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"Post-Nuptial" or Reconcilation Agreements

  • 1.  "Post-Nuptial" or Reconcilation Agreements

    Posted 01-13-2015 02:07 PM

    Client called me and is coming in tomorrow.  13 year marriage, no children.  Husband told her that he wanted her to sign a "post-nuptial" agreement whereby she permanently waives alimony and equitable distribution of marital assets or he would file for divorce.  In the short phone conversation I had with her while setting the appointment, I asked if there had been any marital rift, any infidelity or wrongdoing on her part.  Was this proposed as consideration for a reconciliation?   She said no infidelity or wrongdoing on her part and this was the first inkling she had of husband wanting to end the marriage.  I said I did not believe such an agreement would be enforceable and just to tell her husband for now that she was thinking about it if he was pressuring her.

     I was aware of Pacelli v. Pacelli and Nicholson v. Nicholson and went back and checked to see if there was any new progeny.  I saw nothing.  Is anyone aware of anything that would change the general principle that post-nuptial agreements are inherently coercive and must be fair and equitable to be enforceable and reconciliation agreements may be enforced if the marriage has deteriorated to the point where it is on the brink of divorce, if it is a promise that induces a reconciliation, and is fair and equitable?

    Thanks,

    Clara S. Licata

     

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    Law Office of
    Clara S. Licata, Esq.
    55 Harristown Rd.
    Suite 302
    Glen Rock, NJ 07452
    201-612-1170
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    ------------------------------



  • 2.  RE: "Post-Nuptial" or Reconcilation Agreements

    Posted 01-13-2015 07:44 PM
    Clara,



    The best answer is "maybe". We don't know whether mid-marriage agreements will hold up until they are tested, and they are tested in the light of what occurs later, not earlier. If the deal is unconscionable when enforcement is sought, then the agreement is dead. If the deal is deemed pressured when it was made, then the agreement is dead.



    On the other hand, consenting adults are entitled to self determination.



    I don't agree that mid-marriage contracts are inherently coercive. That is not how I read the few cases that exist in our state. They are certainly vulnerable to challenge.



    Your best bet is to have a signed enforceable retainer agreement that lays out the uncertainties. You cannot disclaim professional liability. All you can do is show informed consent and your advice as to whether or not to enter into the agreement.



    And keep paying your professional liability insurance premiums.



    Hanan




  • 3.  RE: "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 06:35 AM
    What about when the parties decide to "get back together" while the case is
    pending and do not want to do any agreement, just discontinue the case.
    Would it make a difference if they have assets subject to ED?



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  • 4.  RE: "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 08:06 AM
    That is very fact sensitive. It would seem to depend on what each did with his/her income and how they dealt with their assets. To the extent that they effectively continued the marital enterprise, it would seem that the judge could include post-complaint assets in the marital estate by virtue of a continued marital partnership. To the extent they maintained separate bank accounts and supported themselves from their individual income, that would support maintaining the cutoff of the marital estate with the filing of the complaint.


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  • 5.  RE: Family Law : "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 08:33 AM

    Thanks to all who responded.  Client is coming in this morning and perhaps with additional facts I'll have a better sense.  I may be back with more questions!

     Clara

    ------------------------------
    Law Office of
    Clara S. Licata, Esq.
    55 Harristown Rd.
    Suite 302
    Glen Rock, NJ 07452
    201-612-1170
    Fax 201-612-1179
    ------------------------------




  • 6.  RE: Family Law : Family Law : "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 10:21 AM

    Clara - 

    Been there, done that, got the t-shirt.  Very frustrating and not uncommon scenario. Had it more than once, but most extreme -- Client was completely dependent spouse, H earned $125+ and controlled all the marital assets.  A p.l. order was entered requiring him to advance a retainer and pay $3500 / month in support.  H files for reconsideration, saying he couldn't possibly do either, motion denied and counsel fee award entered.  H then appears (literally) with roses and apologies for W.  Transparent to me, but easier for us to see what's up than someone who has 25 years and three kids invested.  Sure enough, he appears with a consent order and a "reconciliation agreement" that can only be politely called financial sodomy.  I did everything I could to get her not to sign it, delayed, had her sign two giant-font CYA letters saying it was explicitly against my advice, even made her get on a phone conference with family members.  She signs it.  Six months later, H reveals he'd never broken up with his new GF, never loved W, just wanted out from under on the agreement.  He files new complaint and wants to use this "Agreement" as basis for it. Also, coincidentally, he left his prior job and was working for a friend "earning $40,000", all the assets were gone "through a series of bad investments in a friend's business venture", etc, so no funds beyond a limited credit card line for her to retain counsel.  Client was borderline suicidal. Sometimes practicing Family Law is hard.

    Anyway, I thoroughly briefed  the issue of pre-nups, mid-marriage, and PSA's and the different standards that apply (as H's agreement purported to be a reconciliation agreement that would automatically become a PSA if the parties again filed for divorce -- that didn't fly; different legal standards).  I'll shoot you a copy of the pleadings off-list.

