Divorce litigation is rarely simple. The emotional stakes are high, the facts are often complicated, and the courtroom can be unpredictable. But having the best chance to achieve your goals at trial almost always comes down to the same thing: preparation. Whether you’re representing the financially disadvantaged spouse or the primary breadwinner, your divorce trial preparation must be thorough, strategic, and tailored to the unique facts of a case. Pretrial strategy sets the tone and often determines the outcome.

Master the Financials Before Discovery Closes

The heart of most divorce trials is financial—whether it’s asset identification, valuation, and division, alimony, child support, or all of these. If you walk into court without full command of each party’s financial picture, you’re already at a disadvantage.

Start by creating a clear financial roadmap. Review every income source, asset, debt, and expenditure. Then when appropriate, go deeper. Track bank statements over time to reveal patterns, hidden transfers, or lifestyle discrepancies that might undermine the other side’s claims. In higher-asset cases, consider working closely with forensic accountants who can provide supporting documentation and testimony.

If discovery is still open, be proactive and strategic. Request tax returns, profit and loss statements, and credit card statements early. Use interrogatories and depositions to lock in financial narratives that you can later challenge with hard evidence. And don’t underestimate the value of your own client’s financial statement and disclosures. Review them carefully. Inconsistencies can come back to haunt you at trial.

Create a master financial exhibit binder that aligns with your theme. If seeking alimony, build a clear and credible picture of need and the other spouse’s ability to pay. If a party wants to retain a specific asset—such as the marital home—have an updated appraisal, budget, and feasibility plan ready.

These financial divorce litigation tips will help ensure you walk into court confident and credible. By trial, you should know the numbers cold. Your credibility in front of the judge will depend on it.

Build a Narrative That Frames the Case Early

Judges are busy. They’re sifting through dozens of cases, each with their own emotional complexity and legal nuance. The clearer your narrative, the easier it is for the court to follow your argument and rule in your favor.

Begin developing your trial narrative months before the trial date. Your goal is not just to present facts—but to tell a coherent story that makes sense of the marriage, the breakdown, and a party’s needs moving forward.

A strong narrative does a few things well:

• It aligns with the law and evidentiary record
• It anticipates and preempts the opposing counsel’s version of events
• It gives the judge a clear framework for crafting equitable relief

Avoid getting lost in the weeds. Every piece of testimony and every exhibit should serve the broader story. If a fact doesn’t move the judge closer to understanding why your client’s proposed outcome is fair and lawful, cut it. Trial isn’t the time to dump your entire case file into the record. It’s the time to be focused, making it easy for the judge to understand and do what you want.

Consider using a trial brief or pretrial memorandum that lays out this story in a structured and digestible format. Connect facts and exhibits directly to legal points. Quote directly from deposition transcripts if a party’s testimony supports your version of events. Include timelines, summaries, and visual exhibits that reinforce your points (of course, providing the required advance notice).

And rehearse your opening. A well-delivered opening statement doesn’t just introduce the case—it anchors the judge’s attention and builds credibility from the start. One of divorce litigation best practices is ensuring your narrative isn’t just legally sound—it’s also emotionally resonant.

Prep Witnesses Like It’s the Real Thing

You know the law. You’ve done the research. You’ve outlined your case. But no matter how airtight your preparation may be, poor witness testimony can torpedo your strategy in a moment.

Start with your client. Don’t just explain what questions you’ll ask—practice them. Run mock examinations that simulate courtroom pressure. Clients often think they’ll do fine until they’re faced with cross-examination. Walk them through likely traps, emotional flashpoints, and how to stay calm and composed. If custody is at stake, make sure they understand how their demeanor, tone, and word choice may influence the judge’s impression.

Then focus on third-party witnesses. Teachers, therapists, business partners, or friends may all play a role in supporting your client’s claims. Set expectations early. Explain the courtroom format, prep them on direct and cross, and make sure they know how to handle objections. Keep their testimony focused and relevant. Don’t try to cover everything. Aim for credibility and consistency over volume.

Cross-prep is just as important. Identify weaknesses in your case and how opposing counsel may try to exploit them. Prepare your witnesses to acknowledge mistakes without crumbling. Where possible, frame vulnerabilities in your own terms—get ahead of bad facts and shape the narrative, instead of hoping they don’t come up.

Don’t forget your own performance. Have a trial binder or organized folder system that includes a streamlined outline for each witness, cross questions, key exhibits, and your objections cheat sheet. Use color coding or tabs to stay nimble. Trial days move fast, and you’ll want to keep your head above the procedural chaos.

Your Trial Success Starts Before You Enter the Courtroom

In divorce litigation, preparation isn’t just a box to check. It’s critical to setting the stage for the best possible outcome. From mastering financial records to developing a compelling story to prepping your witnesses under pressure, every detail counts.

I’ve been representing Maryland clients in complex family law matters for more than 20 years. Whether you’re preparing for your first divorce trial, your fiftieth, or your own trial, I’m here to collaborate, co-counsel, or provide support on strategy and preparation.

If you're searching for trusted divorce trial preparation tips, or need help navigating the most effective divorce litigation best practices, contact us today.