Litigation Tactics for CFIs & PREs (Presentation at the 2021 Colorado Family Law Institute) | Episode 50

Mitigating Parenting Evaluations in Colorado Divorce Cases (CFIs & PREs)In this episode of Divorce at Altitude, Ryan Kalamaya is joined by John Zervopoulos for a practical, strategy-focused discussion on mitigating adverse parenting evaluations in Colorado divorce and custody disputes. They break down what happens when a court-appointed Child and Family Investigator (CFI) or Parental Responsibilities Evaluator (PRE) issues a report that could seriously impact parenting time or decision-making—and what lawyers and clients can do next.The episode covers key procedural and litigation tools (discovery, evaluator-file requests, subpoenas, depositions, consulting experts, and the realities of motions to strike), along with John’s structured approach for analyzing evaluator work. Using frameworks like the “three-legged stool” (interviews, testing/questionnaires, and collateral sources) and the PLAN Model (qualifications, methods, reasoning, and the link between data and recommendations), they explain how to spot gaps, bias, and weak support for conclusions—while keeping the court’s perspective in mind and using the evaluation record to reinforce your client’s narrative.Guest InformationJohn Zervopoulos is a board-certified forensic psychologist and attorney who consults nationwide with family law attorneys on mental health issues, expert testimony, and litigation strategy. Through his practice, he assists lawyers with deposition preparation, cross-examination, motion drafting, and understanding psychological evaluations in custody and parenting disputes. He is also an author published by the American Bar Association on examining mental health experts.Episode OutlineWhen Parenting Evaluations Go Wrong The reality of adverse CFI and PRE recommendations.Procedural Options After a Bad Report Discovery, depositions, motions to strike, and consulting experts.Looking Under the Hood Why evaluator files, billing records, and timelines matter.Conceptual vs. Practical Frameworks Understanding best-interest analysis and evaluation structure.The PLAN Model Explained Qualifications, methods, reasoning, and opinion reliability.Bias and Analytical Gaps Identifying confirmation bias, overconfidence, and missed alternatives.Effective Examination Strategy How to challenge or support evaluators while persuading the court.What is Divorce at Altitude? Ryan Kalamaya and Amy Goscha provide tips and recommendations on issues related to divorce, separation, and co-parenting in Colorado. Ryan and Amy are the founding partners of an innovative and ambitious law firm, Kalamaya | Goscha, that pushes the boundaries to discover new frontiers in family law, personal injuries, and criminal defense in Colorado. To subscribe to Divorce at Altitude, click here and select your favorite podcast player. To subscribe to Kalamaya | Goscha's YouTube channel where many of the episodes will be posted as videos, click here.  If you have additional questions or would like to speak to one of our attorneys, give us a call at 970-429-5784 or email us at [email protected].************************************************************************DISCLAIMER: THE COMMENTARY AND OPINIONS ON THIS PODCAST IS FOR ENTERTAINMENT AND INFORMATIONAL PURPOSES AND NOT FOR THE PURPOSE OF PROVIDING LEGAL ADVICE. CONTACT AN ATTORNEY IN YOUR STATE OR AREA TO OBTAIN LEGAL ADVICE ON ANY OF THESE ISSUES.