Seeking procedural relief before seeking substantive temporary relief

February 23, 2013

My colleagues frequently recount war stories in which their attempts to obtain substantive relief on a temporary basis early in the case failed while subsequent

Considerations in reconciliation

February 18, 2013

Occasionally separated spouses in marital dissolution actions attempt to reconcile.  Even though it’s bad for my business when they do so, I generally encourage reconciliation

Is there ever sufficient evidence of “continued cohabitation” to terminate alimony?

January 30, 2013

I occasionally get telephone calls from men whose ex-wife’s are receiving alimony but also appear to be living with a boyfriend.  They want to know

When a child’s mental health professional makes a guardian ad litem unnecessary

January 17, 2013

South Carolina Code §63-3-810(A)(1) allows the family court to appoint a guardian ad litem in a private custody case when “without a guardian ad litem,

When a child supposedly speaks ill of a parent

January 10, 2013

How an attorney should react when a client’s child speaks ill of the client is often dependant upon things young attorneys (and often even experienced

Objecting to discovery that you sought yourself

December 5, 2012

I often see attorneys object to discovery requests when those same attorneys request the same discovery.  There are potential ethical violations and tactical problems in

Filing second, serving first

November 27, 2012

Before 2004, when SCRCP 3(a), was revised, it was strategically advantageous to serve a family court complaint as soon as it was filed.  This was

What makes a good request for admission?

November 13, 2012

Other than requests for admissions on the authenticity of documents–which can be issued in unlimited numbers--South Carolina Rule of Civil Procedure 36(c) limits a party

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