i haven't dealth with bitcoin in a divorce case. however, my thoughts are if bitcoin has been purchased via a KYC exchange, such as Coinbase, then those assets are known and part of the divorce settlement. if those coins were "lost" or "stolen", then that might be a moot point. that is, until someday, those coins are moved. if those wallets are being watched you might be able to say that they were stolen or lost and you didn't move them, but that would need to be proven in court.