​​By the time I was in over my head as to what I could do to keep my child support modification case going - so I brought on a​n amazing divorce attorney.  

At this point he was​ working with me delivering unbundled legal services and ​therefore, only on board to keep the subpoenas and their evidence in the game.

​Read the Motions to Quash the Subpoenas.

Divorce ​Checklist Lessons:

  1. ​​​If you cannot afford, or don't want to pay for, an attorney on retainer, you can sometimes find good lawyers who will work with you delivering unbundled legal services.  This means that they will work on and charge you for discrete tasks such as drafting documents or representing you at a certain court appearance. When my back was against the wall, unbundled legal services enabled me to keep the case alive.
Judgement for the Dissolution of Marriage

IN THE CIRCUIT COURT OF XXXXXXXXXXXCOUNTY, XXXXXXXXXXX COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

RESPONSE TO MOTION TO QUASH SUBPOENAS

NOW COMES the Respondent, XXXXXXXXXXX by and through her attorney XXXXXXXXXXX and in response to the Petitioner XXXXXXXXXXX and non-party XXXXXXXXXXX Motion to Quash Subpoenas (the Motion"), XXXXXXXXXXX states as follows:

           1. XXXXXXXXXXX moves to strike the allegations contained in Paragraph 1 of the Motion as it states legal and factual conclusions; in the alternative XXXXXXXXXXX denies the allegations as stated in Paragraph 1 of the Motion.

           2. XXXXXXXXXXX moves to strike the allegations contained in Paragraph 2 of the Motion as it fails to state a plain and concise statement of the Petitioner's cause of action; in the alternative XXXXXXXXXXX moves to strike the allegations contained in Paragraph 2 of the Motion as it states factual conclusions; finally and in the alternative XXXXXXXXXXX admits that XXXXXXXXXXX is an assumed name used by XXXXXXXXXXX as identified in the IRS notice, but is without sufficient information with which to either admit or deny the remaining allegations set forth in Paragraph 2 of the Motion and therefore denies the remaining allegations and demands strict proof thereof.

           3. XXXXXXXXXXX moves to strike the allegations contained in Paragraph 3 of the Motion as it states legal and factual conclusions; in the alternative, XXXXXXXXXXX denies the allegations as stated in Paragraph 3 of the Motion.

           4. XXXXXXXXXXX denies that the language related to XXXXXXXXXXX Supreme Court Rule 137 is precise restatement of the Rule. XXXXXXXXXXX moves to strike the remaining allegations contained in Paragraph 4 of the Motion as it states legal and factual conclusions; in the alternative, XXXXXXXXXXX is without sufficient information with which to either admit or deny that XXXXXXXXXXX owns, operates, is or has been employed by XXXXXXXXXXX and therefore denies the allegations and demands strict proof thereof and states AFFIRMATIVELY that the purpose of the subpoena is to make such a determination. XXXXXXXXXXX further denies the remaining allegations as stated in Paragraph 4 of the Motion.

           5. XXXXXXXXXXX moves to strike Paragraph 5 of the Motion as it states legal and factual conclusions and also states a prayer for relief; in the alternative XXXXXXXXXX denies the allegations contained in Paragraph 5 of the Motion.  XXXXXXXXXXX states AFFIRMATIVELY that her attempts at discovery are relevant to the matter at hand as XXXXXXXXXXX Supreme Court Rule 201(c) provides:

           "Full Disclosure Required.  Except as provided in these rules, a party may obtain by discovery full disclosure regarding any matter relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking disclosure..." (Emphasis added)

Further, Skonberg V Owens-Corning Fiberglass Corp., holds, "[G]reat latitude is allowed in the scope of discovery, and discovery thus includes not only what is admissible at trial, but also that which may lead to the discovery of admissible evident" 576 N.E.2d28 at 33 (1st Dist. 1991). And finally, there is the holding from Maxwell V Hobart Corporation, which states, "Pretrial discovery presupposes a range of relevance and materiality much broader than that of admissibility of evidence at trial." 576 N.E.2d 268 at 270 (1st Dist. 1991).

           6. XXXXXXXXXXX moves to strike Paragraph 6 of the Motion as it states legal and factual conclusions and fails to allege specific facts, and merely states a prayer for relief.

WHEREFORE, Respondent, XXXXXXXXXXX, respectfully requests that this Honorable Court:

           A. Deny Petitioner's Motion to Quash;

           B. Grant Respondent attorney's fees for the response and defense of the Motion; and

           C. Grant such other and further relief as this Court may deem just and equitable under the circumstances of this cause.