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Court orders discovery supplements and unredacted financial records under protective order in custody disputes

May 19, 2026 | Judge David D. Wolfe State of Tennessee, Judicial, Tennessee


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Court orders discovery supplements and unredacted financial records under protective order in custody disputes
A chancery court judge ruled on multiple discovery disputes in a family‑law docket, directing a responding party to supplement discovery answers within 30 days and ordering production of unredacted financial statements under a protective order.

The judge sustained an objection to a "superseding" second set of interrogatories and explained that, under the rules of civil procedure, a party cannot file amended pleadings or discovery without leave or a motion when it would circumvent procedural protections. He ordered supplementation and specific objections to be filed within 30 days.

On financial discovery, the judge required the production of the mother’s tax returns dating from the 2024 divorce forward and unredacted copies of checking, savings, money‑market and retirement account statements going back to June 17, 2024. He directed that those unredacted records be transmitted to opposing counsel under a court protective order and limited use to trial preparation; the judge allowed redaction of third‑party names in person‑to‑person payment platforms initially but said names could be unsealed on application if necessary.

Why it matters: Counsel for the father argued bank and electronic‑payment records are relevant to child‑support calculations and to assess whether a party is under‑ or over‑reporting income. The judge said transaction records can reveal undisclosed income or large expenditures relevant to support and custody disputes.

Other orders and practice points: The court declined to compel a party to create new photographs of a residence but said photos used at trial must be exchanged in advance. The judge also reiterated a local rule requiring mediation before final hearings and reserved evidentiary hearings for contested matters such as contempt or allegations of substantial harm.

What the parties must do next: The party ordered to supplement discovery has 30 days to provide complete responses or to file specific objections; the producing party must deliver unredacted financial records to opposing counsel under seal within the same period. The court said it will enforce discovery rules and may exclude evidence at trial if a party fails to answer required interrogatories.

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