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California Divorce and Family Law Discovery Sample Forms and Exemplars

California Divorce and Family Law Discovery Form Exemplar and Sample Library

First, I have a number of Blogs in our EnlightenedDivorceBlog™ library that you should read if you are seriously and intelligently attempting to get the information that is critical to your case, or is sorely being denied you by the other side, as a preliminary study of how to use the exemplars that I provide below. Our Blog is broken out into categories and I admit there is so much information I've written over these years that it is hard for me to manage it all as efficiently as I would like. Our on-board search engine will be of use to you.

Second, the work product that I've drafted over the course of many hundreds of cases is specific to those cases and you will need to adapt it to your issues. While this is not "one size fits all," I do try to provide exemplars that will cover what you need in terms of the basics. If you are not an attorney, you really do have to spend dozens of hours educating yourself, but I promise I've spent many hundreds of hours trying to make family law and family law litigation samples and exemplars available to you - so we are all suffering together -:).

  • Family Law Form Interrogatories

This is easy - there is a judicial council form FL-145 that you simply need to complete the caption on and send out. You should do this within the first 60 days of filing, or being served with, a Petition for Dissolution or Legal Separation. You are also entitled to use it in post-judgment RFO's to modify existing orders, but usually you will not have enough time to serve them and get responses before your hearing date. In post-judgment proceedings, or where there is a hearing pending within 60 days or less, you might still use these but chances are that the other side will stall or game you so that you don't receive the responses early enough for them to be useful. Remember, if you mail them this adds five days to the due date for a response, but also you cannot personally serve them on the other party yourself. You must use a process server or a credible friend instead.

  • Family Law Special Interrogatories

Other than by deposition, family law special interrogatories are hands-down the best way to get information or as a vehicle for limiting the other side from coming up with new stories later on in the litigation, but they must be adroitly written in order to be effective and may require a motion to compel further responses if you get bullshit responses. I provide (or will be) a series of exemplars for every critical aspect of a divorce or family law related case, including custodial disputes as I can crank it out.

  • Family Law Demands for Production

Demands for production of documents or things (i.e., photos) are likewise critically valuable in obtaining information that you, presumably as the "out-spouse," don't have. I will be providing you a series of versions directed to common property, income and related issues but until I do I've written some pretty detailed blogs on the subject that you should now read and consider.

At times, the only way you are going to get back onto real property or into the family home to do an inspection, or to allow your appraiser to do so, is through a formal request for inspection. Here is a simple sample form that you might use as a template.

  • Family Law Requests for Admission

Requests for Admission also utilize a judicial council form, the DISC-020, but they require that you actually draft the facts or identify the truth of the nature of the items that you are seeking have unequivocally and conclusively admitted. I will be providing samples. They should always be accompanied by the judicial council "form interrogatories-general" form DISC-001 with the appropriate boxes checked, and especially number 17.1. Always be sure to check the "definitions" box at page two of that form (i.e., "the pending dissolution" or "support proceeding") along with number 1.1. The beauty of Requests for Admission ("RFA's") is that any fact, or genuineness of a document, that is admitted it completely binding on the other party - but perhaps more importantly, since often they will be denied without a genuine basis to do so, if you use the civil general form interrogatories along with it, the responding party MUST identify each fact that supports their denial, all writings that support denial, and all witnesses they would call to at trial to refute the RFA. It is a powerful set up for liars, and is especially useful in setting up attorney fee and sanctions requests!

Here is a simple sanitized example of divorce related Requests for Admission addressing the types of questions that might be posed, together with the required declaration in the event the number of RFAs exceed 35. I will come back and provide a more specific exemplar in time.

  • Party and Witness Notices of Deposition and Demands for Production
  • Subpoenas and Notices to Appear and Produce Documents at Evidentiary Hearings, RFO's, and Trials


Testimonials & Endorsements

  • “Not only is Mr. Peterson’s knowledge of the law beyond measure, he’s able to articulate it so it’s understandable.”
    If you are going through a divorce, The Law Offices of Arnold, Peterson & Criste is in my opinion the best option available. Mr. Peterson and his assistant Jordyn are top notch. Not only is Mr. Peterson’s knowledge of the law beyond measure, he’s able to articulate it so it’s understandable. He was able to navigate my emotions and help my uphill battle to receive proper visitation as a father. Jordyn never hesitated to reach out within the same business day if documents were needed or for any question I had about the process. Thanks to the team, we resolved the divorce healthfully. I couldn’t be more grateful.
    - Josh Arguijo
  • “I needed the best analysis and advice possible. I found Attorney Thurman Arnold III in Palm Springs.”
    I am a Veteran and Retired Deputy Sheriff. My divorce involved complicated property distribution and spousal support issues. I spent considerable time looking for the best Counsel I could find before I negotiated with my ex-wife and her Attorney. In fact, my case was in another county, but that didn't matter. I needed the best analysis and advice possible. I found Attorney Thurman Arnold III in Palm Springs. Attorney Arnold is a BAR Certified Family Law Specialist. In my humble opinion the best! His review of my case and how "Moore Marsden" property division applied was invaluable. His guidance saved me $30,000 dollars. Thank you, Thurman!
    - Jeff Jones
  • “Mike is adept at managing expectations and being very fair and measured.”
    Needed to modify a settlement and hired Mike Peterson. Mike is very, very knowledgeable and experienced. When you are going through a divorce or child custody issues, it is the most terrifying and stressful experience. Mike is adept at managing expectations and being very fair and measured. I wish I had hired him initially to get it all done straight the first time around. He is very responsive and communicative and understands the client well. Good luck going through this process - have a good guide like Mike without a doubt.
    - Donika McKelvie
  • “I would highly recommend him and the firm”
    Micheal Peterson is very knowledgeable of law and can help you make the best decisions for your family. He does is job with integrity. He helps with giving discounts when he can . I would highly recommend him and the firm . Very good staff .
    - Vincent Hall
  • “Very professional, honest, and handled everything without a hiccup.”
    Arnold, Peterson & Criste are a class act. Very professional, honest, and handled everything without a hiccup. When a year had passed, he and Jordyn contacted me to let me know I still had retainer on the books! I had forgot and they sent me the money anyway! For this I am very grateful and cannot recommend them enough. You won’t go wrong with Thurman Arnold. He is definitely the guy to have on your side.
    - Matt Feenstra
  • “Simply the Best of the Best!!!”
    I Highly Recommend Michael C. Peterson at the Law Office of Thurman W. Arnold!!! I hired Michael for my custody case and he is very knowledgeable and took the time to educate me on the process so we can put together a winning strategy. He fought for me and my children in court and successfully won our case. There are no words to describe how grateful and appreciative I am for Michaels service!!! If you are sitting on the fence on which Attorney to hire, do yourself a favor and hire Michael. I would not recommend anyone else!!! Simply the Best of the Best!!!
    - John and Lukes Tube
  • “Mike amazes me by his knowledge of my case, made me feel like I was his only client.”

    I reached out to this law firm 2 years ago when my life was falling apart. My case was assigned to attorney Michael Peterson. I didn't know much about him except few reviews on google but I'm glad I hit the jackpot. Mike amazes me by his knowledge of my case, made me feel like I was his only client. He's very responsive, respectful and and goes above and…

    - Damaris M.
  • “He and Michael Peterson are truly masters of their craft.”
    When my clients have family law issues, I routinely refer them to Thurman Arnold. He and Michael Peterson are truly masters of their craft. Family law can be an unwieldy beast, but they handle it with precision and finesse.
    - Edward Cross

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