Dear Colleagues:
I am being swamped lately, I and cannot get to all the matrimonial motions I have to prepare and/or respond to on a timely basis.
I have deadlines for a summary judgment motion on a Lepis alimony reduction application I am defending against and wish to file a motion returnable by mid-May to ask the court dismiss the Lepis application because I don’t think there is evidence to sustain the moving party’s burden of proof. I have a motion pending in Warren County now returnable April 29 that I must respond to and file a cross-motion with complex facts. I just got hit today with a 8 inch think motion to enforce litigant’s rights and for other relief, and that is also returnable April 29. I need to file a motion to enforce a settlement agreement involving a million dollar buy out on a condo and compliance with other equitable distribution terms, etc, which I would like to get heard by mid-May at the latest.
If you know of anyone willing to help on a per diem basis, I would love to hear from you or whomever you recommend. Thanks.
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Robert Goldstein Esq.
Manalapan NJ
(732)972-1600
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