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Text Box:  

                                                                                                                                                                               

   

Text Box:  

30445 Northwester Highway, Suite 230, Farmington Hills, MI 48334/248-737-8410 phone/1-866-728-4718 fax, christopherkohler@kohlerlaw.net

The Law Offices of Christopher P. Kohler, P.C.Text Box: "Your Michigan Divorce Lawyers!"

 

Trial Preparation...

Testimony Interview

The following is a very good approximation of the kinds of questions you will be asked either at a deposition or a trial.  As with the other pages in site, please take the time to complete this form in its entirety.  If the particular question asked doesn't apply to you, then simply enter "not applicable".  There are questions after the section regarding children at the end of the form, so don't stop once you have reached the children's section.  Also, you must complete this form in one sitting.  Otherwise, the form will reset, and you will have to begin again.  Some of the information requested here you have already provided, either during our initial office visit, or in other parts of the form.  I need you to provide the information again nonetheless.  I apologize for the redundancy, but you are still saving time and money by giving it to me over the internet.  Also, I need you to be as descriptive as possible.  At this stage there is no such thing as too much information.  Dates, specific events, and other witnesses to said events are especially helpful.   As always, should you have any questions, comments or concerns, please don't hesitate to contact me.    Office number:  248-737-8410.

 

 What is your name for the record?
 

How old are you?
 

Are you the Plaintiff or Defendant in the current action?
 

What is your relationship to the opposing party?
 

How long known opposing party?
 

What was the date of marriage/or date your relationship with the opposing party began?
 

Did you own any real property at the time of the marriage?
 

When was this property purchased?
 

What was the purchase price?
 

How was the property purchased?
 

What was the purchase amount?
 

If you put any money down, what was the payment amount?
 

What was the source of the down payment?
 

How long have you owned said property?
 

If this property was sold, what was the date of sale?
 

Did the date of sale occur after your marriage to the opposing party?
 

Who was responsible for the mortgage payment on this property?
 

Who was responsible for the property taxes on this property?
 

Who was responsible for the utilities taxes on this property?
 

Were there any improvements to the property?
 

Who paid for the improvements, how were they paid for?
 

What was the selling price of the property?
 

Did you net any equity at the time of the sale?
 

What happened to equity?
 

Did you own any other property at the time of the marriage?
 

How much was your 401(k) worth at the time of your marriage?
 

How much was your mutual fund worth at the time of your marriage?
 

How much was your pension worth at the time of your marriage?
 

How much was your IRA worth at the time of your marriage?
 

Did you own any bank accounts time of your marriage?  If so, who were they with and what were the balances?
 

Did you own any equities at the time of your marriage?  If so, who were they with and what were the balances?
 

Did you own any mutual funds at the time of your marriage?  If so, who were they with and what were the balances?
 

What was your education at the time of your marriage?  Please include the name of the institution graduated from, the degree earned and the year recieved.
 

Describe your employment at the time of your marriage?  Please include the name of your employer at the time.
 

position with company
 

gross pay time of marriage
 

Summary your employment history during the marriage, include employers worked for, positions held, and money earned per position.  Also, please indicate why employment was terminated, i.e., you were fired, you quit etc.  Include the reasons for moving on as well.
 

Current employment
 

Current employment gross pay
 

Other benefits current employment:  include medical, retirement assets, frequent flyer miles, etc.
 

IF you own the marital home, when was it purchased?
 

How was the marital home purchased?  i.e., mortgage, land contract?
 

Who is mortgage lender or creditor who has a lien against the property?
 

Balance marital mortgage?
 

Marital home mortgage payment?
 

Interest-rate marital home mortgage?
 

Who makes payments marital home mortgage?
 

Who is responsible for the marital home property taxes?
 

Who is responsible for the marital home utilities?
 

 

If your case does not involve minor children, please answer any questions pertaining to children with "not applicable"  However, I need to have the fields filled in for the form to save properly.


If you have children, how many?
 

names and ages
 

Where have the children resided during the marriage?
 

Please describe how you have helped with nutrition and seeing to it that the children are well fed.
 

Please describe the measures you have taken to develop a strong bond with the children.
 

Please describe how you help the children to solve problems they might have.
 

Please describe how you celebrate a triumph the children might have.
 

Please describe the typical amount of time you spend with the children during the week or on the weekend.  Be specific in terms of what is done during that time.
 

Please describe how you place the child's interests before your own, especially in the context of cooperating with the opposing party, or inviting them to cooperate, to work with you as a team in dealing with the children.
 

