Video

Divorce Navigator Workshop #1: Starting Your Case

Divorce Navigator Workshop #1

How to represent yourself in family court

Video Transcript

Today we’re going to talk about finding an attorney and working with an attorney. What you need to know about attorneys; how to prepare for the first consultation, the things that you should be asking; the list of questions you should have for your attorney and then the list of things you should be thinking about before you meet with your attorney; information you should be collecting prior to meeting with the attorney and prior to making decisions and then how to decide once you have an attorney if you should change the attorney. That happens a lot. It’s a big question!
The next time we do the workshop will be in 2 weeks and we’ll talk about fees. How much does it cost to get a divorce? How can you save money? How could you minimize your cost and maximize your budget, flat fee options and limited scope options? That will be next time.
The remainder of our 11-part series we’ll go over disclosure and discovery, pre-hearing conferences like a resolution management conference or return hearing, divorce negotiation tactics and then divorce negotiation process which is pretty much mandated through the court and highly encouraged. Trial preparation and trial presentation. This is gold. If you’re going to be representing yourself in court, you need to know things like how to present evidence, how to select evidence, how to organize evidence. So, we’ll go over that in our 6^th session. After that we’ll go over legal issues.
So, the first half up to session 5 is procedural – how to procedurally get through the process and then after that we go into the more substantive issues surrounding the matter like the divorce legal issues, child custody issues how to develop a parenting plan, things like that. Child support, how that works, all the ins and outs, how to deal with the division of economic security and getting income withholding orders and then we’ll talk about alimony and property concerns. That will conclude our 11-part series, and we’ll see how you like it and whether or not it’s helpful and see whether we want to offer it again or we want to offer something else, based on what it is you want. Please do give us feedback because we will make changes based on what works for you.
Before we do anything, we have to start out with the big picture. This is the big picture plan, or guide, that you can use when developing your plan. Divorce from our perspective lawyers is kind of a legal process. It’s a transaction, a legal process. But for you its way more than a legal process. We’re talking about restructuring your entire life and determining the direction for the rest of your next phase of your life, the next chapter of your life. With that in mind I like to tell people to start off by figuring out where you’re at now and what you want to accomplish for your life. What are your goals? Then determine what are my resources. If your goal is to move out of your 3,500-square-foot house and get a new 3,500-square-foot house but your spouse is paying ¾ of your house you may want to reassess those goals based on the actual resources, you have.
Step 2 is planning your finances and figuring what your budget is today and what it will be during the period of time you’re going through your family law matter. You may not be married but living together and your moving to living on your own you have to reassess your budget.
Step 3 figures out a plan for kids. What’s going to happen temporarily and long term and this will be highly dependent on your goals. Where will you live in relation to your soon to be ex-spouse or partner? That’s going to impact your child custody plan which is why everything has to start with #1. Then we look at your balance sheet. Your balance sheet is what I have for property and what I have for debts. Being in Arizona it’s a community property state so if those assets and debts were accumulated during the marriage they’re largely going to be divided. That doesn’t mean each single piece of property has to be divided, but the whole of debts and property is divided and most often equally. Equitably is the law, most often equitably is equal but it doesn’t mean its always that way or its dollar for dollar. But in general, that’s what you’re doing.
(5:00) Step 5 is to protect yourself on social media this isn’t limited to just social media. It’s about kind of protecting your privacy and your reputation as you move forward and being as intentional as you can while you manage a very emotional transaction. It is human nature to want to talk to your friends and family and these days its really easy for us to fire off a shot on social media that’s clearly geared toward your ex or your situation and you need to take time to think about it and determine who it is you want to be 2 or 3 years from now before you post on social media or talk to family or friends or spreading intimate details about your breakup.
Step 6 is to assemble your support team. This is really where we’re at today. Who’s your lawyer going to be if you’re going to have one? Who is your counselor going to be if your going to have one? Who is going to advocate for your children if you need a third party mutual? What type of team do I need to get me through this, and who are my family and friends I can trust and bring in and those who I can go out with on Friday night, but they’re not necessarily the family and friends you want in your situation. It’s important you have people around you who are level headed, calm and grounded. Not those that fan the flames and live off drama. Do some intentional soul seeking when you assemble your support team.
