Original Message------

Hi all,

I represent the wife in a very contentious divorce matter.  Husband is presently pro se.  It's a bad case (client had obtained 3 TRO's against Husband resulting in 2 Civil Restraints and finally a FRO, which is currently in place).  Husband's parenting time with the parties' son is suspended (except for a couple of Skype calls per week).  

2 weeks ago, Husband became irate at my client after his call to their son and began posting nude pictures of her (along with other inappropriate pictures and statements) to her father's facebook page.  There is a pending FO (contempt/violation of FRO) charge against Husband, but I want to evaluate pursuing additional remedies (criminal and civil).  

I know these posts fall under the crime of "invasion of privacy" statute N.J.S.A. 2C:14-9, so she could press charges there,  However, for her to pursue a civil claim, would I have to amend my Complaint for Divorce to add a "Tevis" claim for the tort of invasion of privacy pursuant to the Entire Controversy Doctrine, or should she pursue this separately outside of the FM Docket?

I'd appreciate your input!

Thanks,

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100
Fax: (732) 736-9505

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Case is:

------------------------------
Curtis Romanowski Esq.
Senior Attorney - Proprietor
Metuchen NJ
(732)603-8585

Original Message:
Sent: 07-01-2016 10:21
From: Hanan Isaacs
Subject: Adv. posted nude pictures of my client - want to pursue claim (Tevis?)

Hi Greg, The Entire Controversy Doctrine requires joinder of all cases and controversies, even if the matters end up referred to other Divisions.  However, there is a clear marital tort remedy under Tevis.  Why NOT amend the Complaint and add a Tevis count here? The only thing you gain by a Law Division claim is the right to a jury trial. Do you want a jury trial? Tevis mostly says you don't get one. And Husband may even have a right to circle the claim back to Family Court if you file a Law Division claim, because it arises directly out of the same family conflict. Bottom line: I would amend the Complaint to add a Tevis count, and be done with it. Hanan

Hanan M. Isaacs, Esq.   t 609.683.7400   f 609.921.8982 e [email protected]   w www.hananisaacs.com 4499 Route 27, Kingston NJ

Original Message------

Hi all,

I represent the wife in a very contentious divorce matter.  Husband is presently pro se.  It's a bad case (client had obtained 3 TRO's against Husband resulting in 2 Civil Restraints and finally a FRO, which is currently in place).  Husband's parenting time with the parties' son is suspended (except for a couple of Skype calls per week).  

2 weeks ago, Husband became irate at my client after his call to their son and began posting nude pictures of her (along with other inappropriate pictures and statements) to her father's facebook page.  There is a pending FO (contempt/violation of FRO) charge against Husband, but I want to evaluate pursuing additional remedies (criminal and civil).  

I know these posts fall under the crime of "invasion of privacy" statute N.J.S.A. 2C:14-9, so she could press charges there,  However, for her to pursue a civil claim, would I have to amend my Complaint for Divorce to add a "Tevis" claim for the tort of invasion of privacy pursuant to the Entire Controversy Doctrine, or should she pursue this separately outside of the FM Docket?

I'd appreciate your input!

Thanks,

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100
Fax: (732) 736-9505

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Original Message------

Hi all,

I represent the wife in a very contentious divorce matter.  Husband is presently pro se.  It's a bad case (client had obtained 3 TRO's against Husband resulting in 2 Civil Restraints and finally a FRO, which is currently in place).  Husband's parenting time with the parties' son is suspended (except for a couple of Skype calls per week).  

2 weeks ago, Husband became irate at my client after his call to their son and began posting nude pictures of her (along with other inappropriate pictures and statements) to her father's facebook page.  There is a pending FO (contempt/violation of FRO) charge against Husband, but I want to evaluate pursuing additional remedies (criminal and civil).  

I know these posts fall under the crime of "invasion of privacy" statute N.J.S.A. 2C:14-9, so she could press charges there,  However, for her to pursue a civil claim, would I have to amend my Complaint for Divorce to add a "Tevis" claim for the tort of invasion of privacy pursuant to the Entire Controversy Doctrine, or should she pursue this separately outside of the FM Docket?

