Once you're sure that the financial side is up to date, for the Conference Brief you need to consider both the issues that the other side has raised and any issues you wish to raise yourself. So for every specific claim your ex has made, you need to give your reasons why that claim should not be granted. That can be a direct contradiction of an allegation she has made, or it can be a series of statements from your point of view that show that her allegation is not likely to be true or unbiased. Once you have addressed her claims --and you don't need to address every allegation, if the allegation doesn't support a specific claim, ignore it-- then address your own claims. What do YOU want? Set out each claim separately and give the background information necessary to support that claim from your point of view.
You can make this easier for a Judge to follow by using small headings ... just bold, nothing fancy! But if you break it down by Wife's claim 1, claim 2, etc., then Husband's claim 1, claim 2, etc., the Judge will have an easier time understanding what you're saying. Generally Judges like it when materials are clear and focused, rather than a jumble of allegations and claims with no particular organization. Instead of "wife's" claim, you can say "plaintiff's claim" or "Ms. LastName's" claim ... whatever you prefer. Also make it clear what the 1, 2, 3, are. So as an example:
- "Plaintif's claim for spousal support"
- "Defendant's claim for property division"
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My answer here contains only general legal information and not legal advice. No solicitor/client relationship has been created by this communication.