Walter and Renee Albertson have been married for thirty-seven years and have three adult children: Eleanor, Edward, and Walter, Jr. The marriage has been rocky, and each party believes that the other has been "unfaithful" on several occasions. The only confirmed affair occurred in 1996 when Renee became involved with a next-door neighbor and at one point moved in with him after Walter "threw her out" of the marital home because of the ongoing and open affair. After a month, he begged her to come home. She did, and they went to counseling, reconciled, and resumed their marital relationship. However, Walter never really trusted Renee after that. As a result, he kept all of his assets as separate as possible from hers, with the exception of a joint bank account, out of which he paid all of the expenses related to the marital home as well as the food bills and car-related costs. Renee has been depositing her entire paycheck into this account, but Walter only matches what she puts in. He earns funds from four sources: Social Security, a modest salary as a school bus driver, an investment portfolio he established in 1985 and has maintained ever since, and money he earns doing electrical work "under the table," for which he is paid cash or "in-kind" (e.g., he does some wiring for his mechanic, and the mechanic repairs Walter's vehicle without charging him). He deposits his Social Security into the joint account along with about 20% of his check from the bus company. Throughout the marriage, he has maintained the couple's finances and largely kept Renee "in the dark," although he does give her a modest weekly "allowance." He has always kept extensive financial and business records on his computer. He pays his bills online and uses Turbo Tax to prepare the parties' joint tax returns. The marital home (jointly held) is assessed at $350,000 for property tax purposes, but Walter claims it is worth closer to $500,000, based on work he has done building an addition that includes a den, bedroom, and bath with a hot tub in it. He spent the better part of a year doing the work in his free time. There is a $112,000 mortgage and a $20,000 equity loan secured by the property. The parties had to obtain the loan to cover income taxes (plus interest and penalties) due to previously undeclared income Walter had collected doing electrical work for friends and acquaintances. He asserts that he is not still doing this work, but Renee is certain he continues to do it and not pay taxes on the funds collected or on in-kind services received. He claims to never have any money but went to Aruba for a week in January 2015, allegedly alone, and has a new Toyota convertible, for which Renee believes he paid cash. She also saw a credit card statement that listed expenditures at two local jewelry stores and several local restaurants that she has not been to with him. In December 2014, Renee became suspicious that Walter was having an affair with his old high school sweetheart, Valentina Ferrara, with whom he "reconnected" at his fiftieth high school reunion. Valentina had recently been widowed. Walter admits that he is "in touch" with her (particularly by telephone and e-mail) but that she would never consider having an intimate relationship with him as long as he is still married. Besides, he claims that at the age of seventy, he is no longer able to function sexually. Renee believes he is seeing a doctor and has a prescription for "that little blue pill." Renee's heart is broken, and she has filed for divorce on the ground of adultery in a jurisdiction that retains fault grounds.

Assume that you are a paralegal working for Attorney Juliana Dahl Johnson, who represents Renee in the above hypothetical. You have been asked to suggest an appropriate discovery plan to guide the information-gathering effort in this case. Develop an informal discovery planthat would be appropriate for use in connection with the fact pattern provided. Be sure to also note any other forms of discovery that might be appropriate for these facts and why. The plan you propose should identify the kinds of information needed, the techniques to be utilized (both formal and informal), the sequencing of efforts, and the assignment of tasks. After she reviews and approves the plan, the attorney will eventually estimate the projected cost and discuss the plan with Renee. The fact pattern indicates Renee is filing for divorce on the grounds of adultery. Assume that in the jurisdiction where you reside and/or are employed when making property division decisions, the court considers both conduct during the marriage and financial and nonfinancial contribution to the marital enterprise. Your plan should include at a minimum of five examples of informal discovery. It should also include use of at least three methods of formal discovery with examples of the kinds of information to be sought using each method. You should consider weaving electronic discovery into various aspects of your plan.