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Old 11-08-2017, 08:28 PM
Doctor Martins Doctor Martins is offline
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Quote:
Originally Posted by OrleansLawyer View Post
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.
Thanks.. Im still figuring out what a factum is and haven't seen a good sample. The one on the link that was posted here didnt work. In either case its an evolving document in that Its kind of the rough sketch for my thought process and arguments.. even when it comes to talking to OCL etc. Appreciate the feedback! Thats why I posted it.. I have a lot of work to do to understand a factum and how to enter it. The Applicant Mother is self represented.. if you think I'm bad she's far worse, her Affidavits are just basically a bunch of made up irrelevant stuff or talking about who I've dated etc.. but she often gets advice from duty council etc. So its possible they may instruct her on getting stuff struck down. Either way I just want to keep learning and evolving my case both on paper and in how I think about it. I can be quick on my feet if I know what my objectives are and my arguments.. So even writing things out helps my mental process.

To the other poster, yes in general I always aim to to say "our daughter"
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