Request for Production of Documents

Jordan Rossi is a Paralegal at DHHW.  She has worked with Dragga, Hannon, Hessler & Wills since 2012.

During the course of your case, you will engage in discovery, which is exactly what it sounds like, the discovering and disclosing of information about the opposing party.  This includes the answering of questions and exchanging of information by way of a document production. 

The exchanging of documents starts when receiving a written Request for Production of Documents.  Each party is allowed to request documents from the other, and Maryland Rules have not imposed a limit on how many requests may be asked of a party, within reason.  Providing the documents to the opposing side is known as the Response to Request for Production of Documents, and contains a written portion as well as the documents themselves.  You have 30 days from service of the Request for Production of Documents to gather what is requested so it can be provided to the opposing side. 

Starting the Journey – Hiring an Attorney – What to consider?

Hiring an attorney means putting your trust in someone to advocate for you, your family, and your future on the unfamiliar path of divorce and custody.  It is a stressful journey, arising from a difficult and challenging family situation.  When you may feel like your future and your family are at risk.  Finding the right attorney is the first step on that journey.

There are lots of ways to find an attorney – asking those you know who have been through this, asking a trusted professional (accountant, therapist, doctor, etc.), online searches, advertisements, and more.  Followed by information gathering – usually by word of mouth and online – to narrow the options.  Then, contacting the offices of a select few to decide if you will make an appointment, probably depending on cost, availability, and your initial impressions from that contact.  Culminating with the initial consultation.  All with the goal of deciding whether to place your trust in this attorney with what’s most important – you, your family, and your future.

Client FAQ's - Financial Statements

Sandra Mendez is a Senior Paralegal at DHHW.  She has worked with Dragga, Hannon, Hessler & Wills since 2012.


A financial statement, in sum, is a monthly overview of your expenses, income and assets and liabilities. You may have completed some version of one when you applied for a loan or a credit card. The Court’s version may look a little different and two forms are available from which to choose. One is known as the Short-Form Financial Statement, and the other one, not surprisingly, is known as the Long-Form Financial Statement. Alas, you cannot just choose the version you prefer to complete.  The circumstances of your case determine which version applies to your case.

Client FAQ's – Interrogatories

Laura Holt is a Paralegal at DHHW.  She joined Dragga, Hannon, Hessler, & Wills, LLP in 2014 and has worked with the firm as a Paralegal since 2015.

In a contested case, one portion of the case is dedicated to discovery.  Discovery is the gathering and exchange of information (for example facts, information, and documents) to understand each party’s position and develop evidence in the case.  One discovery tool often used are Interrogatories. Interrogatories are written questions to the opposing party that must be answered in writing and under oath. This means the answers must be truthful and accurate, as if the client is testifying in court.

What to Expect at Your Scheduling Hearing – Part 2

Ok, so now you’ve made it to the courtroom.  What next?

After your case is called by the clerk, you will approach the appropriate table (either Plaintiff or Defendant) and wait for the Magistrate to address you.  You will identify yourself for the record when prompted, by stating your name and confirming that you are the Plaintiff or Defendant, and then await the Magistrate’s instructions.

What to Expect at Your Scheduling Hearing – Part 1

You’ve now received in the mail a “Notice of Scheduling Hearing and Order of Court”.  It Orders you to appear in court for a Scheduling Hearing before a Family Division Magistrate on a date and time certain.  What should you expect?  How, if at all, should you prepare? 

Generally speaking, the Scheduling Hearing is your and the Court’s opportunity to:

  • Identify the issues in dispute in the case;
  • Initiate court-sponsored services such as mediation/alternative dispute resolution or custody-related services (e.g. court custody evaluations; custody mediation; attorneys for children); and
  • Develop a schedule of future hearing dates and filing and discovery deadlines that will govern the progression of your case.

Reading My Monthly Invoice

Linda Normoyle is our Billing Specialist at DHHW.  She has worked with Dragga, Hannon, Hessler & Wills since 2002.

Welcome to our firm.  If you are reading this, you are currently a client or considering becoming a client.  Please call me if you have any questions regarding your monthly invoice.  You can receive your monthly invoice by mail or email.  You will be given this option at the time of the Initial Consultation.

Once you are a client, you will receive regular monthly invoices dated the 11th of each month.  The charges included on each invoice covers the prior month’s fees and expenses.  For example, your May 11 invoice will include charges from April 1 – April 30.  Below is a summary of the details provided on each billing statement you will receive.  


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