CHECKLIST FOR REQUIRED INITIAL DISCLOSURES
You will need to provide this information soon after filing a lawsuit:
- Parties’ Information: Names, addresses, and telephone numbers of any potential parties
- Claims & Defenses: Factual bases of your claims & defenses
- Fact Witnesses Information: Names, addresses, & telephone numbers of persons having knowledge of relevant facts, and a brief statement of each identified person’s connection with the case
- ALL Supporting Documents: A copy of all documents, electronically stored information, and tangible things that you have in your possession, custody, or control that you may use to support your claims or defenses (if copies cannot be obtained, then provide a description by category and location)
- Agreements: Any settlement agreements you may have with your spouse, including any Premarital Agreements, Marital Property Agreements, mediation agreements etc.
- Witness Statements: Any witness statements, including written statements and recordings of oral statements
- Real Property: All deed and lien information on any real property owned and all lease information on any real property leased
- Retirement Account Statements: All statements for the past 2 years relating to any pension plan, retirement plan, profit-sharing plan, employee benefit plan, and individual retirement plan (more information and statements may be required depending on the character of the asset)
- Life Insurance: Each current life, casualty, liability, and health insurance policy, and statements re: the policy for the past 2 years
- Financial Account Statements: All statements for the past 2 years pertaining to any account at a financial institution, including banks, savings and loan institutions, credit unions, & brokerage firms
- Health Insurance: All policies, statements, & the summary description of benefits for any medical and health insurance coverage that is or would be available for the parties and children
- Income Tax Returns/Info: Income tax returns for the previous two years or, if no return has been filed then the Form W-2, Form 1099, and Schedule K-1 for those years
- Payroll Stubs: Your 2 most recent payroll check stubs