“The doctrine of judicial estoppel operates to ‘bar a party to a legal proceeding from arguing a position inconsistent with one previously asserted.’” Cummings v. Bahr, 295 N.J. Super. 374, 385 (App. Div. 1996) (quoting N.M. v. J.G., 255 N.J. Super. 423, 429 (App. Div. 1992)); see Commercial Ins. Co. of Newark, v. Steiger, 395 N.J. Super. 109, 115 (App. Div. 2007). This court has recognized that the doctrine should be invoked when “a party assumes a certain position in a legal proceeding, and succeeds in maintaining that position, [s]he may not thereafter, simply because h[er] interests have changed, assume a contrary position, especially if it be to the prejudice to the party who has acquiesced in the position formerly taken by him.” Newell v. Hudson, 376 N.J. Super. 29, 38 (App. Div. 2005) (quoting Davis v. Wakelee, 156 U.S. 680, 689, 15 S. Ct. 555, 558, 39 L. Ed. 578, 584 (1895)). This doctrine should be applied “when a party’s inconsistent behavior will otherwise result in a miscarriage of justice.” Steiger, supra, 395 N.J. Super. at 114-15 (quoting Ali v. Rutgers, 166 N.J. 280, 288 (2000)). The doctrine of judicial estoppel “protect[s] the integrity of the judicial process by not permitting a litigant to prevail on an issue and then to seek the reversal of that favorable ruling.” McCurrie v. Town of Kearny, 174 N.J. 523, 534 (2002).

In a similar vein, “[t]he doctrine of invited error operates to bar a disappointed litigant from arguing on appeal that an adverse decision below was the product of error, when that party urged the lower court to adopt the proposition now alleged to be error.” Brett v. Great Am. Recreation. Inc., 144 N.J. 479, 503 (1996). In other words, “[a] party who consents to, acquiesces in, or encourages an error cannot use that error as the basis for an objection on appeal.” Spedick v. Murphy, 266 N.J. Super. 573, 593 (App. Div.), certif. denied, 134 N.J. 567 (1993); see also Brett, supra, 144 N.J. at 504 (explaining that the doctrine is “particularly applicable where a party attempts to present a different theory on which to decide the case than the one advocated below”). Fairness and the preservation of the integrity of the litigation process are the guiding principles for this doctrine. Brett, supra, 144 N.J. at 503.

See related Blog Post, published in the New Jersey Family Law blog.

NOTE: My legal and mediation services are offered to Polish-speaking and other clients in Fanwood 07023; Garwood 07027; Kenilworth 07033; Mountainside 07092; New Providence 07974; Roselle Park 07204; Roselle 07203; Elizabeth 07201; Linden 07036; Plainfield 07060; Rahway 07065; Summit 07901; Westfield 07090; Berkeley Heights 07922; Clark 07066; Cranford 07016; Hillside 07205; Scotch Plains 07076; Springfield 07081; Union 07083; Winfield; Carteret 07008; Dunellen 08812; East Brunswick 08816; Edison 08817; Jamesburg 08831; Metuchen 08840; New Brunswick 08901; Old Bridge 08857; Perth Amboy 08861; Sayreville 08871; South Amboy 08878; South River 08877; Avenel 07001; Colonia 07067; Iselin 08830; Woodbridge 07095; Somerset 08873; Somerville 08876 and Watchung 07069, New Jersey.

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In Dendrite International, Inc. v. John Doe, No. 3, 342 N.J. Super. 134 (App. Div. 2001), the court held that where an anonymous person posted defamatory speech on broadly-available Internet message boards, a plaintiff would be entitled to an order divulging the identity of the anonymous author only if the plaintiff: provides sufficient information to demonstrate that his or her cause of action could withstand a motion to dismiss for failure to state a claim, supported by prima facie evidence to support each element of such cause of action (third prong); and establishes, through a balancing test, that the necessity for the disclosure of the anonymous defendant’s identity outweighs the defendant’s First Amendment right of anonymous free speech (fourth prong). Id. at 141-42.

“A defamatory statement is one that is false and ‘injurious to the reputation of another’ or exposes another person to ‘hatred, contempt or ridicule’ or subjects another person to ‘a loss of the good will and confidence’ in which he or she is held by others.” Romaine v. Kallinger, 109 N.J. 282, 289 (1988) (quoting Leers v. Green, 24 N.J. 239, 251 (1957)).

