January 30, 2015

Disclosure of Financial Information in Divorce Cases

As a Jacksonville divorce lawyer, I am familiar with how messy things can get in a divorce case. People tend to have emotional responses during divorces that can sometimes cloud their judgement. For instance, the Florida Family Law Rules come right out and tell us what financial disclosures must be provided to the other side, yet there will still be disputes regarding what information has to be provided. Oftentimes, the motivation not to provide information as required under the Florida Family Law Rules stems from spite. Divorces are understandably very emotionally draining and tough events to endure for most people. It is your divorce lawyer's role to help by being your legal counsel and help you make the best decisions in your case.

Thumbnail image for 150130_accounting-calculator-9-90373-m.jpgRule 12.285, entitled Mandatory Disclosure, lists the disclosures that must be made, such as pay stubs, bank statements, tax returns, and more. There can be sanctions for parties that refuse to comply with the rules. You could end up paying your spouse's attorney fees associated with asking the court to compel you to comply. It is important to only refuse to produce the information if there is a valid objection to be made. Any objection must be timely. If your objection is not made five (5) days or more before the due date of the disclosure, your objection is considered waived.

Working with your attorney to quickly comply with the rules and time limits can save you time, money, and stress. At the Law Office of David M. Goldman, PLLC, we have experienced Jacksonville divorce and family lawyers that can help guide you through the divorce process with care and understanding. It is our pleasure to help with a stressful situation in your time of need. Call us today (904) 685-1200 to schedule a free consultation regarding your divorce case.

December 31, 2013



There are numerous reasons that spouses cite when filing for divorce. These reasons vary greatly. However no matter what the reason, in recent years a new trend has developed on when spouses actually file for divorce- and it is right after New Years Day.

The most common time of year for filing for divorce is the month of January, which is now nicknamed divorce month. In the month of January, the most popular day to file is January 2nd and January 3rd, which is right after the New Years's Day holiday.

There are probably many reasons why divorce filings double during this period of time. Many spouses report wanting to stick it through the holidays because they feel it will be easier on the family and/or the children. Some couples believe that the togetherness and emphasis on family that comes with the holidays of Thanksgiving and Christmas will solve all of the preceding year's problems. Sometimes the stress of the holidays makes an already declining marriage much worse.

Since the New Year's Holiday seems to bring with it a period of reflection and review of the previous year, it may be the last reflection that a spouse needs in order to get them to file. No matter what the reason for the split is, divorce filings double in January. Statistics show that approximately 10 percent of couples don't make it to their fifth wedding anniversary and roughly 25 percent divorce before they make it to their tenth wedding anniversary.


November 15, 2013

Why Do Good People Cheat?

Dan Marino, probably the greatest quarterback the NFL ever produced, and champion of autism awareness, cheated on his wife of 28 years and fathered a child with an attractive television personality. Always seen as a clean cut family man and all around good guy, he's had four children with his wife and adopted two children, and inspired by his autistic son developed the Dan Marino Autism Center with his fortune.

How could someone everyone sees as so good do something so bad? Generally 50 percent of men are assumed to cheat on their significant others and in a study of 400 women, 39 percent admitted to physically cheating on their husbands.

So why is cheating so rampant? It may be that we crave emotional connection. In study after study only around 7 percent of cheating men said all they were after was sex as compared to 48 percent who reported it was the desire to have an emotional connection. Eighty Eight percent of cheaters said the object of their carnal desires was not more attractive than their spouses. It seems that most cheating occurs after someone has formed some close friendship with the person they eventually have an affair with.

Americans don't seem to protect their marriages. Chemistry is a powerful force and someone with seemingly everything can still be left feeling wanting companionship and love.

Since cheating is so common, it is a good idea to ask yourself before you contemplate a divorce, should I try to reconcile with my unfaithful spouse? We all make mistakes of some degree, and the longer one is married, the more difficult both emotionally and financially it can be to walk away from a relationship.

However, the other side of that coin reads, fool me once, shame on you. Fool me twice, shame on me. How can you ever trust again?

