What discovery material should I turn over to opposing counsel prior to a plenary hearing in New Jersey Family Court?

You should be using an attorney to handle a matter this complex. It is almost impossible to divulge such information without reviewing the facts of the matter. Herbert Tan, Esq. E-mail: [email protected] Website: www.tanlaws.com The National Newark Building 744 Broad Street, 16th Fl. Newark, New Jersey 07102 (973) 735-2681 (W) (973) 735-2682 (F) Manhattan Office 305 Broadway, 14th Floor New York, New York 10007 (888) TAN-LAWS

You need an attorney to tell you what you need to prove your case and to disprove the other side's case. It's impossible to answer your question without knowing the issues though a meeting where you can answer questions.

I agree with my colleagues that you should consult with an attorney in your area.

I don't think you realize how complicated and fact-sensitive your question (and the answer to your question) is. If you cannot retain an attorney to help see this through to conclusion, then you should at least pay an attorney for a couple hours of their time to review the motion, cross motion and order and sit with you to learn the facts of your case so they can then answer this question for you. That's the only way the answer will be worth anything.