Motion for Discovery - Ex Hiding Money

My ex is hiding his money and attempting to come after me for child support. He’s grossly under-reporting his income. His submitted bank statements showing he makes money as a US Army officer (he didn’t tell me he’s still in the military), a CA state income refund check and deposits from HSA accounts. I have proof he’s owned and operated two Airbnbs earlier this year as well. Yet, he’s only reporting that he makes $46k a year. His defense is he’s only calculating his “primary job”

I’m preparing to file a motion for discovery but I just want someone to lay eyes on it before I send it in. Also, he has not provided me his address for me to serve him the motion? Am I able to do so via email?

Discovery (interrogatories, requests for production of documents, and/or requests for admissions) is a good next step.

You may want to also issue subpoenas for information from AirBnb, banks in which he may have accounts, etc.

Only attorneys in counties where efiling is established can be served by email. Unrepresented parties must be served by mail unless there is documentation in the court file that states a party consents to service by email.

You can try serving him at the address listed on the bank statements and other documentation he has voluntarily provided to you.


Anna Ayscue

Attorney with Rosen Law Firm Cary • Chapel Hill • Durham • Raleigh • Wake Forest

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