Prompt Pilotby Write.law
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Strategy

Build a child support deviation argument

Turns a guideline number you already ran into a deviation the judge can actually write: factor, facts, evidence, arithmetic, and an adoptable finding, with the counter-move on each ground named.

About 25 minadvancedFamily

Your prompt5,294 characters

Still to fill in: State and court, Guideline baseline and its inputs, What I am asking for, Facts supporting departure

RoleYou are a family lawyer who has argued dozens of deviation motions and lost the ones where the number came before the finding. You build a deviation the way the judge has to write it: factor, facts, evidence, dollars, and a sentence the court can adopt. You never argue from a guideline number whose worksheet you have not seen.What I needBuild the child support deviation argument for a case in State and court. My goal: What I am asking for.InputsState and court: State and court Guideline baseline and its inputs: Guideline baseline and its inputs What I am asking for: What I am asking for Facts supporting departure: Facts supporting departure My state's deviation factors, pasted: My state's deviation factors, pastedHow to work this1. Restate the baseline in numbers first: the guideline figure, the inputs that produced it, and the delta to my target. If I have not given you a worksheet output, say you cannot build the argument and name the inputs you need. Never compute or estimate a guideline number yourself. 2. Work only from the factor list in My state's deviation factors, pasted. If I pasted none, do not supply one. Produce the argument with the factor slot blank and marked [INSERT YOUR STATE'S FACTOR - verify the text before filing]. 3. Build each ground in five parts: the factor as written, the facts that trigger it, the evidence that proves those facts, the dollar adjustment with its arithmetic, and a finding sentence the court could adopt verbatim. 4. Separate the three fights people conflate. An income determination (imputation, underreporting, distributions) is not a deviation. An allocation of add-ons (childcare, health premium, uninsured medicals, private school) is not one either. Say which of the three actually gets my client the money, and whether the quieter route reaches the same place. 5. Rank the grounds by dollars gained against proof required. Name the one to lead with and the one to abandon. 6. Run the counter-move on each ground. An upward ask invites imputation of income to my client and a look at their spending; a downward ask invites a lifestyle audit and the business returns. Name the exposure each ground opens. 7. Handle the tail: effective date and retroactivity, what this does at the next modification, and whether a deviation granted on these facts becomes hard to undo when the facts change.Ask me firstBefore you produce anything, ask me these questions, then stop and wait: 1. What number does the state worksheet actually produce, and what inputs generated it: each parent's income figure, overnights, health premium, childcare, credits for other children? 2. Which direction and how much? Give me the target monthly figure and tell me what the client needs as opposed to wants. 3. What does State and court list as deviation grounds, and must the court make written findings? Paste the text if you have it. I will not supply it from memory. 4. How many overnights a year does each parent actually have, and does your guideline already adjust above a threshold? 5. What can you prove, and with what: receipts, an IEP, medical records, pay records, business returns, a vocational evaluation? Do not begin until I answer. If I tell you to proceed anyway, state each assumption at the top and mark it [ASSUMPTION - verify].Output formatThe baseline restated in numbers with the delta to target. Then each ground as a five-part block: factor, facts, evidence, dollars with arithmetic, adoptable finding. Then the ranking with a recommended lead, the exposure each ground opens, a route comparison across deviation versus income determination versus add-on allocation, and the retroactivity note. End with one line naming the two of my answers that most changed the ranking, and which ground you would have led with without them. If an answer changed no ground, say so. It means I should not have been asked.Never do this- If this argument would fit any support case in any state, it is too generic. Anchor it to this worksheet, these overnights, these receipts. - No hedging filler. Cut "arguably," "it should be noted," and "the court has broad discretion" offered as though it were an argument. Do not tell me to consult family counsel. I am family counsel. - Never invent or estimate a guideline amount, a schedule value, a self-support reserve, a statutory factor, a percentage, or a citation. Every number comes from my inputs or is marked [UNVERIFIED - run it through the state calculator]. - Where you do not know whether State and court recognizes a ground, say you do not know and leave the slot blank. Do not smooth the gap over with fluent prose. - Do not pad. Two grounds with proof beat six without. Length is not value.Before you answer- Did I restate the baseline and the delta using only numbers from the inputs? - Did any factor, schedule figure, or dollar amount come from me rather than the lawyer? - Does every ground rest on evidence that exists, not evidence that would be nice to have? - Did I give the court a finding sentence it could adopt verbatim? - Would this argument fit a different family? It should not.

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

2

Pressure-test it

Makes the AI switch hats and attack its own answer.

Take the bench and answer as the judge who treats the guideline number as presumptively correct and has to write findings that survive appeal. For each ground, say what makes it look like a request to re-litigate the parenting schedule through the checkbook, which evidence you would find thin, and what the obligor's lawyer will say in twenty seconds. Then tell me which single ground you would grant, at what number, and what the order would have to say.
3

Go deeper

Pushes the work further once the basics are right.

Court staff will look for the proposed findings before they look at the motion. Draft the filing package: the motion with the deviation grounds in the order you recommended, the proposed findings of fact written so the court can sign them, the exhibit list keyed to each factual assertion, and the direct examination outline for the client covering the expenses, the documents that prove them, and the two questions opposing counsel will open with on cross.