    I agree with Hanan that there is no case that says a reconciliation agreement is inherently coercive.


    Gary - Recently went through this issue here; be careful.  I had the same thinking you did as to the cut-off date for ED still possibly being based on the complaint date if it is later dismissed.  I cited Portner from the App Div.  Hanan corrected me, pointing out that the Supremes had stepped in and reversed.  Black letter: Absent an explicit written agreement to the contrary, a complaint only serves as the cutoff date for ED if it results in a final judgment of divorce.  What the parties do with their money after a reconciliation and complaint dismissal would NOT control:  http://community.njsba.com/communities/alldiscussions/viewthread/?GroupId=1291&MID=16961



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  • 7.  RE: Family Law : Family Law : Family Law : "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 01:29 PM

    Thanks, everyone.

     I advised client not to sign the agreement and gave her a thorough letter confirming everything we discussed.  Actually, the agreement has not been prepared, but husband gave wife a memo by e-mail of the features he wanted in the agreement, including:

    1.  50-50 split of assets, although he claimed the marital joint account contained cash "gifts" from other people he claimed were exempt (even though commingled. . .);

    2.  Either waiver of alimony or very limited alimony on the ground that she had substantial pre-marital assets.  (A non-sequitur in my opinion).  Also, agreement to 50-50 distribution of assets would be affected if she asked for alimony.  (It is a 13 year marriage, so there is going to be some entitlement to alimony, even under the new statute, and given the disparity in income, I don't think the amount would be insignificant.

     3.  Segregation of future assets (including income) and payment of marital expenses on a 50-50 basis.  Did I mention he makes $210K annually and she makes $60K?  And that he might be willing to contribute more than half if he feels he is "happily married."  (a completely subjective standard). 

    This proposed agreement is not a reconciliation agreement.  Parties had not been separated, there was no marital infidelity or significant marital "fault" on my client's part.  In fact, she had been attending therapy for the past year to actively work on issues he identified, such as "you are curt and dismissive of me. . ." He also had been to therapy to work on some issues she identified.  She felt they had made real progress and then he dropped this bombshell proposal, which was positioned as sign this, if you want to stay married to me.  Reading Pacelli, this agreement is inherently coercive.  Do what I say or get ready for a divorce (which she didn't want, she loves him) and in light of the inbalance in incomes, she could not maintain the same marital standard of living.  Marriage had not genuinely deteriorated, husband's motivation was financial, and agreement was not fair.

     I told her to call his bluff and if he files for divorce, in my opinion what she would get in settlement or at trial would be fairer than what he is offering her.

    Clara

    ------------------------------
    Law Office of
    Clara S. Licata, Esq.
    55 Harristown Rd.
    Suite 302
    Glen Rock, NJ 07452
    201-612-1170
    Fax 201-612-1179
    ------------------------------




  • 8.  RE: Family Law : Family Law : Family Law : "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 02:07 PM
    Great advice.

    Hanan
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  • 9.  RE: Family Law : Family Law : Family Law : "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 02:26 PM
    I would have done the same thing you did, Clara. You did the right thing, moreover, by writing her. You have just earned the trust of a new client – albeit, down the road – because that is where this situation is going. Bluff or no bluff, he is posturing for the divorce that is inevitable, I bet.



    I didn't jump in and give my two cents to your prior email until now but was going to. I was going to say, it takes two to tango. If he doesn't want to be married, so be it. There's nothing she can do about that. But to keep the marriage going – for probably what is a little period of time anyway -- by signing an obviously coercive and unfair agreement is not a good program. That is not the way for her to go. It is just putting off until a later time the inevitable, and you certainly don't want to be there with a bad agreement in place. Like you, I would have had nothing to do with that. Being involved in such an agreement is not a fee you need to earn!



    I would have, further, told her to do her own posturing, if you will, with respect to document accumulation in the interim. It will make her life, and yours, so much easier later on. Photocopies are cheap. You probably already told her that.



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  • 10.  RE: Family Law : Family Law : Family Law : Family Law : "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 05:32 PM

    I agree you handled it well.

    I was about to post and say essentially the same thing Mark did -- that she needs to gather as much documentation as possible, whether she stays in the marriage or not. If things work out (which doesn't sound likely), then no harm done.  If this goes where we all seem to suspect it will, it will make it that much easier down the road to at least track the assets.

    ------------------------------
    David Perry Davis, Esq.
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax: 609-737-3222
    http://www.FamilyLawNJ.pro
    ------------------------------ 



  • 11.  RE: "Post-Nuptial" or Reconcilation Agreements

    Posted 01-14-2015 09:23 AM
    Just for another idea - you could put a choice of law paragraph in the agreement and pick PA. IN PA mid-marriage contracts are certainly enforceable as long as there is consideration. PA's case law is very different one pre and post nuptial agreements in that it looks at the time the agreement was signed, not when the agreement is seeking to be enforced. And, unlike NJ, it is difficult to get agreements vacated.

    Just an idea.

    Megan


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