To establish a prima facie case of defamation, a plaintiff must present proof tending to establish each of the following elements:
1) defendant made a defamatory statement of fact about the plaintiff;
2) the statement was false;
3) the statement was communicated to a third party; and
4) defendant made the statement while either knowing that it was false, or while failing to exercise due care to ascertain the truth or falsity of the statement.
Leang v. Jersey City Bd. of Educ., 198 N.J. 557, 585 (2009).

“A truthful statement will not support a cause of action based on defamation, and the truth of the statement is an absolute defense to a claim of defamation.” G.D. v. Kenny, 411 N.J. Super. 176, 187 (App. Div. 2009). “True statements are absolutely protected under the First Amendment.” Ward v. Zelikovsky, 136 N.J. 516, 530 (1994). Significantly, “[a] statement can be ‘fairly accurate’ and still be considered the truth as a defense to a defamation claim.” G.D., supra, 411 N.J. Super. at 193 (quoting LoBiondo v. Schwartz, 323 N.J. Super. 391, 407 (App. Div.), certif. denied, 162 N.J. 488 (1999)).

NOTE: My legal services include family law, divorce, child support, litigation, arbitration, mediation, child custody and visitation, alimony, equitable distribution, separation agreements, palimony, PSA, property settlement agreement, premarital and prenuptial agreements, midmarriage and marital agreements.

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Nicole’s Law permits the court to issue an order as a condition of bail or to continue a prior order or issue a new order upon conviction, prohibiting a defendant charged with or convicted of a sex offense from having any contact with a victim, including restraining the defendant from entering a victim’s residence, place of employment, business or school and from harassing or stalking the victim or victim’s relatives. The law defines “sex offense” by referencing Megan’s Law, N.J.S.A. 2C:7-2. Nicole’s Law restraining orders are similar to domestic violence restraining orders, except that there need not be a domestic relationship between the defendant and the victim for a Nicole’s Law restraining order to be entered if a defendant has been charged with or convicted of certain sex offenses.

See ADMINISTRATIVE OFFICE OF THE COURTS DIRECTIVE # 01-10 (MARCH 2, 2010) relating to RESTRAINING ORDER AND NOTIFICATION PROCEDURES.

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union County, New Jersey.

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Although New Jersey follows the American rule which generally disfavors the shifting of attorneys’ fees, a prevailing party can recover fees in limited circumstances if they are expressly provided for by statute, court rule, or contract. Litton Indus. v. IMO Indus., 200 N.J. 372, 401 (2009). Rule 4:42-9(a)(3) recognizes the appropriateness of an award of counsel fees in a probate action. The rule states in relevant part:

if probate is refused, the court may make an allowance to be paid out of the estate of the decedent. If the probate is granted, and it shall appear that the contestant had reasonable cause for contesting the validity of the will or codicil, the court may make an allowance to the proponent and the contestant, to be paid out of the estate.

[Id.]

The decision to award attorneys’ fees and the quantum of the award, rests within the discretion of the trial judge, and we must review the award under the abuse of discretion standard. IMO Probate of Alleged Will of Hughes, 244 N.J. Super. 322, 328 (1990) (citing In re Reisdorf, 80 N.J. 319, 326-27 (1979)); Packard-Bamberger & Co. v. Collier, 167 N.J. 427, 444 (2001).

“In determining the reasonableness of a counsel fee award, the threshold issue ‘is whether the party seeking the fee prevailed in the litigation.’” Packard-Bamberger, supra, 167 N.J. at 444 (quoting North Bergen Rex Transp., Inc, v. Trailer Leasing Co., 158 N.J. 561, 570 (1999)).

Rule 4:42-9(b) requires that in an action for counsel fees in probate actions, all applications must “be supported by an affidavit of services addressing the factors enumerated by RPC 1.5(a).” Further, “[t]he affidavit shall also include a recitation of other factors pertinent in the evaluation of the services rendered, the amount of the allowance applied for, and an itemization of disbursements for which reimbursement is sought.” R. 4:42-9(b).