Now we get into attorneys. Everything you need to know about them and how to work with them. Not everyone needs an attorney. If you have no assets debts or kids and not fighting over anything you don’t need an attorney – you need the right paperwork. If you have separate property issues, or other tricky legal issues we’ll cover later you probably do an attorney, but it doesn’t have to be all or nothing. You may need an attorney to review the paperwork, guide you and be a behind the scene coach. You definitely don’t want that person to be your emotional support. We should know the role your attorney plays. He’s too expensive and not qualified to be your emotional support system.
When you decide if you need an attorney or not your going to have your consultation. This is where you ask the right questions and know what to ask before going in. I have a handout that shows how best to do that. Then you need all the information ready for your attorney during that consultation to give you the best and most accurate information. When you give them the information, they’ll be able to maximize that time and give you the best information.
This is along list of questions – we will break down and go over in groups.
First set is about how you determine if the attorney you’re meeting with is qualified to take your case. These are questions you might want to think about asking: you’re looking for the right fit, and that is more education or experience. It’s a combination of experience, education and fit and click and culture fit and value fit. These questions we developed will help you determine all those things.
One thing you want to ask is if they will work on the case. We do that often here at modern law. I like to do the majority of the consultations but sometimes I’m not fit for the case. I might be too expensive or a case someone else in my office is more suited to take given their niche. You will have an associate that will work for less money. Then you’ll have a paralegal and billing team. You want to know the team. Ask the attorney what’s your background? How long are you out of school? You want to ask. How many cases like mine have you handled as a firm in the past year? It’s not unusual for lawyers to dabble, it’s not advisable but they do. If you walk into a firm and meet with an attorney, ask what are the average fees in cases like mine? At Modern Law our average fee is around $6,000. Its hard to say. That’s not a guarantee anyone will spend, some spend far less or far more. But an average gives you an idea as to how the firm operates. Your circumstances are going to be specific, and you want to get into that with the attorney.
(11:40) The next set of question you like this attorney and want to move forward. One of the biggest complaints about attorneys’ people have, is about money. And mostly that comes out to expectations. We found people are happy to pay the bill when they know what to expect. So many people get invoices from their attorney and they didn’t know it was coming.
What will my case cost? How often will I be billed? What does this fee include? And what are your policies on payments, phone calls, etc. how am I gong to be gilled and for what? These are worth asking and should be written into your agreement. You should absolutely insist on this and make sure it’s followed.
The next set of questions has to do with expectations on communication. Beyond fees or maybe along with fees the next biggest complaint people have about working with attorneys is regarding communication. Clients almost always want more communication than their attorneys are giving them. So, this is something we can fix this with expectations. How long will it take for me to get an appointment when I call in? I need to talk to my attorney how quickly can I get in? Can I call afterward and if no can I expect a response? Are my goals realistic? This is important – not everyone’s goals are necessarily realistic – if you don’t know what this world looks like or what to expect how you know if your goals are realistic?
If the attorney you’re meeting with says your goals aren’t realistic, don’t stop there. Get a 2^nd or 3^rd opinion. If they all tell you they’re not realistic then you need to go back and reassess those goals. Figure out alternative strategy to figure out what you want because going through court system won’t cut it.
What problems do you foresee? If I have a client that comes to me with unrealistic expectations, per the court, we’re talking about strategies that don’t involve court. How can we get creative to solve this problem before we say you have to pick a new goal?
The next question involves strategy. How will we solve my problem? Accomplish my goals? How much time will it take? How much time should I prepare on this case? Is it likely we will have to litigate this case or settle it? These are things your attorney will want to know from you.
Do you have an existing case number, do you have any pending hearings, is it a 4-D case (that is Division of child support) or is CPS involved? Are there any other alternative agencies? Say grandparents have custody of children – are there other people involved beyond people in this particular case number – is there an existing decree we’re to enforce or modify. These are things attorneys need to know to come up with your cost and assess your goals.
(15:45) Q. So, it’s important for people to prepare before they come to that first initial meeting, so they can have a better discussion with you on the question above?

