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Old 11-08-2017, 08:03 PM
OrleansLawyer OrleansLawyer is offline
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What started as a reply in terms of a Affidavit quickly changed as I started adding in case law, which I know you don't recommend. And then I added a table of contents etc. Its almost become a factum but isnt.
1 - If the other side is smart about it, the start of the motion will involve all of your submissions-in-the-affidavit being struck. They are not evidence. Example in paragraph 9: "As a result of jurisprudence the threshold to deny 50/50 shared parenting is very high." That is not evidence.

2 - Why are you making an affidavit into "a factum but isnt"? Swear your affidavit for your evidence and then prepare a factum.

3 - You are not limited to only a certain number of paragraphs. Putting text in large blocks is an unsubtle way of asking the judge not to bother reading it. Break it up with spacing and paragraphs! Good work with the headers.

Last edited by OrleansLawyer; 11-08-2017 at 08:06 PM. Reason: edit: #3
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