Confirming Suspected Alienation
The questions below are designed to elicit alienating responses during a deposition. It will be necessary to rewrite many of the questions to make them more relevant to a particular case.
1. How would you describe your children’s relationship with Parent prior to the divorce?
2. Have you had occasions since the divorce when you felt angry towards Parent?
3. Could you explain to the court the various reasons for your anger? (This line of questioning helps assess the Parent’s possible motivations for parental alienation).
4. Since the date of the divorce have you ever made negative comments to your kids about Parent?
5. What type of comments have you made about Parent to your kids?
6. Since the date of the divorce, have you ever argued with Parent about visitation?
7. (If yes) Could you explain your reasons for arguing or why the arguments about visitation occurred? What were the issues?
8. What have you been doing to help encourage the relationship between Parent and Child?
9. Have you ever talked with your children or asked your children about Parent’s personal life?
10. Have you failed to return the children from a visit? Why?
11. Have you ever commented to your children since the date of the divorce concerning any lack of money that was a result of the divorce?
12. Have you ever asked your children since the date of the divorce any questions regarding with which parent they want to live?
13. Since Child has been living with you, has Child ever talked to you on the telephone complaining about their time with Parent?
14. (If yes) After hearing Child’s complaints, have you felt a need to pick him up from their Parent’s home without Parent’s consent?
15. Have you shown either of your children any of the legal documents associated with this case? What documents have you shown? Why did you show them?
16. Do you believe that Parent exaggerates Child’s medical, psychological or health problems?
17. (If yes) Could you explain these exaggerations to the court?
18. Do you perceive yourself as having a very different parenting style than Parent?
19. Do you believe that Parent should follow your recommendations or beliefs about rules and discipline?
20. (If yes) Have you tried to communicate to Parent your beliefs about rules and discipline?
21. Do you believe that you have good reason for being critical of Parent’s parenting skills? Why?
22. Has Child ever suggested to you that he had a good time with Parent?
23. Have you ever heard any complaints from the children about their safety?
24. (If yes) When you heard the children complain, what did you do to communicate with Parent the complaints?
25. Have you ever expressed your anger toward Parent in the presence of your children?
26. What do you think Parent’s role as a divorced parent should be with the children?
27. What do you think the relationship should be with their stepparent?
28. Have you heard Child make allegations of abuse by Parent?
29. Have you ever known Child to exaggerate or lie to get what he or she wants?
30. What do you believe should be the Child’s relationship with Parent’s family?
31. (If negative) Would you explain your reasons why your Child’s should not have a relationship with Parent’s extended family?
32. Do you believe that Child has good reasons for not wanting to live with Parent? Why?
33. Do you believe that Child is old enough or is sufficiently maturity to decide for himself whether or not he should visit Parent?
34. Have you suggested to Child since the date of the divorce that he has the right to choose for himself whether or not to visit his Parent?
35. Since the date of the divorce would you say that there are occasions when Child is too busy to visit his Parent?
36. What have you done to help strengthen the relationship between Child and Parent?
37. Do you believe you have any responsibility to help strengthen the relationship?
38. (If no) Why not?
39. (If yes) Would you explain the steps you have taken to help strengthen the relationship between Child and Parent?
40. Do you believe that you know better than Parent as to what is best for Child?
41. (If yes) Could you explain the reasons for your belief?
42. Do you believe that Parent does not discipline Child?
43. Are you ever concerned that Parent is excessively punitive with Child? Why?
44. Since the date of the divorce, have you personally witnessed Parent being excessive with discipline?
45. Have you ever filed a complaint with the local Children’s Service Board (your jurisdiction may have a different name for the investigative agency)?
46. Could you explain the reasons for your report? (This line of questioning may offer some insight into a parent’s motivations for alienation, but at the same time it could open up a can of worms that will require a lot more testimony.)
47. Do you believe that Parent should follow your rules when it comes to how visitation is to be accomplished?
48. Do you believe that Parent should follow your rules or suggestions about how Child should be raised?
49. Do you believe that there are aspects of your private life that Parent has no business knowing?
50. Have you conveyed to your Child that he should not share any information or activities to Parent about your private life?