In order to make a decision to reconcile, it is important to separate emotion from logic. Infidelity is a highly emotional issue surrounded by feelings of betrayal and jealousy. Separate those emotions from the logic of the situation, no matter how hard that may be. It may be helpful to decide at this point to figure out what your dealbreakers are. It is also important to think about your safety and financial security.

It may also help to discuss your feelings with a family law attorney who is not just concerned with getting your divorce dollars. Such a lawyer can explain to yo the pros and cons of a divorce and reconciliation and what your options are to protect yourself in the future.

November 13, 2013

More Things to Never Say to Your Divorce Attorney

1. "I brought my 'friend' with me to the interview."

You and I have an attorney client privilege. But once you bring in a third party, whether it's a friend, a lover or whoever, the benefit of the attorney client privilege is gone. Unless that third party is named in the case or otherwise officially associated with the case, there is no attorney client privilege.. If a friend or a lover is in a meeting with attorney and the case goes sour, in the event of a trial or deposition, there is no privilege and all those secrets can spill out in a deposition or in court.

2. "I am so depressed over this."

If you need to cry on someone's shoulder, don't use your attorney's. He or she is billing you by the hour, and while they may sympathize with your problems, they have to bill you for the time you spend with them commiserating on the telephone or in person. If you tell all your troubles to your attorney, you'll really be crying when you see the bill.

3. I know he or she is cheating on me because I've been following him/her everywhere.

If you say this to your attorney, one of the things you might be saying to your attorney in the near future is "get me out of jail."

4. I just got into an altercation with my spouse and the police arrested me.

When going through a divorce, keep things civil. While things may have been stormy right before you decided on a divorce, now is the time to be on your very best behavior.

November 11, 2013

Things to Never Say to Your Divorce Attorney

Family law can be expensive, both emotionally and financially. When clients come to see a family law attorney, rarely are they happy or in a good frame of mind. With this in mind, here are a few things that are often said to family law attorneys, that in hindsight, were better left unsaid:

1. "I don't care what it costs, I would rather give you everything than give my wife/husband anything."

No matter what you pay your family law attorney, you are going to give something to your spouse when the marriage is over. You may want revenge but that rarely happens in a divorce. Things said when you are angry will later be taken back, especially when the client receives my final bill for their act of "revenge." Wouldn't you rather spend your money on your children's education than on legal fees?

2. "My friend or neighbor's divorce worked that way and they told me to do it this way."

There is nothing worse than asking for advice from people who have nothing to lose when you have everything to lose, and you hired a professional to advise you. Each family law case is different and unique. What makes sense to your well-meaning friends may make no sense for you. Sideline quarterbacking will only be detrimental to your divorce.

3. "I'm in a hurry to get this done"

When you say this, you immediately put yourself at a disadvantage. Compromise is critical in any family law case. Without compromise, you can never come to a resolution, and in Florida, the Judge will make all the decisions absent a compromise. If you tip your hand and let your spouse know you want to get the divorce in a hurry, your spouse's attorney will know this as well. These cases come up when a client is eager to move forward because of a new relationship. In cases like this the divorce is going to cost you much more than initially anticipated and you will rue the day you told everyone you wanted this over quickly. Don't rush. Hurrying will be costly.

4. "Never say Never."

Never say your spouse can have everything. Never say you will pay your spouse nothing. Never say you are going to leave your children. Each case has an n upside and a downside. Saying never is one the worst things you can do. An attorney is here not just to give you legal advice, but to counsel you on how to rebuild your life after the storm is over.

November 8, 2013

18 Laws Every Jacksonville Florida Parent Should Know About Part 3

The last several days we looked at laws Jacksonville, Florida parents should know about. This is the last installment in this series.

18. I am not sure that I want my kids vaccinated against all of the diseases that my pediatrician recommends. I have heard about negative side effects. Do I have a choice? Section 381.003, Florida Statutes establishes programs for the prevention of preventable disease. The law requires that all children receive vaccines protecting against the spread of diphtheria, tetanus, polio, measles, mumps, rubella, and other diseases for child-care center or school attendance. There are religious exceptions.

