divorce

Paul:

My mother will be bringing a check to you tomorrow in partial payment of
services rendered.

I'd like to subpoena Jack's apartment lease and application for Pin Oak
Estates. Can you provide me with some form subpoena and I'll do whatever
"leg work" needs to be done in order to minimize your time. I know time is
short for you with your vacation coming up. I'm hoping Jack signed his lease
(and possibly the application) post April 12. However, I'm afraid he signed
the application prior to the April 12 hearing date, but signed the lease post
hearing date. Is this of any significant relevance?

Secondly, after we receive the lease and application, I'd like to send out
some requests for production. It doesn't seem as though we're going to be
able to settle this, so I thought we'd be best served by getting as much
information from them as possible. Let me know what you think about this
idea. Below, I have listed a few discovery requests ---- let me know if
you think these are adequate.

1. Please produce your paycheck stubs from each full-time and part-time job
you have had since January 1, 2000 until the present.
2. Please produce your application for apartment lease at Pin Oak Estates
Apartments.
3. Please produce your lease agreement on your apartment located at Pin Oak
Estates Apartments.
4. Please produce your bank statements from Chase Bank (or any other banking
facility you have) for the months of April and May 2000.
5. Please produce your credit card statements for all credit cards in your
name, both jointly with your wife and solely in your name.
6. Please produce all statements of the stock account in your name with the
brokerage firm, Datek, and any other stock brokerage firm.
7. Please produce your 401K account statement from all such accounts both
with your current employer and with your previous employers.
8. Please produce a copy of your current W-2 as filed with your current
employer(s).

Like I stated above, we need to get his lease agreement and application
before we ask him to provide it, so he doesn't try to alter the date or
anything else.

Also, I am happy to put these discovery requests in final form or do whatever
you think is best. I hope you understand my need to keep costs at a
minimal. Thanks for your advice.

Linda

P.S. In light of your vacation, will there be anyone who can help me while
you're gone? Would you like me to ask my boss to step in as co-counsel? I
don't know if he's willing or not, but I can certainly ask. After all, pride
left me a long time ago. Money is a factor, however, I need representation
while you're away. Let me know what you think. Thanks.