Discovery Manager Agent

Florida Rule 12.285 - Mandatory Disclosure (45 days from service):

Required Documents:
✓ Financial Affidavit Form 12.902(b) (under $50k income) OR Form 12.902(c) (over $50k)
✓ Federal and state income tax returns (past 3 years)
✓ Pay stubs for preceding 3 months
✓ Bank statements (all accounts, past 3 months)
✓ Credit card statements (all accounts, past 3 months)
✓ Retirement account statements (past 12 months)
✓ Life insurance policy statements
✓ Real property deeds and mortgage statements
✓ Vehicle titles and loan statements

Note: Florida requires BOTH parties to exchange these documents within 45 days
of service of the petition, even before discovery requests are served.

Your Discovery Command Center shows you're currently at 60% compliance.
Still missing: Retirement Accounts and Property Records.

REQUEST FOR PRODUCTION NO. 1:
All business records for [Business Name] for the past three (3) years, including
but not limited to:
  a) General ledgers and journals
  b) Cash receipts journals
  c) Daily sales reports
  d) Deposit slips and bank deposit records
  e) Point-of-sale system reports
  f) Customer invoices (all formats: printed, electronic, carbon copies)
  g) Accounts receivable aging reports

REQUEST FOR PRODUCTION NO. 2:
All business bank account statements for [Business Name] for the past three (3)
years, including checking, savings, and merchant services accounts.

REQUEST FOR PRODUCTION NO. 3:
All merchant services statements (credit card processing) for [Business Name]
for the past three (3) years, including but not limited to statements from
Square, Stripe, PayPal, Clover, or any other payment processor.

REQUEST FOR PRODUCTION NO. 4:
All business tax returns (federal and state) for [Business Name] for the past
three (3) years, including all schedules, attachments, and supporting documentation.

REQUEST FOR PRODUCTION NO. 5:
All contracts, bids, proposals, and estimates provided to customers for services
performed by [Business Name] during the past three (3) years.

STRATEGY NOTE:
Cash businesses often show discrepancies between:
1. Deposit records vs. reported income
2. Lifestyle expenses vs. reported income
3. Credit card processing totals vs. cash deposits

Once you receive these documents, ask me to analyze them for red flags
indicating unreported income.

Based on your jurisdiction (Florida), here's what you need to reach 100% compliance:

RETIREMENT ACCOUNTS (currently missing):
You need statements for ALL retirement accounts for the past 12 months:
  ☐ 401(k) / 403(b) plans
  ☐ Traditional IRAs
  ☐ Roth IRAs
  ☐ SEP-IRAs (if self-employed)
  ☐ Pension plans
  ☐ Deferred compensation plans
  ☐ Annuities with cash value

Each statement should show:
  - Current balance
  - Contribution history (past 12 months)
  - Beneficiary designations
  - Loan balances (if any)

PROPERTY RECORDS (currently missing):
  ☐ Real property deeds (all properties owned individually or jointly)
  ☐ Current mortgage statements showing balance and payment amount
  ☐ Most recent property tax assessment
  ☐ Homeowner's insurance declarations page
  ☐ Vehicle titles for all vehicles
  ☐ Vehicle loan statements (if financed)

NEXT STEPS:
1. Upload retirement statements to Discovery Command Center
2. Upload property deeds and mortgage statements
3. System will auto-categorize and update compliance percentage
4. Once at 100%, use "Generate Certificate" button for FL-compliant Certificate of Compliance

Need help requesting these from opposing party? Ask me to draft the requests.

This is a common incomplete disclosure tactic. Here's your follow-up strategy:

1. DEFICIENCY LETTER (send first):

"Your response to Request for Production No. 5 is incomplete. You produced
statements for Wells Fargo checking account ending in -4532 only. However:

a) The financial affidavit you filed under oath (Form 12.902(c), page 3, line 8)
   lists THREE bank accounts with total balance of $47,850.

b) You produced only ONE account with balance of $8,200, creating a discrepancy
   of $39,650.

c) Tax return Schedule B (Interest and Dividend Income) shows interest from
   institutions not represented in your production: Chase Bank and Navy Federal
   Credit Union.

Demand: Produce complete statements for ALL accounts listed in your financial
affidavit and all accounts generating interest reported on tax returns, for
the past 12 months, within 10 days pursuant to Florida Family Law Rule 12.285."

2. IF NO COMPLIANCE (file motion):

"MOTION TO COMPEL COMPLETE FINANCIAL DISCLOSURE"

I can draft the full motion if needed. The key is catching the discrepancy
between what he disclosed under oath vs. what he actually produced.

Cross-reference:
- His financial affidavit (page 3, line 8)
- His tax return Schedule B
- Account numbers on checks (if you have any)
- Venmo/PayPal transfers showing other account numbers

High-Asset Medical Practice Discovery Strategy:

PHASE 1: STANDARD FINANCIAL DISCLOSURE (immediate)
Request mandatory disclosure documents per your jurisdiction, focusing on:
- Personal tax returns (3 years) - look for Schedule C/1099 income
- Personal bank statements - track lifestyle vs. reported income
- Credit card statements - identify business vs. personal expenses

PHASE 2: BUSINESS FINANCIAL DISCOVERY (30 days)
Request for Production targeting:
1. Business tax returns (3 years, all schedules)
2. Profit & Loss statements (monthly, 3 years)
3. Balance sheets (monthly, 3 years)
4. Business bank statements (all accounts, 3 years)
5. Accounts receivable aging reports
6. Payor contracts (insurance companies, Medicare/Medicaid)
7. Patient billing records (anonymized aggregate data)

PHASE 3: BUSINESS VALUATION DISCOVERY (60 days)
8. Buy-sell agreements (valuation methodology)
9. Partnership/shareholder agreements
10. Prior business appraisals (if any)
11. Capital equipment lists and depreciation schedules
12. Office lease agreements
13. Employee compensation records (benchmark for spouse's salary)

INTERROGATORIES (serve with Phase 2):
- Identify all sources of business income
- List all business bank accounts (past 5 years)
- Identify personal use of business assets (vehicle, phone, etc.)
- Detail compensation structure (salary, distributions, bonuses)

RED FLAGS TO INVESTIGATE:
☐ Discrepancy between lifestyle and reported income
☐ Large "loans" from business to personal accounts
☐ Timing of reduced income (post-separation income reduction)
☐ Personal expenses paid through business
☐ Deferred compensation or bonuses timed around divorce

Want me to draft any of these requests specifically?

California Discovery Response Deadline:

Served: May 15, 2025
Due: June 19, 2025 (35 calendar days)

CALCULATION:
- California Code of Civil Procedure § 2030.260(a): 30 days to respond
- PLUS 5 days for service by mail (CCP § 1013)
- Total: 35 calendar days from date of service

IMPORTANT NOTES:
✓ Deadline falls on Thursday, June 19, 2025 (business day - no extension needed)
✓ If you need more time, request extension BEFORE deadline
✓ Failure to respond = deemed admissions to facts asserted in questions
✓ You can object to specific questions but must still respond to others

NEXT STEPS:
1. Review interrogatories for objectionable requests
2. Gather responsive information
3. Draft responses (I can help)
4. Have client verify accuracy
5. Serve responses by June 19, 2025

Want me to help you draft objections to any overly broad questions?