Depositions questions about unemployed spouse’s attempts to find work and employment prospects

When one spouse seeks support or alimony, the divorce lawyer representing the employed spouse will typically take the other spouse’s deposition. The divorce lawyer representing the employed spouse should inquire into the attempts by the spouse seeking support to secure employment, or employment more suitable to her education and work history. A series of questions for this line of inquiry of a spouse who is not currently employed, or is “under employed” follows.

• When did you last work?
• Was it full or part time?
• Who was your employer?
• What were your title and duties?
• What was your salary?
• Have you been seeking full time work?
• If not, why not?
• If yes, what attempts have you made to secure full time employment?
• Do you have a resume?
• Do you need any additional education or training to secure a better/more lucrative position?
• What job skills do you possess?
• For what other types of employment are you qualified?
• Does anything prevent you from working full time?  If so, what?