Thank you for your new question.
Quite honestly, if she does not have to attach any exhibits to her complaint the better. It is generally always best to hold off on exhibits until the discovery phase. That is a problem many pro se litigants have, they want to attach all of their proof to the complaint because they think it helps and all it does is give the opponent chance to object or come up with evidence to counter her evidence. So in discovery she would request them to produce documents and they would request her to produce her documents and she would produce some that are required under the Rule 16 disclosures
and the rest she would wait until she receives a request for production. If they never request them, she would introduce them in trial. Ultimately, she will want to introduce all of those exhibits.
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