Evidence before argument

Property-division document checklist

Ask for the document that resolves the issue, not “all financial records.” A precise request is easier to answer and easier to verify.

Accounts and investments

  • Statements covering the date of marriage, date of separation and the current valuation date where available.
  • Complete account identifiers, ownership, transaction history and cost-basis detail for taxable investments.
  • Plan statements, service history, summary plan description and loan detail for retirement benefits.

Real estate, business and personal property

  • Vesting deeds, closing files, refinance files, current loan statements, appraisals and improvement records.
  • Business tax returns, financial statements, ownership records, compensation records and governing agreements.
  • Vehicle title and loan statements; appraisals or insurance schedules for material jewelry, art or collections.
  • Insurance statements showing whether a policy has cash surrender value.

Taxes and debts

  • Filed returns, notices, transcripts and records supporting an expected refund or balance due.
  • Current statements for each unsecured obligation and records establishing when and why it was incurred.
  • A log connecting every received document to the exact request it satisfies, including account, property and period.
Review pointA document with the right institution but the wrong account or statement date does not satisfy the request. Verify identity and period, not just file type.

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