The Request for Production of Documents can seem inundating. The categories listed below do not represent a complete list and does not represent all of the documents you may be ask to produce. All of the documents mentioned below pertain to both you and your spouse and for both separate property and community property. In most instances one party is the keeper of the family’s documents, and if that person is you and you have the documents pertaining to your spouse you must produce those documents.
1. BANKING RECORDS: This includes copies of bank statements, checks, deposit slips,
and signature cards.
2. SAFE DEPOSIT BOXES AND VAULTS: This includes copies of any sign-in card the signature card indicating who has access to the box; the location of the box and a list of the contents.
3. FINANCIAL STATEMENTS: This includes copies of all financial statements you may have prepared to obtain a loan; as a requirement of your banking institution personally or if you own a business; etc.
4. RETIREMENT BENEFITS: This includes a copy of your monthly and/or quarterly/annual statements for any and all retirement accounts, this includes, IRA accounts, 401(k) accounts, etc.
5. BENEFITS FURNISHED: If your place of employment offers any type of benefits this includes medical insurance, medical savings account, retirement benefits, auto allowance etc. a copy of the policy must be produced.
6. INCOME: This includes copies of your pay stubs, direct deposit receipts, W-2s 1099s, 
etc. If you earn money through craft fairs, referring, or any other type of self employment you need to produce documents evidencing that income.
7. BUSINESS EXPENSE RECORDS: This includes copies of all documents reflecting expenses paid by you or your spouse in connection with any business you may be involved in.
8. EXPENSE REIMBURSEMENT: If you are reimbursed for any business expenses through you place of employment you will need to produce copies of those reimbursements.
9. GIFTS, INHERITANCE, AND BEQUESTS: If you received any gifts, inheritance, and/or bequests from any person during your marriage you will need to account for those gifts, inheritance, and/or bequests.
10. PROBATED ESTATE: If there is an estate in which you are designated as distributed you will need to provide a copy of the will, inventory and appraisement and a letter stating when distribution may be expected and the probable amount that you will receive.
11. GIFTS: If you gave large gifts during you marriage these gifts will need to be accounted
for. Gifts include monies you may have loaned to a person and/or family member.
12. TRAVEL: If you have traveled outside of you geographic area you will need to produce documents relating to that travel. The documents that you will need to produce are copies of airline tickets, hotel receipts, restaurant receipts, car rental, etc.
13. PAID OFF INDEBTEDNESS: If any debt have been totally paid off copies of those documents will need to be produced..
14. LOANS: If you have any outstanding loans, all documents relating to those loans must be produced.
15. PROMISSORY NOTES, INSTALLMENT NOTES, ETC.: You must produce all documents relating to promissory notes, installment notes, drafts, bills or exchange or other orders for the payment of money.
16. CHARGE ACCOUNT RECORDS: If you have any credit cards you must produce copies of those credit card statements.
17. GUARANTEES: If you have guaranteed a loan for anyone you must produce copies of those documents.
18. MORTGAGE INDEBTEDNESS: All documents relating to any mortgage indebtedness payable on our homestead showing the method of repayment required, must be produced.
19. VEHICLE OWNERSHIP: Any and all books, records, documents, or instruments pertaining to all motor vehicles, boats, aircrafts, recreational vehicles, motorcycles, trailers, and other motor powered equipment or vehicles owned must be produced.
20. REALTY INSTRUMENTS, EXCLUDING MINERAL RIGHTS AND OIL AND GAS RIGHTS: Any and all books, records documents, or other instruments, must be produced.
21. REAL PROPERTY INTEREST HELD THROUGH PARTNERSHIP OF JOINT VENTURE: If you are a part of a partnership or joint venture then you must produce copies of all documents forming those partnerships or joint ventures, including the agreement, contracts of any form, financial statements, names and address of all the other partners or co-ventures etc.
22. STOCKS AND BONDS: If you own any stocks and bonds copies of all documents recording your ownership must be produced.
23. INVESTMENTS: Copies of all investment/brokerage accounts must be produced; this includes all statements, buy/sell orders and other correspondence and documents you may have relating to those accounts.
24. ANY OTHER PROPERTY INTERESTS: If you have any interest in any other type of investment, asset, or property interest, whether or not in your name, and including any property or property interest that you used or over which you exercised any type of dominion or control, those documents must also be produced.
25. INSURANCE: Any and all records pertaining to insurance, this includes motor vehicle insurance, homeowners insurance, renter’s insurance, life insurance, disability insurance, health insurance, etc.
26. INSURANCE PROCEEDS: If you received any type of insurance proceeds those documents must be produced.
27. TAX RETURNS: This means a complete copy of your income tax return including all of the attachments, forms and schedules. These should be the signed copies. This will also include copies of any business entity tax returns you may be involved with, trust tax returns, and if you are a business owner this will include copies of 941s, 940s, state withholding forms and sales tax reports.
28. NOTICE OF UNPAID INCOME TAXES: Any and all records, documents, instruments, or notices of unpaid income taxes.
29. PERSONAL CORRESPONDENCE: If you have written any form of correspondence, this includes emails, to anyone regarding your marriage problems and the dissolution of your marriage you must produce a copy of those documents.
30. EMPLOYMENT CONTRACTS: If you have signed any type of employment contract, this includes non compete agreements they must be produced.
31. REPORT OF EXPERTS: All documents and tangible things including all tangible reports, physical models, complication of data and other material prepared by, for, or provided to an expert in anticipation of the expert’s trial and/or deposition testimony, whether it was prepared in anticipation of litigation or for trial when it forms a basis in whole or part of the opinion of the expert who is to be called as a witness.
32. HEALTH PROFESSIONAL’S DOCUMENTATION: All documents, reports and tangible items which state the findings, conclusions, or diagnosis made by any physician, psychologist, psychiatrist, counselor, or other health professional whom you have seen.
33. MEDICAL RECORDS: All medical records, prescription records, pharmacy records, hospital bills, or other billings reflecting medical care rendered on your behalf.
34. DIARIES, ETC.: Any and all notes, diaries, calendars, journals, memoranda, and other type of personal notations, hand written or entered into or kept on a computer, palm pilot or like device.
35. TANGIBLE DOCUMENTS: All photos, tape recordings, written documents, or other demonstrative evidence that you intend to use at trial or you contend supports any request for damages made by you in this cause of action.
36. BUSINESS ENTITIES: If you own a business entity you will need to produce all the records pertaining to that entity including making a back up of the accounting records if they are maintained on a computer.
