“Behold, I am sending you out as sheep in the midst of wolves,
so be wise as serpents and innocent as doves.”
Matthew 10:16
Jesus sent His people out expecting them to meet wolves. He told them to be
shrewd and to stay innocent, both at once. Being naïve will not protect you here, and
neither will becoming hard. This page is meant to help you with the shrewd part.
You are most likely here because of one person in particular. Someone across from you
has set God's word aside and is acting like it. Scripture does not pretend otherwise.
“Behold, they have rejected Yahweh's word. What kind of wisdom is in them?”
(Jeremiah 8:9)
What follows is not about them by name. These are patterns, and they run much the same
way on nearly everyone who ends up self-represented in a contested case. Naming a pattern
takes away a good deal of its power. You stop reacting to a person and start recognizing
something you have seen before. Paul wrote that “we are not ignorant of his
schemes” (2 Corinthians 2:11), and Ephesians 6:11 tells us to stand firm against
“the schemes of the devil.” The tactics are old and common, and they are worth
knowing by sight.
The person on the other side may not have arrived here on their own. Good people are
led astray, and Scripture says how. “Don't be deceived! Evil companionships corrupt
good morals” (1 Corinthians 15:33). An attorney paid to win has every reason to feed
your spouse the worst account of you, and someone frightened and grieving will believe
it.
Paul writes of people “taken captive by him to his will,” and hopes they
“may recover themselves out of the devil's snare” (2 Timothy 2:26). Your former
spouse may be more captive than commander. That does not excuse what is being done to you
and does not oblige you to trust them. It changes who you are angry at, and it gives you
someone to pray for.
Educational, not accusatory. These are common patterns observed across
many contested cases. We are not accusing any specific person, and not everyone who does
one of these things is acting in bad faith. This page is not legal advice and cannot tell
you what to do in your case. For that, please talk with your court's self-help center or a
licensed attorney. See more free help →.
If fear, monitoring, isolation, threats, or forced compliance are part of the
pattern: Start with Abuse, Safety, and Family
Court. For a closer explanation of the pattern, read
Coercive control.
Promise-and-Roll
What it looks like
You may see the other side repeatedly promise a document, response, or draft
“shortly” or “in a day or so,” but each deadline passes with only
another promise instead of the substance. Small, low-value items may be handed over to
create an appearance of good faith while the core evidence never actually arrives.
“let your ‘yes’ be yes and your ‘no’ be no”
James 5:12
The wise response
Keep a simple written log of every promise and its due date. After one reminder,
convert the open-ended promise into a plain yes/no question with a firm date, and state
that silence will be treated as a refusal rather than grounds for another extension. One
clear request and one closing note, calmly written, build a far stronger record than
repeated argumentative follow-ups.
Claim Fog
What it looks like
You may see a large or emotionally charged claim asserted, such as “all
damages” or “all missing property,” without any amount, date range, or
supporting document ever being identified, so the claim cannot be evaluated or resolved.
The total may shift from message to message with no ledger explaining the change.
“Unequal weights are an abomination to the LORD, and false scales are not
good.”
Proverbs 20:23
The wise response
Ask, in writing, for a simple itemized list before you respond to the substance. Ask
for the claim, the amount, the time period, and the document that supports it. Do not
answer an unbounded assertion with an unbounded reply. A calm, bounded request for
specifics is not evasion. It puts the burden of proof where it belongs.
Discovery Attrition
What it looks like
You may see formal requests for documents answered with boilerplate objections, partial
production, or vague promises to “supplement,” without ever clearly stating what
was produced, what was withheld, or why. Each round can consume your time while the core
evidence stays just out of reach.
Hundreds of pages get produced while the useful bank statement, text thread, or
accounting record is buried inside. More serious conduct includes withholding responsive
evidence or obstructing access to it; Rule 3.4 expressly addresses suppression or
obstruction of evidence.
“nothing is hidden that will not be made manifest”
Luke 8:17
The wise response
Track each request and response in a simple table noting exactly what remains missing
and why it matters. Raise only the deficiencies that are genuinely important and ripe, ask
plainly for a specific cure, and set a reasonable deadline. A focused, well-documented
request is far more credible than a long list of every frustration.
