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01/12/2024

8Tips for Your Initial Conference with a Divorce Attorney 

Preparation is important when you meet for the first time with your divorce attorney! In this episode of Divorce Team Radio Todd Orston, Partner at the Divorce and Family law firm of Meriwether &Tharp, LLC, discusses how to prepare for and make the most of your initial divorce attorney conference.

Transcript

Todd Orston (00:07):

Welcome, everyone, to Divorce Team Radio, show sponsored by the divorce and family law firm of Meriwether and Tharp. I'm your host, Todd Orston, and here you're going to learn about divorce, family law, and from time to time, even tips on how to save your marriage if it's in the middle of a crisis. If you want to read more about us, check us out online at atlantadivorceteam.com.

(00:29):

All right. Let's get started. I'm always thinking about just, well, divorce and family law and cases and how they progress and different ways that you can efficiently approach the issues that you're dealing with, and what better place to start than at the beginning? In other words, we talk and we've done shows about how to be efficient, and so I want to dig a little bit deeper because that efficiency can and should start at the very, very beginning.

(01:15):

This show is about eight ways to make the most of your initial attorney conference. What am I talking about? I'm talking about, you're looking to hire an attorney, and we've done shows on that. You want to hire the right attorney, somebody qualified, experienced as to the practice area and jurisdiction, and by jurisdiction I mean they've actually walked into that court before. Maybe they've even practiced in front of that judge before. That's not a deal breaker. We represent people all over Georgia and our attorneys have, from time to time, walked into a courtroom where maybe we don't have as much experience in front of that judge, but that doesn't mean we can't do a good job, but nonetheless, it's something to think about.

(02:06):

Once you decide, once you think about those things, once you then get a sense, not just for what they know, but, is their personality the right fit for you? As with anything, different people have different personality types. One may work really well with you, while another, maybe it's going to be just oil and water. It's going to be a lot of friction. You don't speak that same organizational language, and so it's going to be more difficult for you to have that healthy relationship that will allow you to accomplish everything you need to accomplish.

(02:53):

We've talked about choosing the right attorney, but today, again, I want to talk about eight things and eight ways you can make the most of that initial attorney conference. You've done your research, you've maybe spoken to a few people, you have chosen, and now you are going to have a meeting, some initial contact with the attorney. How do you make the most of that meeting? Well, should you go in cold, having done nothing to prepare? No, absolutely not. You can, and trust me, a good attorney, we have the ability to elicit the information that we need, but I can tell you that's not an efficient way to go about it.

(03:54):

I would never go into a meeting with a professional where I'm paying money to sit and get the most out of that meeting unprepared. Doesn't mean you have to be an expert in divorce law. It doesn't mean you have to be as knowledgeable and well-versed in these issues as that attorney, but absolutely, with a little bit of research, a little bit of reading will be incredibly helpful so that you don't need to get bogged down on basic stuff that could have been dealt with offline outside of that meeting with the attorney.

(04:37):

I'm not talking about you need to spend days and days and days preparing, but especially, and knowing that the information is out there, good information is out there, does it make sense for you to do a little bit of reading to gather some of the data, understand the basics, formulate a plan of attack when you sit down with the attorney so you can get the most out of that meeting? I believe it does. If you think of it that way, then you're going to understand that by preparing, you are going to accomplish more during that meeting.

(05:24):

How does that benefit you? Well, how about these two ways? You could shorten the meeting, thereby lowering the cost. You go in totally cold and the attorney has to basically get information from you like he or she is pulling teeth, well, maybe it's a two-hour meeting. Maybe it's more than that, as opposed to you go in prepared and not only do you not need two hours, but a majority of the meeting is done strategically, talking about strategic issues, doing strategic planning. That's the second issue. You can deal with those bigger strategic issues because you've already prepared, you've educated yourself, you've walked in with some basic information, or better yet, ahead of the meeting, you have forwarded the attorney and the attorney team the information that they wanted and needed.

(06:27):

Now you can sit down, and it's what I oftentimes refer to as a, "Roll up your sleeves and get to work" kind of meeting. You can just sit down and say, okay. "You understand the basics. You understand those facts, and we fill in some gaps. I do have some questions, and now let's talk about how we accomplish my goals."

