Neutralizing the So-Called Neutral

In terms of the art world, a designer “tames the material to an application.” That is exactly analogous to the lawyer's purpose when a Custody Evaluator or Guardian Ad Litem (CE/GAL) is brought into a case. Using certain practice and trial techniques, you can minimize the negative impact of a report from a “less-than-neutral” CE/GAL in a custody dispute. Obviously, your work starts long before the CE/GAL writes his or her report. When the decision is made to involve a CE/GAL, you need to be one step ahead in determining what he or she will be looking for. It is crucial that you perform an early appraisal of the critical issues in the case, including an honest assessment of both parents – and children – and the evidentiary strengths and weaknesses in your case regarding these issues. In essence, be ready with an advance sheet on which you would like the neutral to focus and be realistic about what he will likely see.