After you’ve hired your attorney, the first meeting between attorney and client—whether in person or by video—is about orientation, risk assessment, and planning.
Most people come in overwhelmed and discouraged to some degree. That’s normal. Divorce and child custody disputes are unfamiliar, fast-moving, angst-inducing, and often already in progress by the time you hire an attorney.
What matters is moving you from confusion to clarity and then into a realistic and workable plan to make your best case.
The quality of the advice you receive depends almost entirely on the quality of what you send in advance
If you want clarity instead of guesswork, prepare the following, and send it (or a link to your cloud storage for it) to me:
1. All Court Documents — The Complete File
If anything has been filed, served, signed, or issued, send it—everything, the whole and complete file.
That includes petitions, answers, motions, protective order paperwork, financial declarations, commissioner recommendations, signed orders, scheduling notices, and any discovery requests or responses.
If you are unsure whether something matters, include it; we winnow out later anything that does not apply.
Utah family law turns a great deal on procedure. Small details in the file often determine what can be done next—and what cannot. Before we meet, I need to be able to determine things like:
· Was service proper?
· Is default in play?
· Are temporary orders already shaping custody or support?
· Is a Rule 108 objection window running?
· Is a hearing already set?
Many people believe they “just have a hearing coming up,” only to discover that deadlines are expiring or that temporary rulings are already shaping long-term outcomes. That last point matters more than most people realize. Parts of your case are often being decided long before trial. Temporary orders, early agreements, and unchallenged arrangements tend to become the baseline courts are reluctant to disturb.
What happens early in your case is not preliminary—it is foundational.
2. Accurate Financial Documentation
Child support, alimony, and property division are driven by numbers, not estimates.
You will need a complete and accurate financial declaration. If you have not prepared one yet, we will help you get there—but sending the underlying documents in advance makes everything faster and more reliable.[1]
You can find the office Utah Courts financial declaration form here: Financial Declaration
Accuracy is not optional. Financial declarations are signed under penalty of perjury, and credibility becomes an issue quickly when numbers are incomplete or inconsistent.
Clean, clear numbers allow for clear, persuasive argument. If the numbers are off, your strategy will be too.
3. A Written Timeline (Facts, Not so Much Feelings)
Do not rely on memory during the meeting. Instead, prepare a written timeline of your marriage; that allows us to review your history more efficiently and accurately.
Prepare a basic chronology that includes:
· Date of marriage and separation
· Major conflicts
· Police involvement
· Custody or parent-time changes
· Protective order filings
· Significant parenting disputes
· Major financial events
If there are facts or patterns you believe matter or might matter—even if you are not sure they are legally important—include them. But keep this in mind:
Adjectives and adverbs are not evidence. Facts tied to dates are.
· “On March 3, police were called…” is useful.
· “He/she was acting crazy and aggressive” is not.
Courts do not decide cases based on general impressions like “this has been going on for years.” They decide based on specific, provable events.
Also understand this:
What you leave out can hurt you more than what you did.
If there is something you are embarrassed about or hoping “won’t come up,” that is exactly what needs to be disclosed early. Problems are usually manageable. Surprises are not.
4. Relevant, Organized Evidence
Sheer volume is not the goal. A small number of clearly labeled, relevant documents is far more useful than hundreds of unorganized files.
Useful examples include:
· Key texts or emails showing threats, admissions, parenting issues, or financial misconduct
· Police reports
· Medical or counseling records
· Documentation of denied parent-time
· School records (if custody is disputed)
· Financial records showing hidden income or misuse of funds
If issues like domestic violence, child abuse, untreated mental illness, or substance abuse are present, include documentation that supports those claims.
If infidelity is part of the history, include it only if it has legal relevance. Often, it does not.
Two things most people do not realize:
Screenshots beat “your word against mine” stories. A clear, dated message will usually carry more weight than a detailed explanation.
Over-documentation can be as harmful as under-documentation. Dumping everything into the case makes it harder to identify what actually matters.
5. Communication Is Evidence
Assume every message you send will be read by a judge.
Not just what you say, but how you say it.
Calm, factual communication strengthens your case. Reactive, sarcastic, or hostile communication weakens it, even when you are otherwise in the right.
You are building your record in real time.
6. Your Objectives—and Your Stamina
Before you walk into court or mediation, you must be clear about what matters most. And you must also be honest about your stamina. Family law is a marathon, not a sprint, and your “objectives” are often limited by how much time and emotional energy you are willing to spend. So first, define your desired outcomes for:
· Child custody arrangements (and the daily reality of them)
· Financial stability (short-term cash flow vs. long-term assets)
· Safety concerns (for yourself and your children)
· Settlement versus litigation (knowing when to compromise and when to dig your heels in)
The Requirement of Patience
There is no “right” answer, but there needs to be an honest one. Understand what this process requires: Family law is not fast. It is not driven by who feels more wronged; it is a structured, document-driven process that rewards consistency and responsiveness.
If you lack the stamina for a one- or two-year battle, your objectives need to reflect that. Consistency—how you act over months of litigation—often matters more than any single “gotcha” incident.
The Cost of Delay
One point that catches people off guard: Delay is a decision. If you lack the patience to gather information quickly, or if you wait to respond to a motion, you are making a choice. In Utah, waiting often locks in the “status quo”—and the status quo is frequently what the court chooses to keep permanently.
Efficiency: The Key to Preserving Stamina
To preserve your energy (and your budget), do not overwhelm the process at the start. A “document dump” drains your stamina and your attorney’s time.
What Not to Send:
· Large volumes of unorganized documents: These require hours of sorting that don’t move the needle.
· Every message ever exchanged: Highlights are evidence; a 500-page PDF of “he-said-she-said” is a distraction.
· Duplicate or unlabeled files: Organization is the antidote to burnout.
The goal is not to send everything. The goal is to send what matters, in a way that can be reviewed efficiently, so you have the stamina to reach the finish line.
The Takeaway
You are not expected to know Utah family law. That is your attorney’s job.
But you are responsible for providing your attorney with the information your case is built on. The better that information is, the better your attorney’s advice will be.
The first attorney-client meeting does not resolve everything. It gives you direction—and helps avoid mistakes that are far more expensive to fix later. Because in divorce and child custody cases, the biggest problems are usually not what people did. They are what was not disclosed, not documented, not challenged, or not addressed in time. Prepare accordingly. It is worth every bit of the time and effort spent.
Utah Family Law, LC | divorceutah.com | 801-466-9277
[1] Tax returns. For the two years before the petition was filed:
• federal and state income tax returns – personal and for any entities in which I have a majority or controlling interest
• all documents used to prepare the tax returns, pay stubs or other proof of income.
For the 12 months before the petition was filed:
• pay stubs
• other proof of all earned and un-earned income
Loan applications. For the 12 months before the petition was filed:
• all loan applications
• financial statements used to apply for the loans
Real estate documents. Documents verifying the value of all real estate in which I have an interest. This includes the most recent appraisal, tax valuation, and refinance documents.
Financial statements. For the 3 months before the petition was filed all financial statements. This includes, but is not limited to, checking, savings, credit cards, money transfer apps, money market funds, certificates of deposit, brokerage investment, and retirement.
Monthly Expenses. Proof of amounts listed. If the proof is not available, estimate the amount and explain how you reached that amount.
Personal Property. Proof of ownership (where applicable). Proof of values listed.
Debts Owed. 3 months of credit/debit account statements.