Last updated October 4, 2026.
Bring the facts and papers that Pennsylvania's divorce, support and custody rules will ask for anyway: your marriage details and separation date for the complaint (Pa.R.C.P. 1920.12; 23 Pa.C.S. 3103), recent tax returns and six months of pay stubs for support (Pa.R.C.P. 1910.11(c)), statements for every asset and debt as of the separation date for the property inventory (Pa.R.C.P. 1920.33), and any agreement, court order or protection order already in place. With those in hand, a first meeting can move from general questions to a plan.
Giribaldi Law offers free consultations at our office at 117-119 N. Olive St. in Media, across from the Delaware County Courthouse, with evening and weekend appointments available. For the family matters we handle, see our family law page.
What is the full checklist?
| Bring | Why it matters | Rule or statute |
|---|---|---|
| Date and place of marriage; each spouse's address; any earlier divorce case between you | Required in the divorce complaint | Pa.R.C.P. 1920.12(a) |
| How long each of you has lived in Pennsylvania | Six-month residency to file | 23 Pa.C.S. 3104(b) |
| The date you stopped living together as spouses, with proof | Starts the one-year clock and fixes the inventory date | 3103; 3301(d); Rule 1920.33 |
| Last federal tax return with schedules, W-2s and 1099s; business returns and K-1s if self-employed | Support and alimony calculations | Pa.R.C.P. 1910.11(c) |
| Six months of pay stubs for you, and any you have for your spouse | Support uses an average of at least six months of income | Rules 1910.11(c) and 1910.16-2(a) |
| Bank, investment, retirement and pension statements near the wedding date, the separation date and now | Marital versus separate property and values | 23 Pa.C.S. 3501; Rule 1920.33 |
| Deed, mortgage statement and any appraisal for the home | Usually the largest asset | 3502 |
| Loans, credit cards and other debts in each name | Liabilities go on the inventory | Rule 1920.33(a)(3) |
| Proof of gifts, inheritances or pre-marriage assets | Excluded property must be traced | 3501(a)(1) and (3) |
| Any premarital, postnuptial or separation agreement, with exhibits | May exclude property or set alimony | 3106; 3105; 3501(a)(2) |
| Child care, health insurance and children's medical costs | Added to child support | Rule 1910.16-6 |
| The current custody schedule, school information and any safety concerns | Custody factors and the criminal record and abuse history form | 23 Pa.C.S. 5328; Rule 1915.3-2 |
| Any existing custody, support or protection order and any criminal case papers | Current obligations and safety factors | 5328(a)(2); 5329 |
| Life insurance, retirement beneficiary forms and your will | Beneficiaries need review after divorce | 3323(b.1) |
How should I prepare, step by step?
- Write a short timeline. Wedding, children's birth dates, moves, the separation date and any key events, such as a protection order.
- Gather income records. Use the support rule's list as your guide: tax returns with schedules, W-2s and 1099s, and six months of pay stubs (Rule 1910.11(c)). If you or your spouse are self-employed, add business returns.
- Collect account statements. For each account, try to find one near the wedding, one near separation and the latest one. These map directly onto the inventory each spouse must file (Rule 1920.33(a)).
- List debts. Note whose name each is in and whether payments have been made since separation; the pre-trial statement asks for both (Rule 1920.33(b)(9)).
- Find agreements and orders. A premarital agreement, an existing support order or a PFA changes the starting point.
- Write down your goals and your questions. For example, staying in the house, a schedule for the children, or keeping a pension.
- Note deadlines you already face. A hearing date, a 20-day appeal window in a support case or a relocation notice.
If you have not filed yet, the filing steps in Media are in how to file for divorce in Delaware County.
What if I do not have access to my spouse's records?
That is common, and it does not need to delay the consultation. Bring what you have and a list of what you know exists, such as an employer's name, a bank or a retirement plan. Once a case is filed, discovery is available as in other civil cases (23 Pa.C.S. 3505(c)), each spouse must file an inventory (Rule 1920.33(a)), and in a Delaware County support case a party can ask for discovery by written motion when income is unclear (Delaware County Local Rule 1910.9(c)). Do not take or copy your spouse's private papers in ways that could create other problems; ask first how to obtain them properly.
If you think assets are being moved, say so at the consultation. The court can issue an injunction against disposing of property to defeat distribution or support (3505(a)), and an undisclosed asset worth $1,000 or more left out of the division can later be placed in a constructive trust (3505(d)).
What questions are worth asking at the first meeting?
The papers answer the "what"; your questions should cover the "how" and "when." These are the questions that usually shape the plan in a Pennsylvania divorce:
- Which grounds fit? Mutual consent after 90 days, or one year of separation if your spouse will not sign; see what if your spouse will not consent.
