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I was recently asked, if I could give one piece of advice for prepping for a custody evaluation, what would it be? I really don't believe there is just one thing you or your clients can do to get what you want out of an evaluation. But one thing that I have heard over and over again by mental health experts is that they want the information to be delivered in an organized fashion and they really only want relevant information. I think a good timeline helps with both of these issues.

Timelines help you to organize your thoughts. They also help you to jog your memory for dates and certain events. For instance, if you are making a timeline about domestic violence that occurred in your relationship with your ex, you will want to be very thorough about the abuse that happened from the time you met. And you want to put in dates of important events. It is sometimes helpful to write things on a calendar to help you remember the dates. However, if you do not remember, just put the month and the year. If you are not even sure of the money and the year, just put the season. Try to remember anything that helps you determine the approximate date.

BE CAREFUL - If you are keeping a journal and say "see page 5 of journal" your whole journal may be brought in as evidence. It would be better to copy things on a calendar and give that to your attorney or use it as a guide. You may be asked how you know the dates, so try to give as many emails, texts and reports as possible to show how you know the dates.


February 27, 2012 - Met and went on first date.

June 12, 2012 - Bill called me a fucking bitch. So we broke up.

June 14, 2012 - Bill apologized profusely and begged me to go back with him and promised he would not do that again. I went back.

July 22, 2012 - We had a pregnancy scare. Bill threw the remote against the wall and was cursing and yelling because he did not want to be "tied down to a baby".

July 23, 2012 - Found out we were not pregnant. Bill apologized and said he was just afraid and begged me to go back with him said he would go to counseling. I did.

August 15, 2012 - Bill started anger management at my request because he was stilling being a jerk.

Sept 6, 2012 - Bill got mad at me for showing cleavage at work. He punched the wall

Sept 8, 2012 - Bill missed his anger management class and said he wasn't going back. He said he doesn't have an anger problem, he has a me problem and that I needed to get out of his face. I left and did not see him for 2 weeks.

Sept 22, 2012 - Bill started back to the anger management class and completed it.

July 4, 2013 - Bill asked me to marry him. No anger since before classes. I said yes.

May 29, 2014 - I gave birth to William Jr. Although Bill was a little nervous he was accepting and he loved Jr.

Nov 18, 2014 - Bill came home late from work smelling like alcohol. I got upset because we were supposed to have a date night. Bill pushed me against the wall when he walked by me. I hit my shoulder (See Exhibit 1 - picture of bruise). He started screaming at me. I started to call the police because he would not leave and I was afraid he would hurt me or Jr. He took my phone and slammed it against the wall. I grabbed Jr. and ran to the neighbors and called police. (See Exhibit 2 - police report)

Dec 5, 2014 - Filed for divorce

Dec 25, 2014 - Bill asked if he could celebrate Christmas with us. I agreed. He bought me lots of gifts. He admitted that he was wrong and said it was because he drank hard liquor and promised not to do that again if I would let him come back home. I agreed.

Jan 5, 2015 - I withdrew my Petition for divorce.

Jan 19, 2015 - Bill started using marijuana and stated that he would do that instead of drinking. I told him that I did not want him smoking around Jr.

May 2, 2015 - Found out I was pregnant. Bill was not thrilled but got high instead of mad.

July 1, 2015 - We bought a house.

Nov 11, 2015 - Bill lost his job because he failed the drug test. He went out and got drunk. Came home, call me a fat pig and told me he would never want to have sex with me again.

January 21, 2015 - Gave birth to Maggie.

August 29, 2015 - Told me to stop breastfeeding because my boobs belonged to him. I wouldn't so he grabbed Maggie off of me and put her in her crib really hard.

October 18, 2015 - I got a job. I was going to save money so I could leave.

November 4, 2015 - I moved out and took the kids when he was at work. When he got home he was crazy texting me. He said he would kill me if he ever sees my face again. He said he never wanted the kids and that I was a whore who was just trying to trap him. (See Exhibit 3 - texts)

Thanksgiving 2015 - No phone call, didn't ask the see the kids. Ignored me calling him to see if he wanted to talk to the kids. (See Exhibit 4 - call log)

Christmas 2015 - No phone call, didn't ask to see the kids, no Christmas presents.

January 26, 2015 - Posted on Snapchat that he was "looking to score some blow" (See Exhibit 5 - screen shot). Also on Snapchat he had a picture of him squeezing a known drug addict's boobs. (See Exhibit 6 - screenshot). Also posted on Instragram that he was out partying and loving the single life. He said "no wife, no kids, no worries . . . ain't nobody got time for that shit . . . that bitch can keep them kids!!!!" (See Exhibit 7, screenshot)

January 31, 2016 - I filed for divorce and asked for child support.

February 13, 2015 - Bill got a DUI. (See police report and court records)

February 15, 2016 - Bill filed his response to my divorce petition and asked for equal parenting time. He had never even spent 2 minutes with the kids since I moved out.

As you can see, this timeline contains a lot of useful information. It tells a story. It shows how things escalated. It shows use of drugs and alcohol and shows domestic violence. You can even color code.

Be careful not to put a bunch of junk in your timeline that is unnecessary. If your ex is spending money golfing a lot. That is not for this timeline. If your ex has a girlfriend that is likely not timeline material unless the girlfriend is using drugs or alcohol near the children or abusing the children. Financial things usually don't belong in this timeline.

Keep your timeline very simple and organized.

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