I am the petitioner in the Main OP divorce. (June 2006) and in IA for Interim custody for Child (Feb 2007). My is now 4 Y 11M. Now she has filed HMOP. I filed the Counter and Proof of Affidavit in the previous hearings, but without marking any documents. Today the case came up for hearing. The case was posted for enquiry and She came up with filing writing arguments and closing her side without marking any exhibits. I was also about to file written arguments with 3 exhibits (1. Wife's matrimonial bio-data, 2. Copy of my Letter to her requesting reunion with RPAD receipt 3. Original bills for the nutritional, dress and misc needs provided to my son, on monthly basis.). Now that their counsel, objected that the bills cannot be proof for supply of items to our son and and prayed that he is filing a counter next hearing, which was admitted. Thus, the copies of written arguments were not filed or exchanged today. Now my questions are:
1. Are the exhibits have to be filed with the counter for HMOP or with the Proof of Affidavit and not alongwith the written arguments in hmop case?
2. How can I find out her savings bank account details and use it in my favour to prove her income. Can the income proof from her past employer (1998-2002) will be of any help to me? (She admitted the fact in her matrimonial bio-data of having worked as sub-editor)
3. What is the procedure to file the exhibits under these circumstances?
3. How can I prove that the items mentioned in the bill were actually provided to our minor son, whom I visit once a month. Can I ask for the evidence of our son who is just 4Y 10 M.
Your valued advice will be much appreciated.
