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Old 04-03-2013, 10:22 PM
involveddad75 involveddad75 is offline
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Join Date: Jan 2013
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involveddad75 will become famous soon enough

Remember include all financial statement, all orders, all endorsements, all 35.1

This way you can question the other side as to how things have changed during the proceedings and how and why their views have changed. Such as parenting plans.

I would go to Staples and buy the binder dividers they have ones that go up to 50 tabs package 1 is 1-25 package 2 is 26-50

With regard to video and audio, burn it on cd or dvd and place it in the document brief in a cd holder again 4 copies.

When it gets to opening statements you can serve it with the trial management brief, or in the document brief.

When writing the opening statement, start with the closing statement as if you have presented the perfect case, state what you have proved to the courts, or shown the courts or remind the courts what has happened. The use that as a template for the opening statement.
You honor will hear about, I will demonstrate, I plan to show.

opening statement / closing statement should be less than 5 pages and or 5 minutes.
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