8.7 Information-gathering

• Library: Virginia Family Law: A Systematic Approach (Virginia CLE) (2018 Ed.)

8.7 INFORMATION-GATHERING

8.701 Information Needed. Before commencing a suit concerning child custody or visitation, counsel must make a reasonable investigation of the facts and the law. ⁷⁶ In a dispute between the child's parents, where the "best interests" of the child govern, the scope of evidence that will be relevant to the court is very broad. The factors that must be considered by the court will help to guide counsel's informal investigative efforts. ⁷⁷ Counsel may wish to gather information concerning the following:

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1.	The age of the child;
2.	The child's physical and mental health and developmental needs;
3.	Which parent the child has been living with;
4.	The times when the child lived with each parent;
5.	Who the child's "primary caretaker" was during the child's early years;
6.	Each parent's child-rearing ability and history;
7.	The amount of time each parent has available for the child;
8.	The work schedules of each parent;
9.	Each parent's involvement in the child's schooling;
10.	Each parent's income;
11.	Prior financial support of the child;
12.	Each parent's age;
13.	Each parent's education and training;
14.	Each parent's residential history;
15.	Plans of either parent to relocate;
16.	Each parent's moral conduct;
17.	Each parent's physical and mental health;
18.	Each parent's use of alcohol and drugs;
19.	Each parent's use of firearms;
20.	Any history of family violence;
21.	Each parent's efforts to encourage contact between the child and the other parent;
22.	Each parent's efforts to obstruct contact between the child and the other parent;

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23.	Each parent's ability to communicate and cooperate with the other parent in resolving disputes concerning matters affecting the child;
24.	Each

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