As to Question #2, you would want to file an ex parte OTSC explaining in detail why you need to file the application without notice to the other side, and specifying exactly which accounts you need to freeze. If you have proof of prior transfers, attach them, being careful to redact any identifying information other than the last four digits of the account. Then once you get the TRO, be sure to serve it on the legal department of every account that the judge is freezing. If once the defendant is served, he is successful in throwing out the TRO, then you would again have to notify the various entities that the TRO was lifted. If a FRO is entered, you would serve that on the same entities as the TRO. Don't forget to mark your file to dissolve those FRO's when the divorce is finalized. Good luck.
Roz
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Rosalyn Metzger, Esq.
Rosalyn A. Metzger LLC
4 Wood Hollow Drive
Pittstown, New Jersey 08867
[email protected] www.mediate.com\RMetzger (908) 238-0099
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