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CDFA as Expert on Alimony Need/Projections

  • 1.  CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 11:22 AM
    I am handling an Arbitration and plan on presenting my client's financial planner as an expert (or, in the alternative, as a lay witness) to help show the short term and long term need for alimony, including the need for savings. 

    The presentation includes a summary of scenarios wherein if the client receives alimony at different levels and maintains her proposed budget (or reduces the budget), how much she can save and what her long term financial outlook is during the alimony term and after.  

    I am being asked to "prove" that my client's financial planner is permitted to provide expert testimony and that her report is admissible to assist the trier of fact in calculating the appropriate alimony amount and term.

    Anyone have any experience with this or know of a specific case where I can show a CDFA or other Financial Planner was used as an expert for alimony purposes?

    It almost seems too obvious--as I know many CDFAs market themselves as potential expert witnesses. 

    TIA

    ------------------------------
    David Cardamone Esq.
    Miller & Gaudio, P.C.
    ------------------------------


  • 2.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 11:37 AM
    Edited by System 12-28-2023 05:26 PM

    The CDFA would have to be qualified to testify as an expert witness since lay witnesses are limited by NJRE 701 to testifying to personal observations through their own sense of touch, taste, sight, smell or hearing.

     

    See footnote 2 in Lombardi v. Lombardi for an example of an expert testifying regarding savings and the impact of different alimony scenarios.

     

    ____________________________________

    Brian G. Paul, Esq.

    Certified Matrimonial Law Attorney

    Szaferman, Lakind, Blumstein & Blader, P.C.

    101 Grovers Mill Road

    Lawrenceville, New Jersey  08648

    Phone:  609-275-0400

    Direct Fax:  609-779-6065

    [email protected]

    2019-Logo-Email-Signature-

     






  • 3.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 12:02 PM
    David,

    Two issues arise:

    1. Is the area of proposed expert opinion one that the field of asserted expertise -- and the courts -- recognize and accept?

    2. If yes, then does your proposed expert have the necessary background, training, and experience to qualify as an expert in the recognized field?

    To the first question: I don't have a case to offer you. It would surprise me greatly if financial planning has not been court approved as an area in which expert opinion has been recognized and welcomed, allowing data and tetestimony regarding forecasting of the marketplace as well as of an individual's or couple's financial future, given certain stated assumptions, such as size of assets, projected growth rates, addition or subtraction of alimony, child support, projected earned incomes, and the "burn rate" of the supported spouse's dollars over time.

    The other team is entitled to counter such testimony with an expert of their own.

    Under the NJ Rules of Evidence, the relevant standard of court review for proffered expert testimony is the US Supreme Court's Daubert standard, recently adopted by our Supreme Court as well.

    To the second question: The individual's expertise to testify, while previous recognition as an expert is helpful, it is not required.  If the individual's knowledge, training, and experience are relevant and helpful to the trier of fact, the person's standing as an expert should follow.

    Relative inexperience as an expert may go to the weight of the court's consideration, not admissibility.

    However, an expert's bare conclusions, unsupported by facts and analysis, will be excluded as a net opinion, even if the field of expertise is recognized and the individual qualifies as an expert.

    It is up to the trier of fact, in its sole discretion, to decide how much weight, if any, to give to an expert's opinion -- even if the person is deemed an expert and the opinion is deemed admissible.

    Perhaps a CPA will qualify where a CFP does not?

    Conclusion:

    Satisfy yourself as to questions 1 and 2, and you are good to go. If either one flunks the test, then your case has a major weakness. Proceed accordingly.

    Hanan Isaacs

    Hanan-New-pic.jpg

    Hanan M. Isaacs, Esq.
    President/Senior Attorney

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  • 4.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 12:11 PM

    Check out Overbay v. Overbay, 376 NJ 99 (App. Div. 2005), where both parties presented expert testimony from financial planners.

     

    Charles F. Vuotto, Jr., Esq.

    Starr, Gern, Davison & Rubin, P.C.

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

    Fellow of the American Academy of Matrimonial Lawyers

    Certified by the American Academy of Matrimonial Lawyers as an Arbitrator

    Qualified by the Supreme Court of New Jersey as an Economic Mediator

    2016 Tischler Award Winner given by the NJSBA

    for Lifetime Achievement in Family Law

    105 Eisenhower Parkway, Suite 401

    Roseland, NJ  07068

    Tel. 973-403-9200, Ext. 246

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    Website: www.vuotto.com

     






  • 5.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 12:18 PM
    Chuck,

    To bolster your point:

    In Overbay, the trial court's own expert was a financial planner.

