These will be the notes you take during sessions with your mediator or your attorney. They can include information and/or documents you need to gather and questions that you think of when you are not with your attorney. Coming to a meeting unprepared can result in wasted time and money. Most attorneys charge for telephone calls: as much as possible, if you save all of your non-urgent questions for your meetings, you will be saving the frequent calls for questions you forgot to ask or had not yet thought of. Remembering to bring requested documents/information when needed will also prevent additional meetings and will allow you, your attorney, and/or your spouse and his team to make informed decisions that could result in faster resolution.


Session Summaries

If you are working with a mediator or a collaborative team, you may likely receive summaries of your meetings. Keep these in order of most recent in front through earliest in the back. You can refer back to them for future discussions.



This section is for any communications such as letters, phone messages, e-mails, and texts, by and between anyone involved in the case. DO NOT keep any correspondence between you and your attorney in this section. Those communications should not be mixed in with the general correspondence - save it for the next tab. If you receive a telephone call from your soon to be ex-spouse, you may want to make a note of the conversation; or, if you confirm the conversation by e-mail, print up the e-mail and keep it in this section. Yes, it's a lot of paper work. But the last thing you want is to be in a meeting trying to remember an e-mail you received and have to go back and search through hundreds of e-mails.



Any and all correspondence between your attorney and you is protected by the Attorney-Client privilege unless you waive that right. Handing a confidential letter to your spouse can waive that right. This section separates these documents from all others to avoid any confusion or mistakes. You may even want to put this section as the last tab, far from the general correspondence section.



In every divorce, decisions come down to "show me the proof". Whether you litigate, mediate, or collaborate, the judge, the mediator, and/or your spouse are going to need to know how much you have paid for various obligations, be it the mortgage on the family residence or your own attorney fees. Again, remember, if you are in a meeting with your professional team, your spouse, and his/her professional team, time is money - you really do not want to spend 5, 10, 15 minutes searching for a receipt and possibly not finding it at all.



You may reach agreements during the process that are not filed with the court. Sometimes, the purpose is to take some time to see if the agreement works for you or if it needs to be adjusted. Keep these in this section so that they are not confused with the agreements that do become court orders. If the agreement does become a court order, you will have the original to compare to the draft of the court order to make sure that they are the same or that your requested changes have been made. This is also a good place to put your collaborative/mediation rights and responsibilities agreement (that is not filed with the court) to refer back to when your mediation or collaborative case becomes more challenging.


Court Documents

Pretty self explanatory, here. Anything that gets filed with the court, will go in this section. You will also include certain documents that do not: some of the financial disclosures (schedule of assets and debts, for example) are not filed with the court, but are on court forms. To avoid confusion, include any court documents that are exchanged with your spouse and/or filed with the court in this section. Keep these in chronological order (by date), with the most recent date on top.



Keep all retainer agreements here: your attorney, the mediator, your coach, the child specialist, and/or the financial specialist retainers.


Financial Disclosures

Any and all documents that the law requires you to disclose. These include your pay stubs, bank statements, credit card statements, tax filings, title documents, appraisals, etc.


Other Documents

Keep any documents that you feel may be useful in your process. These can include medical reports, employment rejection letters, notice of layoff, credit reports, and the like.