(06:47):

All of the things that you did to choose that attorney, determining experience, handling the actions, their knowledge, their strategic thinking, understanding on how to use evidence and present evidence, their skill in trial, out of trial, out of court, all that's been done. We are now talking about you're sitting down with your chosen attorney and you want to make them successful. You need them to be successful, but even the best attorney can't be successful or efficient if you don't play an active and organized role in your case. By being efficient from the very beginning of your case, it's going to help by, again, lessening the duration of the case, lowering the cost, and even increasing the possibility of settlement. That's what I'm going to talk about, how to prepare for that first meeting.

(07:45):

A good way is to come up with a checklist. You go into the first meeting prepared. Well, before we get to the checklist, what are the primary purposes of that meeting? You need to understand that. You don't want to not only go in unprepared, but if you don't even understand what you're trying to accomplish in that first meeting, you're already behind the eight ball.

(08:10):

Primary purpose of the meeting, I'll say it's basically two things. A, information gathering, I have questions. As an attorney, I know people who want to meet with me and sit down with me. They have questions. And, B, information, providing the attorney, saying, "Hey, I have questions."

(08:38):

So if you think of it in that basic way, then information gathering, the more you go in knowing, the less you have to ask about, the less time needs to be spent educating you. And if you go in prepared, having ahead of time gathered and maybe even forwarded information that is relevant to your case, that's going to limit the amount of information gathering that the attorney has to do during that meeting. So that leads to a logical checklist of ways to prepare for that initial meeting. Number one, we're going to go into more detail, educate yourself about the core issues, custody, child support, alimony, equitable division of property and debt. Two, determine what you want to learn about family law and divorce. What specific questions do you need or have to fill in those gaps that you need to fill in. Three, why are you seeking a divorce?

(09:43):

Make sure you can explain that because that's going to actually be a good start to painting a picture for the attorney as to why you guys are in the situation that you're in and why you're going through this divorce. Number four, what are your goals for the case? Number five, be ready to provide details about the relationship. Number six, provide relevant personal information. Number seven, discuss facts related to AAA, adultery, abuse, abandonment, any other issues that might or will come up in your case. And then number eight, be ready to provide if you haven't already, documents and evidence related to the four core analysis. So those are the eight things we're going to go into more detail, all right? But if you use a checklist like that, you're going to go into that meeting, you're going to be incredibly prepared and that's going to be a very efficient and helpful meeting. And when we come back, I'm going to dive deeper. I'm going to give you some additional information on how you can make this an incredibly helpful initial meeting. Be right back.

Speaker 2 (10:56):

I just wanted to let you know that if you ever wanted to listen to the show live, you can listen at 1:00 A.M. on Monday mornings, WSB, so you can always check us out there as well.

Todd Orston (11:07):

Better than counting sheep, I guess, right?

Speaker 2 (11:09):

That's right.

Todd Orston (11:10):

You can turn on the show and we'll help you fall asleep.

Speaker 2 (11:14):

There you go.

Todd Orston (11:14):

I'll talk very softly.

(11:21):

Welcome back everyone. This is Divorce Team Radio, a show sponsored by Meriwether and Tharp. I'm your host, Todd Orston, and if you want to read more about us, you can check us out online at atlantadivorceteam.com or if you want to read a transcript of this or other shows or listen to this or other shows, again, you can find them at divorceteamradio.com. So today I'm talking about that initial meeting you have with your chosen attorney. How can you make the most of it? How can you do something, anything to make sure you are prepared and to give your attorney the tools that they need to be successful for you and also to be efficient as they work with you because that's really what we're talking about. You want to make the most of that meeting. How? Go in with a plan, have a checklist, and that's what we're talking about.

(12:17):

And when we ended the last segment, I was going over a basic checklist of things you should be thinking about as you're going into that meeting. So let's jump in and we'll start talking about those points, those eight points. Number one is education. Obviously, you are hiring an attorney because you need to be educated, so I am not trying to sit here and say you need to do all of your learning before you sit down with the attorney. What I'm saying is that there are some people who will go in and they have done nothing to educate themselves and again, that's fine.

(13:07):

I mean I love doing this show. Why? Because I love educating people. I love pushing out this information that I have based on my knowledge and experience and all of that so that I can educate and help people. But I have seen the difference when somebody comes in and they've done some basic work to educate themselves. Even going to our website at Meriwether and Tharp and they read about the four core issues and they understand basics at the very least, basics about custody and that includes legal custody and physical custody, decision-making authority, different types of parenting schedules, ways to handle summer, ways to handle holidays. If they come in and they've educated themselves about that, that means I don't have to, which means I don't have to spend 5 minutes, 10 minutes, 20 minutes talking about the basics on that issue.

