The guardian’s questionnaire is additional interrogatories

September 17, 2019

While not thought of as such, the guardian’s questionnaire is akin to additional (child-custody related) interrogatories. As an example, the current questionnaire of a local

Does your work product convey seriousness?

September 15, 2019

With every litigation both parties have the options of settlement or trial. One factor in deciding whether and on what terms to settle is how

The pitfalls of boilerplate supplemental interrogatories

September 14, 2019

I’m shocked how often I encounter supplemental interrogatories in family court in which the issuing attorney has clearly given no thought into how interrogatories might

Wives can pay alimony too

September 13, 2019

When I first began practicing family law twenty-five years ago it was almost unheard of for South Carolina wives to be ordered to pay alimony.

Ambiguity in the rules on requests for admissions

September 12, 2019

There is a clear ambiguity in the South Carolina Rule of Civil Procedure regarding requests for admissions–SCRCP 36. I suspect that many denied requests to

A few big things trump a lot of small things

August 28, 2019

At the very beginning of any new domestic client relationship the attorney and client need to discuss the client’s goal, discuss the law related to

Don’t forget rebuttal

June 26, 2019

One of the biggest mistakes I see my family court colleagues making is forgoing the opportunity to present rebuttal (sometimes called reply) testimony. Rebuttal is

What are you communicating with your proposed parenting plan?

January 31, 2019

In 2012, South Carolina revised its child custody statutes and added a provision requiring proposed parenting plans at temporary hearings. This parenting plan asks each

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