A religious exemption for vaccination is a written form certifying that the parent's objection to immunization for religious reasons exempts the parent and child from state vaccination requirements.

This exemption is only necessary for use in Florida Public and private schools for kindergarten through grade 12.

  • A religious exemption is for anyone who has a sincere religious conflict with vaccination.
  • A religious objection may be expressly implied by religious denomination or it may be based on an individual's own moral/spiritual conscience to live God's Word.
Q: What constitutes a religious conflict with vaccination?
  • All vaccines are made in violation of God's Word.
  • Vaccines are made with toxic chemicals that are injected into the bloodstream by vaccination.
  • All vaccines are made with foreign proteins (viruses and bacteria), and some vaccines are made with genetically engineered viral and bacterial materials.
  • A conflict arises if you believe that man is made in God's image and the injection of toxic chemicals and foreign proteins into the bloodstream is a violation of God's directive to keep the body/temple holy and free from impurities.
  • A conflict arises if you accept God's warning not to mix the blood of man with the blood of animals.
  • Many vaccines are produced in animal tissues.
  • A conflict arises if your religious convictions are predicated on the belief that all life is sacred.
  • God's commandment "Thou Shall Not Kill" applies to the practice of abortion.
  • When you believe that the practice of abortion should not be encouraged or supported in any way, a conflict arises with the use of vaccines produced in aborted fetal tissue even though you did not have any other connection with the abortions from which the vaccines are derived.
Q: What religions qualify for religious exemption?
  • The statutory language for Florida vaccine policy clearly states that religious exemption must be granted without question if vaccination conflicts with a person's religious convictions.
  • A religious objection may be expressly implied by religious denomination or it may be based on an individual's own moral/spiritual conscience to live God's Word.Agents acting on behalf of the state in vaccination matters are prohibited from requesting ANY administrative proof that explains the recipient's religious belief or that proves membership in an "acceptable" or specific religion.
  • The state may NOT discriminate between religious denominations and may NOT make judgments regarding religious convictions.
Q: What specific scriptural teachings form the basis for religious objection to the practice of vaccination?
  • The New Testament epistles provide an exposition of Christian teaching regarding ethical behavior.
  • Christians think of life as a gift of God and the body as a marvelous work of divine creation to be reverenced as a temple of God (I Corinthians 3:16, 6:19).
  • To keep the body/temple holy and clean from blemish, scripture warns against defiling the body. (I Corinthians 3:17, 2 Corinthians 7:1).
  • There is no scriptural support for injecting poisons or any virus into the bloodstream to cure or prevent disease.
  • The Old and New Testaments, however, are replete with references to keeping the body blemish-free so that we may have abundant life.
Q: Where can I obtain a religious exemption from vaccination?
  • A religious exemption from vaccination must be obtained from a county health department.
  • Religious exemption is not authorized or issued by schools or physicians.
  • Every county health department issues a standardized approved religious exemption form (DH 681) that includes the following written statement from the parent or legal guardian:
  • "I am the parent or legal guardian of the above-named child.
  • Immunizations are in conflict with my religious tenets or practices.
  • Therefore, I request that my child be enrolled in school, preschool, child day care facilities, or family day care homes without immunizations required by sections 232.032, F.S., 402.305, F.S., and 402.313 F.S."
  • (232.032 is now 1003.22)
Q: Is the religious exemption process the same in every Florida county?
  • Whether you live in Manatee County, Palm Beach County, or St. Johns County, the procedure for getting a religious exemption from vaccination is the same.
  • The Florida statute regarding either proof of vaccination or authorized exemption for entry into school (FS 1003.22) is a state-wide requirement that applies to all students enrolled in all Florida public and private K-12 schools.
  • All county health departments are obliged to authorize a religious exemption when requested.
  • Therefore, your request for religious exemption can be provided by any county health department.
Q: Is it necessary to schedule an appointment in advance with the county health director to obtain a religious exemption?