- Which claims should be raised? Property division, alimony, alimony pendente lite and counsel fees can be lost if not claimed before the decree, as the notice at the start of every complaint warns (Pa.R.C.P. 1920.71).
- Is temporary support available now? Spousal support before filing, or alimony pendente lite once the divorce is filed; see spousal support, APL or alimony.
- Does an agreement control? A premarital or postnuptial agreement can exclude property; see whether a prenup is enforceable.
- What about the children right now? A temporary schedule, school and the home, and whether a custody complaint should be filed at the same time.
- What is the likely sequence in Delaware County? Filing at the Office of Judicial Support, service, the hearing officer's conferences and, for custody, the conciliator.
Write your questions down before the meeting and bring them; it is easy to forget the most important one once the conversation starts.
What changes the answer?
- Children. Add the schedule, school and health details and any safety concerns; see the steps in a Delaware County custody case.
- Support needs now. If you need support before the divorce, bring the documents for a support conference; see how child support is calculated.
- A business or professional practice. Bring business returns and financial statements.
- A pension. Bring a statement of service dates and the accrued benefit; the coverture fraction depends on months of service (3501(c)).
- Abuse. Bring any PFA, police reports and photos; safety is weighted in custody (5328(a)), and your address can be protected from disclosure (5336(b)).
- Estate planning. A divorce is a good time to review a will and living will; see our living wills page. A divorce also changes how an existing will treats a spouse, as explained in what makes a will valid in Pennsylvania.
For example: a well-prepared first meeting
Here is a hypothetical. A woman in Brookhaven, married 16 years, wants to file for divorce. She brings a one-page timeline showing the separation date, last year's tax return, six months of pay stubs, recent statements for two bank accounts and her 401(k), a statement for her husband's pension that she found at home, the mortgage statement and a printout of their credit cards.
She also brings the custody schedule they have been following and a note about the children's schools. In one meeting, she and her lawyer can confirm residency and venue, spot that the pension needs a coverture fraction, see that she may qualify for spousal support now, and plan whether to try for a written settlement or prepare for the hearing officer. This example only illustrates the preparation; it does not predict any result.
What mistakes do people make before a consultation?
- Coming without income papers. Support and alimony questions cannot be answered without them.
- Not knowing the separation date. It controls timing and values.
- Moving money first. It can look like dissipation, a listed factor (3502(a)(7)).
- Leaving out an existing order. Current orders must be followed until changed.
- Forgetting the agreement. A premarital agreement may decide major issues (3106).
- Bringing children to the meeting. Arrange child care so you can talk freely.
What should I do this week?
- Write the timeline and the separation date.
- Download or request tax returns, pay stubs and account statements.
- Copy the deed, mortgage and loan statements.
- Find any agreements, orders or protection orders.
- List your goals and questions.
- Call to book the consultation.
Frequently asked questions
Is the first consultation free?
Yes. Giribaldi Law offers a free consultation, with evening and weekend appointments available.
Should I bring my spouse?
No. A lawyer represents one spouse, and you should be able to speak freely.
What if I am not sure I want a divorce?
A consultation can still cover your options and timing; see how long a divorce takes.
What if I have already been served with divorce papers?
Bring the complaint and every page that came with it, including the notice to defend, and note the date you received it. If an affidavit under section 3301(d) came with a blank counter-affidavit, its statements are treated as admitted unless you deny them (Rule 1920.14(b)), so do not wait.
What if there is a support or custody hearing coming up?
Bring the notice. Support conferences have their own document list, and missing a 20-day window to ask for a judge can make an order final.
Do I need originals?
Copies are fine for a first meeting; keep the originals safe, especially of any agreement.
Where is the office?
117-119 N. Olive St., Media, across from the Delaware County Courthouse, where family cases are heard; see Delaware County family court.
Call Giribaldi Law at (610) 891-8303 or contact us online to schedule your free consultation. Evening and weekend appointments are available.
Sources
- Pa.R.C.P. 1920.12: the divorce complaint
- Pa.R.C.P. 1920.71: notice to defend and claim rights
- Pa.R.C.P. 1920.14: counter-affidavit
- Pa.R.C.P. 1920.33: inventory and pre-trial statement
- Pa.R.C.P. 1910.11: documents for a support conference
- Pa.R.C.P. 1910.16-2: income for support
- Pa.R.C.P. 1910.16-6: additional expenses
- Pa.R.C.P. 1915.3-2: criminal record or abuse history
- 23 Pa.C.S. 3103: definitions
- 23 Pa.C.S. 3104: residency
- 23 Pa.C.S. 3501: marital property
- 23 Pa.C.S. 3505: discovery, injunctions and undisclosed assets
- 23 Pa.C.S. 3323: beneficiary designations
- Delaware County local rules of civil procedure (Rule 1910.9(c))