I'd appreciate your input!

Thanks,

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100
Fax: (732) 736-9505

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Original Message------

an easy call is to add a tort claim to the divorce complaint. maybe file emergency motion to force removal

 

Original Message------

an easy call is to add a tort claim to the divorce complaint. maybe file emergency motion to force removal

 

Original Message------

I keep thinking about this post, and it's scarier and scarier. I would push strongly with the PD to have this prosecuted as a violation of the FRO and be all over the prosecutor that you want a full psych evaluation before he's released. I don't even know if that would really do anything if he's off the hook the completely, but I'm not sure what else could be done aside from your client relocating or hiring private security, at least for a period of time.


<x-sigsep>

</x-sigsep> David Perry Davis, Esq.
----------------------------------------------------
   www.FamilyLawNJ.pro
----------------------------------------------------
112 West Franklin Avenue
Pennington, NJ 08534
Voice: 609-737-2222
Fax:    609-737-3222

You wrote "I have not experienced a litigant this out of control before" and you have "a psychiatric evaluation pending (he was supposed to have it completed 6 months ago), a psychological evaluation occurred last year..."  Is he represented by an attorney?  Have you applied for a guardianship or to have him committed?

------------------------------
Jenny Berse Esq.
Cranford NJ
(855) 326-5291

Original Message:
Sent: 07-01-2016 12:37
From: Gregory Thomlison
Subject: Adv. posted nude pictures of my client - want to pursue claim (Tevis?)

Thanks to everybody for the responses.  I am amending my complaint to add marital torts (invasion of privacy, intentional infliction of emotional distress).  

David - yes, this case is scary.  I have not experienced a litigant this out of control before.  We have an OSC pending regarding the pictures, a psychiatric evaluation pending (he was supposed to have it completed 6 months ago), a psychological evaluation occurred last year, five previous Orders to Show Cause (all of which were granted), five (5) prior incidences of TRO Violations (which were merged and reduced to two counts of harassment, not contempt), PL Support motion (and enforcement), and a multitude of harassing communications not only to my office, but to my client's friends and family.  I am not sure what else I can do to protect my client, especially since he keeps getting more time to comply, minimal/nominal sanctions/penalties from the court for his repeated bad faith conduct, and basically has free reign to do or say anything with impunity.  

Most alarmingly, he has a gun on his boat in Florida that he will not turn over despite the many TRO's and current FRO, and the Florida police will not seize the weapon.  Any thoughts on how to handle that issue is most appreciated as well.  I've filed for him to turn over his weapon under the FM, but judge's position is it should be brought under FV (I assume as an enforcement motion).  The problem is, there seems to be a jurisdictional issue whereby Florida doesn't seem interested in seizing the gun (they won't go to his boat because we don't know exactly where it is and they won't look for it).  

Again, I appreciate all of the responses and help.  

Greg

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

You could file a motion requesting the judge order the defendant to provide the exact location of his gun. If it is granted and defendant doesn't comply, you can file a motion for enforcement. Perhaps with all this history, you might persuade a judge to hold him in contempt and put him in the county jail until he complies. Not a long term solution but perhaps spending time cooling his heels for a bit might give him pause? Though he might just be so mentally ill that it won't help. Such a tricky situation.

Has your client received any counseling from a domestic violence group? Sounds like she needs to make a safety plan in addition to pursuing all legal options.

Anne

Anne Cralle, Esq.


Sent from my iPad


Original Message------

Thanks to everybody for the responses.  I am amending my complaint to add marital torts (invasion of privacy, intentional infliction of emotional distress).  

