trial for sole legal custody

[livednlearned]

Hi everyone,

I started a thread about trial for sole legal custody, but can't figure out an easy way to find it.

So I'm starting a new thread. Trial is July 17. N/BPDxh is a former trial lawyer, and he is representing himself. I just learned today that he can ask me questions directly while I'm on the witness stand.  :'(

I'm trying to be strong about it, but the truth is I can barely breathe just thinking about it. I used to feel like I was on a permanent witness stand in my marriage because N/BPDxh would interrogate me like I was being prosecuted for crimes all the time. It was awful. He would ask these questions that always trapped me into agreeing with statements I didn't believe, so I know from experience how awful this kind of thing can be. 

I've been in court over custody 3 times now, but each time I managed to hold it together because my L was doing all the talking. They were more procedural than anything, and the Ls (back when N/BPDxh's L was representing him) would settle things between them. This court date is different, because the judge is deciding something -- to determine sole legal custody. It's the one item we were not able to settle in our custody order 2.5 years ago, and a lot has happened in those years to move the needle in my favor. My L says that legally I'm on good footing, although who knows how that will play out in court.

I know this is a bit of a perverse turn, with N/BPDxh being an L, representing himself, and being able to cross-examine me. I guess I just need some moral support, and any words of advice you can all think of. I'm going to need everything you've got.

[egribkb]

Trust in your lawyer. Is this a jury trial?

[Ishenuts]

OMG! I am getting upset for you just thinking about it. My uNPDexH always treated me as if I were on the witness stand, too. Your lawyer can object, especially if he is badgering you. And your L gets to cross examine him, too! So, as ekribkb says, 'TRUST IN YOUR LAWYER!"

I don't know our story but your ex will have to be on his best behavior to avoid looking like he's attacking you. If he can't do that, it might look better for you, and help prove your case.

GOOD LUCK!

[livednlearned]

I do trust my lawyer.

What parts of the trial (not a jury trial) go into the court record?

Honestly, I think N/BPDx knows he is going to lose legal custody. I'm wondering if he is doing this because he wants to paint me black in a permanent, public record. He wants S11 to think I'm awful.

[atcrossroads]

This sounds like a horrible situation.  I know with my own husband, his BPD mother is a big reason why he is so screwed up now (BPD/NPD) himself ... . in my opinion.  I know judges don't usually understand pd's like we do, but clearly it's better for your son to be with you.  You said your husband likely knows he will be losing custody. That leads me to believe he has done some rather heinous things and left a trail behind.  I wouldn't hold back and bring everything forward -- verbal/physical abuse of you and/or children, any substance abuse, patterns of instability, etc.  It sounds like he is pushing you to the wall, so you have no choice but to fight for the best life for your son.

Good luck - glad to hear you have an attorney who seems to understand the full picture.  Let us know how it goes!

[atcrossroads]

This sounds like a horrible situation.  I know with my own husband, his BPD mother is a big reason why he is so screwed up now (BPD/NPD) himself ... . in my opinion.  I know judges don't usually understand pd's like we do, but clearly it's better for your son to be with you.  You said your husband likely knows he will be losing custody. That leads me to believe he has done some rather heinous things and left a trail behind.  I wouldn't hold back and bring everything forward -- verbal/physical abuse of you and/or children, any substance abuse, patterns of instability, etc.  It sounds like he is pushing you to the wall, so you have no choice but to fight for the best life for your son.

Good luck - glad to hear you have an attorney who seems to understand the full picture.  Let us know how it goes!

[ForeverDad]

In my court, all testimony is on the record.  The judge or magistrate states when going on the record and I guess to when going off the record.  Paperwork filed with the court is added to the record.  I've had some previous court recordings transcribed and the transcribing service automatically filed those with the court.  Exhibits may be returned afterward to the side which submitted it, but I'm not sure about that.

Likely your ex will try to subtly intimidate you, pressing your buttons so to speak.  Or ex may count on you keep hushed about certain things, being reluctant to speak about things that might impact his job and income.  Be aware, prepare yourself, be honest but not talkative*, wait a moment before answering in case your lawyer will object and it will likely be fine.  Test of fire.

