NJSBA Family Law Section

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  • 1.  How stale is stale?

    Posted 09-17-2013 03:19 PM
    Greetings,

    I have a client who has been trying to collect reimbursable expenses for daycare, out of pocket medical, camp, activities etc since 1995.  Ex-husband relocated to 10 different addresses since 1995 so keeping up with him was not easy and often years went by before she actually knew where he lived.

    Does anyone think she has a prayer of recovering expenses back to 1995?? My gut says no but ..... I hate to leave her without a remedy. 

    The proofs are enormous too.  I'm sure the court will not be happy to receive 24 inches of exhibits to substantiate these expenses.  Has anyone filed a motion with this volume of exhibits?

    Any thoughts or angles would be appreciated.

    Thank you.

    Regards,
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    Rosanne DeTorres Esq.
    Flemington NJ
    (908)284-6005

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  • 2.  RE:How stale is stale?

    Posted 09-17-2013 03:49 PM
    18 years does sound like too long unless she was unable to locate him.
    However, regardless of the amount of years, I suggest a summary page where the expenses are listed and the total is calculated, in addition to the proofs.  That makes it easier to see what you are seeking.

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    Wendy Ezor Engler, Esq.
    Hackensack, NJ 07601
    201-488-7001

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