David - yes, this case is scary.  I have not experienced a litigant this out of control before.  We have an OSC pending regarding the pictures, a psychiatric evaluation pending (he was supposed to have it completed 6 months ago), a psychological evaluation occurred last year, five previous Orders to Show Cause (all of which were granted), five (5) prior incidences of TRO Violations (which were merged and reduced to two counts of harassment, not contempt), PL Support motion (and enforcement), and a multitude of harassing communications not only to my office, but to my client's friends and family.  I am not sure what else I can do to protect my client, especially since he keeps getting more time to comply, minimal/nominal sanctions/penalties from the court for his repeated bad faith conduct, and basically has free reign to do or say anything with impunity.  

Most alarmingly, he has a gun on his boat in Florida that he will not turn over despite the many TRO's and current FRO, and the Florida police will not seize the weapon.  Any thoughts on how to handle that issue is most appreciated as well.  I've filed for him to turn over his weapon under the FM, but judge's position is it should be brought under FV (I assume as an enforcement motion).  The problem is, there seems to be a jurisdictional issue whereby Florida doesn't seem interested in seizing the gun (they won't go to his boat because we don't know exactly where it is and they won't look for it).  

Again, I appreciate all of the responses and help.  

Greg

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Original Message------

You could file a motion requesting the judge order the defendant to provide the exact location of his gun. If it is granted and defendant doesn't comply, you can file a motion for enforcement. Perhaps with all this history, you might persuade a judge to hold him in contempt and put him in the county jail until he complies. Not a long term solution but perhaps spending time cooling his heels for a bit might give him pause? Though he might just be so mentally ill that it won't help. Such a tricky situation.

Has your client received any counseling from a domestic violence group? Sounds like she needs to make a safety plan in addition to pursuing all legal options.

Anne

Anne Cralle, Esq.


Sent from my iPad

Original Message------

Thanks to everybody for the responses.  I am amending my complaint to add marital torts (invasion of privacy, intentional infliction of emotional distress).  

David - yes, this case is scary.  I have not experienced a litigant this out of control before.  We have an OSC pending regarding the pictures, a psychiatric evaluation pending (he was supposed to have it completed 6 months ago), a psychological evaluation occurred last year, five previous Orders to Show Cause (all of which were granted), five (5) prior incidences of TRO Violations (which were merged and reduced to two counts of harassment, not contempt), PL Support motion (and enforcement), and a multitude of harassing communications not only to my office, but to my client's friends and family.  I am not sure what else I can do to protect my client, especially since he keeps getting more time to comply, minimal/nominal sanctions/penalties from the court for his repeated bad faith conduct, and basically has free reign to do or say anything with impunity.  

Most alarmingly, he has a gun on his boat in Florida that he will not turn over despite the many TRO's and current FRO, and the Florida police will not seize the weapon.  Any thoughts on how to handle that issue is most appreciated as well.  I've filed for him to turn over his weapon under the FM, but judge's position is it should be brought under FV (I assume as an enforcement motion).  The problem is, there seems to be a jurisdictional issue whereby Florida doesn't seem interested in seizing the gun (they won't go to his boat because we don't know exactly where it is and they won't look for it).  

Again, I appreciate all of the responses and help.  

Greg

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Original Message------

Clearly, you are stuck in a bad matter with an individual who has little to no regard for the consequences of his actions. That said, my suggestion is that you review your office  protocols for protection for yourself and your office staff. My experience is that an out of control type person may soon turn his attention to you, thinking that you have some type of personal vendetta against him instead of simply recognizing that you are doing your job representing a client. 

This is the type of setting, where you should make sure  that your office door is locked at 5 pm each day and don't be afraid to reach out to the local police department if there is anything suspicious taking place ( hang up calls to your office, suspicious car parked outside, etc). 

This is not the type of matter to prove how tough you are or that any threat rolls off your back. 

Presume you already thought about this stuff but simply wanted to reinforce the benefit of being cautious.

Richard Diamond

Diamond & Diamond P.A.

225 Millburn Avenue, Suite 208

Millburn NJ 07041

973-379-9292

Original Message------

Clearly, you are stuck in a bad matter with an individual who has little to no regard for the consequences of his actions. That said, my suggestion is that you review your office  protocols for protection for yourself and your office staff. My experience is that an out of control type person may soon turn his attention to you, thinking that you have some type of personal vendetta against him instead of simply recognizing that you are doing your job representing a client. 

