An evasive or incomplete answer is to be treated as a failure to answer

Posted Monday, October 14th, 2019 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys

I find it curious that attorneys routinely treat incomplete or evasive discovery responses as no big deal. From my reading, Rule 37(a)(3), SCRCP, could not

The guardian’s questionnaire is additional interrogatories

Posted Tuesday, September 17th, 2019 by Gregory Forman
Filed under Child Custody, Guardians Ad Litem, Litigation Strategy, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys, South Carolina Specific

While not thought of as such, the guardian’s questionnaire is akin to additional (child-custody related) interrogatories. As an example, the current questionnaire of a local

Does your work product convey seriousness?

Posted Sunday, September 15th, 2019 by Gregory Forman
Filed under Law Practice Management, Litigation Strategy, Not South Carolina Specific, Of Interest to Family Law Attorneys

With every litigation both parties have the options of settlement or trial. One factor in deciding whether and on what terms to settle is how

The pitfalls of boilerplate supplemental interrogatories

Posted Saturday, September 14th, 2019 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys

I’m shocked how often I encounter supplemental interrogatories in family court in which the issuing attorney has clearly given no thought into how interrogatories might

Wives can pay alimony too

Posted Friday, September 13th, 2019 by Gregory Forman
Filed under Alimony/Spousal Support, Litigation Strategy, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys, Of Interest to General Public, South Carolina Specific

When I first began practicing family law twenty-five years ago it was almost unheard of for South Carolina wives to be ordered to pay alimony.

Ambiguity in the rules on requests for admissions

Posted Thursday, September 12th, 2019 by Gregory Forman
Filed under Family Court Procedure, Litigation Strategy, Not South Carolina Specific, Of Interest to Family Law Attorneys

There is a clear ambiguity in the South Carolina Rule of Civil Procedure regarding requests for admissions–SCRCP 36. I suspect that many denied requests to

A few big things trump a lot of small things

Posted Wednesday, August 28th, 2019 by Gregory Forman
Filed under Attorney-Client Relations, Litigation Strategy, Not South Carolina Specific, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys

At the very beginning of any new domestic client relationship the attorney and client need to discuss the client’s goal, discuss the law related to

Don’t forget rebuttal

Posted Wednesday, June 26th, 2019 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Law Attorneys

One of the biggest mistakes I see my family court colleagues making is forgoing the opportunity to present rebuttal (sometimes called reply) testimony. Rebuttal is

What are you communicating with your proposed parenting plan?

Posted Thursday, January 31st, 2019 by Gregory Forman
Filed under Child Custody, Litigation Strategy, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys, South Carolina Specific

In 2012, South Carolina revised its child custody statutes and added a provision requiring proposed parenting plans at temporary hearings. This parenting plan asks each

The most obvious malpractice there is in South Carolina family law

Posted Thursday, January 17th, 2019 by Gregory Forman
Filed under Litigation Strategy, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys, South Carolina Specific

About five years ago–after being burned for the umpteenth time by entering a temporary consent order binding my client to a temporary support without first

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