Subpoenaed Evidence:
- All documents, records, and evidence that have been subpoenaed in relation to this case.
*. Witnesses:
- A list of all witnesses, along with their contact information and the subject matter of their testimony, who have been subpoenaed for this case.
DATED this ___ day of [Month], [Year].
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, Zip Code]
[Your Phone Number]
[Your Email Address]
---
Would you like any further alterations or additional information?
yes, please. add to the draft, any corrosponance between parties, all recordings, video or audio, phone calls. Also, all title to the corvette, or a bill of sale for the corvette, *
Sure, here's the updated draft:
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IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT, IN AND FOR [COUNTY NAME], FLORIDA
Case No.: [Your Case Number]
[Your Name],
Petitioner,
vs.
[Spouse's Name],
Respondent.
---
RESPONDENT'S REQUEST FOR PRODUCTION
Respondent, [Your Name], requests that the Petitioner produce the following documents and electronic records within thirty (*) days from the date of service of this request:
*. Electronic Records:
- All electronic communications, including emails, text messages, and social media messages from the past five (*) years.
- All call records from the past five (*) years.
*. Income Tax Returns:
- Copies of federal and state income tax returns filed by the Petitioner for the past five (*) years.
*. Business Tax Returns:
- Copies of all business tax returns filed by the Petitioner for the past five (*) years.
*. Accounting Documents:
- All accounting documents and QuickBooks informationrelated to any businesses owned or operated by the Petitioner for the past five (*) years.
*. Household Tax Records:
- All household tax records, including property tax records, for the past ten (*) years.
*. Subpoenaed Evidence:
- All documents, records, and evidence that have been subpoenaed in relation to this case.
*. Witnesses:
- A list of all witnesses, along with their contact information and the subject matter of their testimony, who have been subpoenaed for this case.
*. Correspondence:
- Any correspondence between the parties, including letters, emails, and messages.
*. Recordings:
- All recordings, including video or audio, and phone calls.
*. Vehicle Information:
- All titles or bills of sale for the * Corvette.
DATED this ___ day of [Month], [Year].
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, Zip Code]
[Your Phone Number]
[Your Email Address]
---
Would you like any further alterations or additional information?
Yes, But can you please add to the draft, all bank statements for the past 5 years, including all records from Quickbooks, and accountant tax returns.
Sure, here's the updated draft:
---
IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT, IN AND FOR [COUNTY NAME], FLORIDA
Case No.: [Your Case Number]
[Your Name],
Petitioner,
vs.
[Spouse's Name],
Respondent.
---
RESPONDENT'S REQUEST FOR PRODUCTION
Respondent, [Your Name], requests that the Petitioner produce the following documents and electronic records within thirty (*) days from the date of service of this request:
*. Electronic Records:
- All electronic communications, including emails, text messages, and social media messages from the past five (*) years.
- All call records from the past five (*) years.
*. Income Tax Returns:
- Copies of federal and state income tax returns filed by the Petitioner for the past five (*) years.
*. Business Tax Returns:
- Copies of all business tax returns filed by the Petitioner for the past five (*) years.
*. Accounting Documents:
- All accounting documents and QuickBooks information related to any businesses owned or operated by the Petitioner for the past five (*) years.
- All accountant tax returns for the past five (*) years.
*. Household Tax Records:
- All household tax records, including property tax records, for the past ten (*) years.
*. Subpoenaed Evidence:
- All documents, records, and evidence that have been subpoenaed in relation to this case.
*. Witnesses:
- A list of all witnesses, along with their contact information and the subject matter of their testimony, who have been subpoenaed for this case.
*. Correspondence:
- Any correspondence between the parties, including letters, emails, and messages.
*. Recordings:
- All recordings, including video or audio, and phone calls.
*. Vehicle Information:
- All titles or bills of sale for the * Corvette.
*. Bank Statements:
- All bank statements for the past five (*) years.
DATED this ___ day of [Month], [Year].
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, Zip Code]
can you rewrite this for me pleease
Sure, here's the revised document:
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DEFINITIONS AND INSTRUCTIONS
As used herein, the following terms shall have the meanings indicated:
- "Document" or "documents": Any original (or copy differing from the original) of any writing or recording, whether handwritten, typed, printed, or recorded by physical, mechanical, electronic, or electrical means. This includes books, records, computer listings, printouts, programs, tapes, papers, pamphlets, brochures, advertisements, specifications, blueprints, maps, surveys, drawings, sketches, graphs, charts, plans, reports, notebooks, worksheets, lists, analyses, summaries, ledger accounts, audits, inventories, tax returns, financial statements, correspondence, communications, telegrams, solicitations, minutes, stock ledgers, certificates, licenses, permits, calendars, diaries, telephone bills, expense reports, balance sheets, accountant’s work papers, payroll records, notes, memoranda, checkbooks, canceled checks, receipts, contracts, agreements, applications, offers, acceptances, proposals, financing statements, documents of title, appraisals, purchase orders, invoices, bills of lading, written memorials of oral communications, forecasts, photographs, slides, negatives, films, tapes, and recordings.
- "You" or "your": Refers to the Mother, including her employees, agents, legal representatives, or corporations.
- "Related to" or "relating to": Directly or indirectly mentioning, describing, pertaining to, being connected with, or reflecting upon a stated subject matter.
- Singular & Plural: Singular includes plural and vice versa.
- Pronouns: Masculine, feminine, or neuter pronouns include all genders.
- Time Span: If not specified, production shall cover documents from the past three (*) years to the date of production.
- Possession or Control: Each request extends to all documents in the possession or control of the Husband, his agents, or employees during the covered period.
- "Identify" or "Identification" of a document: Includes the author/originator, addressee, signatories, date, title/subject matter, present custodian of any copy, and the last known address of each custodian.
- "And" & "Or": "And" includes "or" and vice versa.
- "Any" & "All":