1. What is your goal today?
2. Why should you have custody?
3. Why should your spouse not have custody?
4. What are your spouse's strengths and weaknesses?
5. What are your strengths and weaknesses?
6. What is the worst thing your spouse can say about you?
7. If drugs or alcohol are an issue, when was the last time you used drugs/alcohol?
8. What proof do you have of your spouse's drug/alcohol abuse? If there are DUI's, you need to have gotten certified copies to back-up your claim.
9. How has this custody fight impacted the child?
10. Describe (in detail) a typical day in your child's life.
11. What is your child's bedtime ritual each evening? Your client should know their favorite book, bedtime story, bedtime prayer, favorite toy, etc.
12. Who helps the child study each evening?
13. How is your child doing in school? Your client should be able to name the school principal, registrar, school nurse and teachers at the school. Have attendance records if tardiness and/or absences are an issue. If grades are an issue, bring report cards and progress reports.
14. Who can testify to your relationship with your child? Your client will need their full legal name, address and telephone number. How long they have known each other and what they would be able to testify to in detail? Your client should know all the doctors that the child has visited and the reasons for each visit.