Checklist of questions whose answers can derail a custody or visitation case
August 29, 2014
I tried a custody case last month in which I learned a few weeks prior to trial that my client was using marijuana approximately once
Why file for separate maintenance when one doesn’t have grounds for divorce?
April 24, 2014
Separate maintenance is the action one files with the family court when one is no longer living with one’s spouse but one doesn’t yet have
Should one explain one’s request to admit responses?
April 4, 2014
I had a lively debate a few weeks ago with colleagues I respect over whether one should explain request to admit responses that look bad
The two types of motions to compel discovery
March 30, 2014
Although the rules of civil procedure don’t differentiate them, there are really two distinct types of motions to compel discovery: one addressing the untimeliness of
Better to be an adulterer than an adulterer and a liar
March 7, 2014
A mentee recently asked me if one should admit an allegation of adultery in a responsive pleading when the adultery is obvious. While I think
Reserving alimony when there’s military retirement
November 22, 2013
One of the quirks of family law is that a veteran’s military retirement is subject to equitable distribution but that veteran’s military disability is not.
Script for the beginning of each deposition
November 7, 2013
There’s a routine set of questions I ask at the beginning of every deposition. I suspect that script would be useful for new attorneys and
Are you cross-examining that witness for mistake, bias or corruption?
October 21, 2013
Recently one of my prior mentees was regaling me with the story of his first custody trial. One of his concerns was his overly confrontational