This is the type of setting, where you should make sure  that your office door is locked at 5 pm each day and don't be afraid to reach out to the local police department if there is anything suspicious taking place ( hang up calls to your office, suspicious car parked outside, etc). 

This is not the type of matter to prove how tough you are or that any threat rolls off your back. 

Presume you already thought about this stuff but simply wanted to reinforce the benefit of being cautious.

Richard Diamond

Diamond & Diamond P.A.

225 Millburn Avenue, Suite 208

Millburn NJ 07041

973-379-9292

Original Message------

Don't u just love being a matrimonial attorney?!!!

Sent from my iPhone

Original Message------

 I'ts funny.... but not really:

http://www.ksfamilylaw.com/news/Murder_highlights_safety_risks_of_family_law/

https://www.google.com/webhp?sourceid=chrome-instant&ion=1&espv=2&ie=UTF-8#safe=off&q=killing%20divorce%20lawyer

What we do can be dangerous - to us, to our clients, and to the judge who sit in Family. I know the idea of training folks who do Family Law to spot warning signs, both in clients and in their ex's, has been tossed around, but not sure what if anything has come of it. I wonder if the ABA or AAML or anyone has put something together? Is there any way to reliably tell a "vent" or extremely angry (rightfully or wrongly) client from someone who is an actual danger?  There oughta be mandatory training and reading on this....


<x-sigsep>

</x-sigsep> Please confirm that you received this email and referenced attachments (if any).

- Dave

David Perry Davis, Esq.
----------------------------------------------------
   www.FamilyLawNJ.pro
----------------------------------------------------
112 West Franklin Avenue
Pennington, NJ 08534
Voice: 609-737-2222
Fax:    609-737-3222

Original Message------

A few years ago I was in Brooklyn Supreme Court and I saw a man attacked a lawyer outside of the courtroom. in  about two minutes he had beat the lawyer so severely that blood was all over the floor... he mopped the floor with this lawyer.

I ran into the courtroom screaming for help..when it was over some colleagues said sarcastically "it could not have happened to a nicer guy" 

I have had  a client hung himself when I worked at legal services for New York and did  highly contentious DV cases.  He was just really down could not see his kids, lost his job in the tech bubble, got one after a year with the MTA and then the MTA downsized he was the first hired and the first fired. I still think about him.

I have had another client commit what I believe was suspected suicide.  I quit legal services soon after that...

I am very careful to be respectful of the litigants in divorce matters. I always preface my statements with "my client alleges.." After all I was not present... I represent my clients but I don't unnecessarily ramp up the litigation. I have seen attorneys deliberately bait litigants especially ones who are down on their luck and I always wondered if one day I would be in court when one of them snap and lash out again...it is scary...

This is not to say that being respectful and professional would lead to more safety I know on any given day that you can be attacked. 

________________________

Angela Barker, Esq.

Law Office of Angela Barker LLC

E-mail: [email protected]

Web: www.angelabarkerlaw.com

Tel: (646) 415-8883

Yes. I have one.


Original Message------

Every matrimonial attorney has horrific stories 

Sent from my iPhone

Just one, Peter? Hey, maybe the Courts can sell some of these instead of charging for gold seals and substitutions. I already suggested a bake sale or maybe a carnival, but didn't get the votes.

------------------------------
Curtis Romanowski Esq.
Senior Attorney - Proprietor
Metuchen NJ
(732)603-8585

Original Message:
Sent: 07-07-2016 14:42
From: Peter Paras
Subject: Adv. posted nude pictures of my client - want to pursue claim (Tevis?)

Yes. I have one.

Agree as to adding Tevis claim.

As to the criminal side. Given there is a pending violation under the FO docket, perhaps you could speak with the prosecutor handling the case to get her opinion on filing additional criminal charges? The prosecutor will be working with an investigator who may have turned up any number of interesting items.

