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Divorce and Financial Witness Depositions: Strategies, Techniques for Revealing a Complete Financial Picture

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, June 13, 2023

Recorded event now available

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This CLE webinar will guide family law attorneys through deposing witnesses concerning financial records and other documents containing financial information or reflecting financial condition. The panel will review deposition strategies and practical techniques for asking questions about business and personal tax returns, W-2s and 1099s, financial statements, spending patterns, and more to ensure that a complete and accurate financial picture is obtained.


Tax returns, financial statements, and other financial documents are snapshots in time and are usually prepared to facilitate some transaction other than a divorce or division of property. The information most relevant to parties in a divorce case may not be completely, clearly, or adequately reflected on the face of these documents simply because of how the information is organized.

The value of deposition testimony depends very much on the attorney's approach. In that regard, family law litigators must hone their skills with practiced techniques to elicit testimony and evidence critical to a favorable disposition of the case for their clients. When examining witnesses about finances and related documents, counsel will want to be proficient in the techniques of exhaustion, boxing-in, and summarizing.

If the witness holds an interest in multiple entities, and especially if those entities are within an enterprise, getting useful information from all the financial documents takes strategy and skill at both the planning and execution stages. Counsel need to know who to depose and what questions to ask about these financial documents to get the whole truth.

Listen as this experienced panel shares both strategy and deposition skills for lawyers in divorce cases.



  1. Goals of deposition
  2. Strategies
  3. Use of accountants and other financial experts
  4. Techniques
    1. Exhaustion
    2. Restating/summarizing
    3. Boxing-in
    4. Structuring depositions for difficult and evasive witnesses
  5. Questioning about specific documents
    1. Income tax returns and related documents
    2. Financial statements
    3. Other common documents with financial information


The panel will review these and other key questions:

  • What deposition questioning techniques will maximize the information obtained from witnesses?
  • How should deposition best practices be applied when structuring a deposition for an evasive witness?
  • How will these approaches improve counsel's ability to impeach an opposing witness?


Nelson, Andrea
Andrea E. Nelson

Burns & Levinson

A Senior Associate in the firm’s Divorce & Family Law Litigation Group, Ms. Nelson works with a wide range of...  |  Read More

Spanu, Catherine
Catherine E. Spanu

Burns & Levinson

Ms. Spanu is an associate in the Private Client Group. She represents clients in divorce, alimony, child support, child...  |  Read More

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