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…

Appellate Division Of New Jersey Affirms Change of Marital Settlement Agreement and Suspension of Father’s Parenting Time

April 21, 2025

N.T. v. C.T. Docket No. A-2940-21 Decided December 27, 2024 Submitted by New Jersey Divorce Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey affirmed the modification of the parties’ Marital Settlement Agreement (MSA) that the parties would attend mediation for any disputes and suspension of father’s parenting time. In N.T.…

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 In a recent unpublished decision the Appellate Division of New Jersey affirmed a trial court’s denial of defendant’s request to modify supervised parenting time and child support,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 In a recent unpublished decision, the Appellate Division of New Jersey affirmed an entry of a Final Restraining Order after denying defendant’s testimony regarding her GPS location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

Remanded: An Order of Sole Custody and Over $20,000 In Sanctions Due to The Court’s Failure to Allow a Custody Expert to Be Cross Examined

February 3, 2023

R.G. v. K.G. Docket No. A-0464-21 Decided February 2, 2023 Submitted by New Jersey Family Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey remanded an order of sole custody and over $20,000 in sanctions due to the Court’s failure to allow a custody expert to be cross examined. In R.G.…

Plaintiff And Defendant Could Not Agree on The Valuation of The Marital Home, And the Court Appointed an Appraiser Discarding Both Plaintiff and Defendant’s Valuations.

September 6, 2022

Knaust v. Knaust Docket No. A-0346-20 Decided August 30, 2022 Submitted by New Jersey Divorce Lawyer, Jeffrey Hark. In a recent unpublished decision the Appellate Division of New Jersey reversed an order denying a motion for reconsideration after plaintiff and defendant could not agree on the valuation of the marital home, and the court appointed an…

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…

Unless Divorce and Custody Agreements Are Reduced to Writing and Signed by the Parties Normally the Agreement Is Not Going to Be Enforceable

June 30, 2022

Goethals v. Goethals Docket No. A-3657-20 Decided June 29, 2022 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 enforce an agreement after mediation but never put into writing. In Goethals, after fifteen years of marriage, the…

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…