Yes – its information we need to have in that consultation in order to give you accurate information and answer those questions accurately.

Be prepared to share the details. Here I want to make sure that whatever’s important to you, you share with me. The best example here: I have all these questions that you can and should be thinking about before you come in that we give to our clients before they come in – but this is the best example – at a consultant a few years ago with a woman, she told me about her situation. She had been married. She was older, and she confessed essentially that the sex life was really bad. It turns out they didn’t consummate the marriage. They had never been able to consummate the marriage which meant we were able to get her an annulment and because she was the primary bread winner and earned that money and put it into a 401K it meant she could keep that money. She didn’t have to split it up as community property – that’s why sharing these uncomfortable details with your attorney may end up saving you a lot of money and in her case, it was easier than getting a divorce. If you’re going to be talking about things like your sex life, then you want to make sure there’s a level of trust there that your comfortable talking with one another. That there’s a cultural fit.
Do you have religious differences? Do you have disagreements, and what are they mostly surrounding? I know these aren’t necessarily related to issues of alimony but when it comes down to creative solutions having all that information about what makes the two of you tick. What works and what doesn’t? What motivates somebody makes us more able to get a better result or at least factor that in when crafting creative solutions.
What is your residence status? When did you move here? How long have you been here in Arizona? Somebody has to be here for 90 days in order to file for divorce. That’s not true for a legal situation. So, if a couple just moved here from Florida and they want to get a divorce we can file for a legal separation get the process started, and later convert it to a divorce and you’re not stuck waiting your 90 days.
We want to talk about businesses, criminal history, domestic violence, life insurance policies, postnuptial agreements, prenuptial agreements, etc.
A lot of people put off going to see a lawyer. It’s uncomfortable. Maybe you don’t need to see a lawyer. Maybe there are enough resources online. In general, going to see a lawyer early is like going to see a doctor early. You can head off a lot of problems or kind of strategically figure out what you want to do. For instance, I met with a woman yesterday, and she decided that, she’s in a 23-year marriage, and it’s been bad for about 15 years and just now it hit her that she’s lost herself. She’s numb. She’s almost going to be 50, she’s still gorgeous and all these things she wants to do. She wants out of her marriage. In talking through the specifics of her circumstance it doesn’t make sense for her to file today. Its not her best option given her circumstances. So, by talking to me about it before talking to her husband, she is better set up for her long-term goals.
(20:30) Q. One of the people on Facebook brought up a good point. Do you feel respected by your attorney? Is that something that is on that list of things to make sure?

I love that point. One of the reasons that people don’t go to see lawyers or don’t want to see them is because they are scary, and they feel intimidated. These are things to think about when meeting with the attorney. The attorney should respect you and your opinion. This is your life. Let’s not lose sight of it. Just because we’re the expert who works on divorce all year long doesn’t mean we make decision on your life. Our job is to guide you through the process.

Keep looking if your attorney doesn’t inspire confidence, he/she was not attentive, your attorney appears disorganized or distracted, not focusing, attorney can’t follow what you’re saying. You don’t feel understood. Then how can they help you understand your objectives? If they can’t – move on – or you don’t have a rapport you like.
What if you have a lawyer and your trying to determine whether or not to dump them? You should consider switching attorneys if your calls are not being returned, you don’t know what fees you’ll be charged and if you don’t feel like you guys have a clear strategy, objective in your case. You’re not sure what’s going on. You feel in the dark. Try to talk about it. Any good relationships worth attempts to communicate. if its not working get a second opinion.
What do you want? You want regular updates, objectives clarified and settlement strategies and strategies for your execution of your litigation to be clear. If you don’t have those things, you might want to try to talk about it and if it doesn’t work, move on.
Ask how you will be billed. Howe the office works. How the courtroom works. How will you be charged for copies? Will you be charged in advanced? If depositing into a trust are you expected to put more money in and how far in advance are you notified. Plus, you need to look at your written agreement.
An attorney can make all the difference in your case. It’s an important decision that is worth you spending time on. The attorney you choose must understand you and be smart enough about law to help you navigate the system.
If you are somebody who has had two or three attorneys and are unhappy with all of them and have done a fairly decent job researching them, the problem is you. At that point it’s time to really look in the mirror. Get a counselor, talk to somebody you can trust and reassess your situation, because you are literally flushing your money down the toilet. We are really passionate about this at Modern Law is protecting peoples’ resources. If we’re taking your money, we want to be doing great work for you that is worth it, that you achieve your objectives. If you switch attorneys several times it usually is a sign that things are not going to end well for you and you won’t like what the judge says. You probably want to reassess.
(25:10) That is all for today. Now we have time for questions for people in the office and for our friends on Facebook.
QUICK DISCLAIMER: Everybody here in the office and on Facebook has a disclaimer. So that your aware that I’m not your attorney and this is not Confidential, and we don’t have attorney/client privilege. But we’re going to protect your anonymity as much as we possibly can. If you want to get us questions but you don’t want to type them on Facebook because you don’t want to see – you know – these are personal questions. Go ahead and text us those questions at 480-649-2905. Caitlin will put that in the comments, so you know.
Q&A

