How to deny a "request of production of documents" for any type of income, retirement, pension, w2 forms etc, for the past present and future when 1. parties were never married 2. the child was born 9 months after for when they asked for the documentation to go back to and 3. the Defendants lawyer signed as the Plaintiffs lawyer.
1 Answer from Attorneys
You should address each and every question/request separately. Relevance is a specific ground on which you can deny a request. But keep in mind that the standard of relevance for a discovery request is a lower threshold than admission of evidence at trial. You should consider consulting an attorney to properly advise you on the pending request.
This response is based on the limited facts you have provided and is not intended to create an attorney-client relationship. I cannot provide adequate advice to you without meeting with you in person. If you would like to schedule a consultation, please feel free to contact me