Has a client asked you to look under every rock to account for every dollar spent in their 20-plus year marriage? Has a party refused to provide responses to discovery to the point where litigation has ground to a halt and the case cannot proceed? Has a client demanded that you depose the other party’s employer? If you are regularly involved in divorce litigation, the answer to these questions is likely a resounding “yes.”

With the oft-reported judicial vacancies and the backlog of divorce cases in New Jersey—which has hovered between 4,000-5,000 cases over the past year—divorce matters, in particular, often feel stagnant. Many litigants find themselves desperate to move their matters forward. Complicating this dynamic is the inevitable lack of trust between the parties and the need to ensure the parties are educated as to the income, assets, and liabilities of one another. Litigants—and practitioners—are thus forced, now more than ever, to educate themselves on their case outside of a courtroom. But how much education is really needed? When is enough really enough? There is a broad discovery standard in New Jersey for matrimonial matters; broad, however, does not mean limitless.