Florida law provides that you are entitled to a religious exemption. When requesting a religious exemption, it is NOT necessary to provide any administrative evidence that proves your religious beliefs. Any agent acting on behalf of the state in compliance with vaccine mandates may not ask for religious documentation, letters from religious leaders, or church membership. It is also not necessary to discuss any other particulars regarding your beliefs or your child's health history.

The standardized approved religious exemption form (DH 681) requires only your child's name and birth date, the requesting parent or legal guardian's name, the date of authorization, and the signatures of the county director and the parent/guardian. The social security number of the child is optional, but not required. You need only provide valid identification.

Q: Can I get an exemption from some vaccines?

The vaccine dilemma applies to both the decision of whether to vaccinate or not, as well as to the decision to vaccinate with only specific vaccines. On the first question, one could desire never to vaccinate based entirely on religious grounds or based on a belief that all vaccination is inherently dangerous because (1) all vaccines are toxic, (2) the theory that vaccinations improves immune function is flawed, and (3) injecting harmful substances, including attenuated diseases, into the blood stream is ethically immoral.

Similarly, there are both religious and non-religious reasons fordeciding the second question. The theory that vaccination improves immune function need not be disputed to conclude that there are unacceptably high known risks, including death, associated with certain vaccinations (though reasons for those risks is not generally understood). Likewise, some vaccines are inherently more dangetous than others. Also, the risk for getting some diseases is less than the immunological risks associated with the vaccine for that disease.

For that reason, a parent may desire to vaccinate for only the diseases with which a child is likely to be infected or feared to be infected. If your religious objection concerns use of vaccines developed from aborted fetuses, you may desire to never use those vaccines while having no objection to other vaccines.If you believe that some vaccines are not objectionable and con be useful, then you should have the right to decide on one, some or all vaccines, and you should be able to determine when to have them administered. Ethics in medicine generally requires informed consent for all medical procedures, including vaccination. Public health law undercuts that ethical standard by purporting to eliminate informed consent for parents of children enrolled in K-12 public and private schools, childcare, daycare or other preschools. Because vaccine policy adheres to one-size-fits-all full vaccination schedules determined by public health officials, you are not free to decide optimal timing forvaccinations or pick and choose which vaccines to utilize.

You are not free to choose to withhold vaccination in the event that your child is not fully healthy before the deadline for compliance, and you may not claim to know whether your child is at risk for immunological consequences when your doctor or pediatrician says otherwise.

Florida's vaccine policy seems to demands that you choose either all vaccinations or none, regardless of individual circumstances or health history. Unless a doctor has a reason to authorize a medical exemption, your only options with current vaccine policy are to (1) comply with accepted vaccine standards and all mandates, or (2) have religious objections to vaccination because partial exemptions and exemptions for personal or philosophical reasons are not permitted in Florida.

If you realize that the administration of immunizing agents conflicts with your religious belief after some vaccines have been administered, you are entitled to a religious exemption from vaccination.

November 7, 2013

18 Laws Every Jacksonville Florida Parent Should Know About Part 2

Yesterday we looked at laws Jacksonville, Florida parents should know about. Here are a few more.

9. My kid is always bruised from playing. His teacher suspected we were abusing him and called the police and DCF on us. Why did she do that?
She was following Florida law, which requires any person who believes that a child is being abused, neglected or exploited to report the suspicions to the Department of Children and Families (DDCF). The law provides the person making the report with immunity, as long as she acted in good faith. If your son's teacher hadn't reported her suspicions, she could have been charged with a crime.

10. What does a child need to know before entering kindergarten?
Admission to a public kindergarten is not contingent upon what a child knows; if the child meets the age requirement, he or she is eligible for admission. The Florida Partnership for School Readiness has published "Performance Standards" for 3, 4, and 5 year olds. Those standards reflect what children should know and be able to do. You may access that information and other resources from the Partnership's website. In addition, the Sunshine State Standards provide expectations for student achievement in Florida. These were written in seven subject areas, each divided into four separate grade clusters (PreK-2, 3-5, 6-8, and 9-12).

