1. Minimum 40 paragraphs for a First Appointment; 90 for a FDR;
2. Tone should never deviate from rant. Work those adjectives – there is no such thing as delay, only disgraceful delay;
3. Figures on the schedule should read like the bottom line of a sight test: practically invisible to the human eye;
4. When it comes to adding colours, the more the merrier. Make your schedule look like a TV test card;
5. Your client is a modern saint. The other side is engaged in a criminal conspiracy;
6. Always confuse gross and net incomes. Gross for other side: net for your own;
7. Never cite one case when eight will do;
8. Property particulars: out of budget and off the market;
9. Never identity the issue until paragraph 60. Then disguise it;
10. No matter hopeless your case, always threaten costs.
Family Brief 
One reply on “Ten Commandments of Financial Remedy Notes”
[…] As noted above, what happens in financial remedies is that each party’s advocate lodges a single (and not agreed) document, comprising a mixture of factual background, sardonic asides, law and sometimes analysis (see earlier post, “The Ten Commandments of Financial Remedy Notes”). […]
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