I have prepared a basic checklist of issues which should be considered and discussed with your attorney. The list is intended to be general and broad in scope. Some items may not apply as part of the negotiated settlement or preparation for trial.


1. Custodial arrangements for children.

2. Visitation.

3. Parenting plan.

4. Child support.

5. Medical, dental, hospital, pharmaceutical and psychological expenses for the children.

6. Medical insurance for the children.

7. Cobra or medical insurance for former spouse.

8. Income tax deductions regarding the children – who will claim them.

9. Alimony/spousal support.

10. Division of personal property.

11. Division of real estate, transfer and deeds.

12. Separate property – inheritance and gifts from non-spouse.

13. Investments, including stocks, bonds, savings and business interest.

14. Debts – handling of joint debts – who is responsible for the debt.

15. Pensions, IRA accounts, 401K transfers.

16. Personal property including furniture, furnishings, household goods, art and collectibles.

17. Motor vehicles including boats, trailers and motor homes – transfer of title.

18. Income taxes – are they to be filed jointly and the liability for payment of taxes or the distribution of any refund. In order to file a joint tax return you must be married on December 31.

19 Bankruptcy issues – protection in case one spouse declares bankruptcy.

20. Proper security and protection regarding property division.

21. A hold harmless and indemnification clause in case one spouse fails to live up to his or her obligations under the terms of the divorce (i.e., one spouse fails to pay a joint debt, the paying spouse can seek recovery for the debts paid on behalf of former spouse).

22. Spousal abuse and restraining order.

23. Restoration to prior maiden name.

24. Life insurance policies as protection for child support payments, alimony – spousal support payments, and/or property payments in the event of death.

25. Attorney’s fees, mediator fees, accountant and other fees and payment of same.

26. College education for children or spouse.

27. Private school education for children.

28. Clause such as payment for summer camps and/or religious training and/or upbringing or other special situations involving the children.

29. Change to Last Will and Testament and Power of Attorney.