Rule of Professional Conduct 1.5(a) “commands that ‘[a] lawyer’s fee shall be reasonable’ in all cases, not just feeshifting cases,” and requires courts to consider:

(1) the time and labor required, the novelty and difficulty of the questions involved, and the skill requisite to perform the legal service properly;
(2) the likelihood, if apparent to the client, that the acceptance of the particular employment will preclude other employment by the lawyer;
(3) the fee customarily charged in the locality for similar legal services;
(4) the amount involved and the results obtained;
(5) the time limitations imposed by the client or by the circumstances;
(6) the nature and length of the professional relationship with the client;
(7) the experience, reputation, and ability of the lawyer or lawyers performing the services;
(8) whether the fee is fixed or contingent.

[RPC 1.5(a).]

In calculating the dollar amount, courts use the lodestar method of calculation in many settings, including probate actions. Furst v. Einstein Moomjy, Inc., 182 N.J. 1, 21 (2004); Packard-Bamberger, supra, 167 N.J. at 445 (citing In re Estate of Reisen, 313 N.J. Super. 623 (Ch. Div. 1998)). The lodestar calculation is defined as the number of hours reasonably expended by the attorney, multiplied by a reasonable hourly rate. Furst, supra, 182 N.J. at 21.

In addition, courts should consider other relevant factors when determining the quantum of the fee. Packard-Bamberger, supra, 167 N.J. at 445. For example, the trial court should consider “the interest to be vindicated in the context of the statutory objectives, as well as any circumstances incidental to the litigation that directly or indirectly affected the extent of counsel’s efforts.” Szczepanski v. Newcomb Med. Ctr., Inc., 141 N.J. 346, 366-67 (1995). Furthermore, “[i]f the trial court concludes that the hours expended by counsel ‘exceed those that competent counsel would have expended to achieve a comparable result, a trial court may exercise its discretion to exclude excessive hours from the lodestar calculation.’” Packard-Bamberger, supra, 167 N.J. at 446 (quoting Rendine v. Pantzer, 141 N.J. 292, 336 (1995)).

Our Supreme Court has noted that “fee determinations by trial courts will be disturbed only on the rarest of occasions, and then only because of a clear abuse of discretion.” Id. at 444. The decision to award attorneys’ fees at all, and the amount awarded are accorded great deference.

NOTE: My legal and mediation services are offered to Polish-speaking and other clients in Union, Middlesex, Somerset, Essex, Hudson, Bergen, and Morris counties in NJ.

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The term “neglected child” is defined in N.J.S.A. 9:6-8.21(c)(4) as a child under the age of eighteen

whose physical, mental, or emotional condition has been impaired or is in imminent danger of becoming impaired as the result of the failure of his parent . . . to exercise a minimum degree of care . . . (b) in providing the child with proper supervision or guardianship, [or] by unreasonably inflicting or allowing to be inflicted harm, or substantial risk thereof . . . .

The Supreme Court has interpreted this statute and enunciated the standard encapsulated within the phrase “minimum degree of care.”

[T]he phrase “minimum degree of care” refers to conduct that is grossly or wantonly negligent, but not necessarily intentional.
Conduct is considered willful or wanton if done with the knowledge that injury is likely to, or probably will, result. . . .
[A]ctions taken with reckless disregard for the consequences also may be wanton or willful. . . .
[T]he difference between merely negligent conduct and wanton and willful misconduct cannot be described with mathematical precision. . . .
Essentially, the concept of willful and wanton misconduct implies that a person has acted with reckless disregard for the safety of others.

[G.S. v. Dep't of Human Servs., Div. of Youth & Family Servs., 157 N.J. 161, 178-79 (1999).]

“The standard is not whether some potential for harm exists. A parent fails to exercise a minimum degree of care when she is ‘aware of the dangers inherent in a situation and fails adequately to supervise the child or recklessly creates a risk of serious injury to the child.’” New Jersey Div. of Youth & Family Servs. v. J.L., 410 N.J. Super. 159, 168-69 (App. Div. 2009) (quoting G.S., supra, 157 N.J. at 181.)

There is a vast gulf between carelessness and recklessness.

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union County, New Jersey.

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See: ADVISORY COMMITTEE ON PROFESSIONAL ETHICS OPINION 717: RPC 1.5(d)(2) — Contingency Fees in Criminal and Quasi-Criminal Matters.

NOTE: Adwokat / Prawnik Pawel Kostro mowi po polsku.

