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    Default Motion for Discovery

    My question involves a child custody case from the State of: ohio
    i wrote this my self is there any thing im missing or did wrong?

    fyi the ~~~~ are spaces




    IN THE MIAMI COUNTY COMMON PLEAS COURT
    JUVENILE DIVISION


    IN THE MATTER OF~~~~~:~~~~~~~CASE NUMBER: numbers
    childs name~~~~~~~~~: ~~~~~~~SETS NUMBER:numbers
    dob~~~ ~~~~~~~~~~: ~~~~~~~ JUDGE name


    my name and adress
    PLAINTIFF

    VS.

    mothers name and address
    DEFENDANT ~~~~~~~~ :~~~~~~~~~~MOTION OF DISCOVERY




    Plaintiff hereby moves the court for an order for discovery.
    The reason for this order is so that I can properly prepare my case for trial.
    The items I am requesting are the following.

    1) Any scientific or other reports that a party intends to introduce at the hearing or
    that pertain to physical evidence that a party intends to introduce ( Juvenile rule 24 A (4) )
    2) Electronically stored information ( Civil rule 26 B (4) )
    3) Any and all Documents that is to be used as evidence ( Civil rule 26 B (3) )
    4) The names and last known addresses of each witness to the occurrence that forms the basis of the charge or defense ( Juvenile rule 24 A (1) )
    5) Copies of any written statements made by any party or witness ( Juvenile rule 24 A(2) )


    Dated this day of month, 2011



    Plaintiff

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