Continue reading "18 Laws Every Jacksonville Florida Parent Should Know About Part 2" »

November 6, 2013

18 Laws Every Jacksonville Florida Parent Should Know About Part 1

Like every state in the Union, Florida has a host of laws that affect you as a parent. Some of this laws or Administrative Rules may enhance your parental rights, while others, if not followed could land you in jail or create civil or criminal liabilities if not obeyed. While every Parent in the United States has a Fundamental Right to be a parent, with these rights come important responsibilities.

So how do you know what is the law? We hope this series of articles will guide you to a few important concepts regarding Florida Law.

1. How long can I keep my kids home with me before I have to send them to school?

Florida law, states that all children who are either six years of age, who will be six years old by February 1 of any school year, or who are older than six years of age but who have not attained the age of 16 years, must attend school regularly during the entire school term.

2. Does Florida law specify an age requirement for admission into a public school first grade?

Florida law does not provide a specific age requirement for enrollment to public first grade, the provisions of Florida law related to kindergarten admission and student progression dictate that first grade enrollment be limited to (1) students who turn six years old on or before September 1 who have successfully completed kindergarten; and (2) out-of-state students who turn six years old after September 1 who meet the age requirement for public kindergarten admission from the transferring state, and who have successfully completed kindergarten.
3. Can we home school our Children?

Yes. When you decide to home school a child in Florida, you must notify the school district superintendent of your intentions in writing. The letter must include names, addresses, and birth dates of the children who will be enrolled in home education and must be filed within 30 days of beginning the homeschooling process. The same process must be completed if you decide to stop homeschooling your children, and the letter again must be filed within 30 days of the termination of the home education program. You will also be required to have an annual educational evaluation of your child or children, which is to be performed by a licensed teacher within the State of Florida. If you are teaching elementary grades, an elementary teacher will be needed for the evaluation; and if you are teaching secondary grades, you will need to have the evaluation performed by a secondary teacher.

Continue reading "18 Laws Every Jacksonville Florida Parent Should Know About Part 1" »

February 26, 2013

When Attending Mediation have a Good Attitude, an Open Mind (and an Open Heart) and you just might be Pleasantly Surprised

A client walked into Apple six months ago, trying to get his alimony modified. He was not sure about hiring an attorney because he felt his previous attorney was a tiger in his office but a wallflower in Court. We finally asked us him to let us try to solve his family law problem and made a commitment to treat him like our most important client. His reluctance gave way to confidence in our firm and he hired us.1035051.large.jpg

The case was a garden-variety modification of alimony, one of the most heavily litigated types of family law cases. The standard for a modification of alimony is completely at the discretion of the court. The court does not have an obligation to modify; it just has the option...that is if your attorney proves the three elements. To receive a modification of alimony the petitioner, the person asking for the modification in layman's terms must demonstrate that three things have happened since the original divorce:

• The party asking for a modification must demonstrate a material change in circumstances. That means things have drastically changed for one party for the better or the worse. Sickness or long-term loss of employment can be examples of such material changes.
• This change in circumstance must not have been contemplated at the time of the divorce. For example, graduating from college would not apply. A severe illness might apply (but not always).
• The change in circumstance must be sufficient (usually meaning whatever the Judge feels is sufficient), material, permanent and involuntary. Quitting a high paying job to join the Peace Corps would not apply. Layoffs from a permanent closing of a factory might apply.

To protect my client's privacy, I won't disclose what his or her circumstances were, but I believed they warranted a permanent change in the alimony my client was paying. But the trick was convincing someone else that it was. Namely a Judge...or the other party.

Too many attorneys in family law cases litigate every single issue...we are good at arguing...but just as important as a good argument is being a good diplomat. They say you can get more with sugar than with vinegar. I convinced my client that the diplomatic approach was better than a win at all costs approach and perhaps we could tap into a well of emotions and good will. So we went in with a good attitude, and open mind...