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In this case, Dr. Cynthia Lischick, Ph.D. was qualified as an expert on domestic violence. She explained that “battering” is separate from episodic assault in that it involves a pattern of various conduct over time, including: (1) isolation from support systems; (2) intimidation and threats; (3) degradation; (4) tactics and strategies involving psychological abuse; and (5) deprivation of rights and freedoms. She noted that there can also be physical and/or sexual abuse.

She testified that batterers often believe they are “privileged and entitled to coerce and control the victims using intimidating gestures, using threats, [and] depriving them of rights and freedoms” to get what they want. Generally, they believe that there will be no consequences as a result of their actions and therefore they have no reason to stop.

She explained that there are three categories of victim coping responses: (1) they can adapt to the coercive control environment and begin to follow exactly what is demanded by the batterer; (2) they can become “numb” to the degradation that occurs; or (3) they can resist. Victims of battering often do not want to testify against the batterers because they are afraid, and, in fact, often protect the batterers by testifying on their behalf and denying that the battering occurred, or by minimizing it. Approximately sixty percent of domestic violence reports involve battering and approximately forty percent involve episodic instances of domestic violence.

Dr. Lischick explained further that battering involves a malevolent course of action: “It involves strategies of isolation, intimidation, depravation of rights and freedoms, and tactics of abuse,” which can be psychological, sexual, or physical. She defined battering as a coercive control pattern and the effects of that pattern on the victim, that is, learned helplessness. Battering goes beyond an episodic assault and involves all of the above strategies in a pattern over time.

She acknowledged that the mere fact that physical violence occurs does not automatically create a battered woman because isolation from other people on more than one occasion is a critical component of battering. Where there is no isolation, there is no battering. She also acknowledged that a wife may fabricate a charge against her husband and then recant; the recantation itself would not prove she was a battered spouse.

However, she opined that it was not unusual for a battered spouse to not want to testify on behalf of the State, most often because she is afraid or loves the batterer or because of her culture. It would not, in her opinion, be unusual for the victim to minimize the violence or to recant her initial version of events.

She also acknowledged that BWS and the theory of the cycle of violence do not apply to every case. BWS is not recognized in the Diagnostic and Statistical Manual as a separate illness, and the theory of BWS has been discredited by some.

====

In State v. Kelly, 97 N.J. 178, 187 (1984), the Supreme Court, in the context of a claim of BWS self-defense to the killing of the batterer, held for the first time that

a battering relationship embodies psychological and societal features that are not well understood by lay observers. Indeed, these features are subject to a large group of myths and stereotypes. It is clear that this subject is beyond the ken of the average juror and thus is suitable for explanation through expert testimony.

[Id. at 209.]

After examining the law governing self-defense and concluding that expert testimony regarding BWS was relevant to that defense, id. at 197-207, Chief Justice Wilentz noted that N.J.R.E. 56(2) (now N.J.R.E. 702) provided:

that an expert may testify “as to matters requiring scientific, technical or other specialized knowledge if such testimony will assist the trier of fact to understand the evidence or determine a fact in issue.” In effect, this Rule imposes three basic requirements for the admission of expert testimony: (1) the intended testimony must concern a subject matter that is beyond the ken of the average juror; (2) the field testified to must be at a state of the art such that an expert’s testimony could be sufficiently reliable; and (3) the witness must have sufficient expertise to offer the intended testimony. See N.J. Rules of Evidence (Anno. 1984), Comment 5 to Evid. R. 56.

[Id. at 208.]

Chief Justice Wilentz went on to observe that “[t]he primary justification for permitting expert testimony is that the average juror is relatively helpless in dealing with a subject that is not a matter of common knowledge.” Id. at 209 (citing Angel v. Rand Express Lines, Inc., 66 N.J. Super. 77, 85 (App. Div. 1961)). As a consequence, “the proponent of expert testimony must demonstrate that testimony would ‘enhance the knowledge and understanding of lay jurors with respect to other testimony of a special nature normally outside of the usual lay sphere.’” Ibid. (citing State v. Griffin, 120 N.J. Super. 13, 20 (App. Div.), certif. denied, 62 N.J. 73 (1972)).

