If you are a divorcing spouse, judgment creditor or other litigant, how do you conclusively establish whether or not assets have been hidden from you? You can sometimes reasonably determine this by using legal tools to search for assets. In a pending litigation, these tools might include: depositions; subpoenas; interrogatories; production requests; etc.
Below is part of a production request in the hypothetical case of “JOHN DOE.” The production request seeks access to JOHN DOE’s passport; credit cards; phone records; etc. By analyzing this kind of material one might possibly detect secret offshore bank accounts or other hidden assets.
1. JOHN DOE’s original passport of which FRED L. ABRAMS, ESQ. (or his representative), may possess for a period of not more than 45 minutes to photocopy and return to JOHN DOE.
2. All paid and unpaid invoices from creditors arising from obligations incurred by JOHN DOE for the period January 1, 2011 to present.
3. All of JOHN DOE’s telephone records, (including cell phone records), for the period of January 1, 2011 to date.
4. Receipts and copies of airplane tickets for all air flights JOHN DOE traveled, during January 1, 2011 up to the present date.
5. All frequent flyer miles statements relating to any air flights JOHN DOE traveled, during January 1, 2011 up to the present date.
6. Receipts or documents relating to all hotel accommodations JOHN DOE paid for or hotels JOHN DOE stayed at anytime during the period of January 1, 2011 to the present.
7. All records and documents relating to any transaction entered into on or after January 1, 2011 in which JOHN DOE presently has or will have a financial interest or from which JOHN DOE has received or will receive compensation of any nature.
8. All documents related to any transaction since January 1, 2011, entered into by another person or entity for the benefit in whole or in part, of JOHN DOE.
9. All documents showing the amount, purpose or source of all payments over $5,000.00 made since January 1, 2011, to, by or for the benefit of JOHN DOE.
10. Copies of all of JOHN DOE’s current and previous wills and other estate planning documents.
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