NJSBA Family Law Section

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  • 1.  FRO Dissolution - Help

    Posted 12-12-2016 12:11 PM
    Hey Family Law Section!

    Currently, I am working on a case where our office represents the Defendant in a matter where he is seeking to have a FRO dissolved. The FRO is almost 20 years old, the parties have  had  relations since the FRO was entered, they communicate with each other, sit next to each other at their children's games, etc. However, the Plaintiff has been opposed to having the FRO dissolved for years, until a couple of days ago when she called our office and expressed that she would consent to the dissolution of the FRO. 

    Thereafter, I called the court to inquire as to whether this can be resolved by a Consent Order, and the court advised me that either the Plaintiff must go to the Domestic Violence Unit to fill out forms, and establish on the record that she consents to the dissolution of the FRO, or we file a motion. I have a feeling that Plaintiff will not be willing to take a day off to go to the court to fill out the forms. 

    Has anyone had a similar case? Any feedback will be appreciated!

    Thank you for your time! 


    Stephanie R. Carney
    Rutgers School of Law-Newark, Juris Doctor c/o 2015
    Minority Student Program Member

    Rutgers University- The State University of NJ, B.S. Environmental Policy (EPIB) c/o 2012
    Douglass Residential College Alumna



  • 2.  RE: FRO Dissolution - Help

    Posted 12-12-2016 02:08 PM
     
    I have not done one, but last time in was in Somerset County waiting to start my FRO trial, there was a case before us where the defendant brought that motion and the Judge granted it, the other side was there and consented.
     
    Gerri Duswalt


    GERALDENE SHERR DUSWALT

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  • 3.  RE: FRO Dissolution - Help

    Posted 12-12-2016 02:11 PM

    what the court said is correct. because it is dissolution of an FRO the Plaintiff must go to court if consenting on the record.  File your motion. Add a certification that the plaintiff consents and do a letter brief and make your argument in court. your case has the right facts.

     

    Alice M. Plastoris, Esq.

    Law Office of Alice M. Plastoris, Esq.

    82 Speedwell Avenue, 2nd Floor

    Morristown, NJ 07960

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    Fax No. (973) 538-7088

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  • 4.  RE: FRO Dissolution - Help

    Posted 12-12-2016 02:26 PM

    Because it is the Court's decision, and the Plaintiff must always ask the Court to dismiss an FRO rather than tell the Court.  Check R. 5:7A and comments:

    11. Dissolution of Restraining Orders.

    11.1 Dissolution on defendant's application. As to the general standards for dissolution of a final restraining order on application of the defendant pursuant to the good cause provision of N.J.S. 2C:25-29(d), see Kanaszka v. Kunen, 313 N.J. Super. 600 (App. Div. 1998), requiring defendant, based on the record of the prior proceeding and its history, to make a showing of substantial changed circumstances warranting that relief and requiring a plenary hearing only if there were such a preliminary showing as well as the appearance of material factual disputes. Kanaszka overruled the holding in M.V. v. J.R.G., 312 N.J. Super. 597 (Ch. Div. 1997), which required a defendant must wait one year before making the application. See also Sweeney v. Honachefsky, 313 N.J. Super. 443 (App. Div. 1998) (dissolution of the order depends on the specific facts of each case without prescribed time limits).
    11.2. Dissolution on plaintiff's application. As to dissolution of a preliminary restraining order at the request of plaintiff before final adjudication, see Kelleher v. Galindo, 350 N.J. Super. 570 (Ch. Div. 2002), requiring, under the circumstances, plaintiff's actual court appearance rather than telephonic request.
    The Appellate Division has not yet addressed the issue of the standard of proof required for vacation of a final restraining order on application of the plaintiff. The Family Part is split on this issue. Compare Stevenson v. Stevenson, 314 N.J. Super. 350 (Ch. Div. 1998), applying a "good cause" standard, and I.J. v. I.S., 328 N.J. Super. 166, 177 (Ch. Div. 1999), requiring only a showing that the application is voluntary, that there is a lack of coercion, and that the victim understands the "cycle of violence." Although N.J.S. 2C:25-29(d) requires the application to vacate a final restraining order to be brought before the issuing judge or a judge having a complete record, the court in I.J. v. I.S. held that because of the impracticality of the same judge requirement, any Family Court Judge may, upon proper showing, vacate an order on the plaintiff's application. The court, in so holding, concluded that a "complete record" need not include the transcript of the FRO hearing and that the affidavit filed with it and the affidavit for dismissal and the testimony of the plaintiff at the dismissal hearing constituted a complete record.

    ------------------------------
    Jenny Berse, Esq.
    Cranford, NJ 07016
    (855) 326-5291
    [email protected]



  • 5.  RE: FRO Dissolution - Help

    Posted 12-12-2016 03:04 PM

    Stephanie,

      The defendant could have gone to court with a motion to dissolve the FRO a long time ago with these facts. The plaintiff can't contribute to the mutual violation of the FRO and then withhold consent to dissolve the order.

      But the court is right, as others have noted.

    Regards,

    Ed

     

    * * *

    Edward J. Zohn, Attorney at Law

    Zohn & Zohn, LLP; 7 Mount Bethel Road, Warren NJ 07059

    908.791.0312 voice; 908.660.4866 fax

    "Leges sine moribus vanae" (Laws without morals are useless) - U. of Penna. Motto

    www.zohnlaw.com

     






  • 6.  RE: FRO Dissolution - Help

    Posted 12-12-2016 03:36 PM

    Remember, of course, that if Plaintiff won't go to Court and fill out the papers and request that the Judge dissolves the FRO, and Defendant files the Motion, Defendant must address the Carfagno factors.

    ------------------------------
    Jenny Berse, Esq.
    Cranford, NJ 07016
    (855) 326-5291
    [email protected]



  • 7.  RE: FRO Dissolution - Help

    Posted 12-12-2016 06:42 PM
    Stephanie -

    He needs to file a motion and go through the Carfagno factors. I had one with very similar facts about six months ago - plaintiff had no real objection to it being dismissed (they'd also freely communicated, she listed him as next-of-kin on hospital paperwork, etc) but she didn't want to take the time to go to the courthouse as required by the Domestic Violence Procedures Manual - http://dpdlaw.com/dv_procedures_manual.pdf - (a judge needs to question the plaintiff and ensure the withdrawal of the order is voluntary, not coerced, knowing, etc).

    If he files a motion and reviews the Carfagno factors and she doesn't oppose it, then there's no need for a plenary hearing (which is generally if not always required if plaintiff opposes the dissolution), and the court can dismiss the FRO without a plenary.

    I'll share the motion I filed last year, but don't want to attach it since DV records are confidential. Send me your email address and I'll shoot you a copy off-list.


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