By: John P. Paone, Jr.

Frequently, we deal with clients who refuse to heed our advice. It is a never ending battle for the divorce lawyer to remain in control of the litigant who just doesn't get it. For that wayward client, I have compiled a list of what not to do during your divorce. The goal is to enable the misguided client to appreciate the folly of his or her aberrant conduct. It is hoped that the natural instinct toward self-preservation will deter even the most stubborn client from engaging in behavior which appears as part of a "dunce list." The following list has been compiled (unfortunately) from prior experience.

1. Avoid opening mail from your attorney.

2. Assume that your telephone conversations with your spouse are not

being recorded.

3. Assume that your mail and e-mail in the home are secure and private.

4. Upon vacating the marital abode, leave behind financial records

and documents which are critical to your case.

5. Make admissions; boast about your personal success to your spouse.

6. Confide in paramours, in-laws and potential third party witnesses.

7. Visit gambling resorts such as Atlantic City or Las Vegas (especially

if your ability to pay is in issue).

8. Take a lavish once-in-a-lifetime vacation; purchase unusual luxury

items.

9. Open new bank accounts jointly with third parties.

10. Make an unnecessary visit to your safe deposit box.

11. Sign financial applications under oath which conflict with your Case

Information Statement or other documents filed with the Court.

12. Take jobs for cash, barter or unreported income.

13. Make major deviations from your marital lifestyle by significantly

increasing or decreasing your monthly expenses.

14. Pay your spouse in cash.

15. Quit your job/change careers/retire early.

16. Get involved in a new business venture or speculative investment.

17. Put off a comprehensive physical health exam.

18. Terminate or modify existing insurance coverage or beneficiary status.

19. Make settlement proposals directly to your spouse without conferring

with your attorney.

20. Tell the children "bad things" about the other parent's personality

or character.

21. Fail to comply with custody and parenting time schedules.

22. Flaunt your new romantic interest to your spouse (and to your

children).

23. Take the children to court and to your attorney's office.

24. Show court documents and attorney letters to the children.

25. Make the children feel guilty for loving both parents.

Hopefully, clients who read this list will experience an increased sense of awareness concerning their individual conduct. This may lend to greater appreciation of the financial risks and emotional damage which may result from careless or misguided actions. By avoiding such conduct litigants may minimize their costs and avoid making their children the innocent victims of divorce.