In State v. J.Q., 130 N.J. 554, 574 (1993), the Supreme Court explained the rationale for allowing such expert testimony:

[E]xpert scientific evidence concerning “battered-woman’s syndrome” does not aid a jury in determining whether a defendant had or had not behaved in a given manner on a particular occasion; rather, the evidence enables the jury to overcome common myths or misconceptions that a woman who had been the victim of battering would have surely left the batterer. Thus, the evidence helps the jury to understand the battered woman’s state of mind.

See also State v. Ellis, 280 N.J. Super. 533, 541-44 (App. Div. 1995) (“[A]pplication [of BWS] is limited to explaining a victim’s reactions or late reporting of the events and not as evidence that the crime occurred” where victim testified to many incidents of controlling behavior, beatings, and threats as well as unfounded accusations and suspicions over a five-year period and expert had a two-and-one-half-hour interview with the victim.); State v. Frost, 242 N.J. Super. 601, 613-14 (App. Div.), certif. denied, 127 N.J. 321 (1990) (evidence of BWS can be used to bolster a victim’s credibility in the State’s case in chief).

In State v. Townsend, 186 N.J. 473, 479 (2006), the State presented expert testimony without a diagnosis of BWS to prove that the decedent’s dying declaration exonerating defendant was not credible. On appeal, the court reversed the conviction because the court “concluded that although testimony in respect of [BWS] satisfied the requirements of New Jersey Rule of Evidence 703, the testimony that battered women not diagnosed with [BWS] exhibit characteristics similar to women with the syndrome did not.” Id. at 494 (citing State v. Townsend, 374 N.J. Super. 25, 55 (App. Div. 2005)). The court “also found that it was plain error to admit those discrete expert opinions that were net opinions.” Ibid. (citing Townsend, supra, 374 N.J. Super. at 56). The Supreme Court concluded “that the characteristics of battered women with or without a diagnosis of [BWS] are sufficiently reliable to support expert testimony as an aid to the jury.” Id. at 493.

The Court held that the opinion of the State’s expert that women with BWS commonly lie about the source of their injuries was not a net opinion because it was based upon medical information and the expert’s education and considerable experience counseling battered women. Id. at 494-95. The Court upheld the admission of such testimony because it satisfied three basic requirements for the admission of expert testimony set forth in N.J.R.E. 702: (1) “the ramifications of a battering relationship are beyond the ken of the average juror,” id. at 491; (2) “that the characteristics of battered women with or without a diagnosis of [BWS] are sufficiently reliable,” id. at 493; and (3) “based on her training and experience, [the prosecution's expert] was qualified to give expert testimony on battered women and [BWS],” ibid.

However, the court has found no case where expert testimony respecting the characteristics of a battered woman and BWS was presented in the absence of any evidence of a coercive control pattern and its effects and an expert opinion as to whether the victim was battered. Generally, the woman is evaluated by the expert. See, e.g., Kelly, supra, 97 N.J. at 196-97; State v. McClain, 248 N.J. Super. 409, 414-15 (App. Div.), certif. denied, 126 N.J. 341 (1991); Frost, supra, 242 N.J. Super. at 611-12. Where that is not possible, as in Townsend, there is evidence of systematic abuse. State v. Gartland, 149 N.J. 456, 472-73 (1992).

The opinions offered by Dr. Lischick in this case were simply not sufficient to be relevant to the facts of this case. “‘Relevant evidence’ means evidence having a tendency in reason to prove or disprove any fact of consequence to the determination of the action.” N.J.R.E. 401. Relevancy is “the hallmark of admissibility.” State v. Gookins, 263 N.J. Super. 58, 63 (App. Div. 1993), rev’d on other grounds, 135 N.J. 42 (1994); accord, State v. Darby, 174 N.J. 509, 519 (2002). Probative value is “the tendency of evidence to establish the proposition that it is offered to prove.” State v. Wilson, 135 N.J. 4, 13 (1994).

“In determining whether evidence is relevant, the inquiry should focus on the logical connection between the proffered evidence and a fact in issue.” State v. Bakka, 176 N.J. 533, 545 (2003).

====

Resource: The New Jersey Coalition for Battered Women

Resource: Where can I locate information about available services for victims of domestic violence in my area?

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union County, New Jersey.