51. (If yes) Could you explain how you have communicated to Child that he should not share certain information with Parent?
52. What information about your life did you not want Parent to know?
53. Have you had any discussions with Child about your plans to gain his custody?
54. (If no) You mean to tell me that Child doesn’t even know you are going to court to seek his custody?
55. (If yes) Then please explain what you and Child have discussed about how you are going to get custody?
56. Would you explain what those plans are?
57. Have you ever listened in on phone calls between Child and Parent?
58. Have you ever asked Child to get information for you or report for you on any of Parent’s behavior since the date of the divorce?
59. Do you believe that the court has any right to tell you what to do with respect to your children and their relationship with Parent?
60. Would you describe Parent as a good parent or a poor parent?
61. Could you explain your reasons for your opinion?
62. Who initiated the divorce between you and Parent?
63. Could you explain the reasons for the divorce? (This line of questioning again is to assess possible motivation for parental alienation. The question is looking for continued bitterness, a sense of betrayal or anger.)
64. Do you blame Parent for the divorce?
65. Are you and Parent able to talk with each other without arguing?
66. (If no) Could you explain why you are not able to communicate?
67. Is Child presently having visits with Parent?
68. (If no) Could you explain to the court the reasons?
69. What is Child’s attitude about seeing his Parent?
70. (If the child has resisted visitation) How long have you observed these behaviors?
71. What have you done personally to help Child overcome these feelings and encourage visitation with his Parent?
72. Do you believe that whatever problems have occurred between yourself, Child and Parent that these problems should be worked out?
73. Do you believe that working out these problems is in Child’s best interest? Why or why not?
74. What do you see as your role in helping work out any problems that exist between Child and Parent?
There are many more questions that will bring out a parent’s attitude about the child’s relationship with the other parent. As one becomes more familiar with parental alienation, more questions will come to mind.
Abstract from: PARENTAL ALIENATION: NOT IN THE BEST INTEREST OF THE CHILDREN by DOUGLAS DARNALL from NORTH DAKOTA LAW REVIEW, Volume 75, 1999, p 323-364
The questions below are designed to elicit alienating responses during a deposition. It will be necessary to rewrite many of the questions to make them more relevant to a particular case.
1. How would you describe your children’s relationship with Parent prior to the divorce?
2. Have you had occasions since the divorce when you felt angry towards Parent?
3. Could you explain to the court the various reasons for your anger? (This line of questioning helps assess the Parent’s possible motivations for parental alienation).
4. Since the date of the divorce have you ever made negative comments to your kids about Parent?
5. What type of comments have you made about Parent to your kids?
6. Since the date of the divorce, have you ever argued with Parent about visitation?
7. (If yes) Could you explain your reasons for arguing or why the arguments about visitation occurred? What were the issues?
8. What have you been doing to help encourage the relationship between Parent and Child?
9. Have you ever talked with your children or asked your children about Parent’s personal life?
10. Have you failed to return the children from a visit? Why?
11. Have you ever commented to your children since the date of the divorce concerning any lack of money that was a result of the divorce?
12. Have you ever asked your children since the date of the divorce any questions regarding with which parent they want to live?
13. Since Child has been living with you, has Child ever talked to you on the telephone complaining about their time with Parent?
14. (If yes) After hearing Child’s complaints, have you felt a need to pick him up from their Parent’s home without Parent’s consent?
15. Have you shown either of your children any of the legal documents associated with this case? What documents have you shown? Why did you show them?
16. Do you believe that Parent exaggerates Child’s medical, psychological or health problems?
17. (If yes) Could you explain these exaggerations to the court?
18. Do you perceive yourself as having a very different parenting style than Parent?
19. Do you believe that Parent should follow your recommendations or beliefs about rules and discipline?
20. (If yes) Have you tried to communicate to Parent your beliefs about rules and discipline?
21. Do you believe that you have good reason for being critical of Parent’s parenting skills? Why?
22. Has Child ever suggested to you that he had a good time with Parent?
23. Have you ever heard any complaints from the children about their safety?
24. (If yes) When you heard the children complain, what did you do to communicate with Parent the complaints?
