Divorce Source: Pattern Interrogatories

I just received a request for pattern interrogotories from ex's attorney and I had some questions. First, this is a custody hearing, not a child support hearing, and child support is only up for review if there is a change in custody, which it is obvious the reason why then.

They are asking for very detailed financial information, including copies of all bank statements, etc for the past three years, all credit card statements, etc.

I fail to see how any of this is relevent. I can see why they would want income, but why expenditures? Again, there is no question that I am blowing the money elsewhere and not providing for the kids or anything. Also, it asks about real property owned, if I stand to inherit from anyone's estate, etc. Again, all property was divided five years ago. There was no dispute then and no dispute has been mentioned now. And this just asks for within the past five years, so it would all be after the previous property division. Unless it earns me money, why would this be relevant?

I am thinking about filing an objection with the above mentioned issues simply because, while I can see their applicability for a divorce hearing, I don't for a custody hearing five years after the divorce.

Also, there are questions such as how much involvement he has had in their lives in the last ten years, descriptions of any domestic violence incidents, why I don't think custody should change to him, etc. I don't have a problem with anyof these, but obviously I need to develop some questions for him to answer, also. Any advice, beyond just repeating what they are asking for, what I should ask for?

A big reason for the financial information hesitation is that somebody drained my bank account to pay credit cards in his name. My bank reversed the charges and I got hte majority of my money back, but two weeks later, he filed fraud reports with the police department stating I had taken out those accounts in his name without his permission and as proof submitted that payments had come from my bank. The police investigated but found nothing to prosecute. They apparently just told him last night, and he called and left me a very nasty message about it. He stated that every move I make he was going to watch, every bit of money I spent he was going to know about, and one wrong move on my part and he would pounce. He said he was going to be my shadow for the rest of my life. Anyway, I reported it to the police, not much they can do because he is in a different state and cannot be cited, or it would be pointless to cite him because there was nothing they could do unless he came back to the state and got in trouble for some reason. They said my best bet would be to contact his local PD and see if they would investigate, I have many other similar messages saved, which I did but have not heard back.

At any rate, there is no way I am willing to trust him wiht any of my financial information, especially since I don't see what relevence it has.

BTW, usually, in a child support review, there is a form we fill out listing all income and monthly expenditures, attach pay stubs and tax returns, and that is it. So since income is not being disputed, why would they need all that detailed information?

Thanks for any help...