* My lawyer said his first priority was to sit on his clients so they didn't speak when they should have stayed quiet or should have just answered the minimum Yes, No or I don't remember.

[livednlearned]

Thanks FD.

I'm wondering if I can answer questions with, "The way you have phrased the question, the answer is yes."

For example, in the 40-page discovery/interrogatory he just sent (which he didn't file on time, so my L says the trial can go forward without it), his questions are like this one:

"Admit that the plaintiff (LnL) does not deny the affair(s)."

My L said that almost all of the questions are objectionable, but there are 39 questions and I'm trying to save money, so don't want to waste time and money going over everything. As a result, I'm not sure which ones I'll have to answer, but I'm guessing it's just like the deposition, where you barely answer?

[ForeverDad]

A few decades ago affairs and closet behaviors might have had an impact in court, they were typical weapons in divorces, but today most courts studiously avoid such things.  In most states, no-fault ones, his strategy would be decades out of date and probably meaningless as leverage.  Sort of, "live and let live, parenting behaviors are the focus here, move on to next question".  Today's hot button issues are far different: DV, threat of DV, child abuse or child neglect.

Probably your lawyer could object to such things and the court might sustain them.  So pause before answering, look to your lawyer to see which direction to go.

[catnap]

In my son's sole legal custody hearing everything was on the record.  However, it was not transcribed.  You have to pay for that and it is rather expensive. . .we had it transcribed (around 1k) in preparation for his going back to court to remove her parental rights. 

I believe there is an adage: The lawyer who defends himself has a fool for a client.

[seeking balance]

Everything is typically recorded and like catnap said, you likely will have to pay to have it transcribed.

Practice your mindfulness techniques so you can stay grounded and not react emotionally.  Answer the question that he asks, nothing more - nothing less. 

This will be about facts - the judge will look at facts, not emotional manipulations that your ex may try.  Focus on the facts, rehearse the facts - you are asking for sole custody ... . why?  Focus on those examples, those facts - not emotions.

Trust your attorney to do his job - this is why you paid him.

Overall, remember to breathe 

Good luck!

[livednlearned]

A few decades ago affairs and closet behaviors might have had an impact in court, they were typical weapons in divorces, but today most courts studiously avoid such things.  In most states, no-fault ones, his strategy would be decades out of date and probably meaningless as leverage.  Sort of, "live and let live, parenting behaviors are the focus here, move on to next question".  Today's hot button issues are far different: DV, threat of DV, child abuse or child neglect.

Yeah, not here. I live in one of the old-school states. In my state, there are still Alienation of Affection" laws. But if he wanted to sue me or the "paramour," he had to do it before making a financial settlement. Since there was no affair, and no paramour, it wouldn't have gone anywhere, but he still makes false allegations whenever he gets a chance.

I included the question because of the way it was phrased -- as a double negative. I would have had to admit that I did not deny something. It's the kind of thing he did in the marriage to trap me into admitting something.

[livednlearned]

Thanks SB and catnap,

I'll be breathing like I've never breathed before, and trying to channel mindfulness. I haven't had to face him quite like this since leaving, so I notice my anxiety is back, plus a surprising number of gray hairs 

[livednlearned]

In my son's sole legal custody hearing everything was on the record.  However, it was not transcribed.  You have to pay for that and it is rather expensive. . .we had it transcribed (around 1k) in preparation for his going back to court to remove her parental rights. 

I believe there is an adage: The lawyer who defends himself has a fool for a client.

That's good to know -- that the transcription is optional, and expensive. Did you have it transcribed right away? Or can you wait? In my case, I don't think the case to remove his parental rights is strong, so that's not likely going to happen.

[Ishenuts]

LnL - This court date is to decide only sole legal custody? Where do you stand on physical custody?

[livednlearned]

LnL - This court date is to decide only sole legal custody? Where do you stand on physical custody?

