Steven, our client, is seeking a divorce from his husband, Todd. Steven is concerned that Todd, who has been in charge of the couple's finances for several years, will angrily respond to the service of the complaint by hiding or destroying the marital assets, many of which he had titled in his name. Your attorney has reviewed the situation and asked you to relate her position to Steven as a

conduit, because she is in court today. What information did she cover?

What will be an ideal response?


Assuming we are about to file, we will consider asking for court intervention in a per-return date relief request. We will need prejudgment remedies pending litigation. Steven may even need a pendente lite support order. We would want to avoid any dissipation by freezing the marital assets. A request for an order attaching known assets would be a good start. Of course, Steven does not have the knowledge that Todd has, so we might need to make a motion for disclosure of assets, as well. We will prepare for an eventual deposition during discovery (we'll need a subpoena duces tecum!) and prepare a notice to appear for a deposition to disclose assets to be served on Todd.

Legal Studies & Paralegal

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