The Value of a Narrative Response in Family Law Cases
By Judge James A. Shapiro & Adam R. Heusinkveld
Family Law,
January 2024
The failure of many family law practitioners to appreciate the distinction between pleadings and motions results in the common practice of using the “admit/deny” format in responding to motions.
The Value of a Narrative Response in Family Law Cases
By Judge James A. Shapiro & Adam R. Heusinkveld
Bench and Bar,
December 2023
In domestic relations matters, many practitioners follow practice conventions that defy statutory rules governing pleading in civil matters and forgo the opportunity to educate the court by providing written argument and citation to case law in support of legal positions—most often, this occurs in the context of responding to motions.
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