• NJ Case Information Statements (all financial affidavits)

  • Propounding Interrogatories and Discovery Demands

  • Assisting Client Discovery Responses

  • Analysis of Adversary Case Information Statement

  • Analysis of Adversary Discovery

  • Identification of Fraudulent Documents & Deceptive Activities

  • Settlement Proposals





NJ Case Information Statements (all states financial affidavits):
The goal is to provide accurate disclosure within the foundational piece of every divorce. The income and financial disclosures are prepared by referencing all applicable IRS and State tax returns and from the supporting documentation. The budget is reviewed with the client carefully to insure there are no excessive costs, and if valid, include line by line explanations to avoid confusion or adversary accusations. The questions are also reviewed with the clients and any unusual circumstances which are important to the client’s case and position, are strategically included where applicable.
Propounding Interrogatories and Discovery Demands:
Revision of template demands based upon the knowledge of the case having had in depth conversations with the client as well as preparation of the client’s Case Information Statement wherein the adversary’s income, assets and liabilities are unknown. Finally a thorough analysis of the adversary’s Case Information Statement provides additional insight and missing information to be included in discovery demands.
Assisting Client Discovery Responses:
Complete and strategically detailed responses with insuring client acquires the required historical documents within the demands. Assisting clients in locating sources for documents in a timely fashion. Discussion of interrogatory answers with clients to insure completion and accuracy of same.
Analysis of Adversary Case Information Statement:
It is very common to see a Case Information Statement with omissions and exaggerations. Complete review and analysis will include line by line scrutiny of income, especially where deductions may be exaggerated in cases where the litigant has any type of self-employment income. Assets and liabilities disclosed are compared to the other Case Information Statement to identify any omissions. Subpoenas may be suggested when the adversary refuses to comply if it appears the information may impact a fair distribution. Additionally, the expenses claimed are scrutinized with an understanding of the lifestyle from drafting the other Case Information Statement and the in-depth discussions with the client.
Analysis of Adversary Discovery:
Preliminary analysis involves determining whether or not the required documents have been provided, and itemizing deficiencies for further demands. Detailed analysis of interrogatory answers to determine accuracy and completeness, again itemizing deficiencies. Financial analysis of income tax returns, bank records, investment statements and small business records, itemizing deficiencies, discrepancies and omissions.
Identification of Fraudulent Documents & Deceptive Activities:
Adversary disclosures occasionally include creative fraudulent documents or deceptive activities that must be exposed. By way of example, one client who was considering emancipation of his 23 year old son, received a Notice of Motion from the ex-wife with significant claims. Due to an in depth analysis of all the exhibits, a series of poorly redacted checks was discovered. They were evidence that the ex-wife was taking significant funds from the son's wages for "rent" in addition to receiving child support. While all issues were not settled at that time, the son was deemed emancipated due to the ex-wife's duplicitous activities coming to light.
Settlement Proposals:
With the understanding that the general starting point is an equal equitable distribution of assets, creative settlement proposals with credits for non-asset-based obligations can be an effective tool leading to final settlements of the case. One such proposal was accepted by the parties, much to the surprise of both counsels. CLICK HERE for a sample which became the parties’ global settlement agreement.