It sounds like you have a very strong case, which is wonderful. Generally, the discovery you must provide is that which is requested by the other side. Thus, if they ask for it, you need to get it to them before 14 days before trial. If they asked you for any statements,documents, etc. purporting to show any criminal activity on the part of the mother
, you'd want to send them a copy of what you have. If they don't, I do not see that you would. (Not to mention, none of that would be a 'suprise' to her, since she knows or has reason to know of her own criminal record.) The reason for the provision is so that if you have a secret witness, and they have asked for names of all witnesses that MIGHT be testifying, you provide same, so they have the opportunity to depose her or investigate. Florida Rule of Civil Procedure 1.280 provides:
(a) Discovery Methods. Parties may obtain discovery by one or more of the following methods:
depositions upon oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property for inspection and other purposes; physical and mental examinations; and requests for admission. Unless the court orders otherwise and under subdivision (c) of this rule, the frequency of use of these methods is not limited, except as provided in rule 1.200 and rule 1.340.
So really, each party is responsible for ASKING for the discovery it wants.
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