Client: [Your Name]
Defendant: [Husband’s Name]
Previous Denuncia: [Case Number, Date Filed]
Purpose:
Document each incident individually for separate criminal and civil action while showing an overall pattern of deliberate obstruction, interference with personal property, and harassment.
1. Timeline of Incidents (Incident-Specific)
| Date | Incident | Description | Evidence | Denuncia Reference |
|---|---|---|---|---|
| [Date] | Computer wiped | Husband deleted all data on your personal computer without consent. | Backup drive, screenshots, logs, company invoice, messages referencing deletion | Previously reported in Denuncia [Case #], new filing emphasizes financial/professional losses |
| [Date] | Security system locked | Codes changed by husband; you could not access home security system. System registered in his name. | Invoices for code change/reinstallation, screenshots of failed access, messages/emails requesting access | Previously referenced in Denuncia [Case #]; filing new claim for cost of recovery |
| [Date] | Car key withheld | Husband took your car key and did not return it, preventing use of vehicle. | Proof of car ownership, photos of keys, messages/emails requesting return, receipts for alternative transportation | New denuncia, previously part of timeline but now incident-specific |
| [Date] | Unauthorized surveillance / stalking | Husband monitored you through security cameras without consent; repeated recordings and live monitoring. | Camera logs/screenshots, app notifications, placement photos, messages | New denuncia referencing pattern in Denuncia [Case #] |
2. Civil Damages Outline (Per Incident)
| Incident | Type of Damage | Amount / Evidence |
|---|---|---|
| Computer wiped | Replacement cost | Invoice / receipt |
| Computer wiped | Data recovery / forensic | Forensic report / backup evidence |
| Computer wiped | Lost work / professional data | Documentation of lost files or revenue |
| Security system | Reinstallation / reprogramming costs | Installer invoices |
| Security system | Loss of access / inconvenience | Statement of disruption |
| Car key withheld | Alternative transport costs | Taxi/rental receipts |
| Car key withheld | Potential lost income | Documentation if vehicle was necessary for work |
| Surveillance | Privacy violation / emotional distress | Timeline, screenshots, witness statements |
3. Evidence Checklist
- Proof of Ownership / Access
- Computer receipts, serial numbers
- Car registration / proof of ownership
- Security system invoices or contracts
- Proof of Unauthorized Action
- Backup drives, forensic logs
- Messages, emails, or admissions
- Camera logs / screenshots
- Financial / Material Damages
- Invoices for replacement hardware or systems
- Receipts for transport, lost revenue, or professional work
- Context & Pattern
- Original Denuncia [Case #]
- Timeline showing repeated, deliberate actions
- Witness statements or corroborating evidence if available
4. Filing Strategy
- Separate criminal denuncias per incident:
- Reference previous Denuncia [Case #] to show pattern of repeated offenses
- Provide new, incident-specific evidence and damages
- Civil claims per incident:
- File together with criminal case or separately
- Include exact amounts, invoices, and expert reports
- Evidence preservation:
- Keep originals safe
- Avoid altering devices or footage
- Optional:
- Present pattern as evidence of coercive control in family/divorce court
