Client: [Your Name]
Defendant: [Husband’s Name]
Context: Pattern of deliberate obstruction, interference with personal property, and damages.
1. Timeline of Incidents
| Date | Incident | Description | Evidence |
|---|---|---|---|
| [Date] | Computer wiped | Husband deleted all data on your personal computer without consent. | Backup drive with original data, screenshots, logs, company invoice for wipe, messages referencing deletion |
| [Date] | Security system locked | Codes changed by husband; could not access home security system. System registered in his name. | Invoices for code change/reinstallation, screenshots of failed access, messages/emails requesting access |
| [Date] | Car key withheld | Husband took your car key and did not return it, preventing use of your vehicle. | Proof of car ownership, photos of keys, messages/emails requesting return, receipts for alternative transportation if applicable |
Optional column: Impact / Damage — for civil claim purposes (e.g., cost of recovery, lost work, inconvenience).
2. Civil Damages Outline
Legal Basis:
- Computer wipe: Código Penal art. 264 (daños informáticos) + civil claim for replacement, data recovery, lost work, emotional distress
- Security system lockout: Civil claim for costs of reinstallation, lost access, inconvenience
- Car key not returned: Aprop. indebida / obstruction + civil claim for any transportation costs
Damages to claim:
| Incident | Type of Damage | Amount / Evidence |
|---|---|---|
| Computer wiped | Replacement cost of computer | Receipt / invoice |
| Computer wiped | Data recovery / forensic | Invoice / expert report |
| Computer wiped | Lost work or professional data | Documentation of lost files or revenue |
| Security system | Replacement/reprogramming costs | Invoice from installer/company |
| Security system | Loss of access / inconvenience | Statements or proof of inability to use system |
| Car key withheld | Cost of alternative transport | Taxi, rental receipts, Uber/Google Pay, etc. |
| Car key withheld | Potential loss of income | Documentation if car use was necessary for work |
3. Evidence Checklist
- Ownership Proof
- Computer purchase receipt, serial number
- Car registration & proof of ownership
- Security system registration / invoices
- Proof of Interference
- Backup drives showing deleted files
- Screenshots / logs
- Invoices from company used for wiping or reinstallation
- Messages/emails from spouse admitting or referencing acts
- Financial Impact Documentation
- Receipts for replacement hardware, installation, repairs, or alternative transport
- Evidence of lost professional work or opportunities
- Communication & Context
- Messages/emails requesting return or access
- Notes on date/time of incidents
- Any pattern showing repeated obstruction
4. Suggested Legal Strategy
- File criminal denuncia for each act:
- Computer wiped → daños informáticos
- Security system → interference / obstruction
- Car key → aprop. indebida / interference
- File civil claim (can be attached to criminal case or separate):
- Include all quantifiable damages and invoices
- Provide timeline to show pattern of deliberate obstruction
- Preserve all evidence in original form; do not attempt to reinstall, overwrite, or retrieve items forcibly.
- Optional:
- Include statement showing pattern of controlling or obstructive behavior (useful for family/divorce court context)
