Get a lawyer involved now. A motion for enforcement and contempt is very technical in both pleading and proof at a hearing. Without an experienced lawyer involved, you won't get far. File your motion for discovery separate and apart forom the enforcement. You may combine the two enforcements or handle them separately. You need personal service on the respondent for the enforcement. GET A LAWYER.
I am not intending this to be legal advice, because I don't know the particulars of your situation. Call me if you would like to discuss this or other isues.Ask a similar question