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Orders setting child support, even those arising from a private agreement, “may be revised and altered by the court from time to time as circumstances may require.” N.J.S.A. 2A:34-23; see also Lepis v. Lepis, 83 N.J. 139, 146 (1980)(stating that alimony and support obligations “are always subject to review and modification on a showing of ‘changed circumstances’”). “If circumstances have changed in such a way that [the support provision] would no longer be equitable and fair, the court [ ] remains free to alter the prior arrangement.” Lepis, supra, 83 N.J. at 161 n.12. The burden of proving this change in circumstances rests with the moving party, Zazzo v. Zazzo, 245 N.J. Super. 124, 132 (App. Div. 1990), certif. denied, 126 N.J. 321 (1991), and the trial judge’s guiding principle remains the “best interests of the children.” Lepis, supra, 83 N.J. at 157 (quoting Hallberg v. Hallberg, 113 N.J. Super. 205, 209 (App. Div. 1971)).

The standard for modification of a negotiated child support agreement has long been that of “changed circumstances.” Smith, supra, 72 N.J. at 360; Clayton v. Muth, 144 N.J. Super. 491 (Ch. Div. 1976).

However, settlement agreements must be afforded special deference. “Settlement agreements in matrimonial matters, being essentially consensual and voluntary in character, . . . [are] entitled to considerable weight with respect to their validity and enforceability in equity, provided they are fair and just.” Dolce v. Dolce, 383 N.J. Super. 11, 20 (App. Div. 2006). Where the parties have agreed to provide for a child beyond what is legally required, courts must “giv[e] due weight to the strong public policy favoring stability of [consensual] arrangements[,]” Smith v. Smith, 72 N.J. 350, 360 (1977), before freeing a parent from his or her contractual obligations. Such agreements will be reformed only upon a showing of “unconscionability, fraud, or overreaching in the negotiations of the settlement[.]” Miller v. Miller, 160 N.J. 408, 419 (1999).

In contrast, see: The court can set aside the amount of the child support payments provided in a settlement agreement if they are unjust, oppressive and inequitable, and instead imposed child support payments in accordance with the Child Support Guidelines.

NOTE: This Blog/Blawg, NJ Family Issues, is managed by Paul G. Kostro, Esq., an attorney/lawyer/mediator in Linden, Union County, New Jersey.

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The use of the Guidelines is mandatory in determining child support except on a showing of “good cause.” R. 5:6A. “Good cause” includes “the considerations set forth in Appendix IX-A.” Ibid. The Guidelines “shall not be used to determine parental contributions for college . . . nor the amount of support for a child attending college.” Pressler, Current N.J. Court Rules, Appendix IX-A to R. 5:6A at 2401 (2010). As a result of the Guidelines’ inapplicability, the decision to set support is discretionary, subject to the considerations of the factors enumerated in N.J.S.A. 2A:34-23.

Kiken v. Kiken, 149 N.J. 441 (1997), and Hudson v. Hudson, 315 N.J. Super. 577, 584 (App. Div. 1998) stand for the proposition that defendant was entitled to a reduction “for shelter expenses and a reduced amount for variable expenses while the child is away at college.”

NOTE: My Law Office is located at 726 West Saint Georges [W. St. Georges] Avenue (Route 27), Linden, Union County, NJ. Telephone: 908-486-2200

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The Guidelines define “gross income” as

all earned and unearned income that is recurring or will increase the income available to the recipient over an extended period of time. When determining whether an income source should be included . . . the court should consider if it would have been available to pay expenses related to the child if the family would have remained intact . . . and how long that source would have been available to pay those expenses.

[Pressler, Current N.J. Court Rules, Appendix IX-B to R. 5:6A at 2408 (2010).]

In addition to earned income, “gross income” under the Guidelines includes, but is not limited to, “gains derived from dealings in property,” interest and dividends, rents, bonuses and royalties, annuities, life insurance, personal injury awards, profit sharing plans, the sale of or any earnings from investments, and income tax credits or rebates. Id. at 2408-09. Similar definitions are found in the Internal Revenue Code and New Jersey Gross Income Tax Act. See 26 U.S.C.A. § 61 (2002); N.J.S.A. 54A:1-1.

See related Blog Post, published in the New Jersey Family Law blog.

NOTE: My legal services include family law, divorce, child support, litigation, arbitration, mediation, child custody and visitation, alimony, equitable distribution, separation agreements, palimony, PSA, property settlement agreement, premarital and prenuptial agreements, midmarriage and marital agreements.

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