Robert Coleman Robert Coleman

Navigating the Admission of Declarations into Evidence in California Family Law: A Practical Framework for Practitioners

A Request for Order (RFO) hearing may be less formal than a trial, but the same rule governs both: the judge can only rely on evidence that is properly admitted into the record. If your declarations or exhibits are not admitted, they simply do not exist for the court’s purposes — no matter how compelling they may seem.

This article provides a practical, step-by-step framework for California family law practitioners on how to draft, prepare, and admit declarations in compliance with Family Code § 217, Rule 5.111, and CCP § 2009. It explains how to build declarations on admissible facts, avoid common evidentiary objections, conduct a meaningful meet-and-confer, and ensure your evidence is admitted whether the hearing proceeds by live testimony or submission on the pleadings.

Mastering these evidentiary requirements not only strengthens your presentation at the RFO hearing — it protects your client, enhances your credibility with the court, and improves the likelihood of achieving a favorable outcome.

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Robert Coleman Robert Coleman

Five Provisions Every Parenting Plan Must Contain — and Why they Matter

Parenting plans drafted too quickly often look fine on the surface but fall apart when conflicts arise. California Family Code § 3048 requires specific findings—on jurisdiction, notice, custody rights, penalties, and habitual residence—to ensure clarity and enforceability. When these elements are missing or vague, parents face preventable disputes and enforcement problems, both in California and across state or national borders. A well-drafted parenting plan protects families by removing ambiguity before it becomes conflict.

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Robert Coleman Robert Coleman

Family Law Isn’t Just About Advocacy — It’s About Project Management.

Family law isn’t just about arguments, filings, or court appearances — it’s about managing a complex project with moving deadlines, evolving facts, and high emotional stakes. The strongest attorneys don’t just advocate; they plan, organize, and guide a case from intake through final judgment with the same discipline used in professional project management.

From defining client goals, to building a case roadmap, to coordinating team members and experts, effective project management reduces mistakes, improves communication, and keeps cases on track. In a field where delays and disorganization can quickly increase costs and risk, structure isn’t optional — it’s essential. This article explores how project management principles improve outcomes, reduce stress, and help family law attorneys deliver more consistent, effective representation.

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Robert Coleman Robert Coleman

Why “Quick and Dirty” Rarely Saves Money in Family Law

Shortcuts in family law often seem like time-savers, but they usually create bigger problems later. Whether it’s skipping an MPA, relying on incomplete disclosures, or waiting until the final hour to prepare filings, “quick and dirty” approaches can lead to confusion, missed issues, and higher costs for clients. Careful planning, clear communication, and disciplined advocacy protect both the client’s resources and the integrity of their case.

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Robert Coleman Robert Coleman

Turning Shortcuts Into Setbacks: Why MPAs Matter in Family Court

A Memorandum of Points and Authorities (MPA) isn’t always required in family court — but skipping it often turns simple issues into confusion and higher costs. A clear MPA gives judges the roadmap they need: what you’re asking for, why, and the legal authority that supports it. When attorneys leave it out, they create uncertainty and weaken their advocacy.

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Robert Coleman Robert Coleman

Family Law Firm Economics — From Struggling to Thriving

A thriving family law firm isn’t built on heroics—it’s built on systems. Build even small passive-income streams + create consistent visibility (join, speak, write). That combination moves you from instability → selectivity → healthier cases → predictable revenue.

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