Areas of Practice


Turn over copies of as many documents as possible before the other side even asks for it, with the statement of net worth, bound to the statement of net worth, and get the case closer to the end at the very beginning. Your lawyer knows what the usual documents are to inform you of it. Mandatory disclosure is listed in the Court Rules, rule 202.16(f) Unless it is truly outside of the scope of discovery, a judge will order it produced, so save time and money, and get to the end faster and cheaper. Who cares if the other side does or does not produce as freely. You will be able to go before the judge with clean hands on that issue.

202.16(f) requires both sides exchange and file with the Court the following documents:

A. Sworn Statement of Net Worth and copy of your retainer with your attorney accompanied by all of the following:

  • All pay stubs for the current calendar year, and the last pay stub
  • All filed state and federal tax returns for the previous three years including both personal returns and returns filed on behalf of any partnership or closely held corporation of which you are a partner or shareholder;
  • All W-2 wage and tax statements, 1099 forms, and K-1 forms for any year in the past three years in which you did not file state and federal tax returns;
  • All statements of accounts received during the past three years from each financial institution in which you maintained an account in which cash or securities are held;
  • The statements immediately preceding the commencement date of this divorce action pertaining to:

a. Any policy of life insurance having a cash or surrender value

b. Any deferred compensation plan of any type or nature in which you have an interest including but not limited to:

  • Individual Retirement Accounts (IRA)
  • Pensions
  • Profit sharing plans
  • Keough Plans
  • 401(k) plans
  • Any other retirement type plan