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Tenth in the Top Ten Things To Know When Contemplating Divorce

10. Learn About the Tools of Discovery:

Very often, one spouse does not have complete knowledge of the other party’s assets, liabilities, income or activities.  That is when “discovery” comes into play.  Essentially, “discovery” is organized information gathering.  It can encompass that which is permitted by the Rules of Court or other methods.  Some of the more prevalent avenues of discovery are:

Private investigators

  • Can do things you cannot;
  • Beware of costs.


  • 411locate.com (locate individuals);
  • Wnjpin.net (NJ Dept. of Labor -Employment and Wage data);
  • Artbrokerage.com (art values);
  • Njrealestate.com (cost of Living in certain areas);
  • quickquote.com (insurance quotes).


  • If your spouse leaves messages, save them;
  • Beware of Federal and State Wire Tap Laws.

Litigation Methods

  • Interrogatories;
  • Document demands;
  • Notice to produce;
  • Demand for admissions;
  • Depositions.

Forensic Experts: Very often, there are many issues that arise in a divorce that require outside experts.  Your attorney cannot assess mental health issues, value a business or decide on the employability of a party.  Experts such as the following are necessary:

  • Business valuations;
  • Lifestyle analysis;
  • If your spouse is not reporting all of his/her income, you may need an expert to evaluate his/her books and records;
  • Custody evaluations;
  • Employment evaluations.

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