Build the Binder (Tabs A–F)
Tabs & Structure
- Tab A — Texts/Emails (timestamp visible)
- Tab B — School Records (attendance/grades/notes)
- Tab C — Medical/Therapy (letters, visit notes)
- Tab D — Police/Incident Reports
- Tab E — Photos/Maps/Screens
- Tab F — Financials (support/fees)
Timeline on Top
Timeline (1 page): 02/12/25 — Missed exchange; child returned 8:45 PM — Exhibit A-1 03/15/25 — ER visit; dx & safety plan — Exhibit C-2 03/18/25 — Police welfare check — Exhibit D-1
Three Sets (Always)
Court • Other Party • You — identical pages; flags at key lines; spare USB just in case.
Label & Index (Bates-Style)
Exhibit Footer
Exhibit A-1 | Text 02/12/25 7:41 PM | Page 1 of 2 Exhibit B-3 | Attendance Sept–Nov | Page 1 of 3
Simple = credible. Every page labeled. No mystery PDFs.
Index Page
Exhibit Index: A-1..A-7 — Texts with timestamps (02/03–03/11) B-1..B-4 — Attendance/grades (Fall) C-1..C-3 — Therapy/clinic letters D-1 — Police report #XXXXX E-1..E-3 — Photos/maps F-1..F-4 — Paystubs/tax pages
Highlighting Rules
- Highlight the line that matters—nothing else.
- Use yellow only, thin underline if needed.
Texts & Emails (Clean Screenshots)
Capture
- Full screen with date/time visible
- Include 1–2 lines before/after for context
- Don’t crop names/time bars off the top
Bundle
A-1..A-4 — Feb thread (pickup refusals) A-5..A-7 — Mar thread (threats)
Foundation (You)
Q (to yourself on direct): What is Exhibit A-1? A: A text I received from Respondent on 02/12/25 at 7:41 PM; it’s a true and correct copy.
Photos & Video (Legit & Lean)
Metadata & Caption
E-1 — Photo 03/15/25 21:07 — Bruise left forearm Caption: Taken by me on iPhone; location: home hallway; same night as ER visit (C-2).
Clips
Short clips only. Add a written summary under the exhibit heading with who/what/when/where.
Foundation (You)
Q: Did you take this photo (E-1) on 03/15/25? A: Yes, on my phone; this is a true and accurate copy without filters.
Records & Business Docs (School, Med, Messages)
Get Them Cleanly
- Ask the source (school/clinic) for a signed letter or portal printout
- For tough records, use a **business records subpoena** (see links)
Subpoena Play (Business Records)
- SUBP-010 — Deposition Subpoena for Business Records
- Ask for custodian declaration (records certified as business records)
This helps with hearsay via the business-records exception when properly certified.
School & Clinic Letters
C-2 — Counselor letter (03/05/25): child anxious after late exchanges; recommends consistent 7pm return. B-3 — Attendance log: 5 tardies in 3 weeks.
Authentication Scripts (Fast Foundation)
Texts/Emails (You)
Q: What is Exhibit A-3? A: A text from Respondent to me on 03/02/25 at 6:14 PM; it fairly and accurately shows what I received.
Photos/Video (You)
Q: Who took E-2 and when? A: I took it on 03/15/25; it accurately shows what I saw.
Business Records
Q: What is B-3? A: Certified attendance records produced by the school; kept in the ordinary course of business.
If the other side objects—meet foundation cleanly, then move on. Short > long.
Hearsay Workarounds (Common Fixes)
- Party statements (their texts/emails) — generally admissible as opposing-party statements.
- Business records — certified school/clinic records produced by custodian under subpoena.
- Present sense impression / state of mind — be careful; keep it tight and relevant.
Pro tip: When in doubt, lay foundation and offer for a non-hearsay purpose (notice/impact/timeline), then move on.
Day-Of Handoff (Win the Room)
Sequence
- Opening (60–90s) → Issue line → Exhibit call-out → Ask
- Hand the court your set; direct to flagged page
Exhibit Call-Out
“Exhibit B-3 is the school attendance log; yellow highlight shows 5 tardies in 3 weeks.”
If Time is Tight
“Your Honor, may I submit a short written summary with exhibit list?”
Official Links (California)
📄 SUBP-010 — Business Records Subpoena
📄 SUBP-001 — Personal Appearance (Hearing)
📄 SUBP-002 — Deposition Subpoena (Appearance)
📄 FL-330 — Proof of Personal Service
📄 FL-335 — Proof of Service by Mail
🌐 Find My Court
🌐 Court Interpreters
🌐 RA-010 — Remote Appearance
🌐 MC-410 — ADA Accommodation
🌐 All California Court Forms