Divorce decree was set in motion already a few months back now we’re in post-divorce decree. Things within the divorce decree have not been resolved yet, and one of those things in the divorce decree had to be with how we communicate and how we actually transport the child. Anyway, that lead to criminal charges because I sent a written request for the Mom to allow me to take my son on a Disney cruise for his birthday. I won a civil rights litigation suit against the company over my service and part of the settlement was to give my son a cruise. He’s allowed to travel anywhere in the U.S. as long as she’s alerted 7 days in advance. Travel outside the country either one of the parents have to have written consent to have that happen. She’s bitter over the divorce, and she said for her own reason “No”. She originally told the minor child “I didn’t say you could go” and 4 days later she sent me a note saying he can’t go. The trip was already paid for. He really, really wanted to go. He was getting on me. He was getting on her. Long story short – I took him anyway. And we had a great time. There’s consequences right. She filed a police report. She initially said she didn’t want to press charges and then about a week ago she said she was pressing criminal charges. She filed a police report and put it in criminal court for failure to, something about I didn’t follow judicial order. That’s how they got it under criminal investigation.
If you have an attorney on the family law side and something like that happens can an attorney represent you on the criminal side?
So, you’ve been charged? You were in Court this morning. I’m assuming the penalties are not such that you will get a public defender? You didn’t know if you could get a public defender? It definitely depends on the attorney. Some family law attorneys are qualified and will represent you in kind of related family law or criminal law matters. Other family law attorneys will say they won’t do it. You need to talk to your attorney and vet your attorney into saying do I think this person is capable and competent to represent me in the criminal matter.
How does a case that starts in Superior Court, or Family Court have jurisdiction to send it to a criminal court or charge under criminal. If I’m being charged with basically not following a court order but that order was set in motion in family court why are they enforcing it in criminal court? Isn’t it a jurisdiction issue when I took the kid out of country and it happened in the court the place where they’re actually charging me?
I’m shocked. Most of the time in this situation what you’ve done is committed contempt of court. There are civil penalties for committing contempt of court and there are potentially criminal penalties. I’ve never seen this situation. Somebody takes their kid on a cruise, and Mom doesn’t like it. I know some great criminal attorneys. I can hook you up with them. I don’t know what to tell you. The family court is a civil court and the remedies for enforcing in civil court are civil contempt (like paying someone’s attorney’s fees or paying a fine). It’s unheard of in this situation that there would be criminal charges. If there are criminal charges, it’s usually for an assault. If you break the criminal code, then there could be criminal consequences. To me this doesn’t sound like a criminal act. You and your attorney have to work that out, look at all the angles and see what you can do. Sounds like it was worth it though.For something like this — penalties can be extremely steep.

(34:50) Q.If you have to go back for changes in parenting plans do you get the same Judge or is it just the luck of the draw each time?

