For this paralegal certificate assignment, I wrote a fictional intake memo based on the following scenario: “Your third client of the day states, ‘I want to file for divorce.”
Intake Memo
TO: Professor Brown CASE: Gigi Westerson vs. Richard Smith
FROM: Natalie Matos, Paralegal CASE TYPE: Divorce
DATE OF MEMO: March 23, 2026 OFFICE FILE NUMBER: 26-03-108
DATE OF INTERVIEW: March 20, 2026 RE: Intake Interview of Gigi Westerson
Personal Data
Name of Client: Gigi Westerson
Address: 555 Cascade Dr., Townville, FL, 46041
Phone: 555-555-1234 (cell)
E-mail: gigi.westerson@email.com
Preferred method of contact: email, text, or phone call; no mail to home address
Age: 50
Marital Status: married, seeking divorce
Employment: assistant teacher, KidsRUs Academy, Townville, FL (10 years)
You asked me to conduct a comprehensive interview with Gigi Westerson, our client, to obtain a list of her assets, the reasons she wants to divorce her husband, and any other relevant facts regarding her wish for a divorce.
Timeline
- June 2018 (approx.) – Gigi and Richard met online via Facebook and spoke via text, calls, and social media.
- September 2018 – Gigi bought a house, titled solely in her name.
- December 2018 – Richard moved from New Mexico to Florida to live with Gigi in her home.
- February 2021 – Richard proposed to Gigi
- April 01, 2022 – Gigi and Richard married
- January 2026 – Gigi reconnected with an old friend from high school and began to consider divorcing her husband, Richard.
- March 09, 2026 – Gigi contacted our office to begin the divorce process.
General
- Gigi Westerson was born in Townville, FL. She lived in New York, New York, for about 10 years in her twenties before returning to Townville, FL.
- Richard Smith (Gigi’s spouse) is 35 years old. Before moving to Florida in December of 2018, he lived his entire life in Albuquerque, New Mexico.
- Gigi has an A.S. degree in Early Childhood Education from Townville Community College.
- Richard has no education beyond his high school diploma.
- This is the first marriage for both parties.
- Neither party has any children or pets.
- Gigi never took Richard’s last name after they married; she kept her maiden name. She did not give any reason for keeping it, other than that “she never got around to doing it.”
Financial
- Gigi earns approximately $2,000 per month.
- When employed, Richard contributes approximately $200 per month toward bills.
- Richard has had 4 jobs at various restaurants and stores since arriving in Florida in 2018. Gigi was evasive when asked whether he had quit or been fired from any of them. She said he was fired from his last job in December 2026 after working there for less than a month.
- All utilities and bills are in Gigi’s name.
- Gigi added Richard to her employer-provided health insurance.
- Gigi has her mortgage through People’s Choice Bank and also uses them as her current bank.
- Gigi has her own phone and plan through the Mobile Phone Company. Richard has a prepaid phone that she sometimes buys minutes for when he doesn’t have the money.
- Gigi and Richard currently file taxes as married, filing jointly, she thinks.
Assets
- House – 2 bedroom, 2 bath, located at 555 Cascade Dr., Townville, FL, 46041
- Purchased by Gigi in 2018 for approximately $125,000 (prior to marriage).
- Current mortgage balance: approximately $150,000 due to forbearance.
- Property is solely in Gigi’s name; Richard was never added to the mortgage or any other documents related to the house.
- The mortgage is currently in forbearance, which is set to end (unless renewed by the bank) in May 2026. Gigi is uncertain of the date. She assumes the bank will allow her to continue the forbearance as long as needed, but she couldn’t provide any evidence that they will.
- Vehicle – 2010 Kia Sorento
- Owned by Gigi (gift from parents).
- Insurance paid solely by Gigi.
- Richard doesn’t have a driver's license and relies on the bus/friends when he’s working.
- Retirement accounts
- Gigi thinks she has some money in her workplace 401k retirement account, but is unsure how much.
Debts
- Gigi has an overdrawn bank account with America’s Bank, but she is unsure exactly how much she owes them.
- Gigi also has at least two old credit cards that were maxed out and never paid, one through the Department Store of M and the other through America’s Bank. She is unsure of the amounts and if they are in collections.
- Gigi has multiple past-due amounts for her own medical expenses; she is unsure what she owes and to which doctors/hospitals.
- Gigi may be behind on her electric and water bills. She has only been paying the minimum balances required to keep them from being shut off; she is unsure of the exact amounts.
- Mortgage in forbearance status; she may owe more than the home is worth.
- Gigi doesn’t think Richard owes anyone money, but she’s not certain.
Reasons for Divorce
- Gigi seems frustrated by Richard’s inability to keep a job and contribute to the bills.
- Richard also drinks heavily. Gigi was reluctant to call him an alcoholic, but noted he’s regularly drunk when she gets home from work and that he will buy alcohol before giving her any money towards bills.
- Richard also doesn’t seem interested in helping clean, cook, or otherwise take care of the house they both live in.
- Gigi is no longer in love with him and would prefer to pursue a relationship with the old friend she reconnected with online.
- According to Gigi, there has been no violence or arguing in the home.
Conclusion
Gigi Westerson wishes to divorce Richard Smith after approximately four years of marriage due to his unemployment, alcohol use, and lack of contribution to the household. They have no children. The main asset, a home purchased by Gigi prior to the marriage and in which both parties currently live, is in forbearance. The client owns her vehicle outright, and it is in her name only. Richard doesn’t have a vehicle or a driver’s license. The client is struggling to pay bills, has multiple outstanding debts, and is behind on her mortgage payments and possibly her utility bills.
When meeting with Gigi, she was frequently distracted and unsure of herself. She was defensive when asked why she wanted to divorce Richard and whether he was aware she was having long online and virtual calls with her old friend. Gigi could not access any of her bank accounts on her phone because she forgot her passwords. She has paperwork and bills mailed to her, but admits she doesn’t always open her mail or check her emails.
Overall, she seems overwhelmed and disorganized, with limited awareness of her financial situation. She may require additional support in gathering documentation and understanding her financial obligations.
I have asked her to gather the following documents and bring them in or email them to us.
- Any mail related to her mortgage
- Current bills owed, especially her water and electric bills
- Her last 3 months of pay stubs
- The last tax return she filed
- Her last 3 months of bank account statements
- A copy of her medical insurance plan showing what Richard’s coverage is
- A statement of her current 401k
Next Steps
- Obtain financial documentation, including:
- Mortgage statements
- Credit card statements
- Utility bills
- Pay stubs and tax returns
- Verify forbearance status and timeline.
- Conduct legal research on:
- Classification of premarital property
- Potential spousal support obligations
- Assess whether referral for financial counseling or support services is appropriate.
Once we have the above documents from Gigi and have verified the information and potential issues for the divorce based on her county, I recommend we set up a follow-up meeting with Gigi to go over what we found and explain the next steps in the divorce process.