5.
KNOW HOW TO ASSEMBLE YOUR EXHIBITS
ON
THIS PAGE:
A.
Know Why You Should Use Exhibits
Exhibits serve two functions:
(1)
they convey or explain large or complicated data, far more quickly and easily than could mere
written words; and,
(2)
they grab the judge's interest and attention, far more quickly and easily than could mere written
words.
Below is a list of preferred exhibits, in the preferred order, to submit with your written
testimony. Please note the word "preferred." It means basically the following: if you have
it, use it. If you don't have it, move on and don't worry about it, because most people don't submit
any exhibits at all.
B. Use Color. On Everything.
Nothing grabs a reader's attention like color.
Look
at the front page of any metropolitan newspaper. Notice that the first thing to grab your eye is
invariably the color photograph.
Some
decades ago, newspapers used black and white photos. When they first started using color photos, it
was hideously expensive. But they started using them any way. Here's why:
(1)
Color photos sold more newspapers than did black and white photos;
(2)
So much so, that the increased revenue arising from the increased sales
outweighed the increased costs of color photos.
Learn the lesson that the newspapers spent billions to teach us: color generates far more interest
and attention than does mere black and white.
Hence, when you have photos to show the court, don't settle for the trash that comes out of a
standard copy machine. Use photographic quality copies, on photographic quality paper.
Similarly, when you have charts, graphs, or anything else to show the court that has any color in
it, always use color copies.
Color, color, color.
C.
Scribble On Your Exhibits
Highlight
it. Draw arrows pointing at it. Draw circles around it. Write descriptive captions next to it. Etc.
Mark
your exhibits, to help the reader better see and understand that which you want to show or
demonstrate.
D.
Know What Exhibits To Use
(1)
Photos – Of You And Your Child
The
goal is to motivate the judge to conclude that your child is thoroughly bonded to you, and that it
would be a travesty against God and Nature if that bond were disrupted.
Ideally, you have been intimately involved with your child, at each and every important moment, from
your child's birth to the present. Equally ideally, you can demonstrate this to the court with
photos of you and your child together at each stage of your child's development, from birth to the
present.
On
the other end of the spectrum, some children have rarely or never seen one of their parents. For
example, this can occur if the absent parent is in the military and deployed out of the country, if
the parent has been in prison, or if the other parent has abducted the child. If you have been one
of these "absent" parents, and you have one or more photos of your child, consider showing
it or them to the court. Notwithstanding you have been absent for
some or all of your child's life, those photos will suggest that you care enough about your child to
cherish what few photos you have.
And use photographic quality copies of your photos, on photographic quality paper.
Color, color, color.
*******************************************
(2)
Photos – Of You, Your Significant Others, And Your Child
Your
significant others include members of your extended family, and of your quasi-family.
Quasi-family members are those persons who are as close to you as are your actual family members.
They include new mates, whether legally married to you or not. They may also include the children of
your extended family or of your quasi-family, whether you are legally responsible for these children
or not.
The
goal is to motivate the judge to conclude that your child is thoroughly bonded to your significant
others, and that it would be a travesty against God and Nature if that bond between them and your
child were disrupted.
Ideally, your significant others have been intimately involved with your child, at each and every
important moment, from your child's birth to the present. Equally ideally, you can demonstrate this
to the court with photos of them and your child together at each stage of your child's development,
from birth to the present.
And
use photographic quality copies of your photos, on photographic quality paper.
Color, color, color.
*******************************************
(3)
Photos – Of Your "Tools Of The Trade"
You
have two, full-time professions:
(a)
Whatever it is you do for a living; and,
(b) raising your child.
Every profession requires certain tools of the trade. Raising your child is no different. Your tools
of the trade include such things as:
food
in the refrigerator;
your child's bedroom;
your child's bed;
your child's car seat;
your child's toys;
your child's clothes;
smoke alarms;
fire extinguishers;
a fence around the pool;
poisons and dangerous substances out of sight and out of reach;
dangerous tools and equipment out of sight and out of reach;
electric socket shields;
firearms stored in a locked safe;
ammunition stored in a separate, locked safe; and,
everything else that assures your child of a happy, healthy and safe home
environment.
The
California Department of Social Services requirements for foster care homes, provide an outrageously
comprehensive list of possible tools such as these. To see those regulations, click HERE.
The
goal is to motivate the judge to conclude that you and your home have all the tools any parent needs
to assure your child of a happy, healthy, and safe environment, while your child is in your custody.
Ideally, you can demonstrate this to the court with photos of these tools of the trade.
And
use photographic quality copies of your photos, on photographic quality paper.
Color, color, color.
*******************************************
(4)
Charts & Graphs
In
November 2004, this nation experienced the new, "Red State, Blue State" cultural
phenomenon. During the presidential election that year, the television news media showed updated
snapshots of which states were voting for which candidate, by assigning "red" states to
one candidate and "blue" states to the other.