You have an assigned Judge in Family Court until that Judge rotates so depending on how long the case goes you could wind up with two, three, four judges. Depending on how long your case goes, you had the decree you could have the exact same assigned judge. I would want to look at the decree and what the Judge said about your situation. Look at the circumstances that have changed since then, what your trying to achieve and then figure out how likely is it we can get you what you want. You get to change your Judge once before they make any rulings. One thing we do is we get to know the Judges and keep track of their leanings everyone’s an individual. Sometimes we know that a judge almost always gives equal parenting time, and our client does not want equal parenting time We are going to file a motion for change of judge and hope that we get someone who is more inclined to our plan.
Do you know approximately how often Judge’s rotate?
It’s supposed to be a three-year rotation, but it doesn’t seem to work that way. Changes are always being made and some judges seem to stick around for a long, long time. Sometimes they change courthouses. It is something we can look at for your given specific situation.
When you go in for modifications is there a specific time to wait before you ask for modifications – three months, six months, a year? Because my situation just was put into motion May and here we are back in the court.
You have to wait 12 months to file for a modification unless the decree is not being enforced or carried out then you can file after 6 months. There is a waiting period. The goal is to settle into the plan. Things are crazy at first and it may be needed to take time to clam down.
You have both the parents, divorce decree in hand, it says something about 12 months and/or deal with mediation first before you come back to court. She has a crafty attorney who knows how to work things on paper, created some sensationalism things were worse than they were. Once the Judge sees this information and sees about 95% of this stuff is not factual is there some type of penalty for them sensationalizing the situation to get it back before the Judge when it wasn’t as dramatic and could have been resolve in mediation. Is there a law or ordinance they can say “hey you violated the statute I’m going to sanction you based on x, y, z for sensationalizing the situation instead of dealing with mediation first?
Yes. There is nothing worse than getting dragged into court having your resources wasted over something as silly as wanting to take your kid on a cruise or pick up and drop off times. Whatever it is people want to fight about. The court system isn’t the place to resolves those issues. There are many statutes. The attorney fee statue is the one most used. If you are unreasonable in your litigation, you may be ordered to pay the other persons attorney fees. That can happen if you have attorney fees. I you represent yourself your losing all this time. There are a lot of other ways to ask for sanctions, and you can get creative – allot of provisions that allow you to ask for sanctions – when you have someone that’s really bad year after year and it happens they can be labeled a vexatious litigant and if you are labeled that then you aren’t allowed to file anything else without prior permission of the court. So, it’s hard to get there, but that is a last ditch final slap for people who can’t help themselves.

If you have to wait 6 or 12 months are there a handful of emergencies that would qualify or fall under modifying early that aren’t dramatizing it up or sensationalizing it?
Absolutely. Mom goes into rehab, and the kid has nowhere to live. Dad goes to jail, etc., etc., Dad assaults the kids. Mom hooks up with a druggy boyfriend and is prostituting herself around the house. You can always file for an emergency modification if your child is in immediate danger of irreparable harm. That is a high bar. Sometimes even when we think the bar but sometimes even when we think the bar has been met and our client wants us to move forward with an emergency motion sometimes it won’t be granted. It will get a hearing sooner, but it’s a discussion we need to have. What’s going on? How likely is it we’ll get the emergency order? What are the pros and cons of moving forward with this?

(42:50) Q.If I may be thinking about getting an attorney what do you expect of me as the client coming into this?

We have the handout we sent that gives people things I’d like you to think about before you come in and questions I would find relevant. Things I would like to know and a list of paperwork or things we’d like you to bring.
Can you get an annulment if you’ve been married for 6 months in the State of Arizona?
Maybe yes. Maybe no. To get an annulment you have to meet the criteria and length of marriage is not one of those criteria. Annulment is a super old-school concept that essentially your marriage wasn’t valid when you entered into it because of a procedural issue or some physical issue. There’s a list of grounds for annulment but simply being married for 6 months won’t get you there. But if there are other circumstances present then we might be able to get you the annulment.
Subpoena. If you represent yourself and your subpoenaed by the other side. How does the person representing themselves get a subpoena for the other side?
I think but I could be wrong. Only attorneys have subpoena power. I think individuals can’t subpoena documents.
Obviously judges want to be fair and impartial. If you have someone that can’t afford representation versus somebody who can. The other person has the upper hand. you don’t have the power to subpoena in that situation do the judges look at that? One person has subpoena power, but the other person doesn’t have subpoena power.
If one party has a good attorney and one party doesn’t there is no level playing field. We go to school for a million years, study this all day and it’s just your David and Goliath but David beats Goliath sometimes. So, yes, you don’t have a level playing field but there are ways to get the information you need. We will go over that – Disclosure and Discovery. So, you don’t have subpoena power, but you can request documents from the other party. If they don’t give it to you and you have the ability to request documents they need to get from you from their bank or whatever. If you don’t get them you have the ability to ask the court to compel the individual to get the documents. You don’t just show up and say you don’t have subpoena power. That’s why we are doing this. So, if you are David, you know how to go up against Goliath.
Follow up to the annulment question. Is there a place that you know of off hand you can go to find out what that list of things is? They wanted to know if cheating was on the list?
Cheating is not on the list. It is a no fault divorce state. Our website has some blogs on annulment with the list. Search annulments and you will get all sorts of common-law grounds. You can also email us.
I did some research on your place before I came. I watched a few of your videos which were very informative. Thanks for doing them it helped me out a lot. It seems like out of all the places I researched you guys are kind of pros, the small guys that have to fight for themselves right. Doesn’t that conflict when you guys are actually trying to work as attorneys and how do you balance that conflict? If you feel it’s a conflict.
We don’t feel it’s a conflict. The bottom line is about 80% of people can’t afford lawyers and have to represent themselves and those people should have access to information and resources. Modern law is kind of 2.0 of our company and we started out as a firm that was started for the purpose of increasing access into justice we found that isn’t best served with a law firm, but a law firm can do a lot to empower people to create resources to do things like this and it’s something we’re happy to do and it lets people know who we are. When you hire Modern Law, this is what you are getting. We are really, really good and committed. We’re also going to help the little guy as much as we possibly can.

