Drafting a Chronology of Events

  1. Get organized
  2. Understand what information your attorney needs
  3. Start at the beginning
  4. Be specific
  5. Fill in the blanks
  6. If in doubt, put it in
  7. Double, triple and quadruple check

#1 Get organized

The function of the chronology you are drafting is to give your attorney the raw data that will be used to explain your case in correspondence and legal documents. It’s at best embarrassing and at worst impossible to correct basic errors about the when’s, where’s and why’s after we have formally put your case in writing. So go through all the documents available to you (date book, email files, cell phone bills, bank records, tax returns, notes made at meetings or in phone conversations) when you start the drafting process. Organize these records and use the information in them as the basis of your draft.

#2 Understand what information your attorney needs

The information your attorney will need will vary depending on the details of your case. Make sure that you have a clear understanding of exactly what your attorney needs. Here are a few examples.

  • For a divorce, the basics will always include date of cohabitation, date of marriage, births of any children, dates when jobs of both parties stopped and started, dates of any separations, and dates when major assets such as houses were acquired and sold.
  • For a contract dispute, your attorney will need the dates of all meetings and phone calls with a summary of what was said, the dates that any draft contracts, notes, emails or other written records were created, and the exact dates, times and circumstances in which you or the other party signed any formal documents.
  • For a boundary dispute, you will need the date that each party acquired their land, the names of the previous owners of each piece of land and the dates of ownership of those previous owners if known, the dates of any conversations about the disputed land, and the dates that any structures or fencing on or next to the disputed land were erected.

#3 Start at the beginning

Resist the common temptation to cut out the boring stuff that happened before things really heated up. Most people when talking about stressful events will concentrate on the things that seem the most upsetting (the day that a spouse left the children unsupervised, that the would-be business partner’s check bounced, or that the neighbor put up the “no trespassing” signs). But the background to any of these events is at least as important, and in many cases more important legally, than the fireworks that came later. So start with the earliest background: meeting your spouse, deciding to start the business venture that eventually went disastrously wrong, the first time you heard about the real estate you now wish you had not bought.

#4 Be specific

A vague description of events is not going to be useful to your attorney. Don’t use shorthand or general descriptions of what happened or what was said.

Instead of: “I always put my children before my career,” say “In April 2003 I took a 10% pay cut so that I could be home by 4 PM every day when the children got home from school.”

Instead of: “He told me that he would pay me back with some money he was expecting soon,” say “He told me that he was going to get about $75,000 from his father’s estate by the end of the year and could pay me back by January.”

#5 Fill in the blanks

You might not have records (or a steel-trap memory) that let you come up with a list of exact dates. If you have to, just tell your attorney approximately when something occurred. For example:

“This happened just a few weeks before my sister’s college graduation in mid- June 2002. I remember that it was after all this happened that I had to cancel our travel reservations.”

“Although I do not have these phone records, I know that these conversations took place before January 2004 because every time we talked he was still promising to pay me the money by January 1st.”

#6 If in doubt, put it in

Better to say too much than not enough. Don’t worry about giving information that might turn out to be irrelevant. Your attorney can disregard anything that is unnecessary to your case, but he can’t use what you don’t tell him about. If you think something just might somehow be relevant, even as background information, include it.

#7 Double, triple and quadruple check

The information you give us needs to be precise and accurate. So read through the chronology a few times yourself before giving it to your attorney. If you aren’t very sure about dates (did that happen on Christmas Day 2002 or 2003?) check your records again. If you still can’t be sure that some of the information you have given is right, note these doubts prominently on the chronology itself.

We make no promises or representations about the accuracy of this information, or how it applies to your particular case. These articles are designed to give you ideas to consider and discuss with an attorney, but are no substitute for legal advice, and must not be used as such.