Please describe how you demonstrate and show the children you love them.
 

Please describe how you bathe the children, that is what is the routine, if they are too young to bathe themselves.
 

Please describe how you have taken care of the children when they have had illnesses.  Include trips to the doctor's and prescriptions filling as well.
 

Please describe how you have guided the children's academic progress in school.
 

Please describe how you have participated with the children's extracurricular activities.
 

Please describe who takes a leading role when it comes to disciplining the children.
 

Please describe your philosophy when it comes to disciplining children.  How do put this philosophy into practice?
 

Please describe how your extended family gives your support or participates with the minor children.
 

Please describe how you make necessary purchases for the needs of the children.
 

Please describe how you attend to any special needs that the children may have.
 

Please describe your current earning capacity, the potential for that earning capacity to increase, and how this compares to the opposing party?
 

Please describe what your current work schedule is.  How likely is it to modification?  How much control do you have over it?  How does this compare to the opposing party?
 

What steps have you taken to insure that the children will have the benefit of your income for support in the future?  ie, life insurances policies, educational trusts, etc.
 

Please describe your ability to provide medical and life insurance.  How does this compare to the opposing party?
 

Please describe your efforts to better educate yourself as a parent.
 

Please describe the times you have taken the children for medical appointments.  If you have not done so already, I need the names and numbers of their treating physicians in the witness list page of the database.
 

Please describe how you have taken the children for dental appointments.  If you have not done so already, I need the names and numbers of their dentists in the witness list page of the database.
 

Please describe how you have arranged for and provided childcare when it has been required.  How does this compare to the other party?
 

Please describe how you have taken steps to provide a secure and stable environment for the children.  How does this compare to the opposing party?

Please describe how you have taken steps to provide the children with continuity in their lives.  Include career choices, choices regarding where you live, ie school districts, choices of doctors, babysitters, healthcare etc.
 

Please describe how you have taken steps to provide a good moral foundation for the children.  Include efforts to introduce them or raise them in a particular faith.
 

Please describe your total physical, mental and emotional health.  How does this compare with the opposing party?
 

Please describe how you have taken the initiative regarding the children's academic progress?  ie, providing them with books from a young age, educational toys, limited tv, etc.
 

Please describe how you have taken the initiative regarding the children's involvement with extracurricular activities. ie, music lessons, sports, scouting, etc.
 

How involved have you been with school conferences and meetings?
 

Please describe how you have provided the children with opportunities to learn responsibility and money management?  ie, chores around the house, living on an allowance, opening bank accts, etc.
 

Please describe how you have assisted the children with their school work?
 

Please describe how you have cooperated with the opposing party with regards to the children?  What suggestions would you have for working effectively together after the case is over with regarding issues like scheduling visitation and making other decisions involving the children?
 

Please describe any incidences of arguments in front of the children.  What steps did you take to try and diffuse the situation?
 

Please describe any incidents of domestic violence occurring in the presence of the minor children (which means in the house when they were present in the house, regardless if they were in the same room or not)  Were there any injuries?  Were the police called?  Any PPO's filed and/or granted?  Any criminal charges filed?  Besides the children, were there any other witnesses the these events.  For all of the follow up questions, please provide details as to case numbers, names and numbers of individuals and any other specifics you can think of.  I also need approximate dates for these events as well.
 

Please describe how the children have expressed a preference regarding where they wish to live.  Why do you think they have the particular preference?  If interviewed by the judge, are you confident that they would express the same preference?  Why or why not?
 

Please describe how you intent to provide, or continue to provide religious training for the children.
 

Please describe what your suggested custodial/visitation arrangement is.
 

Please describe how you have cooperated with the opposing party during the case with regards to custodial and visitation issues.
 

Please describe your current work schedule.
 

Please describe the opposing parties work schedule.
 

Please describe how long after the divorce is final you plan on waiting before exposing the children to a significant other.
 

Please describe how you would characterize the history of the marriage?  Be specific with examples.
 

Please describe how you would characterize the history of the marriage with regards to money decisions.
 

Please describe how you would characterize the history of the marriage with regards to household labor.
 

Please describe how you would characterize the history of the marriage with regards to bill payment.
 

 

Please describe how you would characterize the history of the marriage with regards to household maintenance or improvements.


 

Please describe how you would characterize the history of the marriage with regards to decisions pertaining to childrearing.
 

