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In a divorce action, Elena strongly suspects that her husband, Richard, is concealing assets. In a box at home she has found a mortgage application

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In a divorce action, Elena strongly suspects that her husband, Richard, is concealing assets. In a box at home she has found a mortgage application he apparently led recently to get a mortgage on a vacation property in Lake Tahoe. The application conrms her suspicions in that it lists several assets that he claims to possess. assets not listed on his nancial statement. Her lawyer would like to avoid having to call the mortgage broker as a witness to testify regarding the authenticity of the mortgage application. Which of the following formal discovery methods should the lawyer use to avoid having to prove its authenticity at trial

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