Stop
and think about this for a minute. This one, single chart, INSTANTLY conveyed each and every one of
the following:
which
states were leaning toward one candidate;
which states were leaning toward the other candidate;
which states were still unknown;
which candidate was ahead; and,
by approximately how much that candidate was ahead.
Voluminous data. The ability to draw multiple, reasonably accurate conclusions based on that
voluminous data. Conveyed INSTANTLY.
Moral of the story: Use charts and graphs for quickly conveying or explaining voluminous or
complicated data.
Two common examples include:
maps,
showing locations and distances; and,
calendars, showing who has or had custody of your child, when and for how long
And use color, if at all possible.
Color, color, color.
*******************************************
(5)
Certificate(s) of Completion of Parenting Class(es)
Take
a parenting class.
And
if your child has any special needs or disabilities, consider taking a second parenting class, which
focuses on children with similar issues.
The
local family law courthouse no doubt has an office that can provide referrals to several local
parenting classes, at low or no cost. Classes usually meet for one or two hours on a weekend, 6 or 8
times.
You
will learn all kinds of neat things about how better to raise your child. Including, for example,
how to motivate your child to behave better, without resorting to assault and battery.
The
judge will probably know that your primary reason for taking the class, was to impress the judge
favorably on your behalf. However, the judge will also know that:
(a)
notwithstanding your initial motives, you cared enough about your child to go
through with it;
(b) notwithstanding your initial motives, you probably learned something;
and,
(c) notwithstanding your initial motives, you were probably one of only 2 or 3
students in the class without a court order forcing them to be there.
Therefore:
(a) If your co-parent did not take the class, this will probably help
your case because, unlike you, it will appear that your co-parent:
i. did not care enough about
your child to go through with it;
ii. does not know as much as you
do about quality parenting; and,
iii. probably will not bother to
take a parenting class, unless forced to do so by court order;
AND,
(b) if your co-parent did take the class, that will not adversely
affect your case, because you did too.
And
when preparing copies of your certificate(s) to show the court and the adverse party, use
high-quality color copies.
Color, color, color.
*******************************************
(6)
Records Confirming Child-Centric Activities
Child-centric activities include:
volunteering
to do anything at any children's school;
coaching any children's sport activity; and,
anything else that protects or promotes any children's rights or interests.
Records confirming such activities include:
certificates
of participation or appreciation;
letters confirming participation or appreciation;
photographs confirming participation or appreciation; and,
any other documents, letters, memoranda, or records confirming participation or
appreciation.
And
if any of these items have any color, use high-quality color copies.
Color, color, color.
*******************************************
(7)
Other Relevant Documents
Other relevant documents can include:
School records, to confirm a change in your child's grades, attendance, behavior
and attitude, while under either parent's primary care;
Medical records, to confirm the existence of, or changes in,
any health related issue affecting your child;
Police records;
Civil lawsuit judgments and orders;
Pleadings and other documents on file in connection with
civil lawsuits;
Criminal convictions;
Pleadings and other documents on file in connection with
criminal proceedings;
Telephone records;
Credit reports;
Email messages;
Information gathered from public records;
Information gathered from the internet;
Etc.
And
if any of these items have any color, use high-quality color copies.
Color, color, color.
E.
Label Your Exhibits
Label your exhibits, with exhibit tabs.
There are two categories of exhibit tabs: cheap, and not so cheap.
The
cheap tabs need to be stuck onto the first page of each exhibit by hand, and the exhibit's letter or
number needs to be written on that tab. Do not use these. They look awful, and suggest to the judge
and to the other parent that the rest of your evidence and arguments are similarly shoddy.
Use
professionally prepared exhibit tabs. You can buy them at Office Depot or Staples. They are a little
more expensive, but only by 5 or 6 dollars for each set. And they are well worth the investment.
Their professional appearance will help send to the judge, and to the other parent, the correct
message about the quality of your evidence and arguments.
F.
Make An Exhibit List
Your exhibits should begin with a front page. The front page should be printed on pleading paper,
and have a court caption on it.
Your front page should otherwise look similar to a table of
contents, that has the following information:
(a) The title, or a brief description, of each exhibit;
(b) A brief explanation of the purpose or meaning of each exhibit, if
not already obvious from the title or brief description; and,
(c) The label you have attached to each exhibit.
Your exhibit list will do the following:
(a) Allow the judge
instantly to understand almost everything you want to show or demonstrate,
without actually viewing a single exhibit;
(b) Allow the judge instantly to know which exhibit(s) the judge wants to
review;
(c) Allow the judge instantly to find any exhibit(s) the judge wants to review;
AND,
(d) Dramatically improve the odds that the judge will review and consider
everything you want to show or demonstrate, because it will require far less
time and effort to do so.
