Fact Pattern

The Husband (54) and Wife (39) have been married for fourteen (14) years and have three (3) children, a girl age 16, two boys ages 12 and 9. Two weeks ago, after the daughter disclosed the Husband’s ongoing sexual abuse, the Wife discovered that the Husband has had several mistresses over the years and has recently set up the current mistress in an apartment of her own along with his new baby boy. During the marriage, the Husband has been the primary wage-earner throughout the marriage, building and managing a very successful closely held pharmaceutical company that was started by the Husband’s grandfather. The Wife hasn’t worked for the past ten (10) years, but it was her income as a successful real estate agent that put the Husband through undergraduate and graduate school both before the marriage and in the first few years. While the couple has been married, they have acquired numerous properties and various cars, boats, etc. The Husband has added to his extensive gun collection that began when he received several Civil War era muskets from his grandfather’s estate.

The Wife has come to you for representation and has provided you with her expired immigration paperwork along with as much financial information she can find, all twelve (12) boxes pilfered from the Husband’s office over the last several weeks.

Your task: Analyze the legal aspects of the case and provide recommendations to the senior partner as to the contents of the Petition and potential pitfalls.