Please describe how you would characterize the history of the marriage with regards to socializing with other people.
 

Please describe how you would characterize the history of the marriage with regards to effects of extended family of either party.  Have they been a positive or negative influence on the marriage?


 

Please describe how you would characterize the history of the marriage with regards to infidelity.
 

Please describe how you would characterize the history of the marriage with regards to alcohol substance abuse.
 

Please describe how you would characterize the history of the marriage with regards to domestic violence.
 

Please describe how you would characterize the history of the marriage with regards to emotional psychological abuse.
 

What evidence is there that could help you to prove the answers to the above questions?
 

Please describe how you would characterize the history of the marriage with regards to opposing party hiding or abusing assets.


 

Please describe how you would characterize the history of the marriage with regards to criminal activity.
 

Please describe how you would characterize the history of the marriage with regards to any other issues you feel to be important but were not listed here.
 

Have either you or the opposing party furthered your education during the marriage?  If so, with what institution, and what kind of a degree?
 

How was this additional education paid for?
 

 

 

 

 

 

 

The information provided in this site is purely informational and not intended to, nor should it be construed as, legal advice.  Anyone having a question concerning the law and his rights or remedies there-under should contact an attorney competent to render legal advice within the jurisdiction in which he resides.  Transmission to the viewer of this website and the viewer's receipt of any information through the site is not intended to, nor does it create, an attorney/client relationship with The Law Offices of Christopher Kohler, P.C..  This includes, but is not limited to, the transmission of an e-mail message to or from Attorney Kohler.  No attorney/client relationship shall exist unless and until the facts, circumstances and legal issues of a particular matter have been thoroughly discussed with Attorney Kohler and a written Attorney Fee Agreement has been fully executed by and between Attorney Kohler and the person seeking to enter into an attorney/client relationship with Kohler & Associates, P.C.

Your Michigan Divorce Lawyer serving:  Lake Orion, Michigan. Your Michigan Divorce Lawyer serving: West Bloomfield, Michigan. Your Michigan Divorce Lawyer serving: Farmington Hills, Michigan.Your Michigan Divorce Lawyer serving: Orchard Lake, Michigan.Your Michigan Divorce Lawyer serving: Waterford, Michigan. Your Michigan Divorce Lawyer serving: Pontiac, Michigan.Your Michigan Divorce Lawyers serving:  Keego Harbor, Michigan.Your Michigan Divorce Lawyer serving:  Holly, Michigan.Your Michigan Divorce Lawyer serving: Mt. Clemens, Michigan. Your Michigan Divorce Lawyer serving:  Monroe, Michigan.Your Michigan Divorce Lawyer serving:  Bloomfield Hills, Michigan.Your Michigan Divorce Lawyer serving:  Birmingham, Michigan.Your Michigan Divorce Lawyer serving: Southfield, Michigan.Your Michigan Divorce Lawyer serving: Walled Lake, Michigan.Your Michigan Divorce Lawyer serving:  Milford, Michigan.Your Michigan Divorce Lawyer serving: Trenton, Michigan.Your Michigan Divorce Lawyer serving: Wayne, Michigan.Your Michigan Divorce Lawyer serving:  Redford, Michigan.Your Michigan Divorce Lawyer serving:  Troy, Michigan.Your Michigan Divorce Lawyer serving:  Rochester Hills, Michigan.Your Michigan Divorce Lawyer serving:  Harrison Township, Michigan.Your Michigan Divorce Lawyer serving:  Oakwood, Michigan.Your Michigan Divorce Lawyer serving:  Ortonville,  Michigan.Your Michigan Divorce Lawyer serving:  Clarkston, Michigan.Your Michigan Divorce Lawyer serving:  Oxford, Michigan. Your Michigan Divorce Lawyer serving:  Clawson, Michigan.Your Michigan Divorce Lawyer serving:  Salem, Michigan.Your Michigan Divorce Lawyer serving:  New Hudson, Michigan.Your Michigan Divorce Lawyer serving:  Seven Harbors, Michigan.Your Michigan Divorce Lawyer serving:  Wolverine Lake, Michigan.Your Michigan Divorce Lawyer serving:  Oxbow, Michigan.Your Michigan Divorce Lawyer serving:  Hartland, Michigan.Your Michigan Divorce Lawyer serving:  Leonard, Michigan.Your Michigan Divorce Lawyer serving:  Lakeville, Michigan.

Christopher P. Kohler
Copyright © 2006; All rights reserved.
Revised: August 26, 2008