- I had an affair.
- My spouse had an affair.
- I did something that might make it seem like I had an affair.
- Someone might be in possession of emails, texts, screenshots, etc. that might make it look like I had an affair.
- I have pending criminal charges or had criminal charges in the past.
- I have a current restraining order against my spouse or have in the past.
- My spouse has a current restraining order against me or has in the past.
- I have a girlfriend/boyfriend.
- I have children other than the ones I had with my spouse.
- I’ve hit or threatened my spouse but no one reported it.
- My spouse hit or threatened me but no one reported it.
- I don’t think I am the child’s father.
- I have accounts my spouse doesn’t know about.
- The police have been called to our home on ANY occasion, even if no police report was filed.
- I think my spouse might have proof of ANYTHING that might challenge my case.
This list is not all-inclusive. You should tell your attorney EVERYTHING. The attorney will let you know whether that information will be relevant. Communications you have with your attorney are covered by attorney-client privilege in nearly all cases. There are only a few exceptions that allow an attorney to release information you provided to them in confidence.
Why should you be one-hundred percent truthful with your attorney? Your case may be affected in a negative way. If you are truthful, your attorney can mitigate the damage from any information that may be harmful to your case. Your attorney is only able to represent you to the best of his/her ability if they know all the details surrounding your case. Your attorney will not judge you but will be eternally thankful that you were forthcoming. No one likes surprises in the court room! Help your attorney and help your case by telling the truth.
 See N.C. Rule of Professional Conduct 1.16