Yes, the court date is to determine sole legal custody only. I have primary physical custody. S12 (his birthday is today!  ) sees N/BPDx from 10-2pm on Sat and 3-7pm on Sundays for visitation. There are other motions filed -- to get him to refinance the house (we're almost a year past the deadline), to transfer the title of my car to me (says so in the order), and to get my legal fees paid because this is all stuff that's clearly spelled out in the order.

He has filed a bunch of stuff -- to get rid of the PC (whom he threatened), to have a psych eval of S12, plus the 40-page interrogatory with 39 questions. Apparently he missed the deadline for filing his stuff, tho. My L said she thinks the judge is going to be a stickler because N/BPDx is an L himself.

[catnap]

That's good to know -- that the transcription is optional, and expensive. Did you have it transcribed right away? Or can you wait? In my case, I don't think the case to remove his parental rights is strong, so that's not likely going to happen.

It was a little over a year after the hearing. 

[GaGrl]

Just because your ex included a question in the deposition doesn't mean you have to answer it in the form asked, especially if you know he has a history of entrapping you into arguments in that way. If you don't answer the deposition questions because he missed the deadline, he will probably ask the same questions in court SO BE PREPARED.

You don't have to answer a trick question. He uses double negatives. You can ask him to clarify - "What are you asking?" Or... . MAKE SURE YOUR LAWYER IS ON HIGH ALERT FOR TRICK QUESTIONS/DOUBLE NEGATVES... . and that you and your L have a strategy. L objects to the form of the question or you ask to clarify.

[Rose Tiger]

As much as I can't stand Vakin, this is an interesting read... .

www.samvak.tripod.com/narcissistincourt.html

I don't know how you could possibly work in any of this but hey, knowledge is power.  

"Question:

How can I expose the lies of the narcissist in a court of law? He acts so convincing!

Answer:

You should distinguish the factual pillar from the psychological pillar of any cross-examination of a narcissist or deposition made by him.

It is essential to be equipped with absolutely unequivocal, first rate, thoroughly authenticated and vouched for information. The reason is that narcissists are superhuman in their capacity to distort reality by offering highly "plausible" alternative scenarios, which fit most of the facts.

It is very easy to "break" a narcissist – even a well-trained and well-prepared one.

Here are a few of the things the narcissist finds devastating:

Any statement or fact, which seems to contradict his inflated perception of his grandiose self.

Any criticism, disagreement, exposure of fake achievements, belittling of "talents and skills" which the narcissist fantasises that he possesses.

Any hint that he is subordinated, subjugated, controlled, owned or dependent upon a third party.

Any description of the narcissist as average and common, indistinguishable from many others.

Any hint that the narcissist is weak, needy, dependent, deficient, slow, not intelligent, naive, gullible, susceptible, not in the know, manipulated, a victim, an average person of mediocre accomplishments.

The narcissist is likely to react with rage to all these and, in an effort to re-establish his fantastic grandiosity, he is likely to expose facts and stratagems he had no conscious intention of exposing.

The narcissist reacts indignantly, with wrath, hatred, aggression, or even overt violence to any infringement of what he perceives to be his natural entitlement.

Narcissists believe that they are so unique and that their lives are of such cosmic significance that others should defer to their needs and cater to their every whim without ado. The narcissist feels entitled to interact or be treated (or questioned) only by unique individuals. He resents being doubted and "ridiculed".

Any insinuation, hint, intimation, or direct declaration that the narcissist is not special at all, that he is average, common, not even sufficiently idiosyncratic to warrant a fleeting interest inflame the narcissist. He holds himself to be omnipotent and omniscient."

[Forward2free]

LNL, I feel anxious for you! I thankfully never had to face my BPD/Nxh in court or as the L in court, but if I did, I would have been terrified.

It is hard to rise above the fear and tell the truth, they know this. For years they had power to control our words, and to a large extent, our actions too. I imagine that he is expecting you to be predictable and he may think that he can put you back in your place, so to speak.

Be cautious about answering, but don't over-think it too much. I like Gargrl's option to ask a question to clarify. It will give you more time to see the nuance behind his tricky question/s.

