In a divorce action, Elena strongly suspects that her husband, Richard, is concealing assets. In a box at home she has found a mortgage application he apparently filed recently to get a mortgage on a vacation property in Lake Tahoe. The application confirms her suspicions in that it lists several assets that he claims to possess, assets not listed on his financial statement. Her lawyer would like to avoid having to call the mortgage broker as a witness to testify regarding the authenticity of the mortgage application. Which of the following formal discovery methods should the lawyer use to avoid having to prove its authenticity at trial?
A) a request for production of documents
B) interrogatories
C) a handwriting expert
D) a request for admission
Question 2
In his divorce action, Hugh, is deliberately concealing assets and providing false and misleading information. Which of the following is likely to be the most readily accessible and helpful resource for uncovering hidden assets including sales of stocks and bonds, mortgages on real estate, and sales of real estate and other investments held for a long period of time?
A) credit card statements
B) Hugh's financial statements
C) a search of public records
D) the parties' joint tax returns for the prior five years
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