I break a divorce into three phases. This approach helps clients know where they are in the divorce process, for timing and budgeting purposes. This breakdown also helps clients understand all of the components that can be expected in the divorce process.

Phase 1: Initial Pleadings and Hearings

This phase typically includes:

• Complaint
• Answer
• Counter-complaint
• Preliminary motions
• Financial statement
• Initial hearing
• Scheduling order
• Parenting classes
• Mediation
• Pendent lite hearing.

Phase 2: Discovery

In the second phase, these activities are common:

• Interrogatories
• Request for documents
• Request for admissions
• Notice of deposition
• Third party subpoenas
• Deficiency letters
• Motion to compel
• Motion for sanctions
• Opposition to motions
• Hearings on discovery motions

Phase 3: Trial

It can be surprising just how many steps it takes to get to the actual divorce trial. In this third and final phase, these are typical:

• Trial preparation
• Pretrial statement
• Pretrial hearing
• Joint property statement
• Exhibits
• Direct and cross examination questions for client and witnesses

Settlement discussions proceed simultaneously with the litigation process. A case could settle at any time.