No doubt, he will be reveling in his vision of being top dog in court, tearing you down, and becoming victorious. It might help to remember that he is performing in there - to the reflection in his mirror, to the judge, to you, to your lawyer and to the public in the court room. Everything he does is about him looking better, more powerful, smooth, slick and like the winner he is trying to portray and ultimately, to win at all costs.

I have seen my own legal professionals, psychologists, psychiatrists, court evaluator's etc, fall to his charms in my case. It's the most gut-wrenching feeling to watch the manipulation. You need to be very well prepared, even if you think you will win.

Read Rose Tigers post and look at ways to get him off balance. I few well placed punches can be more effective to bring someone down than madly hitting with no target or plan. Google "Narcissists in court" and more and become as educated as you can. I know you have already done this, but don't leave anything to chance.

In my case, BPD/Nxh tells his lies more convincingly than the truth, which was my version. I cannot tell you how many times this has come back to bite me. Not being 100% certain of the truth and of his angle against me has left me hanging and I think changed the face of the reports which tell me now that the kids are not at risk.

Most of all, be strong. You CAN do this and you are more strong and more powerful than he ever gave you credit for. His bravado is an act, your's in pure and true in words AND actions. Look how far you have come already!

[Ishenuts]

LnL - "Just the facts, ma'am" I think where they trip us up is when we try to defend ourselves. The more we explain, the more ammunition we give them to make us falter. AND the more verbal twisting they do.

I understand about NPDs being very convincing BUT I think eventually people see through the facade. My L and my T saw through my uNPDexH immediately (and that's why they are my L & T! ) I thought our PC was being fooled, but my L assures me that she "gets it". She told my L "I know what I am up against!. And the therapist that exH and I went to talk to recently about an issue with the children, basically interviewing her as our children's future T, "got him" BIG TIME. So, not everyone is fooled!

Is your lawyer up to the challenge? Maybe share the previous post from Rose Tiger with him/her? They will be your advocates in trying to show what he's really all about. Just get the arrogance out there in open court.

You said one of his motions was to get rid of the Parental Coordinator (I assume that's what you meant by PC?). Will the PC be called to testify? If they were court mandated, the court would probably like to hear about how he threatened them?

Why did you get the list of his questions?

[livednlearned]

As much as I can't stand Vakin, this is an interesting read... .

www.samvak.tripod.com/narcissistincourt.html

Thanks RT. I find SV to be deplorable, but as you point out, his advice is relatively useful given that's the exact situation I'm facing -- N/BPD in court. My L does not think N/BPD can ask all his questions because many are objectionable, but I know he will try to work them in somehow. A friend sent me a TED talk about how important posture is, and I think that's going to be how I hang on during the trial. Just thinking about my posture and the message it conveys will help me draw strength and confidence. I can get tongue-tied so easily under stress  :'( So it will help to focus on something that has nothing to do with speech.

[livednlearned]

LnL - "Just the facts, ma'am" I think where they trip us up is when we try to defend ourselves. The more we explain, the more ammunition we give them to make us falter. AND the more verbal twisting they do.

One thing I've been doing is to tally things -- how many emails he has sent in which he alleges alienation, and the number of instances in which I offer him opportunities to spend more time with S12. Facts! Even if no one checks. N/BPDx has sent over 16,000 emails in 2.5 years -- I can hardly believe it. And there are loads of them demanding that I let S12 communicate, but then emails demanding I not coerce S12 into communicating, and then emails saying that I am hovering to make sure S12 is communicating. Plus emails with the PC in which he says he no longer wants scheduled times to talk to S12 because he wants it to happen "naturally." That makes me feel much stronger just thinking of things in those terms. Over a hundred emails of N/BPDx accusing me of alienating S12, then emails saying he doesn't want the time to be scheduled, doesn't want me interfering, hovering, coercing, and more than 20 times I offer more time and N/BPDx turns it down for one reason or another.

You said one of his motions was to get rid of the Parental Coordinator (I assume that's what you meant by PC?). Will the PC be called to testify? If they were court mandated, the court would probably like to hear about how he threatened them?

