NJSBA Family Law Section

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  • 1.  alimony

    Posted 01-29-2015 10:03 AM
    This message has been cross posted to the following Discussions: Solo and Small Firm and Family Law .
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    I am in the process of negotiating a property settlement agreement and the other attorney is insisting on a non-modifiable alimony paragraph. I believe that agreeing to this is tantamount to malpractice. Am I crazy or what.

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    Larry Raiken Esq.
    Montville NJ
    (973) 808-2003
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  • 2.  RE: alimony

    Posted 01-29-2015 10:35 AM
    Larry,
    You are not crazy. I would never agree to do that .
    On Jan 29, 2015 10:03 AM, "Larry Raiken via New Jersey State Bar




  • 3.  RE: alimony

    Posted 01-29-2015 10:48 AM
    Non modifiable alimony may be appropriate in the right case. Depends on the facts. When alimony is in lieu of equitable distribution a non-modifiable alimony provision that survives remarriage and changed circumstances could be appropriate. 

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    Mark Gruber Esq.
    Hopatcong NJ
    (973)398-7500
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  • 4.  RE: alimony

    Posted 01-29-2015 11:01 AM
    But then it's not alimony only disguised as such.
    On Jan 29, 2015 9:48 AM, "Mark Gruber via New Jersey State Bar Association"




  • 5.  RE: alimony

    Posted 01-29-2015 11:04 AM
    There had better be sufficient consideration for such a concession on your client's part as, if you went to trial, husband would not get that relief.

    Gary L. Borger, Esquire
    Borger Matez, P.A.
    1415 Marlton Pike (Route 70) East, Suite 305
    Cherry Hill, NJ 08034-2210
    Office phone: (856) 424-3444
    Cell: (856) 308-6158
    Fax: (856) 424-3690
    E-mail: [email protected]<mailto:[email protected]>
    Website: www.njfamilylaw.net<http: www.njfamilylaw.net/="">
    P Consider the environment before printing this e-mail.




  • 6.  RE: alimony

    Posted 01-29-2015 11:28 AM

    Unless I am missing something, anti-Lepis clauses are routinely drafted and incorporated into MSAs - I have done them for both waivers of alimony and LDA.  If this is an agreement regarding open durational alimony (fka permanent alimony), I would not include such a clause into the MSA, but otherwise, maybe.Remember, that these clauses cut both ways - if you are representing the obligor, it presents the obligee from coming back and asking for more money; if you are representing the obligee, it prevents the obligor from seeking a reduction, suspension or termination.  I also know that, where equity demands it, a Court will allow for a modification/suspension/termination of alimony despite an anti-Lepis clause.  Like in any other family law situation, it depends upon the facts of your case as to whether you agree to such a clause or not. 

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    Nancy Marchioni Esq.
    Middlesex NJ
    (732)667-3668
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  • 7.  RE: alimony

    Posted 01-29-2015 12:03 PM

        Are anti-Lepis clauses valid?  During the first decade of Lepis litigation from 1980 to 1990, no reported decisions directly addressed the question.  Then, from 1990 to the present date, three published opinions have grappled with the issue, and, not surprisingly, reached three different conclusions.   As set forth in the following inconclusive trilogy of cases, the answer appears to be yes and no (at the trial level) and maybe (at the appellate level).

              A. "As this court finds no public policy to support prohibiting the inclusion of an 'anti-Lepis' clause in a voluntary property settlement agreement, no modification shall be granted." Finckin v. Finckin, 240 N.J. Super. 204(Ch. Div. 1990).

               B. "This court respectfully disagrees with the conclusion reached in Finckin, supra, and, for the reasons set forth below, holds that an 'anti-Lepis' clause...is contrary to the public policy of this State...Smith v. Smith, 261 N.J. Super. 198 (Ch. Div. 1992).

               C. "There is a conflict between two Chancery Division opinions concerning whether an anti-Lepis clause is enforceable... Smith v. Smith, 261 N.J. Super. 198 (Ch. Div. 1992),   Finckin v. Finckin, 240 N.J. Super. 204 (Ch. Div. 1990)... we must give an equivocal answer to the question of whether an anti-Lepis clause is enforceable.  It is both yes and no."  Morris v. Morris, 263 N.J. Super. 237 (App. Div. 1993).



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    Charles Abut Esq.
    Hackensack NJ
    (201)342-0404
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  • 8.  RE: alimony

    Posted 01-29-2015 01:41 PM
    Nancy is right and there are many situations and scenarios where the clause
    makes sense for both parties. As long as each party clearly understands the
    risks/benefits, it's something to consider, particularly in shorter LDA
    cases.


    Bruce





    Bruce Evan Chase, Esq.

    Certified by the Supreme Court of New Jersey as a Matrimonial Law Attorney

    Fellow of the American Academy of Matrimonial Lawyers

    Chase & Chase, Esqs.

    1 Atlantic Street

    Hackensack, NJ 07601

    201-343-6555

    201-343-2658 fax




  • 9.  RE: alimony

    Posted 01-29-2015 03:01 PM

    On anti-Lepis clauses, probably all of us have horror stories.  My biggest one was a guy in the textile industry making roughly $450,000 per year.  He was on the verge of opening new factories and reasonably anticipated that his income was going to skyrocket to at least ten times what he was making.  He insisted on an anti-Lepis clause containing an iron-clad non-modifiable alimony provision.  Then, about three months later, President Bush removed the tariffs on textiles and the Chinese flooded the market. His factories closed and his income essentially disappeared.  You can't compete with slave labor.  Eventually, after significant arrears developed, the judge ordered a hearing, holding the anti-Lepis clause left the pre-Lepis standard (Schiffman / "unconscionable") in place and granted relief.  I've still got the briefs from it - if anyone needs them, email me off-list.

    Always, always, stress to a client that an anti-Lepis clause is a double-edged sword.  Always do this in writing.  Always get a CYA letter from the client having them acknowledge the risks and that those risks were fully explained to them and that they're acting against your advice.  I once shared space with a malpractice attorney and I probably ask for a CYA letter in 25% of my cases (e.g., accepting less support or e.d. or paying more).

    Also, be sure that you're not rendering the alimony non-deductible by your clause (again, a potential malpractice trap). Here's a couple of good references on it:

    http://www.irs.gov/publications/p17/ch18.html   (dryer, but more through.  Not long and is mandatory readings).

    http://www.divorcenet.com/states/nationwide/the_seven_alimony_rules  (good, readable summary).

    Be careful that, if audited, there's no room for the IRS to claim that you were disguising child support or equitable distribution as alimony.

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