Modified Cooperative Divorce

"Three Steps To Success"

STEP 1 "The Easy Stuff/Getting Your Ducks in a Row"(0-60 days):

  • Schedule first Mediation date - 60 days out
  • Discuss "Temporary" matters during this time (e.g. Home Possession, Alimony, Child Support, Payment of Household Expenses, etc.)
  • Draft proposed "Parenting Plans", "Equitable Distribution Schedules", "Child Support Guidelines" and "Alimony Cash Flow Analysis" for Mediation
  • Do not complete Certificate of Compliance with Mandatory Disclosure yet
  • Complete Parenting Class early
  • Identify need for "Family Counseling" or "Individual Therapy"
  • Discuss the appointment of a "Parent Coordinator", "Guardian Ad Litem" or "Joint CPA"
  • Require Parties to sign up for and use "Our Family Wizard" or "Talking Parents"
  • Order "Appraisals" of the Home or of "Personal Property" as well as "Pension & Retirement" valuations
  • Do not schedule Depositions or start Discovery Process (Requests for Production or Interrogatories)
  • Attend First Private Mediation date (If Impasse, go to Step 2)

STEP 2 "Time for Transparency/There is Still Hope" (60-120 days):

  • Schedule second Mediation date - 60 days out
  • Engage a "Parent Coordinator" to help Parties create "Parenting Plans" and "Time-Sharing Schedules"
  • Enroll and participate in "Family Counseling" or "Individual Therapy" as needed
  • Engage "Joint CPA" to inventory and create "List" of Missing Documents for second Mediation
  • Do not complete Certificate of Compliance with Mandatory Disclosure yet
  • Schedule "Depositions of the Parties" - not to exceed two (2) hours max
  • Obtain "Appraisal & Valuation Reports" from Experts
  • Revise and update "Equitable Distribution Schedules", "Child Support Guidelines" and "Alimony Cash Flow Analysis" for second Mediation
  • Attend first "Case Management Conference" - Ask Court for second "CMC" another 60 days out
  • Check to see if "Temporary Support" is being paid
  • Do not file any Motions for Contempt or Requests for Production or Interrogatories yet
  • Produce "Missing" documents before second Mediation
  • Attend second Private Mediation (If Impasse, go to Step 3)

STEP 3 "The Heat is On/Start Your Engines"(120-180 days):

  • Schedule third Mediation date - 60 days out
  • Engage a "Guardian Ad Litem" to start Evaluation process & make "Temporary" or "Final" recommendations on ALL co-parenting matters
  • Continue to work with "Parent Coordinator" and update "Parenting Plans" and 'Time-Sharing Schedules"
  • Receive updates from "Counselors" and "Therapists"
  • Have "Joint CPA" start drafting Certificate of Compliance with Mandatory Disclosure and updated "List" of Missing Documents
  • Revise and update "Equitable Distribution Schedules", "Child Support Guidelines" and "Alimony Cash Flow Analysis" for third Mediation
  • Attend second "Case Management Conference" - Ask Court for third "CMC" another 60 days out - at which time a Trial date will be scheduled
  • Check to see if "Temporary Support" is being paid
  • Do not file any Motions for Contempt or Requests for Production or Interrogatories yet
  • Start preparation of "Collateral Witness List"
  • Receive "Temporary Recommendation" from Guardian ad Litem or Parent Coordinator prior to Mediation
  • Attend third Private Mediation (If Impasse, ask Court to Schedule matter for Trial)