(14:20):

By educating yourself a little bit about child support, am I asking you, and is any attorney asking you to be ready to run the calculation yourself, to explain in detail the methodology applied in whatever state you're in? No, that's not what I'm saying, but if you understand, if you go online and find a place where you can rely on that information as being accurate, do some things to educate yourself. For instance, here in Georgia, if you come in, if you know it's an income share model, if you know they're going to include your gross income, your spouse's gross income, that it basically works by pulling that information in, looking at the number of children, just a little bit of reading and you'll understand the basics, then I don't have to educate about that.

(15:28):

How about alimony? Alimony, I want alimony. If you go in and all you know is that alimony is a thing and you want it or alimony is a thing and the other side may want it, okay. If someone looks at me in a meeting and I sort of test the water a little bit and I'm like, listen, I just want to make sure I'm giving you information you can use. What do you know about alimony? And they're like, I know how to spell it, and my knowledge stops there. Okay, then I know I have to sort of build that foundation, start at the bottom level and build them up, give them information, all the information they need to truly understand this core issue.

(16:26):

Or you go online, read a book, do something, but you educate yourself and then you know that at least here in Georgia, it's a need-based analysis, the court's going to look at, in essence, two things, your need or the other side. If you're anticipating a claim being made against you but need and then, is there a corresponding ability to pay? You can look at some of the factors that the court would look at, then you can go in and you can say, hey, I have a basic understanding of alimony. You don't need to spend 5, 10, 15 minutes educating me just on what alimony is. Let's talk about some of the things I think will be important in determining whether or not I get or have to pay alimony. Then if somebody says that to me, I know I'm 1, 2, 3, 4, 5 steps ahead.

(17:33):

The foundation's already there and yeah, I'll do a little bit of testing to make sure that it's a solid foundation. I'll correct whatever needs to be corrected if there are incorrect assumptions, but at least I know we are multiple steps ahead and that just saved us 5 minutes, 10 minutes. Now, are you picking up on sort of the theme here? 5 minutes here, 10 minutes there, 20 minutes here, 15 minutes there. You could carve 30, 40, 50 minutes off of a meeting simply because ahead of time when you weren't on the clock, if you will, you spent some time to educate yourself.

(18:21):

And what about equitable division of property? There are people who come in here in Georgia and they know nothing. They make assumptions. I earned it. It's mine. Oh, it's a community property state, right? No, it's not. In Georgia, it's equitable division of property. These are things that you can educate yourself about. You can go online and you can see and gather information just so you have a basic understanding. So that way when you sit down, if the attorney looks at you and says, okay, I want to make sure your questions are answered, do you know about how property is divided, debt is divided? If you're looking going, "Eeny, meeny, miny, mo," then I know I have some heavy lifting to do as opposed to, oh yeah, I know that Georgia is an equitable division of property state. Equitable doesn't necessarily mean equal. It's what's fair and reasonable under the circumstances of my particular case.

(19:34):

And they're going to look at a number of factors. Court might lean towards fifty-fifty, but it's not a guarantee. Okay, sounds good. Now I can jump in and start gathering information that relates directly to strategy. If we're trying to accomplish fifty-fifty, what facts can I gather that I can use to make that argument? If I have information that I'm going to need to anticipate the other side's coming after more than 50%, or if my client says, I think I'm entitled to something more than 50%, now I can jump in and deal with that. I didn't have to spend 15 minutes educating on the basics. And let me be very clear, again, I'm not saying you can't go in unprepared. A good attorney shouldn't get frustrated because you don't know about divorce law. I've actually joked with people who are apologetic to me. They're like, "I'm sorry, I don't know about this." And I'm like, "It'd be weird if you did."

(20:46):

It's not like when everything was good on a weekend, you're sitting out by the pool with a book on divorce. So it's not that there's an expectation you should know about these things by the attorney. I'm simply saying, this is your money, it's your case. There are very few people I've met that love paying an attorney to represent them and do work that needs to be done. They understand it needs to be done, but if you can limit the cost, limit the cost. If all it takes is a little bit of homework, a little bit of work on your end just to sit down at a computer and do some reading, it's going to benefit you.

(21:39):

All right, I focused on number one, educating about core issues. All right, when we come back, I'm going to jump into a few more in terms of basically gap filling, making sure that you come in with some specific questions and then we will talk about some of the three and four, why you're seeking a divorce and what your goals are and we'll go into those things right when we come back.