The parenting coordinator actually already called a hearing -- she had been threatened by N/BPDx and wanted to know what the judge recommended. The judge basically said, "This is exactly the kind of case that needs a PC." Um, no. It isn't. It's the kind of case where the mom should get sole legal custody.

That's why I'm heading back to court right now. The PC order has expired, and my L does not think there is good cause to renew it. And N/BPDx has filed a motion to have the PC removed. (Finally, we agree on something!)

Why did you get the list of his questions?

He had to file them so he could use them in court. It's part of the discovery, or interrogatory or whatever it's called. He was supposed to file them sometime in June and missed the deadline, and my L said that she thinks the judge is going to hold him to every technical aspect because N/BPDx is an L. The judge will not want N/BPDx to appeal just because the rules weren't followed, so to speak.

So I have a lot of reasons to feel comforted, and I do, but it's still going to be one h3ll of a day in court. I know there is no such thing as winning in these situations, and just the thought of being cross-examined by him makes me feel sick to my stomach.

Thanks for all the good advice and moral support.

[livednlearned]

You need to be very well prepared, even if you think you will win.

Read Rose Tigers post and look at ways to get him off balance. I few well placed punches can be more effective to bring someone down than madly hitting with no target or plan. Google "Narcissists in court" and more and become as educated as you can. I know you have already done this, but don't leave anything to chance.

I really needed to read this, thanks Kormilda. And thanks for your support. It really means a lot coming from people who have been there. I hadn't thought to google "narcissists in court" so thanks for that advice. I'm finding lots of hints that make me feel better prepared.

[ForeverDad]

Appeals are apparently rare.  One reason is that judges prefer settlements which can't be appealed and then make the judge look bad if the case is overturned or remanded back for reconsideration.  Appeals usually don't work unless there's be a technical error, serious failure or somesuch.  Regular family court hearings don't bother much about the holding strictly to the dates, rules and procedures, but trials and appeal cases do.

[livednlearned]

Appeals are apparently rare.  One reason is that judges prefer settlements which can't be appealed and then make the judge look bad if the case is overturned or remanded back for reconsideration.  Appeals usually don't work unless there's be a technical error, serious failure or somesuch.  Regular family court hearings don't bother much about the holding strictly to the dates, rules and procedures, but trials and appeal cases do.

I'm not sure if this counts as a regular family court hearing or a trial -- my attorney is referring to it as a trial and hearing interchangeably.

But she has noticed that the judge is holding N/BPDx to very specific rules and procedures up to this point, and anticipates he is doing it because N/BPDx is an L. I filed in a county that has very high volume. The county where I live has lower volume. I did that at the advice of my L, who said that in the county where I have filed, the judges are much more by the book, and less likely to hear frivolous law suits. So I'm hoping he is a stickler, especially since N/BPDxh is representing himself. It diminishes his effectiveness, in my mind, which is helping me keep the faith that I can get through this.

[Matt]

Thanks FD.

I'm wondering if I can answer questions with, "The way you have phrased the question, the answer is yes."

For example, in the 40-page discovery/interrogatory he just sent (which he didn't file on time, so my L says the trial can go forward without it), his questions are like this one:

"Admit that the plaintiff (LnL) does not deny the affair(s)."

My L said that almost all of the questions are objectionable, but there are 39 questions and I'm trying to save money, so don't want to waste time and money going over everything. As a result, I'm not sure which ones I'll have to answer, but I'm guessing it's just like the deposition, where you barely answer?

Let's talk about questions and answers.

You do not have to answer questions as they are asked.  You can ask for clarification.  You can stop and think.  You can ask your attorney to interrupt - maybe by looking right at him if you have agreed with him in advance that when you do that he should object.

Find out from your attorney what kinds of questions are OK and not OK.  You can't object but if you are uncomfortable with a question you can hesitate and look at your attorney to signal to him, "Please object - I think this question is unfair."

So... .

He says, "Admit that the plaintiff does not deny the affair."  This is not a question, so you do not have to answer it.  You can look at your attorney, and he should object, and the objection should be sustained.  Anything that is not a question, you don't have to answer in any way.

