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Larissa Kunin v. Sergey Kunin Docket No. A-1509-23 Decided July 18, 2024 In a recent unpublished decision the Appellate Division of New Jersey affirmed a trial court’s order requiring Husband to request court approval before paying his attorney fees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

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 In a recent unpublished decision the Appellate Division of New Jersey affirmed a trial court’s denial of defendant’s request to modify supervised parenting time and child support,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 In a recent unpublished decision, the Appellate Division of New Jersey affirmed an entry of a Final Restraining Order after denying defendant’s testimony regarding her GPS location on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…

Court Reversed the Denial of a Paternity Test After Defendant Performed At-Home DNA Test Showing 0% Probability of Him Being the Father of a Nine-Year-Old Child

October 10, 2022

S.L.P. v. A.L.N. Docket No. A-0452-21 Decided October 7, 2022 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey reversed the denial of a paternity test after defendant performed at-home DNA test showing 0% probability of him being the father of a nine year old child.…

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…

Requests To Remove Children Out of State to Reside with A Parent Are Reviewed by The Best Interests of The Child

January 20, 2022

T.Z.S. v. A.G.W. Docket No. A-0898-20 Decided January 19, 2022 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey reversed a trial court’s denial of a custody removal application for defendant living in North Carolina and ordered a plenary hearing because of disputed material facts that…