Small bites on visitation

June 3, 2016

Absent a showing of a “substantial change of circumstances” one is allowed to bring only one motion for temporary relief on a particular issue prior

The problem in filing updated financial declarations at final hearings to approve agreements

May 31, 2016

Family Court Rule 20(a) requires “a current financial declaration” “be served and filed” “[i]n any domestic relations action in which the financial condition of a

Script for defeating the “unclean hands” defense in contempt prosecutions

May 28, 2016

I don’t believe “unclean hands” is a defense to contempt. If an opposing party seeks to hold my client in contempt for conduct that party

“I don’t know/recall” may be the best interrogatory or deposition answer you can get

April 21, 2016

I lectured last week to recent law school graduates about family law discovery. Part of this lecture discussed Rule 37(a)(3), SCRCP which reads: “Evasive or

Why join stepparents as opposing parties to family court proceedings?

March 25, 2016

The short answer is discovery. While I understand the logic of joining stepparents as parties to custody or visitation proceedings when that stepparent will not

Why not divide up legal custody?

February 27, 2016

Deciding who will have legal custody–final decision making authority for a child–can be one of the more contentious issues in custody cases. Often one parent

Using opposing parties’ evasive discovery responses against them

February 9, 2016

Often opposing parties will respond to discovery with evasion: giving answers that respond to some, slightly different allegation; providing lengthy responses to “yes/no” questions without

Acknowledging the obvious

February 7, 2016

In responding to discovery or pleadings, some of the responses, if accurate, will bolster the other party’s case.  Clients, even (especially) sophisticated clients, often balk

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