(22:08):

Hey everyone, you're listening to our podcast, but you have alternatives, you have choices. You can listen to us live also at 1:00 AM on Monday morning on WSB.

Speaker 2 (22:19):

If you're enjoying the show, we would love it if you could go rate us in iTunes or wherever you may be listening to it. Give us a five star rating and tell us why you like the show.

Todd Orston (22:33):

Welcome back everyone. I'm Todd. This is Divorce Team Radio. The show is sponsored by the Divorce and Family Law Firm of Meriwether and Tharp. If you want to read more about us, check us out online at atlantadivorceteam.com. If you want to read a transcript of this show, listen to it again, you can find it at divorceteamradio.com. So today again, we're talking about eight tips, eight ways you can make the most out of that initial meeting with your attorney. You've chosen the attorney and you're sitting down for that first time to really sort of dive in and get some answers to questions and maybe start to formulate that strategy, figure out what needs to be done and how to go about doing it. And if you get bogged down on some basic information gathering or some basic questions, then it's fine, but what could have been a one hour meeting is now going on two plus hours or more.

(23:43):

And then on top of that, unfortunately, and I'm not saying every attorney is going to do this, but I'm just saying sometimes you get into a meeting like that and you are so caught up in just basic education, you kind of run out of time to deal with the deeper strategic questions and issues. So really there are a lot of benefits to just going into it organized and prepared. We talked about educating about the core issues By doing that, that is a great foundational starting point because you can see what applies to you. You can start to figure out goals. You can start to even start to see what kind of information and evidence am I going to need to win certain arguments, to accomplish certain goals?

(24:39):

So number two, determine what you want to learn about family law and divorce. You've already done some of the heavy lifting on your own, okay, now you're sitting in front of the expert, the person who specializes in a practice in this area, meaning divorce law. All right, there has to be a question. There must be questions that you have that you just weren't able to answer by yourself simply by reading a website or reading a book or whatever. So sit down ahead of time, go into that meeting with specific questions, write them down. Hey, I know about custody, but let me, and I've even read about relocation, but can we dig a little bit deeper? I have a few more questions about relocation in these cases. Hey, I'm anticipating that basically I have a question just basically about fourteen-year-old election. I think my child is going to want to elect to stay with me.

(25:59):

Is that a guarantee in practice? How does that play out? But do you see what's happening there? You're not just jumping in saying, can you spell custody for me and then educate me from the very, very beginning? You're saying, okay, I have a basic understanding, even intermediate level, but now I need your expertise. I need to sort of tap into that deeper pool of knowledge that I just didn't get online. And then you can go in with those specific questions. I love educating. So whether somebody has questions or not, I love educating, but I love when somebody comes with specific questions because I can sit, I listen, I can think about that question and then I can say, "Hey, based on everything I know everything I've experienced, boom, here's an answer," and I can hyper-focus on something and what makes me the happiest. I know it's something that's on their mind, something that's important to them as opposed to me just generally talking about things. I have answered a specific question that they have.

(27:19):

I've given them something that they want and need and are asking for. That makes me happy and on top of everything, the other benefit is, and I've done so incredibly efficiently. So absolutely go in with those specific questions. Now let's go into just some of the basic information you want to provide. While I will say the reason for the divorce ultimately may not have any bearing on how the case is handled and what agreement is ultimately reached, go in ready to tell that part of your story. This is what's going on in my family. This is what's going on in my relationship. This is what led us, what led me, to this point here today. Sitting here with you either contemplating a divorce, filing it, initiating it, or responding to one. This is why this is happening.

(28:29):

That can absolutely be very important to an attorney just by going in and having that accurate answer that's going to make that attorney think about and anticipate issues that might be coming. And also to think about goals on how to resolve the matter and basically accomplish whatever your goals are. That leads to number four, what are your goals? Well, number four leads back to number one. I know that you don't have to worry about the numbers. I'll explain.

(29:10):

Four core, if you have built a good foundation, custody, child support, alimony, equitable division of property. Custody, child support, alimony, equitable division of property, I'll say it again, those core issues. If you know which one or ones apply to your case, you can start to think about your goals, custody. What's your goal? What are you trying to accomplish here? I want to be the primary custodial parent. I want joint physical custody. I need sole custody. I need there to be reasonable visitation or I need it to be supervised visitation. There are concerns. Think in terms of the core issues. Then you break it down, figure out what your goals are.

