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Thank you for your question. Please permit me to assist you with your concerns.Has your attorney perhaps suggested sending a signed/sworn & notarized affidavit stating that all the files you provided are in best of your knowledge complete, that at least based as far as you have attempted to comply in good faith, all information that you had is now formally provided to the other party? I say that because such a sworn statement will not cost nearly as much as a deposition and can still be used to potentially impeach you if you aren't telling the truth (the whole point for a deposition is to obtain potentially inconsistent testimony and prove or show that one party may not be being fully truthful, and the document provided would help with such claims). I am not stating or alleging that you are being untruthful at all, this is the way your attorney could 'sell' the idea of an affidavit to an opposing party and keep you from going through another wasted period of time. Furthermore then you could have legitimate basis to go to the judge and claim that additional sessions are no longer necessary, useful, or conducive based on your own documentation and your own sworn statements provided to the opposing party.Good luck.
Jean,Thank you for your follow-up. That is correct, your attorney can argue against it, if he can offer the sworn affidavit in its' place in which all potential concerns are formally addressed and sworn to as being truthful and accurate. Then it would be up to he judge to either agree with your attorney or with the opposing counsel.Good luck.