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last minute deposition advice

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jyoung

Member
tomorrow, 9am, Florida, pro se again, going in unrepresented to the wolves' den pre trial (first week December). Fiancee follows me at 11, I'm sitting in, my boss at 2pm- she's represented by counsel and insists I go back to mind the shop while she's deposed. I've nothing to hide, plenty to say (if asked the right question), confident of my position and will speak the truth. Any pitfalls I might get into, things to avoid, times I will be able to
not answer a particular question, etc.?

Also, at a hearing on 10/19 on a request from my opponent, the general master (and I) agreed to order psych counseling for my daughter. I had made a similar request in a Motion for Custodial Evaluation that was dismissed on a tech issue months ago. The general master recommended that I submit names from my insurance carrier to be chosen by the ex wife, I did so on Oct 24.
Since then the judge has issued the order. I have been unsuccessful in getting the other side to commit yet to a particular doctor in order to get the ball rolling. As the judge's order has only been in effect for two weeks do I have a right to call a hearing to compel the other side to pick the damn doctor and get my kid some assistance or is it too soon to push the issue and if so how much time should be alloted. This should not be a problem since we all agreed to the need, but I feel like they are fishing for a doctor who will prove favorable to their case, against the express wishes of the judge and commissioner.

Finally, I filed my answer to a third pending supplemental petition
(for modification of child support) on November 1. Included with my answer was a Request for Production for documentation that is required by Mandatory Disclosure which was missing from my ex's paperwork, including most recent tax returns and/or proof of income for both my daughter and my ex. How much time should pass before I file that Motion to Compel with the judge?

Thanks in advance for any info....I've been away from the boards
for a while and anyone who needs an update let me know.
 



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