(29:57):

Child support. The only time really in terms of a goal... Look, if you're not the primary custodial parent and you live close by, you can expect you're going to have to pay child support. And child support, in Georgia, it's a formula. It's not subjective. It's not like, "Hey judge, I know I'm supposed to pay this amount, but I'd like to pay less." Whatever the guideline says, you have to pay, you have to pay unless there's an applicable deviation, different show, a lot more information on that. But the bottom line is if you have a basic understanding, you can start talking about what your goal is. If you live out of town and you know it's going to cost money to exercise parenting time, then if you've done some basic research, you know about travel deviations and if you don't know about a travel deviation, now you do and you can bring that up and you can say, "Hey, I know I'm going to have to pay child support, but man, it's going to be expensive for me to exercise parenting time as often as I want to and pay all the child support that I'm supposed to."

(31:13):

So figure out the goals. Alimony, division of property and debt. Are you looking for a fifty-fifty? Do you think something else should apply? Just because it's your stated goal doesn't mean that's what's going to happen, but you're going into the meeting prepared. All right, number five, be ready to provide details about the relationship. Oftentimes I will tell people when they call, I will say, look... I'm trying to think of how to put this. I'll sit initially on the phone with somebody. An hour goes by and they have told me a bunch of stories and I can tell we have just scratched the surface. There are probably a thousand more stories that they feel they need to tell.

(32:06):

And remember, if getting through those five stories took me an hour, do you really want to tell a hundred stories and spend 5 hours, 6 hours in a meeting with an attorney doing it? So I typically will tell people, think about some of those details about your relationship, things that you think are important and as it relates to the relationship you have with your spouse, write them down. Bullet point them. I'm not looking for a book. All right? With all due respect, there's a lot of authors out there. I'd rather read, but as part of my job, it is a lot easier for me to sit there, look at bullet points regarding the relationship, and then when I sit down, I've read it, I've looked at those bullet points and I can say, Hey, 1 through 1,000, thank you for the 90 page dissertation. But number 42 and 73 are very important. Let's dig into those. Well, we're going to dig into the other issues and the other tips when we come back.

Speaker 2 (33:24):

I just wanted to let you know that if you ever wanted to listen to the show live, you can listen at 1:00 A.M. on Monday mornings on WSB, so you can always check us out there as well.

Todd Orston (33:35):

Better than counting sheep, I guess, right?

Speaker 2 (33:37):

That's right.

Todd Orston (33:38):

You can turn on the show and we'll help you fall asleep.

Speaker 2 (33:42):

There you go.

Todd Orston (33:43):

I'll talk very softly.

(33:49):

Welcome back everyone. I'm Todd. This is Divorce Team Radio. Remember, you can check us out online at atlantadivorceteam.com or if you want to read transcripts or listen to the shows again at divorceteamradio.com. And also wanted to let you know that if you want to listen to the show live, you can listen at 1:00 A.M. on Monday mornings on WSB. So you can check us out in many different ways. There's a lot of ways to get to this information. All right, today we're talking about those eight tips for how to make that initial meeting with your attorney, your chosen attorney, successful. It's very important.

(34:28):

That's the very beginning of this process, the path you are taking with this expert. You want to work efficiently and well with that person. And so this list of ways to be efficient, well this is going to help you. This checklist will help you work efficiently and hopefully find a greater level of success in your case. We've been talking about educating about the core issues, determining what gaps you need to fill, answering questions like why you're seeking a divorce, what are your goals, providing details about the relationship. Well number six, let's talk about that. Providing relevant personal information. Sometimes that information is kind of irrelevant. Two people come in, we want a divorce. We see eye to eye on everything. I don't care about some of the more personal facts and factors that relate to the relationship you have with your spouse.

(35:43):

Remember the word here is relevant. What is going to be relevant in this case? What relevant personal information? Are there mental health issues? Are there issues relating to abuse, substance abuse, things like that? Those things are going to be potentially important and ahead of time, you can basically sit down and again, make a bullet point list of things that are personal in nature that you believe are relevant. Relevance, you don't have to determine. You're not the judge. No one's going to object if it's irrelevant to the issues that are going to be pending before a court.

(36:41):

But the attorney will be able to sift through very efficiently all the points that you bring up to determine what they believe is relevant. And we are always open depending on the attorney you've chosen, but your attorney should be open to the discussion about whether or not it's relevant because I will tell you that can sometimes be an issue. What a client believes is going to be important versus what an attorney feels based on experience will actually get some traction and be important in the case. Sometimes it's different. That's where basically you can work either well or not so well with the attorney.