25. Have you ever expressed your anger toward Parent in the presence of your children?
26. What do you think Parent’s role as a divorced parent should be with the children?
27. What do you think the relationship should be with their stepparent?
28. Have you heard Child make allegations of abuse by Parent?
29. Have you ever known Child to exaggerate or lie to get what he or she wants?
30. What do you believe should be the Child’s relationship with Parent’s family?
31. (If negative) Would you explain your reasons why your Child’s should not have a relationship with Parent’s extended family?
32. Do you believe that Child has good reasons for not wanting to live with Parent? Why?
33. Do you believe that Child is old enough or is sufficiently maturity to decide for himself whether or not he should visit Parent?
34. Have you suggested to Child since the date of the divorce that he has the right to choose for himself whether or not to visit his Parent?
35. Since the date of the divorce would you say that there are occasions when Child is too busy to visit his Parent?
36. What have you done to help strengthen the relationship between Child and Parent?
37. Do you believe you have any responsibility to help strengthen the relationship?
38. (If no) Why not?
39. (If yes) Would you explain the steps you have taken to help strengthen the relationship between Child and Parent?
40. Do you believe that you know better than Parent as to what is best for Child?
41. (If yes) Could you explain the reasons for your belief?
42. Do you believe that Parent does not discipline Child?
43. Are you ever concerned that Parent is excessively punitive with Child? Why?
44. Since the date of the divorce, have you personally witnessed Parent being excessive with discipline?
45. Have you ever filed a complaint with the local Children’s Service Board (your jurisdiction may have a different name for the investigative agency)?
46. Could you explain the reasons for your report? (This line of questioning may offer some insight into a parent’s motivations for alienation, but at the same time it could open up a can of worms that will require a lot more testimony.)
47. Do you believe that Parent should follow your rules when it comes to how visitation is to be accomplished?
48. Do you believe that Parent should follow your rules or suggestions about how Child should be raised?
49. Do you believe that there are aspects of your private life that Parent has no business knowing?
50. Have you conveyed to your Child that he should not share any information or activities to Parent about your private life?
51. (If yes) Could you explain how you have communicated to Child that he should not share certain information with Parent?
52. What information about your life did you not want Parent to know?
53. Have you had any discussions with Child about your plans to gain his custody?
54. (If no) You mean to tell me that Child doesn’t even know you are going to court to seek his custody?
55. (If yes) Then please explain what you and Child have discussed about how you are going to get custody?
56. Would you explain what those plans are?
57. Have you ever listened in on phone calls between Child and Parent?
58. Have you ever asked Child to get information for you or report for you on any of Parent’s behavior since the date of the divorce?
59. Do you believe that the court has any right to tell you what to do with respect to your children and their relationship with Parent?
60. Would you describe Parent as a good parent or a poor parent?
61. Could you explain your reasons for your opinion?
62. Who initiated the divorce between you and Parent?
63. Could you explain the reasons for the divorce? (This line of questioning again is to assess possible motivation for parental alienation. The question is looking for continued bitterness, a sense of betrayal or anger.)
64. Do you blame Parent for the divorce?
65. Are you and Parent able to talk with each other without arguing?
66. (If no) Could you explain why you are not able to communicate?
67. Is Child presently having visits with Parent?
68. (If no) Could you explain to the court the reasons?
69. What is Child’s attitude about seeing his Parent?
70. (If the child has resisted visitation) How long have you observed these behaviors?
71. What have you done personally to help Child overcome these feelings and encourage visitation with his Parent?
72. Do you believe that whatever problems have occurred between yourself, Child and Parent that these problems should be worked out?
73. Do you believe that working out these problems is in Child’s best interest? Why or why not?
74. What do you see as your role in helping work out any problems that exist between Child and Parent?
There are many more questions that will bring out a parent’s attitude about the child’s relationship with the other parent. As one becomes more familiar with parental alienation, more questions will come to mind.
Abstract from: PARENTAL ALIENATION: NOT IN THE BEST INTEREST OF THE CHILDREN by DOUGLAS DARNALL from NORTH DAKOTA LAW REVIEW, Volume 75, 1999, p 323-364
