By Nathan A. Hacker
The request for production of documents is the type of discovery that you see in the movies where guys are pushing carts full of bankers boxes out of office buildings.
Each box has thousands of pages in it and some poor summer associate at the big law firm is going to have to sift through all of it looking for the three-line email from the chief chemist to the CEO that says, "I think our new chemical is toxic and will cause birth defects if it gets into the water supply."
No, I can’t name the movie, I think it was Erin Civil Michael… something or other starring any number of Oscar nominated actors.
It typically doesn’t work that way in divorce or other family proceedings, though. Requests for production of documents will be centered on the areas of finance and children, just like the interrogatories examined in my previous article on discovery.

Debra Worthington
By Nancy Fagan
Michelle Skeen has written a book about a topic many 