Before you run it

What to gather first

  • The completed guideline worksheet and every input that produced the number
  • Your state's statutory or rule-based deviation factors, in their current text
  • Overnights per year for each parent, counted the way your guideline counts them
  • The documents that prove the facts: receipts, an IEP, medical records, pay records, business returns
  • Whether your court requires written findings to depart from the presumptive amount

Watch for

  • Deviation factors, findings requirements, high-income treatment, and parenting-time adjustments are set by state statute or rule and change. Read the current text yourself. Do not use any factor the model states without confirming it.
  • Never accept a guideline amount the model produces. Run the number through your state's own calculator or worksheet and treat the model's arithmetic as a draft to check.
  • An upward deviation request invites imputation of income to your client and scrutiny of their spending. A downward request invites a lifestyle audit. Weigh the exposure before filing.
  • Retroactivity and effective-date rules for support modification vary and can wipe out months of relief. Confirm them in your jurisdiction before advising the client what this is worth.
  • Do not paste the client's financial affidavit, medical records, or a child's IEP into a model without checking your firm's AI policy and any protective order in the case.

What comes back

The baseline restated in numbers with the delta to target. Then each ground as a five-part block: the factor as written, the triggering facts, the proof, the dollar adjustment with its arithmetic, and a finding sentence the court could adopt verbatim. Then the ranking by dollars against proof with a recommended lead ground, the exposure each ground opens, a comparison of the deviation route against an income determination and an add-on allocation, and the retroactivity note.

See an example of what you’ll get
*(After you answer the five questions: presumptive amount $1,742/month, target $2,400, Georgia income shares, factor text pasted.)* BASELINE. Worksheet of 6/2/2026 produces $1,742/month from father. Target is $2,400. Delta: $658/month, or $7,896 a year. Every ground below has to account for a piece of that number, and the pieces have to add up to something a court can write down. GROUND 1: Extraordinary medical expense (high-value, well documented) - *Factor:* the extraordinary medical expense provision you pasted, which permits deviation where uninsured medical costs exceed the amount already built into the schedule. - *Facts:* Uncovered ABA therapy of $1,180/month after the plan's 20-visit annual cap, running 14 consecutive months. - *Evidence:* IEP; 14 months of EOBs showing denial after the cap; provider invoices; the plan's benefit summary. This is the strongest documentary record in the case. - *Dollars:* $1,180/month total. Father's pro rata share on the worksheet's income split (9,400 / 13,250 = 70.9%) is $837/month. That alone exceeds the $658 delta. - *Adoptable finding:* "The Court finds that the minor child incurs uninsured medical expenses of $1,180 per month for applied behavior analysis therapy, which exceed the amount contemplated by the presumptive award, and that Father's proportionate share of $837 per month is a reasonable and necessary deviation." GROUND 2: Travel to the therapy provider (small, easy) - *Facts:* 140 miles per week round trip, roughly 607 miles/month. - *Dollars:* At the federal mileage rate in effect on your filing date (do not take a number from me), this is roughly $340-$420/month gross, father's share about $250-$300. [UNVERIFIED - confirm the applicable rate and whether Georgia's provision reaches transportation for medical care rather than only for visitation.] - *Adoptable finding:* left blank until the factor text is confirmed. GROUND 3: The employer-paid vehicle and phone (recharacterize, do not deviate) - This is not a deviation. It is an income determination. Roughly $700/month of in-kind compensation shows on father's W-2 box 14; if it goes into gross income, his figure moves from $9,400 to about $10,100 and the presumptive amount rises before any deviation argument begins. - This is the cheaper route to part of the same money, and it does not require the court to depart from the guideline at all. RANKING 1. Ground 1: best dollars-to-proof ratio in the case. Lead with it. 2. Ground 3: recharacterize income. Quiet, technical, and it raises the floor everything else sits on. 3. Ground 2: worth including, not worth arguing. It reads as thoroughness, not as a demand. ROUTE COMPARISON. Deviation on Ground 1 alone gets you to roughly $2,579 (above target) but it is a departure the court must justify in writing and that father will move to modify the moment therapy ends. Income recharacterization on Ground 3 raises the presumptive amount permanently and is much harder to unwind, but yields less. Running Ground 3 first and Ground 1 as the deviation on top of the corrected baseline is the strongest sequence. EXPOSURE. Ground 1 invites the argument that mother chose an out-of-network provider; have the network adequacy answer ready. Ground 3 invites father's counsel to ask what mother's parents contribute toward the household, which is the question she does not want to answer under oath. RETROACTIVITY. [UNVERIFIED - confirm Georgia's rule on the effective date of a modified award and whether it runs from filing or from service. This decides whether fourteen months of ABA expense is recoverable or merely persuasive.] --- Assumptions I made. The 70.9% income split comes from your worksheet inputs, not from a recalculation [safe]. The ABA cap denial is annual, not lifetime [verify against the plan document]. Georgia requires written findings for any deviation [verify]. I did not supply any factor text. Every factor above is quoted from what you pasted, except Ground 2, which is left open. What your answers changed. Pasting the actual factor text is what let Ground 1 be written as a five-part block with a finding the court can sign. Without it, every adoptable finding above comes back as an empty slot and this is a research memo, not a motion. The worksheet inputs are what make Ground 1 worth $837 rather than a number I would have refused to produce. Your $2,400 target changed the ranking but not the grounds: a smaller ask would have put Ground 3 first, because a corrected baseline is far harder for father to unwind than a deviation.
Why this prompt is built the way it is
## Framework 1. **Baseline before argument.** The guideline figure and the inputs that produced it come from the lawyer's worksheet, never from the model. 2. **Factors come from the statute in front of you.** A deviation ground the model recalls is a ground you will not find when you look. 3. **Five parts per ground.** Factor, facts, evidence, dollars with arithmetic, adoptable finding sentence. 4. **Three different fights.** Deviation, income determination, and add-on allocation are separate routes to the same money. Pick the one with the least resistance. 5. **Rank by dollars over proof.** The strongest ground is the one you can document, not the one that sounds worst. 6. **Every ask opens a door.** Upward invites imputation and a spending review; downward invites a lifestyle audit. 7. **Think past the ruling.** Effective date, retroactivity, and what this deviation costs at the next modification.