So You’re in Court with a Narcissist.
What to Expect: An
Informational Guide.
Part 5
FORTY ITEMS OF INFORMATION HELPFUL IN DOMESTIC LITIGATION
By Jillian M. Tindall,
Esq.
All rights reserved. Portions
copyrighted.
WARNING: The Following Information is Not Legal Advice
Any and all information obtained from this document is not, nor is it
intended to be, legal advice. The following information is not meant to direct
the actions of the person(s) reading/viewing it, and the reader/viewer is
directed specifically to never take action on any information provided in this
document. Instead, the person reviewing such information should consult a
competent attorney in their own jurisdiction for professional legal advice based
upon their own specific facts and circumstances. The following consideration
points are for the reader’s information only.
FORTY ITEMS
OF INFORMATION HELPFUL IN DOMESTIC LITIGATION
(Apologies in advance for the margins if they do not line
up exactly.)
1.
Tax Returns. Federal, State, Personal, Business, Annual
Report and Personal Property Returns, and any attachments: mortgage interest
statements, student loan interest statements, W-2s, 1099s, K-1s, interest and
dividend statements, etc.
2.
Income Records. Paystubs, Social Security earnings
statements, unemployment, worker’s compensation, interest and dividend income,
etc.
3.
Employment Records. Wages statements, salaries,
bonuses/commissions, promotions, awards, sick pay, vacation pay, separation or
severance pay, etc.
4.
Employment Benefit Records. Documents evidencing fringe benefits
and perks, personal and travel expense accounts, reimbursement documents,
company credit cards, gas cards, gifts, company specific benefits, club
memberships, etc.
5.
Employment Contracts and Partnership Agreements, Other. Documents, including
a list of any verbal agreements, and regular business services performed, along
with descriptions of what products/services are provided, and for what
compensation, along with any known business contacts associated with
each.
6.
Retirement Records. 401k, 403(b) or similar, Deferred
Compensation Plans, Pensions, Annuities, Profit Sharing, Employee Stock
Options, Military, Thrift Savings Plans, IRA, Roth IRA, SEP-IRA, Keogh, and any
other type of retirement asset or benefits.
7.
Business Records. Income/financial statements, accounts
payable/receivable statements, profit/loss statements, balance sheets, lists of
assets and debts/liabilities, mortgage/rent agreements and receipts, equipment
receipts, net worth statements, Secretary of State filings, incorporation
records, licenses, etc.
8.
Banking/Financial Records. Monthly/quarterly/annual statements
for checking, savings, money market, certificate of deposit, retirement,
investment, or other accounts in any bank, savings and loans, credit union,
financial institutions, check registers, bankbooks, passbooks, canceled checks,
deposit slips, insufficient funds notices, returned checks, etc.
9.
Stocks, Stock Options, Mutual Funds, Bonds, Securities, and
Brokerage Statements. (Personal and Business)
10.
Financial Statements. Individual/business, any kind prepared by or
for either party.
11.
Credit Reports. Prepared for either party.
12. Loan Applications. Made jointly, or
individually for either party.
13. Loan Documents. Title loans, payday
loans, auto loans, installment loans, or other.
14.
Credit and Credit Card/Charge Account Statements.
15. Other Debt. Records evidencing
debt, either joint, separate, or security for others (cosigned), State and
Federal taxes, health care debt, mortgage, vehicle, RV, boat, payday or title
loans, student loans, promissory notes, legal judgments, etc.
16.
A List of Debts. All debts, amount owed, payment amount, and
how titled.
17.
Bankruptcy Documents. Any documents prepared
for either or both party in connection with a present or past bankruptcy,
including any worksheets, schedules, proof of discharge, records of payments to
the trustee, etc.
18.
Rental/Lease Agreements and Receipts, Mortgage Statements. Monthly, or other
periodic rental agreements, lease agreements, lease to own agreements, etc.
19.