"Admit that... . " is an order or command, not a question.  You are not the other party's slave - you don't need to follow his orders.  If he gives you an order, you don't need to respond in any way.  You don't have to say "No, I won't admit that." - you can just say nothing and look at your attorney or even at the judge, and wait for them to speak up.  "Mr. stbX, you must ask the witness questions and she will answer them."

I'm not an attorney but I have testified under oath a few times.  I was told to listen carefully to each question, and if I'm not 100% clear about what was asked, ask for clarification.  If I'm sure about the question, and the answer is "Yes.", then say "Yes." and stop.  Or "No.", or "I don't know."

Finally, if the question is clear but twisted - that is, if it contains an assumption - there is a way to handle that.  First, you have to recognize what he is doing.  Say he asks, ":)o you still beat your wife?" - a classic example of an unfair question, because if you say "Yes" or "No", either way, it sounds like you are admitting that you previously beat your wife.

The way to handle a question like this is to open it up and expose the hidden assumption.  He says, ":)o you still beat your wife?" which contains the hidden assumption, "I used to beat my wife." plus the question ":)o you still do that?".  You respond to the hidden assumption first:  "I have never beat my wife." and then stop.  He may then re-phrase it as, ":)o you currently beat your wife?" and you answer truthfully, "No."

So... . listen carefully to each question, and decide for yourself if it is clear and fair, and handle it accordingly.  Don't respond til you have decided it's right to respond, because you can't take back what you have said.

Are there any other types of questions you are concerned about?  Any other examples from the past or from the interrogatories?

[livednlearned]

Are there any other types of questions you are concerned about?  Any other examples from the past or from the interrogatories?

Here is part of the interrogatory -- I had to copy and paste from a .pdf and the formatting and spelling went a bit wacky. This isn't all of it, just enough to give you a sense of what he's doing. I agree with my L that this just looks crazy, the sheer volume and the nature of the questions. Much of it is objectionable, but I think he'll try to ask these questions anyway. Not sure I have to emphasize this here with all of you, but I never had an affair. Which makes all of this that much more crazy. It's emotional reasoning run amok.

Admit that Plaintiff did not sign the Parenting Coordinator Consent Order (PC Order), which was agreed to in Date Year to Date Year,

Admit that the PC Order was agreed to because Plaintiff refused to agree to joint legal custody with Defendant for the minor child.

Admit that at her deposition, Plaintiff couid not identify one circumstance where Defendant did not cooperate with Plaintiff making parenting decisions.

Admit that Plaintiff has refused io cooperate with Defendant since the beginning of the separation, and that her continued refusal has endangered the minor child. 

Admit that Plaintiff continues to make unilateral decisions regarding the minor child, such as an application to Private School, without informing Defendant until after the process was underway, and with unreasonably short notice.

Admit that although Defendant expressed concern about Plaintiffs unlateral action, he attended the interview at Private School.

Admit that Defendant made repeated requests for  to sign the PC Order and increased his requests in Month Month Month Month, Year, and Plaintiff did not respond to Defendant or act to sign the PC Order.

Admit that prior to Date Year, Defendant offered to go to marriage and family counseling with Plaintiff “any time and any place" and Plaintiff declined.

Admit that on Date Year Defendant repeated his offer to go to joint counseling with Plaintiff, through Plaintiffs attorney, and Plaintiff declined.

Admit that Plaintiff was assured that the PC would advocate for Plaintiff as an inducement for Plaintiff to sign the PC Order.

Admit refusing to answer Defendants questions directly reiated to the minor child's well-being,  and safety.

Admit that the list of questions, attached as Exhibit X, were forwarded to Plaintiff through Defendants attorney, after Plaintiff complained about Defendant contacting her.

Admit that Plaintiff did not fuily respond to the questions.

Admit that copied her attorneys on her ìncomplete responses.

Admit that in Date Year, Plaintiff withheld information about the minor child's health and conditions at school and, after Defendant picked up minor child at school, Plaintiff exchanged emails with Defendant under false pretenses. 

Admit that on Date Year Plaintiff refused to pick up minor chiid when Defendant's car was in the garage, Exhibit 6.

