NJSBA Family Law Section

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  • 1.  Order to Show Cause Questions

    Posted 07-29-2019 10:36 AM

    Potential client (Somerset County) is in mediation with her husband (no lawyers attending). She thought things were going well, including getting his verbal permission to take their teenager to London for two weeks for vacation this summer. Unfortunately, she did not get written permission, and she bought the tickets, and now husband refuses to give her a letter to travel. Post-separation, every time they have an agreement, husband backs out, which is why we said written agreements are important, but husband wasn't willing to do so. The trip takes place in 2 weeks. Is this worthy of an Order to Show Cause? Or will a Judge not entertain it? We're trying to balance cost of the lost ticket and trip (and wanting to put a stop to the husband's games) with the cost of an OSC. TIA.

     

    Misty

     

    P.S. If it is OSC worthy, would the Judge direct the father to provide a letter permitting the child to travel internationally with the mother, or will the Judge's Order be sufficient for international travel?

     

    New Misty Avellone.jpg

    Misty A. V. Avallone, Esq.
    P: 609.683.7400  F: 609.921.8982
    E: [email protected]
    www.kingstonlawgroup.com

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  • 2.  RE: Order to Show Cause Questions

    Posted 07-29-2019 10:45 AM
    I just handled this exact situation in a non-dissolution matter earlier this month in Warren County. We filed for an OTSC with a detailed supporting Certification and it was granted by the Judge. 

    I think a Court's Order specifically granting the parent permission to travel with the child to the specified destination with dates of travel listed is sufficient, but the Judge also directed the Father to sign a letter of consent. Better safe than sorry.

    Good luck.

    ------------------------------
    Blake W. Rush, Esq.
    Law Office of Blake W. Rush
    14 E. Main Street
    Clinton, NJ 08809
    (908) 713-9800 (PHONE)
    (908) 713-9803 (FAX)
    www.blakerushlaw.com
    ------------------------------



  • 3.  RE: Order to Show Cause Questions

    Posted 07-29-2019 11:31 AM
    It is worth it.  In your OSC ask the Court to designate your client sole legal custodian for purposes of obtaining a passport only and indicate consent of father is not required.

    MSR



    Sent from my Verizon, Samsung Galaxy smartphone





  • 4.  RE: Order to Show Cause Questions

    Posted 07-29-2019 12:07 PM

    Michael and Blake,

     

    Thank you!

     

    New Misty Avellone.jpg

    Misty A. V. Avallone, Esq.
    P: 609.683.7400  F: 609.921.8982
    E: [email protected]
    www.kingstonlawgroup.com






  • 5.  RE: Order to Show Cause Questions

    Posted 07-29-2019 10:47 AM

    I would request and OTSC with preliminary restraints-and counsel fees. Consent is being unreasonably withheld.

    Regards,

    Ed

     

    * * *

    Edward J. Zohn, Attorney at Law

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

    908.791.0312 office; 908.428.7988 direct; 908.660.4866 fax

    Chair, NJ State Bar Association Solo and Small-Firm Section

    www.zohnlaw.com

     






  • 6.  RE: Order to Show Cause Questions

    Posted 07-29-2019 11:51 AM
    Yes, we addressed  this type of commonly recurring issue in detail in Lyle v. Lyle, which was an unpublished  opinion which appeared in the NJ Judiciary's website in 2015.