(37:30):

Meaning if you go in and you're talking about something and you think it's super important and if you've spent, you're going on hour three just telling those initial stories, you may not even have time for the attorney to respond to each of the stories and go, "Yeah, I think that's going to help," or, "That's not." As opposed to you've put together that list, you're sitting down and you're like, "Hey, what do you think about the things I believe are important?" So that leads to seven, and this is more on the behavior side. Be ready to provide if you haven't already, details relating to sort of like I was saying before, that AAA: adultery, abuse, abandonment issues.

(38:18):

And there are other behavioral things and actions that one party could take against another that could be relevant, impactful in the case. So be ready to discuss those. And again, make a list. And also, again, I'm not saying that the bullet points should be three pages each. You can always flesh something out, you can always add more. So you don't need to write a book, but a bullet point, two, three sentences each where you're like, "On this date, there was some physical abuse. On this date, there was drinking and driving. On this date, they left for two weeks, five weeks, a year," whatever the case might be. And we haven't seen that person again. So you can explain more basically.

(39:24):

And trust me, the attorney is then going to say, "Relevant," "Not relevant." Let's talk more about number one, number four, number seven, and these other ones, they're not important. And then that can lead to a discussion of if you disagree, let's talk about why you think it's important. And strategically speaking, I don't. That way you and your attorney can get on the same page. That's going to make for a better, healthier relationship with your attorney. And that's important. The attorney, any paralegals, any younger associates, legal assistants, anyone on the team, they are your team. And I don't want to overstate this, but I also don't want to understate it. This is not an easy process. Attorneys do everything they can. We will do everything we can to make it easier for our clients. Simply being their voice and educating them relieves so much anxiety. But that's not where it ends. And you need to trust that your team has your back.

(40:41):

So having that good relationship, that's going to allow you to really dive in and get to some of these core issues. I'm not talking about core issues, custody, child support, alimony, equitable division. I'm talking if an issue of adultery comes up or abuse or abandonment, if you think it's important, talk to your attorney. Give them the details necessary and be able to explain why you think it should be. Or at the very least, ask the question, "Hey, you're saying it's not that important, why? I need some more education." And then that leads to the final tip and part of this checklist. Number eight, provide documents and evidence related to the four core analysis.

(41:28):

Remember I said towards the beginning of the show, if you look at the core issues as sort of the foundation, we don't have any children. Okay, well we know custody isn't going to apply. And to all the animal lovers like me, your dog is not a child, kind of, sort of. Similar issues, but it's not a custody issue. Child support isn't going to be paid for a pet. So if we know custody is not an issue, child support's not an issue. All right, well what about alimony? Well, I'm not going to ask for alimony. Okay, well, is the other side going to ask you? No? Okay, well then we're down to equitable division of property and debt.

(42:15):

So now you can start thinking about, what documents do I need? What evidence might help me achieve my goals? I'm not asking you to anticipate correctly, all the things that will be important, but there are some basics, right? If income is important for child support, alimony or bank records relating to division of property, then get some of those bank records, scan them, have them ready to either hand to your attorney or hopefully ahead of time, forward them to your attorney.

(42:54):

Gather information regarding income. If there are retirement accounts, gather that information. How about we look at behavior, if there is adultery or an allegation, of adultery, if there is abuse? All right, well what evidence do you have? Do you have the names of potential witnesses? Do you have pictures? Do you have video? Start to gather that and either send it ahead of time or be ready to hand it over and give sort of an explanation, "Hey, this is what I have."

(43:31):

There are people who come in, they're like, "Ugh, adultery." And I'm like, "Okay, do you have any evidence?" "No, but I'm pretty sure it's happening." Well, I have to then look at them and go, that's likely not going to be enough for a court." As opposed to, "I have video, some audio and a sketch artist." Okay, well it sounds like you have quite a bit. Think about phone records, think about all those things. I'm not saying you're going to get it right, meaning that it is going to be a comprehensive, complete itemized list of all the important information. That's a starting point. And the attorney can go, "Hey, great job. You got about 70% of everything that I think we would want. But hey, can you now work on this, this, this, and this?"

(44:24):

All right, checklist. It's going to help for you to be successful in your case and have a successful working relationship with your attorney. Hopefully it helps. Thanks for listening.