Admit that Plaìntiff has refused Defendant's requests to take the minor child to have his eyeglasses repaired, and when Defendant attempted to, Plaintiff gave Defendant misinformation about the Optometrist, preventing Defendant from having the eyeglasses repaired. Exhibit 7.

Admit that that Defendant accepted custody of minor child from Date Year to Date Year when minor child was scheduled to be with Plaintiff, and Date Year, while Plaintiff took a persona! vacation and refused to tell Defendant where she was. Exhibit 8.

Regarding the allegation in Plaintiffs Motion For Contempt and Motion To Suspend Visitation and Motion For Mental Examination Of Defendant (Motion):

Admit that the minor child did not state to Plaintiff or any individual he was up all night

Admit that the minor child did not state to Plaintiff or any individual that he was practicing what to say

Admit that the minor child did not state to Piaintift or any individual that Defendant asked minor child for his baseball bat to use on the Plaintiff.

Admit that the minor child told Plaintiff that he slept through the night on Date Year

Admit that the minor child did not state to Plaintiff or any other individual he was afraid of Defendant as stated in paragraph XX of Plaintiffs Motion, except at the direction of Plaintiff.

Admit that Defendant expressed his emotional pain in the series of messages on Date Year, that he finaîly deduced Plaintiffs affair and Plaintiffs use of minor child in deception.

Admit that Pìaintiff did not deny the affair(s).

Admit that Defendant gave notice to Plaintiff that he was going to inform the minor child of his suspicions about Plaintiffs affair and Plaintiff did not respond to the notice.

Admit that Defendant informed Plaintiff that his sole purpose for telling the minor child of

Defendants suspicions was to allow the minor child to address the issue in therapy and heal the emotional and psychological damage caused by Plaintiffs involvement of the minor child.

Admit that the date and time of the Date Year emal referred to in paragraph 19 of Plaintiffs Motion is inconsistent with the timing of the allegations in paragraphs XX of Plaintiffs Motion.

Admit that Plaintiff did not tell the minor child's therapists, about her affair, or Plaintiffs involvement of the minor child in her affair, or her

current relationship and involvement of the minor child in her current relationship.

Admit that Defendant took minor child to plaintiff's residence on Date Time as required in the Visitation Order.

Admit that Defendant informed Plaintiff that he was going to walk the minor to the Plaìntiffs door prior to arriving.

Admit that Defendant left when Plaintiff refused to unlock the door for the minor

Admit that the Defendant turned to the minor child, said “I think you better go in,” and then the Defendant and the minor  hugged, and Defendant left.

Admit that Defendant has accompanied the minor child to the door of the

Admit that Defendant informed Plaintiff on Date Year that the minor child had left his cell phone at Defendants home.

Admit that Plaintiff did not respond to Defendant's notice about the phone.

Admit that Defendant delivered the cell phone to plaintiff's residence on Date Year by leaving it at the front door.

Admit that Defendant left a voicemail and sent a text message

Admit that Plaintiff has refused to discuss, with Defendant, what Child Therapist has told Plaintiff about minor child's therapy.

Admit that Defendant has met with Therapist muitipie times and has participated

Admit that Defendant met with Child Psychiatrist, at the request of Plaintiff

Admit that Plaintiff has not entered all of minor child's scheduled appointments

Admit that Defendant sent Piaintitf an apoiogy for the messages of Date Year through his attorney, stating, “And regardless of how I feel about what she has done, l apologize to her for my actions that day.

Admit that Defendant sent Plaintiff, through his attorney, an explanation of the fact that he had taken two prescription drugs on Date Year that caused his emotional outburst, stating, “I am not trying to make en excuse, but t know how to avoid another reaction, and at least I feel less confused about it, since I really dont remember sending ail of those messages. l do not went LnL to feel threatened, so I would appreciate you passing this on to her lawyer.” Exhibit XX.

Admit that on Date Year, Defendant had a similar emotional outburst reaction

Admit that Defendant contacted his physician, the following day, who modified the dose, and the emotional reaction did not

repeat.