(49:30) Q.It’s like a different part of your company, you log in and as far as pretrial statements and other documents that have to be prepared. Is that prepared by paralegals or who?

I think you’re talking about our sister company “Access Legal”. That is our sister company – Modern law started as a company that was for the purpose of increasing access to justice and we found it didn’t work well within a law firm so this second company spun-off and created which is “Access Legal” which is a legal document prep company in Arizona that has online legal forms for free for the public to use. Their created in word so you can customize them. If you take that with the information from the workshops, you can create customized documents for your litigation strategy by using all the resources. It’s a $200 a month membership – the certified legal document preparer will look at and assist you with any documents you want to create during your membership. So pretrial statements, etc. She is not an attorney and can’t give legal advice.
My ex is representing himself and running up my lawyer’s bill. He calls and emails constantly. He knows I get charged every time he contacts my lawyer. What can I do?
It happens. I had an opposing party not that long ago that was intentionally harassing me to get to his ex and he said, “I’m going to email you every 5 minutes until you answer the question that I have.” We used it in court. At that point I told him “I’m going to get an injunction against harassment. Knock it off. Its not helping your case. I’m happy to work with you to solve substantive issues but you’re not going to harass me to get to your wife.” There was already an order of protection in place. Talk with your lawyer and see what they can do. I even encourage people to write letters. Sometimes you need that buffer. You tell that person send me letters and I’m filtering emails, so I don’t have to see them. We have to protect our clients and sometimes that means we have to protect them from opposing parties who are using their attorney to hurt them.
When someone’s representing themselves pro per have you been in a courtroom with someone when you’re the attorney and someone else is pro per on the other side?
Yes.
In that situation what have you seen as the biggest barrier or obstacle pro per representation presents in court that you’ve seen?
Sometimes people represent themselves in court very, very well. The most important thing is you are organized and deliberate and that’s what we talk about here in the workshop and the series – preparing evidence and trial preparation – how do you determine what evidence your presenting and in what order and how to question witnesses so your clear on what you want to achieve and maximize your chances of achieving it. It comes down to organization, strategy and deliberate execution of that strategy.
On a timeframe is there a way to utilize the pretrial statement ahead of time how can you help that and plan the strategy?
We talk about a lot in the book (it is a step by step book) to Arizona divorce. My best attempt to give direction to people on how to represent themselves — one thing we talk about is the pretrial statement. It’s everything. Your whole case boiled into a document that goes before the Judge before trial. One thing is if you have money for one document for one piece to have an attorney help you – have them help you draft the pretrial statement, it’s your facts, background, legal argument, rebuttal to their legal argument, your exhibits, your objections to their bad behavior, your position on sanctions and attorneys’ fees. I use it as my outline when I’m in court. You can use your pretrial statement to maximize your chances in court.

(56:30) Q.Are people walking up into court presenting a 5-page pretrial statement?

I’ve drafted 30, 40 50-page pretrials. If the issues are complicated to warrant that. You don’t want to use more words than necessary – but if it takes 50 pages to talk about a complex situation and argument then yes.
Sometimes a Judge mandates a joint pretrial statement. What if you’re not seeing eye to eye with the other side. How do you present your own pretrial statement instead of doing it joint?
That is very challenging. We struggle with that. It depends on the Judge. You could call the JA (Judge’s Assistant) and say, “I’m having a hard time coordinating”. Tell them your unable to get a joint pretrial but that you have a separate one ready to go. They will say, “okay send it over” or “sorry the Judge only accepts joint pretrial statements.” Then you have to show how many times you’ve reached out to do a joint pretrial statement.

We are out of time. The 1^st and 3^rd Tuesdays at noon are our workshop series. Thank you. Offer feedback if you want the format different or didn’t get things answered.