Have I put too much in my Questionnaire and Statement of Issues

This as a general question on format of documents. Removed for privacy protection

The questionnaire is your opportunity to ask for clarification of specific points and request missing documents. It is not a statement of case or a place for debate or cross examination.

Questionnaires are limited to 4 pages of 12pt font spaced at 1.5 lines with a 2cm margin. Anything longer needs to be approved by a judge.

The phrasing of questions is important. You are asking for explanation and evidence to support what's in their form E. Stick to things that would make a material difference to any settlement. So missing bank statements, questions about transactions over £500 and evidence of undeclared assets)bank accounts are all reasonable. Ask for evidence of valuations if it hasn't been provided as well as of liabilities - you want to see loan agreements, credit card statements etc.

Make sure you do actually ask questions and don't just make statements. You could for example say: at 2.8 the applicant/respondent has listed a car valued at xxxx. Please would they confirm the make, model and mileage and provide an independent valuation?
a) If this vehicle is not the xxmakexx sports car purchased during the marriage, please would they confirm if this is still owned? If it is not, please would they provide details of what has happened to the xxmakexx with documents in support and an explanation of what has happened to any money paid for the vehicle.

If there are lots of irrelevant questions, the judge will just strike them out. Remember the point here is to make sure you have full financial disclosure on which settlement can be based.

The statement of issues can include a bit of position but should not be an essay.

One issue may be the current and future housing needs of both parties, how they should be met and the costs involved. It is the applicant/respondent's position that s/he and the children need to stay in the FMH as it is the most cost effective housing option for them.

Or say savings: How savings in the applicant/respondent's name should be divided. It is the applicant/respondent's position that xx of this was derived from an inheritance received post separation and this sum is non matrimonial.

That sort of thing.

Hope that helps. If you need help, you could look at our services to support LIPs in the court process.

Hadenoughnow

thank you very much for the information, it really was helpful. Because my wife's solicitors is late with the exchange (should have been on Friday) I have now gone through it and removed all the unnecessary justifications and proof of things I had put in. it is still over 4 pages, as she has missed out so much information and has so many errors in the form. I will try to cut it down further. Once again thank you very much for the message.