Paper Blizzard
What it looks like
You may receive a single message that mixes many unrelated demands, accusations, and
deadlines together, so that no reply can be both quick and complete. A long, emotional
response to all of it can then be used against you as evidence of instability or
hostility.
“let every person be quick to hear, slow to speak, slow to anger”
James 1:19
The wise response
Slow down, acknowledge receipt, and answer only the one issue that is genuinely urgent,
stating plainly that the remaining subjects will be addressed separately. Do not try to
correct every insult or answer every question in a single reply. A short, sequenced
response protects both your clarity and your record.
Incivility and Character Attacks
What it looks like
You may see personal insults, sarcasm, or attacks on your character, parenting, or
competence used in place of a legal or factual answer. Your understandably frustrated
reaction may then be quoted back, with the provocation that caused it left out.
“Do not repay evil for evil or reviling for reviling, but on the contrary,
bless.”
1 Peter 3:9
The wise response
Do not respond to the characterization. Find the one factual question underneath it
and answer only that. Keep representative examples of the pattern, not exhaustive ones, in
case tone or cost ever becomes relevant. Resist the temptation to match the tone you
received.
Deadline Ambush and Service Fog
What it looks like
You may see confusion created around when a document was actually delivered, what was
attached, or which deadline applies. That confusion can then be used to threaten default
or to claim you missed a filing. Extensions can be worded vaguely enough that a hidden
deadline remains unaffected.
“For God is not a God of confusion but of peace.”
1 Corinthians 14:33
The wise response
In one written message, pin down the facts that matter: what document, when it was
received, the operative delivery date, and the resulting deadline. Ask that any extension
be stated in exact calendar dates covering exactly which deadlines it affects, and do this
before arguing about anyone's intentions.
Moving-Target Closure
What it looks like
You may see the terms needed to close an agreement shift after you perform your part.
A new condition or a new claim appears once you have already paid or delivered what was
described as the resolution. Release language may resolve the easy logistics while quietly
leaving other claims open.
“Let what you say be simply ‘Yes’ or ‘No’”
Matthew 5:37
The wise response
Before you perform, put the closure terms in writing and ask for written confirmation
that your performance resolves every listed item through a stated date, naming any claims
that remain expressly reserved. If the other side won't confirm this in writing, you have
identified the unresolved issue before paying rather than after.
Procedural Asymmetry
What it looks like
You may notice that your own small delays or missing attachments are treated as serious
defects, while similar issues on the other side are excused as harmless. The same rule can
end up applied strictly to you and loosely to them.
“You shall do no injustice in court”
Leviticus 19:15
The wise response
Lay the two situations side by side in a short, neutral comparison. Note the
requirement, each side's compliance or defect, and the cure offered. Leave out the moral
language. Ask that the same cure standard apply to both sides. A calm request for equal
treatment persuades where an accusation of hypocrisy does not.
Recycled Proposal as Movement
What it looks like
You may receive a prior offer restated in new words and described as a “substantive
response,” when none of your specific counterpoints have actually been addressed. The
appearance of negotiating can be used to justify further delay.
“You will recognize them by their fruits.”
Matthew 7:16
The wise response
Keep a simple item-by-item matrix of your proposal and their response, and ask them to
correct the matrix rather than debate the narrative. If a “new” position turns
out to be the old one restated, a plain comparison shows this without you needing to argue
the point.
Narrative Laundering
What it looks like
You may see a letter or brief describe disputed facts, motives, or calculations as
though they were established evidence, without any sworn statement or exhibit behind them.
Confident language like “the record shows” can stand in for an actual
citation.
Lawyers sometimes say things during argument that sound like testimony:
“My client tells me…,” followed by a detailed factual narrative. Attorney
argument itself is not evidence. Watch for whether the underlying fact is actually
established by a declaration, testimony, exhibit, stipulation, or judicially noticeable
material.
“The one who states his case first seems right, until the other comes and examines
him.”