The reason I think your client might want to pursue criminal charges is because she may not get the satisfaction she is looking for under the FO case. I was involved in an FO case where the defendant not only had prior contempt findings but the pending charges involved multiple and more serious allegations than posting nude photos. And he was offered a great deal. (No intent to minimize seriousness of nude photo posting.)

Best of luck with all aspects of this matter. Posting nude photos of an ex is reprehensible. Especially since the parties' children may see them.

Anne

Anne Cralle, Esq.
LAW OFFICE OF ANNE CRALLE
Limited Liability Company
276 Main St.
Metuchen, NJ 08840
(732) 829-5805

Sent from my iPad


Original Message------

Hi all,

I represent the wife in a very contentious divorce matter.  Husband is presently pro se.  It's a bad case (client had obtained 3 TRO's against Husband resulting in 2 Civil Restraints and finally a FRO, which is currently in place).  Husband's parenting time with the parties' son is suspended (except for a couple of Skype calls per week).  

2 weeks ago, Husband became irate at my client after his call to their son and began posting nude pictures of her (along with other inappropriate pictures and statements) to her father's facebook page.  There is a pending FO (contempt/violation of FRO) charge against Husband, but I want to evaluate pursuing additional remedies (criminal and civil).  

I know these posts fall under the crime of "invasion of privacy" statute N.J.S.A. 2C:14-9, so she could press charges there,  However, for her to pursue a civil claim, would I have to amend my Complaint for Divorce to add a "Tevis" claim for the tort of invasion of privacy pursuant to the Entire Controversy Doctrine, or should she pursue this separately outside of the FM Docket?

I'd appreciate your input!

Thanks,

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100
Fax: (732) 736-9505

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Original Message------

Hi all,

I represent the wife in a very contentious divorce matter.  Husband is presently pro se.  It's a bad case (client had obtained 3 TRO's against Husband resulting in 2 Civil Restraints and finally a FRO, which is currently in place).  Husband's parenting time with the parties' son is suspended (except for a couple of Skype calls per week).  

2 weeks ago, Husband became irate at my client after his call to their son and began posting nude pictures of her (along with other inappropriate pictures and statements) to her father's facebook page.  There is a pending FO (contempt/violation of FRO) charge against Husband, but I want to evaluate pursuing additional remedies (criminal and civil).  

I know these posts fall under the crime of "invasion of privacy" statute N.J.S.A. 2C:14-9, so she could press charges there,  However, for her to pursue a civil claim, would I have to amend my Complaint for Divorce to add a "Tevis" claim for the tort of invasion of privacy pursuant to the Entire Controversy Doctrine, or should she pursue this separately outside of the FM Docket?

I'd appreciate your input!

Thanks,

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100
Fax: (732) 736-9505

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

Original Message------

Hi all,

I represent the wife in a very contentious divorce matter.  Husband is presently pro se.  It's a bad case (client had obtained 3 TRO's against Husband resulting in 2 Civil Restraints and finally a FRO, which is currently in place).  Husband's parenting time with the parties' son is suspended (except for a couple of Skype calls per week).  

2 weeks ago, Husband became irate at my client after his call to their son and began posting nude pictures of her (along with other inappropriate pictures and statements) to her father's facebook page.  There is a pending FO (contempt/violation of FRO) charge against Husband, but I want to evaluate pursuing additional remedies (criminal and civil).  

I know these posts fall under the crime of "invasion of privacy" statute N.J.S.A. 2C:14-9, so she could press charges there,  However, for her to pursue a civil claim, would I have to amend my Complaint for Divorce to add a "Tevis" claim for the tort of invasion of privacy pursuant to the Entire Controversy Doctrine, or should she pursue this separately outside of the FM Docket?

I'd appreciate your input!

Thanks,

Gregory Thomlison, Esq.
Kerr & Thomlison, L.L.C.
650 Washington St.
Suite 1C
Toms River, NJ 08753
Ph. (732) 736-8100
Fax: (732) 736-9505

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.