Real Estate Records. Purchase agreements, appraisals, closing
papers, escrow records, deeds, checks, money orders, wire transfer instructions
and other documents evidencing any earnest money deposits or down payments
made, appraisals, work orders, improvement receipts, etc. for any real
property, past or present, including Time-Share/vacation property assets.
20.
Appraisals and Valuations Reports. Cars, boats,
equipment, jewelry, antiques, art, collections, and any other property owned by
either party.
21. Car, Truck, Motorcycle,
RV, Boat, Watercraft, or other Motorized Conveyance Documents. Titles, purchase
agreements, receipts, and evidence of improvements, for all such assets.
22. Safety Deposit Box
Documents.
Any statements, inventories, etc.
23.
Life Insurance Policies. Certificates or statements,
whether whole, term, hybrid, annuities, or other.
24.
Other Insurance Records. Insurance cards and statements:
health, disability, accident, etc.
25. Insurance Attached to
Assets.
Vehicle, recreational vehicles, boats, watercraft, guns, RVs, ATVs, home and
rental insurance, along with documents evidencing special coverage, riders,
etc. for additional assets, such as jewelry, antiques, art, furs, collections,
etc.
26. Wills, Trusts, Health
Directives, Powers of Attorney, Letters of Guardianship etc. Any such documents
prepared for you or on your behalf for the benefit of others, or in which you
are a trustor, or any such documents in which you are named as a beneficiary or
have any present, future, or contingent interest, or are named as a trustee,
administrator, executor or executrix, including any annual or other statements,
reports, minutes, records of expenditures, disbursements, etc.
27.
Mileage, Frequent Flyer, Travel Award Statements. Records
evidencing current and past (used) travel awards.
28.
Membership Records. Documents evidencing purchase agreements and
membership rights to vacation clubs, travel clubs, health clubs, spas, country
clubs, etc., including any monthly, quarterly, annual statements and membership
rules, by-laws, etc.
29. A List of Assets. A list of all
property, owned prior to or during the marriage, noting when it was obtained,
how it was, and is, titled, whether it was a gift or inherited, approximate
value, location, and whether anyone is holding or keeping the asset.
30.
A List of Financial Institutions. A list of banks,
credit unions, brokerages, etc. with account numbers, type of account, address,
approximate value, and title of how accounts are held.
31.
Lawsuits, Judgments, Litigation Records. Pleadings, orders,
garnishments, awards, personal injury, inheritance, collections, criminal
records, judgments of conviction, bail records, Protective Orders, Restraining
Orders, child support judgments, etc.
32.
Education Diplomas, Certificates of Completion,
Certifications, Professional Licenses. Documents evidencing education or
training, continuing education, and vocational achievements for either party.
33.
Counseling, Medical, and Dental Records. Records showing
treatment for illnesses, injury, trauma, disability, etc. occurring during the
marriage.
34.
Police Reports. Any records evidencing abuse,
harassment, theft of assets, etc.
35.
Child Protective Services Records. Any documents
either substantiating or dismissing any investigations of child abuse or
neglect of either party, along with evidence of current disposition.
36.
Children’s School Records. School reports,
attendance records, discipline records, individualized education plans, sign in
and sign out records, news letters, etc., showing which parent has participated
meaningfully in their child’s education.
37.
Children’s Counseling, Medical, and Dental Records. Records evidencing
children’s well being, shot records, co-pays receipts, documents evidencing
which parent took them to health care appointments, and participated in their
care.
38.
Social Media, Text Messages, Emails, Voicemail. Any documentation
harassing, threatening, vendettas, racial, or annoying (time of day/night),
smear campaigns, evidence of infidelity, gambling, drinking, spending time away
from children, long hours worked, including any voicemail messages yelling,
name calling, etc.
39.
Historical Facts. Full chronological list of major
social/economic relationship events. (First meeting to present –obviously may
be more than 3-5 years.) Reference any documents, witnesses (names, addresses,
phone numbers), or other evidence in the chronology.
40.
Potential Witnesses. Names, phone numbers, addresses, and a
brief description of what the witnesses have personally observed.
