Family & Juvenile Law Section “Top 10’s”

Top 10 Things To Do If You Represent The Party Seeking PL Alimony
By: Ronald B. Bergman
Houlon, Berman, Bergman, Finci, Levenstein & Skok, LLC

  1. Prepare an accurate Long Form Financial Statement. Identify what items the other party is paying directly.
  2. Gather documentation for necessity and reasonableness of client's expenses for the past two (2) years.
  3. File suit or counter claim as soon as possible and request that an expedited Scheduling Conference and PL Hearing be set.
  4. File discovery requests along with the complaint/counter compliant.
  5. Schedule the other party's deposition in advance of the PL Hearing, if necessary, to determine accurate income as well as reasonable and necessary expenses.
  6. Secure and prepare expert witnesses to testify regarding the need for counsel fees, suit fees, including expert witnesses.
  7. Gather evidence as to the financial resources and needs of the parties to support testimony for suit fees and other expenses.
  8. Gather evidence regarding normal 'lifestyle' expenses prior to separation and prepare to argue against expense reduction arguments.
  9. If client is not employed, begin working with a vocational expert, or if disabled, gather appropriate records.
  10. Have expert testify about taxable consequences of alimony.