Custody Checklist #3: Photos

In a contested custody case in Maryland, you will be overwhelmed.

There are bills for the lawyers, bills for the kids, bills for your ex etc. There will be time missed from work for court and all other manner of meetings. There will be written questions to answer called “interrogatories” and documents to both locate, produce and copy.

Collecting and disclosing evidence is to prepare for presentation of your case. Presentation in a light most favorable to the goals you hope to achieve. Custody? Access?

Never mind the smoke and the fray, sometimes a blue bird can stand out in a hurricane? By that, I suggest to you: photos. Just a few. Such as, photos of the kids ready for school, games, trips holidays etc. Not the nasty kind like kids with black eyes. I mean photos of the house, their rooms, their play set and a day at the pool. Fun, loving and everyday photos.

It is cliche to suggest a picture is worth a thousand words. A mere cliche until you have watched judge after judge reach over his/her bench past the irate emails, the unpaid child support checks, bank statements and expert reports to pick up…a simple photo.

There you see the judge holding this photo between his/her fingers, leaning back in his/her chair and thinking about how they all look in the photo(s)…. Silently thinking about these images as the parents exchange verbal ballista from the stand.

In some respects it is a “Calgon take me away” type of a moment, but a good impression is what we seek. Is it not? Life is what goes on between court dates. The judges know that. If nothing else, providing photos may show the judge that you are always mindful of what this dispute is about. Bring photos.

Tim Conlon, Esquire for The Custody Place

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