    Hanan

    Hanan-New-pic.jpg

    Hanan M. Isaacs, Esq.
    President/Senior Attorney

    P: 609.683.7400  F: 609.921.8982
    E: [email protected]
    www.kingstonlawgroup.com






  • 6.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 12:20 PM

    What does your arbitration agreement provide?  Are you allowed to relax the rules of evidence?  What are the financial planners qualifications? 

     

    Lawrence D. Forster
    Forster Arbore Velez

    Attorneys at Law
    Tel: (973) 584-1501
    Fax: (973) 584-3150

    www.forsterarbore.com

     

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  • 7.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 09-19-2019 03:04 PM
    This is an interesting discussion.  First, I don't understand how anyone can think that someone who is a certified financial planner would not be permitted to testify as an expert.  Just walk through the foundation to qualify that person.  And I have now done this twice.  I would agree that Overbay and Lombardi are the leading cases but don't forget Gnall.  Well, footnote two of Lombardi is oblique and not overly helpful.  The remand instructions in Gnall are equally oblique.  That just says there was testimony on the savings and the judge failed to rule on it so on remand the trial court needs to rethink it.  Doesn't tell us how to do it.  So in that case I did hire a certified financial planner.  Practical problem with those folks is that they basically are not forensic experts, meaning they have no idea how to write a report or testify.  I basically wrote it.  And if I had to do it again, I would do it differently.  Yes, Overbay does say the experts were certified financial planners but in fact they were not.  Mrs. Overbay's "expert" was her financial advisor, I think from Merrill Lynch but you can ask Bonnie Frost as it was her case.  The Appellate Division does not always have the facts right....  If the App Div thinks your investment advisor is an expert, I really don't see the issue with someone who actually is. 

    But I don't think that is where the issue is.  It is what amount of savings someone is entitled to maintain the standard of living.  We have law that says you are entitled to savings against the day when alimony terminates but no definitive law on what that means or whether, depending on the duration of the marriage, etc., what you might be entitled to on an lda case. I think, and I think most of us agree, that the facts of Lombardi are unique and not something to be applied across the board.  But there is still some good language in that case that goes to the equities.  So we are on uncharted territory which requires us to argue law that doesn't really exist and equitable issues. To my way of thinking that is a much bigger issue than what buzz word credentials some expert has.

    My second case, still on remand after three years will get tried (presumably sometime in this century) and we have expert issues on that as well.  In that case my client is the payor spouse who has a full age, full faith retirement and a boat load of assets.  Remand from the App Div says the there was no testimony as to what a reasonable investment plan in retirement would generate by way of income available to pay support and on remand the court has to consider that.  Again, doesn't say how we are supposed to do that.  On that case I do not have a "certified financial planner."  I have a CPA who formally had those credentials but they are not current.  My adversary simply has a CPA with no qualfications to testify about a reasonable financial plan at all and we are off to the races.  I don't doubt for one minute that anyone with CPA after their name will not be allowed to testify and the issue will be the weight the judge gives to their testimony.  I will get back to you on that after I deal with depositions and file my motion in limine.

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    Dale Console Esq.
    (609)683-0003
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  • 8.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 04-29-2020 09:35 AM

    Any recommendations for mediators in the Los Angeles area?

     

    Lawrence D. Forster
    Forster Arbore Velez

    Attorneys at Law
    Tel: (973) 584-1501
    Fax: (973) 584-3150

    www.forsterarbore.com

     

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  • 9.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 04-29-2020 09:46 AM

    Bosch.

     






  • 10.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 04-29-2020 10:02 AM
    Diane Goodman, Esq. is in LA area.

    Deb Guston


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  • 11.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 04-29-2020 12:13 PM

    Holly Moore, Esq. of Moore Family Law Group 951-534-5440

     

    Jennifer Armstrong

     

     

    Jennifer D. Armstrong, Esq.

    611 Main Street, Suite 4

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  • 12.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 04-29-2020 12:32 PM
    Jill Cohen. Seasoned mediator in LA. 
    That is all that she does. 

    Good luck. 
    --
    Adam J. Berner, Esq., M.A.
    Mediator, Collaborative Lawyer & Trainer






  • 13.  RE: CDFA as Expert on Alimony Need/Projections

    Posted 04-29-2020 02:45 PM
    Gordon D. Cruse, Esq.
    Gordon D. Cruse, APLC
    402 W. Broadway. Suite 1210
    San Diego, CA 92101-8508
    Phone: 619-696-9922
    Fax: 619-696-0586
    [email protected]
    www.gordoncruse.com


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    Madeline Marzano-Lesnevich Esq.
    Lesnevich,Marzano-Lesnevich,O'Cathain & O'Cathain
    (201)488-1161
    ------------------------------