Unless otherwise agreed by the parties that in divorces and
many other probate court actions the parties will have to provide Federal and
State income tax returns and schedules for the past three (3) years. You will have
to provide the four (4) most recent paystubs from each employer; documentation
regarding the cost and nature of available health insurance; three (3) years of
bank accounts held in either parties name, individually or jointly or with
someone else’s name; three (3) years of any securities, stocks, bonds, notes,
obligations, cd’s held by either party for the benefit of the children; 401k,
IRA statements and pension plan statements for all accounts listed; copies of
any loan or mortgage applications made, prepared or submitted by either party
in the last three (3) years; copies of any financial statements or statements
of assets, liabilities prepared by either party in the last three (3) years
prior to filing the Complaint.

The parties are also required to add any material changes
made during the progress of this.  If
some of the documents are unavailable, the party has to state this in writing
the reason under pains and penalties of perjury that the specific documents are
not available and what efforts have been made to obtain the documents.  Although, many times the parties can agree to
a more targeted discovery process where they agree that not all the documents
are needed and other times where more documents are needed than just listed in
the 410 Discovery.