Admit that Date Year, Defendant notified Plaintiff of his intent to take the week of Date Year, as a week of vacation with minor  as agreed to in

visitation order. Exhibit xx.

Admit that on Date Year, Defendant asked the Plaintiff to agree to rules to facilitate better, more frequent, and more genuine communication between the Plaintiff and Defendant and with the minor child, attached as Exhibit xx.

Admit that Plaìntiff, under false pretenses, pretended to be the minor chiid in text messages to Defendant, in order to obtain passwords to the computer Plaintiff took from Defendant surreptìtìousiy in Year Date.

Admit that on Date Year, Plaintiff, under false pretenses, Plaintiff allowed another person to pretend to be Plaintiff in an  exchange with Defendant, as described in request number X above.

Admit that on Date Year Plaintiff aliowed minor child to have a Skype Conversation with Defendant, but Plaintiff remained in the room, monitored the conversation, and exerted emotional and psychologìcal pressure on minor child to not communicate with Defendant and to end the conversation, which he did after a fake yawn and statement from the minor child the he was too “tired” at 7:00 pm.

Admit that prior to Date Year, and while married to Defendant, Plaìntiff had a romantic and sexual relationship with individual(s) not the Defendant.

Produce the name(s), addresss) and contact information, dates of contact and length of relationship for each.

Produce all electronic or other communications between the Plaintiff and individuals identified, including those related to funding and employment

Produce cell phone records for xxx-xxx-xxxx from Date Year to present,

Produce office phone records for same period.

Admit that on Date Year Plaintiff sent the email attached as Exhibit XX, to the Defendant foiiowing her work trip to State.

Admit that Plaintiff was in contact with persons identified in request number XX, above during that trip.

Admit that “doing the right thing” was to discuss Plaintiffs affair(s) and resolve the marriage and custody in an honest and cooperative way.

Admit that Plaintiff has taken minor chiid on trips and has allowed and encouraged contact with individuals named in request number XX above.

For each trip describe the lodging arrangements, including where minor child slept, where Plaintiff slept, and where indìviduals named above slept.

Provide the names of all individuals with knowledge of the arrangements in XX

Admit that Plaintiff has instructed minor child to lie and conceal his contact with individuals named in request number 21 above, to Defendant, his therapists, and others.

Admit that Defendant provided Plaintiff with full domestic and financial support at all times of the marriage, and that Plaintiff entered the marriage unemployed, with student loans, credit card loans, and a vehicle loan, which Defendant paid.

Admit that Plaintiff has been treated by physicians, psychologists, and psychiatrists for mental disorders, including depression, anger management, among others.

Produce dates, diagnoses, treatments, and medications for each treatment.

Admit that on Date Year, Defendant sent Plaintiff a message saying, "You are a liar and a cheat"

Admit that Plaintiff refused to Defendant to contact or see minor child

Admit that after receiving the message, Plaintiff surreptitìously took custody of minor child, went to the home and took personal items, and abandoned the home.

[Matt]

I'm not a lawyer, but I've never seen or heard of anything like this - "Admit that... . ".  See what your lawyer says, but my guess would be that you don't have to answer any of this stuff.  Maybe write something like, "These demands are inappropriate." to show that you read it and aren't obligated to respond.

[Matt]

In my case, the other side asked a number of things that weren't appropriate - nothing as crazy as all these, but for example, they repeatedly asked for documents which were in my wife's possession not mine, and I repeatedly replied, in writing, "This document is not in my possession.  I believe it is in Mrs. Matt's possession, in the house at [address]."  They never acted on that - never produced the documents - never denied that she had them - just issued a new set of interrogatories again asking for those same documents.

My conclusion was that my wife's attorney was just going over the same ground repeatedly in order to increase her billings.  I told my wife, "She is sucking us dry and you're getting nothing out of it." but of course my wife was more loyal to her attorney than to me, and by that point she was not thinking clearly at all, so she just let her attorney do whatever she wanted to and paid her bill (with money I had earned).

This is different, because your husband isn't getting paid for wasting everybody's time.  He's probably acting out, and the court will see that.