Proverbs 18:17
The wise response
Ask, calmly and specifically, which sworn statement or admitted document supports the
assertion. Object to the claim, not to the person making it. If no source is identified, a
simple, respectful request that the record reflect the evidentiary basis is often all
that's needed.
Record Recasting
What it looks like
You may see a later filing or letter describe an earlier hearing or communication in
absolute terms, such as “no evidence was offered” or “no specifics were
given,” when the actual transcript or record does not fully support that. Helpful
context or qualifying language may simply be left out.
“Do not judge by appearances, but judge with right judgment.”
John 7:24
The wise response
Set the later description next to the primary record, the transcript or the original
message, in a simple side-by-side comparison. Note where they align and where they
diverge. Concede whatever the later account gets right. Naming the accurate parts makes the
genuine mismatch far more persuasive than a blanket objection would.
Threat Leverage
What it looks like
You may be told that unless you settle, pay, or concede a point, a report, complaint, or
other consequence will follow. You may also see sanctions invoked without any specific
violation identified, mainly to intimidate rather than to cure a real problem.
“Beloved, never avenge yourselves, but leave it to the wrath of God.”
Romans 12:19
The wise response
Separate the channels in writing: address the underlying issue on its merits, and state
that any separate regulatory or reporting concern belongs in its proper channel, not as
leverage. Do not trade a concession for the threat's withdrawal, and keep the full
communication in case it becomes relevant later.
Order Laundering
What it looks like
You may see a proposed written order include findings, explanations, or conditions that
were never actually stated in the judge's ruling or the minute order. Someone else's summary
or argument can end up dressed as though it were the court's own words, quietly shaping
later disputes.
“who walks blamelessly and does what is right and speaks truth in his heart”
Psalm 15:2
The wise response
Compare the proposed order line by line against the minute order and the transcript, and
object only to the specific words that don't appear in either. Propose short, neutral
replacement language rather than reopening the merits. A precise objection tied to a source
is easy for a court to grant.
Last-Minute Document Dump
What it looks like
Important declarations or exhibits suddenly appear near the hearing, leaving little
practical time to respond.
“The one who states his case first seems right, until the other comes and examines
him.”
Proverbs 18:17
The wise response
The best response is usually calm: identify the document, page, exhibit, and exact
language. Build a simple “claim → evidence → contradiction”
sheet.
Delay as Leverage
What it looks like
Continuances, slow responses, missed discovery, repeated scheduling problems, or
requiring motions over things that could have been resolved informally can exhaust the
financially weaker spouse.
“Do not be overcome by evil, but overcome evil with good.”
Romans 12:21
The wise response
Keep your own chronological record showing what was proposed, rejected, ignored, and
actually answered. Patterns matter more than isolated incidents.
Creating a False “Reasonable Lawyer Versus Difficult Litigant” Narrative
What it looks like
Counsel sends a polished meet-and-confer letter containing a distorted history, then
later tells the judge, “We tried repeatedly to resolve this.”
“The one who states his case first seems right, until the other comes and examines
him.”
Proverbs 18:17
The wise response
Keep your own chronological record showing what was proposed, rejected, ignored, and
actually answered.
Moving the Goalposts
What it looks like
You supply exactly what was requested; suddenly something different is allegedly
missing.
“Let what you say be simply ‘Yes’ or ‘No’”
Matthew 5:37
The wise response
Document every production by date and Bates number or file name.
Making Every Disagreement Sound Like Misconduct
What it looks like
Words such as “refused,” “violated,” “concealed,”
“harassed,” and “failed to comply” are rhetorically powerful.
“You shall not bear false witness against your neighbor.”
Exodus 20:16
The wise response
Strip the labels down to dates and events. Ask: “What exact order? What paragraph?
What deadline? What conduct?”
Overwhelming a Self-Represented Party With Courtroom Vocabulary
What it looks like
Trying to overwhelm a self-represented party with courtroom vocabulary.
“For God is not a God of confusion but of peace.”
1 Corinthians 14:33
The wise response
Do not chase every accusation. Courts generally care much more about admissible evidence
tied to the requested relief than twenty side disputes.