IN THE CIRCUIT COURT FOR
                              COUNTY,                              (STATE)

TO:

          Pursuant to the Rules of Civil Procedure, Petitioner requests that Respondent produce and permit Petitioner, or someone acting on her behalf, to inspect and copy documents and data compilations designated as follows:

1. Any and all financial statements or copies thereof, furnished by Respondent to any bank or other lender, or otherwise prepared, during                         .

2. Any and all W-2 or 1099 forms and Federal and State Income Tax Returns, or copies thereof, received and filed by Respondent during                          to the date of this Request for Production of Documents.

3. A photocopy of the first or identifying page of each of the policies of insurance referred to in Respondent's Answers to Interrogatories.

          Respondent's check register(s), bank statements, and account records regarding deposits and withdrawals for the period                          to the date of this Request for Production of Documents for each depository referred to in Petitioner's Answers to Interrogatories.

1. If Respondent has created any Wills or Trust, either Irrevocable or Revocable, provide copies of each Will and/or Trust’s instrument establishing each such trust.

2. If Respondent is a beneficiary under any trust, either irrevocable or revocable, provide a copy of each trust instrument establishing such trust, all  accountings received or prepared in the last two years to the date hereof.

3. If Respondent has any interest in any pension and/or profit sharing plan, then obtain and forward copies of the following for each plan in which the Respondent participates:
   a) Summary Plan Description.
   b) Latest Summary Annual Report.
   c) Current Statement of Accrued Vested Benefits.
   d) IRS Form 5500C, or its equivalent, for the years to date (if applicable).

4. If Respondent is the beneficiary under any probate or other similar proceeding, then obtain and forward copies of the Will, estate or other documents relating to Respondent's interest.

5. A photocopy of all documentation showing the acquisition and present ownership interest(s) of the asset listed in Respondent's Answers to Interrogatories.

6. For all property owned by either or both of the parties which Respondent claims to be non-marital property within the meaning of the law, provide all documents upon which he will rely in support of his allegation that such property is non-marital. This response should include, but not be limited to, all documents which substantiate:
   a) The exact description or identifying detail of the property/properties;
   b) The date Respondent's interest was created in said property;
   c) If Respondent's interest was not created by gift, the name of the Grantor, transferor or other person or entity, the amount and terms of consideration paid for said property, and the source of the consideration;
   d) If Respondent's interest was created by gift, the name of the donor and the value of the gift at transfer;
   e) Present fair market value;
   f) Present amount of any encumbrance, the nature of the encumbrance and the name of mortgagee or creditor;
   g) The source of any initial funds used to purchase or obtain the property and all documents you will rely upon in tracing those initial funds through any subsequent transfers or other transactions of or concerning the property.

7. If Respondent has consulted with, counseled or been treated by someone for psychological or emotional problems during the term of the marriage, attach all relevant records of said person or provide an appropriate authorization to enable Petitioner's counsel to review, inspect and copy all of said records.

8. Any and all contracts or plans under which Respondent is receiving or may receive compensation or benefits, including but not limited to Paysop plans, thrift plans, stock option plans, and bonus plans, together with such documents as will show the nature and extent of Respondent's interest in any such plan.

9. Any and all appraisals done for or for the benefit of Respondent in the last five years for any property or assets in which Respondent has an interest.

10. Any and all other documents in the possession, custody or control of Respondent which evidence Respondent's current financial position, living expenses and liabilities.

          It is requested that the above designated documents and data compilations be made available for visual inspection and selective photographing at the office of Petitioner's attorney,                                           , within thirty(30) days from the date of these Requests. If additional requested documentation becomes available, Respondent is under a duty pursuant to the Rules of Civil Procedure to inform Plaintiff's counsel and permit inspection and copying of them.