And the other party agreed to a fifty percent reduction in alimony...in mediation.

If you want to hire an attorney who has a good heart and won't take you to the cleaners, give us a call at 904-685-1200.

February 4, 2013

What Is an Order To Show Cause?

An order to show cause is a type of court order that requires one or more parties in a court proceeding to come to court to justify, explain, or prove something to the court. Typically it means the Judge in a case needs more information before he or she decides to do something. For example, in a divorce, at the request of one parent a judge might issue an order directing the other parent to appear in court on a particular date and time to show cause why the first parent should not be given sole physical custody of the children.case-dismissed.jpg

Other examples of an order to show cause in a family law context would be when one parent has not been paying court ordered temporary child support while a case is pending. One party may petition the court to find the other party in contempt. The court may issue an order to show cause to find out if the allegation is true and ascertain why the party is not paying support. Perhaps the party is was in the hospital and was not able to work. The judge can then make an informed decision regarding the order and issue an appropriate sanction or no sanction at all.

If you are on the receiving end of a notice for an order to show cause, it is not something to set aside or ignore. You may wish to contact a family law attorney to assist you in protecting your rights. If you have such an order in hand, or have any questions regarding any other legal issue, give Law Office of David M. Goldman a call at 904-685-1200.

January 31, 2013

Florida man accused of fraud after name change in 'act of love' - Yahoo! News


This is an interesting case in that it clings to the outdated notion that a married woman is an extension of her husband. It will be interesting to see how this turns out.

January 30, 2013

Can Divorce Ruin My Credit?

Yes, it can. It probably will, unless you hire a good financial planner and a good attorney well ahead of the time you decide to file for divorce.

Most credit can be extended to immediate family members. When credit is extended to a family member, the principal member assumes the primary responsibility of paying the amount due on the credit card or credit obligations. Most often, credit extensions are extended to spouses. 196033_457022344317091_31610989_n.jpg

Most couples undergoing divorce or have been divorced for some time, get surprised that they are billed for things that they have no knowledge of having bought. Situational examples are:

1. Your ex-spouse has stolen your identity. Your ex-spouse used your name and Social Security number to obtain credit without your knowledge.

2. Your ex-wife or ex-husband is an extended credit card holder. You being the co-owner are still liable for charges made on the credit card that your ex-spouse has been using. Joint accounts make you responsible for any debts entered by the two of you.

When these things happen, you would certainly be at a point where you want to know what your credit rating is. You should be aware that punctuality in paying debts and the extent of your debts are factors in evaluating your credit score. Your financial history of paying your debts is reported by credit reporting companies to credit scoring companies. Results of these are provided to lending institutions or companies who will decide on whether to grant you a loan or not.

Divorce can ruin your credit if you do not close your accounts ahead of time. Post-divorce credit problems can be avoided if you immediately close your joint accounts with your spouse. Most lenders do not honor divorce decrees. Creditors can still collect payment from the other spouse. The problem in this case is when the other spouse refuses to pay or fail to pay. This will affect the credit score if debt is unpaid on time.

Close accounts that are in both of your names. This one action can salvage some of your credit rating.

January 28, 2013

What to Expect With Your Family Law Case

For most of us, divorce court, or any courtroom proceeding is foreign territory. Navigating through unfamiliar laws and proceedings certainly can be stressful, especially when you are in an emotional low spot. images.jpg

Here is generally what you can expect as you go through the procedure of a divorce:

There are four major issues to be settled in divorce court:
• Child custody and visitation: With whom should the children reside and how often will the other parent see them?
• Child support: How much financial help does the parent with custody receive from the other parent?
• Alimony: Is the lower-income spouse entitled to financial support?
• Division of property: How will you divide the property, assets and debts accrued during the marriage?

