Custody, Parenting Time, and Support Through Judgment
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Custody, Parenting Time, and Support Through Judgment
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Lessons List

Lesson 1: Initial Decisions

1.0 Introduction to Initial Decisions
Rachael M. Sedlacek, Institute of Continuing Legal Education

1.1 Establish a Custody and Parenting Time Strategy
Identify client goals, assess family dynamics, and analyze the strengths and weaknesses of the client’s position.
Analyze best interests factors, recommend a strategy, and manage client expectations.
Ryan M. Kelly, Kelly & Kelly PC
Rachael M. Sedlacek, Institute of Continuing Legal Education
Todd S. Selin, Mallory Lapka Scott & Selin PLLC
Katherine M. Sharkey, Kitchen Sharkey PLLC

1.2 Counsel the Client on Child Support Issues
Advise the client on how child support is calculated and on different payment methods.
Identify sources and types of parental income for child support.
Ryan M. Kelly, Kelly & Kelly PC
Rachael M. Sedlacek, Institute of Continuing Legal Education
Todd S. Selin, Mallory Lapka Scott & Selin PLLC

1.3 Decide Whether to Opt In or Opt Out of the Friend of the Court
Counsel the client on services offered by the Friend of the Court and the advantages and disadvantages for opting out.
Prepare and file necessary documents to opt out of and opt back in to the Friend of the Court.
Suzanne K. Hollyer, Oakland County Friend of the Court

Lesson 2: Pretrial Matters

2.0 Introduction to Pretrial Matters
Rachael M. Sedlacek, Institute of Continuing Legal Education

2.1 Manage the Pretrial Phase
Guide your client through the pretrial process.
Use discovery strategically to address the child-related issues in your case.
Hon. Mary Ellen T. Brennan, 6th Circuit Court
Kanika Ferency, Oakland County Prosecutor's Office
Peter M. Kulas-Dominguez, Kent County Friend of the Court

2.2 Navigate Local Friend of the Court Practices in the Pretrial Stage
Identify local court practices and the role of the local Friend of the Court office.
Determine how Friend of the Court services can help your client meet the client’s pretrial goals.
Ruth Goldner, Goldner Deeg PLLC
Christopher J. Harrington, Oakland County Friend of the Court
Hon. Tina M. Yost Johnson, 37th Circuit Court

2.3 Prepare Motions and Temporary Orders for Custody, Parenting Time, and Child Support
Prepare a motion and proposed temporary order that reflects your custody and parenting time strategy.
Prepare a motion for temporary child support.
Ryan M. Kelly, Kelly & Kelly PC

2.4 Prepare for the Hearing on the Motion for Temporary Orders
Counsel the client on strategy for the hearing on the motion for temporary orders.
Choose and prepare witnesses to offer testimony at the hearing.
Ruth Goldner, Goldner Deeg PLLC

2.5 Handle a Pretrial Friend of the Court Hearing
Examine witnesses on the best interests factors to support your custody and parenting time request.
Determine whether to object to the referee’s recommendation.
Ruth Goldner, Goldner Deeg PLLC
Christopher J. Harrington, Oakland County Friend of the Court
Shalini Nangia, Varnum LLP

Lesson 3: Final Judgment

3.0 Introduction to Final Judgment
Rachael M. Sedlacek, Institute of Continuing Legal Education

3.1 Handle Custody and Parenting Time Mediation
Gather evidence and draft the mediation summary.
Prepare your client to be open to compromise.
Successfully interact with the mediator.
Memorialize the agreement.
Ruth Goldner, Goldner Deeg PLLC

3.2 Prepare for Trial on Custody and Parenting Time
Continue discovery, stipulate to facts and exhibits, exchange witness lists and exhibits, and prepare the trial brief by the dates set in the scheduling order.
Plan the opening statement, testimony, and exhibits and prepare the client and witnesses for trial.
Keri Middleditch, Middleditch Law Firm PLLC
B. Andrew Rifkin, Bank Rifkin
John B. Swift, II, Michigan State Housing Development Authority

3.3 Present Proofs at Trial
Make opening and closing statements and offer testimony and exhibits on best interests factors to achieve the desired outcome.
Present evidence on the parties’ income and expenses related to the children.
Hon. Mary Ellen T. Brennan, 6th Circuit Court
Kanika Ferency, Oakland County Prosecutor's Office
Keri Middleditch, Middleditch Law Firm PLLC
B. Andrew Rifkin, Bank Rifkin

3.4 Enter a Judgment of Divorce
Draft and enter a judgment that conforms to the judge’s opinion and order after trial.
Ensure that the client understands the judgment and the importance of complying with its terms.
Hon. Patrick J. Conlin, Jr., 22nd Circuit Court
Keri Middleditch, Middleditch Law Firm PLLC
B. Andrew Rifkin, Bank Rifkin
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