How to Prepare a Chronology of Events for Litigation in NSW

1. Gather your supplies. You will need sticky notes to flag important items, a system for numbering your documents, and a notebook or computer to record the chronology itself.

1. Collect all documentary evidence. This includes letters, contracts, mortgages, emails, text messages, and advertising material — anything relevant to the dispute. Print off any relevant emails. Be careful with email trails that contain repeated copies of the same message. If your emails are arranged this way, it is better to split the trail into separate emails.

1. Separate legal documents from correspondence. Put legal documents — agreements, mortgages, and contracts — in one pile. Put all other documents and correspondence in another pile. Within each pile, arrange items in chronological order: oldest at the bottom, most recent on top.

1. Organise all correspondence the same way. Oldest at the bottom, most recent on top.

1. Set aside undated material. Any documents, advertising, or other material that carries no date should be kept in a separate pile for now.

1. Number each document. Work through each pile and assign a number to each item, starting with “1” for the oldest document. Use a different reference system for correspondence — for example, starting with “A” for the oldest item in that pile.

1. Start recording your chronology. Begin with the earliest relevant date. This might be the date you first met the other party to the dispute. The sample format at the end of this article shows you how to lay it out.

1. Add significant events. Work through your documents and enter the dates of key events into the chronology. The content of documents will often jog your memory. For example, a letter that says “We refer to our meeting last week” gives you a meeting date to add. Personal anchors help too — you might recall that a meeting happened on Melbourne Cup Day in a particular year.

1. Add your recollections. Once you have recorded all the dates you can identify from documents and memory, add bullet points describing what you remember of conversations, what was agreed, and what took place at meetings.

Unsure where to start? Call (02) 9279 0919 — we can help you prepare for your first appointment.

Sample Chronology

The table below uses a fictional family law dispute to illustrate the recommended format.

| Date | Event | Evidence | Reference |

|—|—|—|—|

| 4/5/1995 | I bought a property at 1 Smith Street, Smithsville for $500,000.00 with a mortgage to the ABC Bank of $350,000.00 and the balance from my savings. | | |

| 2/3/1997 | First met John. | | |

| 1/1/2000 | John and I moved into a property owned by John at 3 Jones Street, Harbourtown which he had inherited from his grandfather. It was worth $650,000.00. | Probate | 1 |

| 4/12/2001 | John and I married. | Marriage certificate | 2 |

| 26/6/2003 | John and I incorporated Smithsville Building Corporation Pty Ltd (“SBC”). | Certificate of Incorporation | 3 |

| 12/1/2004 | I sold my house at Smithsville for $750,000.00. | Contract | 4 |

| 8/2/2004 | John sold the property at Harbourtown for $850,000.00. | Contract | 5 |

| 7/3/2004 | John and I purchased a house at 5 Main Street, Harbourtown for $1.5m with a mortgage to XYZ Bank for $300,000.00. | | |

| 4/6/2009 | John Alexander born. | | |

| 5/11/2014 | John and I separated. | | |

| 1/3/2015 | Meeting with John and his accountants arranged to discuss property settlement. | Email | A |

| 8/3/2015 | Meeting at John’s accountant’s office: 1. John offered to purchase my shares in SBC for $1m; and 2. John agreed to me retaining the Harbourtown home. | | |