Just four issues but those four, as you can see, are extremely important. Your divorce may become more complicated if you have substantial assets such as investment property, more than one house, retirement plans, boats and automobiles. Your case can be decided more quickly if you and your spouse decide how to divide those assets before you file.
If you have disagreements regarding how to divide those assets or how your children will be affected by the divorce, the family law judge will send you to mediation, where a neutral third party will try to help you come to an agreement.

If you have questions about a divorce proceeding and would like a divorce attorney to assist you in the matter call us today at (904) 685-1200.

January 14, 2013

How To Win Your Family Law Case By Keeping The Judge Happy: #2 In Court, Address the Judge, Not the Other Party or Lawyer

Be a professional when you're in Court. Show the Judge you're an well adjusted adult...Address the Judge, never the other party.

For a non-attorney and even some attorneys a courtroom can be a strange and scary place. Courtroom proceedings can seem arcane and intimidating. This is one of the myriad of reasons that it is always far better to try to settle or mediate your dispute outside of court. Why allow a third party to make all the decisions for you when you could conceivably settle the case on your own?

The time to address the other side regarding your case is before you enter a courtroom. Once you enter the Courtroom, it's the Judge's Show, and the "winning litigant" always respects that.

Sometimes it is impossible to even talk with the other side, let along negotiate some kind of agreement that would make stepping inside a courtroom unnecessary. If you have fallen into this situation, you will probably either need to hire an attorney.

January 14, 2013

Ten Unbreakable Rules in Every Child Custody Case

1. Never Lie in Court

The very worst thing you can do is lie in court. Many people take liberties with the truth in a domestic case. In most cases the Family Law Judge has to decide a case based upon conflicting testimony from the parties. Help the court choose your side by telling the truth, the whole truth and nothing but the truth.

2. Never Lie to Your Lawyer

Almost always, a good attorney can make the best out of a bad situation, but only if he knows the situation beforehand. If your attorney is blindsided, the damage is done and the situation may be beyond repair. You may even lose your lawyer and get the lawyer in trouble. Do not lie to your lawyer. Your lawyer can only prepare properly for your case if he or she knows all of the facts. If you lie to your lawyer, he/she cannot possibly prepare an effective case.


Einstein would not recollect every single detail without the benefit of a documented reminder. Make notes of every important detail.

Keep a Journal, Calendar, Photo, Videos, Emails, and Receipts. Life moves at a fast pace. Documenting preserves crucial evidence that you may not recollect and will need.

4. Pay Your Lawyer on Time -- Or You Could Lose Them

No one likes to work without getting paid. Lawyers are no different. The expense demands on a law firm are significant. When a client pays as expected and on time it eliminates an unnecessary distraction. Despite what you may think, most lawyers are working class people and are not sitting on bankrolls of money.

5. Respect the Court

No matter what you think of the Judge, respect the position that he or she holds.Dress at all times for success. Impressions always matter. When you speak, make eye contact with the Judge, speak calmly and in a tone of voice that can be clearly heard.

6. Time Plus Possession = Custody

The court tends not to disturb children from their present setting, if the present setting is stable. The longer they are in a stable environment the greater the likelihood that the court will leave them there. Do everything within your power to provide a stable and secure environment for your child.

7. The Most Important Factor in Any Child Custody Decision Is Stability

This includes stability of parenting, income, mood, relationships, surroundings, etc. A stable environment over time gives children a better chance at developing into healthy adults.

8. Know Your Goals

If you do not know what your goals are, and your spouse knows his/her goals, more than likely you will wind up where they want you. Most domestic litigants do not know their goals, while almost all who do have goals have unrealistic goals.

9. Give The Other Side an Out

You should not box your opponent into a corner. Give them an out, through settlement, with dignity. If they have nothing to gain, they also have nothing to lose by fighting.

10. Arm Your Attorney, Don't Disarm Him

Do not do anything that risks your case. Instead, maintain your calm, gather information for your attorney to use in court. Live to fight another day.

(This entry is based in large part on an entry on Pikrallidas & Associates's web page. Pikrallidas & Associates is an outstanding Central Florida law firm)