Below is a lengthy list of items that a divorce attorney should consider requesting in discovery in family law cases. In an ordinary divorce or child support matter, many of these items will be irrelevant or non-existent.

This list is provided to give you a comprehensive list of items you should consider. However, this list is not exhaustive, and depending on the unique financial issues in your case, additional items may need to be requested. Individual items may need further descriptions in order to ensure compliance and prevent the opposing party from claiming they did not understand the request or do not have the item.

Basic financial documents to request or subpoena:

• All personal balance sheets and financial statements for the last 5 years
• Personal income tax returns (Form 1040) for the last 5 years, including any amended returns
• W-2 and/or pay stubs for all years for which personal income tax returns have not yet been completed or filed
• Copies of personal financial statements prepared for any purpose in the last 3 years
• List of all bank accounts in the party’s name or to which the party has access, including the bank name, bank location, account number, and type of account
• List of all bank accounts in the party’s name or to which the party has access that have been closed within the last 5 years, including the bank name, bank location, account number, and type of account
• List of all credit cards, full account numbers, and current balances for any card in the party’s name, or with which the party has charging authority (this includes credit cards which the party uses, but are paid by a business or other entity)
• List of all cryptocurrencies owned, including information on the wallet and the number of tokens or coins owned
• List of all cash transfer or peer-to-peer (P2P) payment applications (apps) used, such as Cash App, Venmo, Zelle, PayPal, Wise, Google Pay, Apple Pay, or any other such app
• Detailed list of any investments, ownerships, or other interests in brokerage accounts, treasury bills, treasury bonds, stocks, stock options, stock warrants, bonds, debentures, guaranteed investment certificates, annuities, term deposits, bankers acceptances, limited partnerships, commercial partnerships, joint ventures, pension plans, 401(k) plans, individual retirement accounts, Employee Stock Option Plans (ESOP), profit-sharing plans, put options, call options, tax shelters, and any other investment of any nature, whether held directly, indirectly, or in any manner whatsoever
• List of any loans, accounts, or claims receivable with parties, terms, and full details
• All applications for credit made with banks, mortgage brokers, or any other financial institution in the preceding 3 years
• List of any deposits held in escrow for or by the party
• List of all safe deposit boxes in the party’s name and the names of the party’s nominees, including the location of each box, a list of the contents, all people with access to each box, and a schedule of all visits to the boxes in the preceding 3 years
• All life insurance policies (whether term or whole life), beneficiaries, and current cash values
• All wills and trust under which the party is a capital beneficiary or income beneficiary
• List of all vehicles owned or leased by the party of for the party’s personal use, including automobiles, boats, snowmobiles, personal watercraft, motorcycles, and aircraft
• List of all real estate interests owned by the party directly, indirectly, or in any manner whatsoever
• Details of alterations, improvements, or renovations in excess of $5,000 made to the party’s residence in the preceding 3 years
• Schedule of all gifts or transfers in excess of $2,500 made by the party to any individual or business entity in the preceding 3 years, including the recipient, the nature of the gift, the gift’s value, the date of transfer, the relationship to the recipient, and any documentation related to the gift
• List all sources of remuneration, including salaries, bonuses, stock options, expense allowances, auto allowances, club memberships, entertainment, sports events, or other compensation
• List of all persons to whom the party has given power of attorney during the preceding 5 years
• List of all trusts established by the party during the preceding 5 years, including the names of all principal and income beneficiaries

If supporting documentation for assets is deemed necessary:

• All insurance policies covering real estate, vehicles, boats, personal effects, and any other assets
• All tax assessments of real estate owned

If a detailed analysis of spending is deemed necessary:

• All bank statements, checks, deposit slips, deposit items, and wire transfers for the last 3 (or 5) years for any bank accounts to which the party has access
• All credit card statements for the last 3 (or 5) years for any credit card in the party’s name or with which the party has charging authority
• All brokerage account statements for the last 3 (or 5) years for any brokerage accounts to which the party has access
• Electronic copy of any software used to track personal finances (such as Quicken or QuickBooks) along with login and password information

Documents to request if there have been any audits or other tax issues:

• Any notices of assessment or other correspondence about examinations, additional liabilities or other disputes with taxing authorities in the last 5 years

Documents related to business entities wholly or partially owned by either spouse:

• Business ownership records (stock certificates, charters, operating agreements, joint venture agreements, corporate minutes, or other related documents)
• Business income tax returns (Form 1065, 1120, or 1120-S) for any business in which the spouse/parent has had an ownership interest for the last 5 years
• Financial statements for any business entity in which there is an interest, including professional practices, joint ventures, and co-ownerships for the last 5 years
• Valuations or appraisals done within the preceding 5 years
• Budgets, forecasts, projections, or business plans prepared within the preceding 5 years
• List of all bank accounts in the company’s name, including the bank name, bank location, account number, and type of account
• List of all bank accounts in the company’s name that have been closed within the last 5 years, including the bank name, bank location, account number, and type of account
• Books of minutes of companies controlled directly or indirectly by the party, including articles of incorporation, amendments, bylaws, minutes, and resolutions of shareholders and directors
• All applications for credit made with banks, mortgage brokers, or any other financial institution in the preceding 3 years

If a more in-depth analysis of the business entities is necessary:

• Electronic copy of any software used to track business finances (such as QuickBooks, Sage, or other accounting software) along with login and password information
• Employee-related documents, including payroll records for the preceding 3 years, copies of fringe benefits including insurance, medical reimbursement, or cafeteria plans, vacation policy, sick pay policy, child and dependent care plans, bonus computations, commission plan, tuition reimbursement plans
• All employee contracts
• Deferred compensation and retirement plan records, including plan documents for any pension plan, profit sharing plan, 401(k) or any other plan
• Buy-sell agreements
• List of all customers and copies of all major customer contracts
• Lease agreements
• All notes payable
• All appraisals of fixed assets within the last 5 years
• Depreciation schedules
• Current accounts receivable aging report
• Detailed inventory listing
• Schedule of investments
• All notes receivable
• Documents related to all patents, trademarks, and copyrights owned by the company or in the process of being filed

If there are questions about the legitimacy of the financial statements or tax returns of any business entity in which a spouse has an ownership interest:

• Valuations or appraisals done within the preceding 5 years
• Budgets, forecasts, projections, or business plans prepared within the preceding 5 years
• All bank statements, checks, deposit slips, and wire transfers for the last 3 years
• All credit card statements for the last 3 years
• All brokerage account statements for the last 3 years
• All applications for credit with any financial institution during the preceding 3 years
• Access to detailed accounting records, including the general ledger, general journal, sales journal purchases journal, cash receipts journal, cash disbursements journal, check register, and subsidiary ledgers
• List of names, addresses, and ownership percentages of all shareholders