| Total SCPS service years | ~16 years |
| Pre-marital service (before 2021) | ~11 years (separate property) |
| Marital service (2021–2026) | ~5 years |
| Coverture fraction | 5 ÷ 16 = 31.25% |
| Est. total annual pension benefit (Pension Plan) | ~$15,360/yr |
| Est. marital share of annual pension | ~$4,800/yr |
| Est. actuarial present value of marital share | $80,000 – $150,000+ |
| Investment Plan: apply 31.25% to account balance | At time of divorce |
| Priority | Action | Target / Contact | Details | Notes | |
|---|---|---|---|---|---|
| Critical | Subpoena SCPS HR for FRS enrollment details | SCPS Human Resources Dept | Request: FRS plan type (Pension vs Investment Plan), DROP status, years of service confirmation, benefit statement. All name variants: Frisz, Wilson, Pagan. | ||
| Critical | Subpoena TSA Consulting Group (TSACG) for 403(b) records | TSA Consulting Group — tsacg.com | Request: Enrollment status, which vendor(s) selected, account balances, contribution history from Jan 2021 onward, beneficiary designations. All name variants. | ||
| Critical | Request FRS benefit statement via Florida Division of Retirement | FL Division of Retirement — 1-844-377-1888 | Formal discovery request for full FRS benefit statement. Confirm Pension Plan vs Investment Plan. Request DROP account balance if applicable. | ||
| Critical | Subpoena 403(b) vendor(s) directly for account balance | Equitable / Lincoln / Voya / VALIC | Once vendor is identified via TSACG subpoena, subpoena the specific provider for full account history, balance as of date of marriage (Jan 2021) and current balance. | ||
| Important | Determine if DROP was elected and get DROP balance | SCPS HR / FRS Direct | Deferred Retirement Option Program. If elected, there is a separate lump-sum DROP account in addition to the pension. Can be worth $100K+. | ||
| Important | Obtain FRS actuarial valuation of marital share | Forensic accountant / actuary | For Pension Plan: hire actuary to calculate present value of 31.25% marital share. Required for equitable distribution. Cost: $500–$2,000 typically. |
| Priority | Action | Target / Contact | Details | Notes | |
|---|---|---|---|---|---|
| Critical | Demand Florida Family Law Financial Affidavit (Form 12.902) | Florida Courts — Form 12.902 | Required in all Florida divorce proceedings. She must disclose ALL assets, accounts, trusts (as beneficiary or trustee), and debts under oath. False disclosure = perjury. | ||
| Critical | Search Seminole County Property Appraiser for all name variants | scpafl.org | Search owner name: "Cristina Frisz", "Cristina Wilson", "Cristina Pagan". If property is held in a trust, the owner field will show the trust name. Screenshot all results. | ||
| Critical | Search Seminole County Official Records for deed transfers / trust instruments | courtrecords.seminoleclerk.org | Search grantor/grantee: all three name variants. Look for any deed conveying property "to [Name] as Trustee" or "to [Name] Trust." Recorded trust documents are public. | ||
| Important | Search Sunbiz.org for LLC / Corp ownership (all name variants) | search.sunbiz.org | Officer/Director Name search: "Cristina Frisz", "Cristina Wilson", "Cristina Pagan." Any LLCs or corporations she owns are marital assets if formed during marriage or funded with marital funds. | ||
| Important | Serve interrogatories re: trust beneficiary status | Opposing counsel | Key questions: (1) Are you a beneficiary of any trust? (2) Are you a trustee? (3) Have you received any distributions from a trust since Jan 1, 2021? (4) Are you aware of any trust created for your benefit by a family member? | ||
| Important | Search Orange County property records (if she owns property there) | ocpafl.org | SCPS employees may live in adjacent Orange County. Search all three name variants in Orange County Property Appraiser as well. | ||
| Standard | Request production of all tax returns 2021–present | Opposing counsel | Schedule B (interest/dividends), Schedule E (S-corp/partnership/trust income), and K-1 forms will reveal trust distributions, investment accounts, and business income not otherwise disclosed. |
| Priority | Action | Target / Contact | Details | Notes | |
|---|---|---|---|---|---|
| Important | Request production of all bank/financial account statements 2021–present | Opposing counsel | All checking, savings, money market, CDs. Look for large transfers, withdrawals, or deposits that may indicate hidden accounts or asset dissipation. | ||
| Important | Check for brokerage / investment accounts | Opposing counsel / subpoena | Interrogatories: list all brokerage accounts, IRAs, Roth IRAs, annuities. Subpoena if not disclosed. IRA contributions during marriage are marital assets. | ||
| Standard | Request SCPS payroll records 2021–present | SCPS HR | Full payroll history including deductions will show 403(b) contribution amounts, flex spending, and any garnishments — confirms contribution amounts independently. | ||
| Standard | Check for life insurance policies with cash value | Opposing counsel | Teachers commonly have TIAA or similar life insurance. Cash value life insurance (whole life / universal life) is a marital asset to the extent funded during marriage. | ||
| Standard | Check for HSA (Health Savings Account) through SCPS | SCPS Benefits Dept / SCPS HR | SCPS offers HSAs. Contributions made from marital funds are marital assets. Request balance and contribution history 2021–present. |