Appellate Division Confirms Law When Divorce Is Filed In Another Country

November 19, 2025

GENE VAN DEN ENDE v. CROFTON PHILIP REYNOLDS Docket No. A-1565-24 Decided November 3, 2025 Submitted by New Jersey Divorce Lawyer, Jeffrey Hark In a recent published decision the Appellate Division of New Jersey reviewed the law surrounding a situation in which a divorce, or at least a request made typically in a divorce such…

Judge Requires Court Approval of Payment of Party’s Own Attorney In New Jersey Divorce

July 22, 2024

Larissa Kunin v. Sergey Kunin Docket No. A-1509-23 Decided July 18, 2024 In a recent unpublished decision the Appellate Division of New Jersey affirmed a trial court’s order requiring Husband to request court approval before paying his attorney fees because he was behind in his child support and spousal support obligations. In Kunin v. Kunin,…

NEW JERSEY ALIMONY AWARD OF FOUR YEARS REVERSED FOR THIRTY-THREE YEAR MARRIAGE

April 1, 2024

Margaret S. Frey v. Thomas G. Frey Docket No. A-2271-21 Decided March 28, 2024 Submitted by New Jersey Divorce Lawyer, Jeffrey Hark. The Appellate Division of New Jersey in a recent unpublished decision reversed a Dual Judgment of Divorce for alimony and equitable distribution for the Court’s failure to apply correct law to each category. In…

Free Speech Prevails: S.B.B. v. L.B.B. – Landmark Decision, Sept. 6, 2023

September 19, 2023

S.B.B. v. L.B.B. Docket No. A-0305-21 Decided September 6, 2023 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent published decision the Appellate Division of New Jersey reversed a trial court’s order entering a final restraining order (FRO) against defendant for her pressuring her husband, plaintiff, to get a Jewish divorce, or “get” on…

Appellate Division Affirms Denial: Samuel v. Calabrese Child Support Case

August 16, 2023

Rebekah Samuel v. Theodore Calabrese Docket No. A-2231-21 Decided August 14, 2023 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey affirmed a trial court’s denial of defendant’s request to modify supervised parenting time and child support, despite defendant’s alleged inability to pay for the supervised…

NEW JERSEY COURTS FORBID LAY TESTIMONY OF PHONE GPS TECHNOLOGY WITHOUT A REQUISITE KNOWLEDGE OR EXPERIENCE WITH USING GPS

August 2, 2023

H.A. v. S.M.A. DOCKET NO. A-1631-21 Decided July 31, 2023 Submitted by New Jersey Domestic Violence Lawyer, Jeffrey Hark. In a recent unpublished decision, the Appellate Division of New Jersey affirmed an entry of a Final Restraining Order after denying defendant’s testimony regarding her GPS location on the day in question. In H.A. v. S.M.A., Plaintiff…

Affirmed: Final Judgment of Divorce Regarding Custody, Parenting Time, Alimony, And A No Contact Order from Plaintiff’s Brother

September 9, 2022

IVAN BILBAO LA VIEJA v. ALEJANDRA BILBAO LA VIEJA, n/k/a ALEJANDRA MERILES Docket No. A-799-20 Decided September 6, 2022 Submitted by New Jersey Divorce Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey affirmed a final judgment of divorce regarding custody, parenting time, alimony, and a no contact order from plaintiff’s…

Changes In Circumstance and The Decision to Reduce Financial Obligations for Alimony and Child Support

August 2, 2022

Lenore N. Zangrilli v. Jason D. Zangrilli DOCKET NO. A-0542-19 Decided July 29, 2022 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision, the Appellate Division of New Jersey found sufficient credible evidence supporting trial court’s decision to reduce defendant’s financial obligations to the plaintiff. The parties were married in 1994 and…

To Convert a Temporary Restraining Order into a Final Restraining Order, One Must Prove a Predicate Act of Domestic Violence

March 9, 2022

A.L. v. M.C.L. Docket No. A-1733-20 Decided March 7, 2022 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision, the Appellate Division of New Jersey upheld the imposition of a Final Restraining Order (FRO) against defendant for an alleged assault during the break down of a marriage. In A.L., the parties were…

Affirmed: Several Post Judgment Orders From 38 Post Judgment Motions Filed by Plaintiff, Often Requesting the Same Relief

March 4, 2022

S.M. v. J.T. Docket No. A-5359-18 A-4428-19 Decided March 3, 2022 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division affirmed several post judgment orders resulting from 38 post judgment motions filed by plaintiff, often requesting the same relief. In S.M., The parties, who divorced in 2014, have an…