Motion for Mental Examination of Spouse

CAVEAT: Be very careful of this motion.  You don't want to get acquitted and then end up having to pay spousal support until the rest of your spouse's life if your spouse were to be found mentally ill.  Of course, if your spouse is truly mentally ill, you will have to pay support, but if your spouse was only pretending to be ill and would not otherwise have been diagnosed but for your motion, you would have shot yourself in the proverbial foot.
 

Motion to Compel Documents Requested

A motion to compel is brought pursuant to Rule 37 of your state's rules of civil procedure.  This particular motion presumes that you or your attorney have made requests for the production of documents pursuant to Rule 34 of your state's rules of civil procedure.
 

Motion to Compel Answers to Interrogatories Propounded by [your name]

A motion is brought pursuant to Rule 37 of your state's rules of civil procedure to compel your spouse to answer interrogatories.  This particular motion presumes (a) that you or your attorney have, pursuant to Rule 33 of your state's rules of civil procedure, written a list of questions, sent them to your spouse's attorney, and asked that your spouse answer them and (b) that your opponent did not answer any of the "interrogatories."

Answers to interrogatories must be meticulously written.   They may be used to impeach whoever wrote them whenever that party takes the witness stand. 
 

Motion to Compel Further Answers to Interrogatories Propounded by [your name]

This particular Rule 37 motion presumes (a) that you or your attorney have, pursuant to Rule 33 of your state's rules of civil procedure, sent interrogatories to your opponent, (b) that your opponent did answer some of the "interrogatories," but (c) you want further answers because the answers are not complete in number and/or in substance.

SAMPLE: Pursuant to Rule 37(a)(2) of the State Name Rules of Civil Procedure Plaintiff Name moves this Court to order Defendant Name to serve and file, within 30 days, further answers to Interrogatories numbered 1, 4-12, and 15-16, and to provide timely updates of his answers to Interrogatories 13 (expert question) and 14 (documents to be used at trial).  Plaintiff's Interrogatories to Defendant are attached to this motion as Exhibit A.

Then for each and every interrogatory you want answered or supplemented, you must type in your interrogatory, Defendant's answer, and your rebuttal, stating why the defendant's answers are insufficient and objections are incorrect.  See the rule and form books for guidance.
 

Subpoenas

• Subpoena (pursuant to Rule 45(d) of the rules of civil procedure) to get spouse's therapist to deposition
 
• Subpoena (pursuant to Rule 45(d) of the rules of civil procedure) to get child's therapist to deposition
 
• Subpoena (pursuant to Rule 45(d) of the rules of civil procedure) to get supervisor of child-parent visitations to deposition

You are allowed to oppose each of your spouses's motions with which you disagree.
 

In case you fear your spouse will leave the state with the child, a ne exeat motion is possible.