Law Lessons from C.C. V. T.R., App. Div., A-3670-10T1, February 3, 2012:

There is no right to counsel in a civil proceeding, such as a Domestic Violence Hearing. In re Estate of Schifftner, 385 N.J. Super. 37, 44-45 (App. Div.), certif. denied, 188 N.J. 356 (2006).

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