Discovery: Subpoenas, Depositions & Requests

Discovery is how you prove income the other side would rather not show. Aim it precisely.

The tools

Interrogatories, requests for production, and requests for admission establish the basic facts. Subpoenas compel third parties — employers, banks, daycare, gig platforms — to hand over records.

Subpoena smart

Narrow requests get faster compliance and fewer objections. Ask an employer for start date and position, year-to-date gross, bonus/commission policy, health-insurance cost, and the last 12 pay stubs; ask banks for monthly statements over a defined period; ask platforms for 1099s and payout summaries.

Stay proportional, then enforce

Keep timeframes to about two years plus year-to-date, tie every request to a specific issue, and redact or protect sensitive data. If a party stonewalls, meet-and-confer first (an email with a 7-day deadline), then move to compel — courts can award fees against parties who won't respond. Save depositions for business owners or accountants when the documents don't tell the whole story.

Talk to a lawyers for child support at Sinkin Law Firm — we collect and enforce child support across Texas.