NJSBA Family Law Section

 View Only
  • 1.  Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-29-2016 02:44 PM

    Husband and wife married for 18 years, during which time wife is a homemaker raising the parties 3 children. During the same time frame, husband and a partner start a business, which towards the later years of the marriage provides him with approximately 500,000.00 - 550,000.00 per annum of salary, bonus and perqs. 

    In the end of 1998 / beginning of 1999 ( after 18 years of marriage), the parties decide to divorce and husband suggests that they do not need to waste money on divorce lawyers and instead suggests that they use their "friend" - husband's business lawyer to handle the divorce  with the lawyer to determine the amount / duration of alimony, child support, distribution of assets, etc. Wife agrees and husband's business  lawyer  prepares a settlement agreement purporting to resolve all issues outstanding in their matter. 

    While preparing the divorce settlement agreement, since ( under the terms of the deal) husband is going to retain the marital home, the same lawyer represents wife in connection with the purchase of a replacement home for her and the 3 children, with wife signing  a power of attorney authorizing the lawyer to handle all aspects of the home purchase on her behalf including signing off on the HUD statement for her ( so that she did not need the to attend the closing of title for the purchase). 

    Not surprisingly, an examination of the terms of the agreement  reveals that Husband retained at least  93% of the assets of the marriage ( if not more), including retention of his 50% ownership interest in the business operation, the marital home, and both of the parties vacation homes.

    As to the support provisions, while acknowledging that husbands income setting was approximately 500K - 550K per annum and acknowledging that wife had no employment nor any formal employment skills, the agreement provided wife with 70,000.00 per year in limited duration alimony for a 12 year duration and 2000.00 per month in total child support for the benefit of the 3 children, which 2,000.00 per month included husband's contribution to their unreimbursed healthcare costs, summer camp, extracurriculars, etc.

    As to the 2,000.00 per month child support figure, the agreement stated that the amount was based on the "applicable child support guidelines', despite the fact that the guidelines at the time only went up to a max of 2900.00 net per week or 150,800 net per annum.

    As such, after payment of all applicable taxes on the reported portion of his income setting ( 113,000.00) and the payment of the alimony ( 70,000.00),  husband was left with an actual net cash flow of approximately 342,000.00 or about 191,200 of net cash flow in excess of the guidelines applicable at the time. 

    In 2011, after the alimony terminated and wife was heavily in debt and without any form of health insurance coverage, Wife filed an application with the court to set aside the settlement agreement and reexamine the equitable distribution and support provisions of the agreement. The court then set the matter down for a trial on the issues raised.

    In early 2015, the court ruled  that husband and his business lawyer intentionally defrauded and took advantage of wife  and that the terms of the agreement were unconscionable AND that after the agreement was put in place, husband continued to deceive and defraud  wife and their 3 children as to his  health status, the  health status of his business operation and his true income setting.

    The court found that  while husband repeatedly told wife that he was very sickly, that financially he was on the verge of impoverishment and that his business was on the verge of closing down ( which representations were also put in writing by him), it turned out that husband was earning  between 550,000.00 and 710,000.00 per year from that same business operation annually and from 1999 to the present t the revenue of his business  operation remained steady as well.

    Based on all of the aforementioned, the court has now set a date for retrial to take place on the issues of alimony, child support and distribution of assets. 

    So, here are my 2 questions:

    1. Can the court now go back in time and recalculate what the wife should have received in alimony ( amount and duration) and retroactively credit her with the difference between what was paid to her and what she should have received? Hypothetically, if wife should have received 150,000.00 in alimony during that time period and husband only paid her 70,000.00, can the court now apply a form of Mallamo type ruling and award her the difference 80,000.00 x ___ years (ignoring the tax issues for the moment) and if so, can the court then add to that sum an appropriate interest rate for the loss of that money during that time period?

    2. Can the court do the same thing for the child support setting and if so, can the court add an interest rate to it as well? 

    ------------------------------
    Richard Diamond
    Managing Partner
    Diamond & Diamond P.A.
    Millburn, New Jersey
    973-379-9292
    [email protected]
    ------------------------------


  • 2.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-29-2016 02:52 PM

    Short Answer Richard is YES.  Equitable remedy because of the fraud.  The Court can calculate a lump sum and then new amounts going forward from the first motion to set aside the agreement.

     

    (call me if you want to discuss.)

     

    Alice M. Plastoris, Esq.

    82 Speedwell Avenue

    Morristown, New Jersey 07960

    973-538-7070

    973-538-7088 Fax

    [email protected]

     






  • 3.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-29-2016 03:08 PM
    Agreed with Alice as to retroactivity.  Generally, the anti-retro CS statute only prevents a downward retroactive modification of CS (per legislative history and interpreting case law).  Although I'm not certain, I would assume the child support would be handled as "arrears" and added to a Probation Account with a weekly arrears payment to be determined accordingly.


    Gregory Thomlison, Esq.
    Kerr & Thomlison, L.L.C.
    650 Washington St.
    Suite 1C
    Toms River, NJ 08753
    Ph. (732) 736-8100

    THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.





  • 4.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-29-2016 03:17 PM

    It is essentially nunc pro tunc what should have happened but for the fraud.  Once the numbers are determined, the judge will fashion the remedy. I agree CS will probably be arrears with the Probation Account. ED and Alimony can be fashioned as a lump sum to bring current etc.

     

    Alice M. Plastoris, Esq.

    82 Speedwell Avenue

    Morristown, New Jersey 07960

    973-538-7070

    973-538-7088 Fax

    [email protected]

     






  • 5.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-29-2016 04:56 PM
    Rich,

    I agree with the other answers. This was fraud, plain and simple. There's no anti-retroactivity issue even if the statute did apply to increases. What you're asking for is completely realistic / reasonable. Not to apply any formula or anything, but I'd say she was getting $200,000 less than she should have gotten. Times 16 years. The CSG issue is even simpler. No worksheet attached - none even possible as income was over the max.

    Although I'm sure you'd think of this anyway - the result should be permanent alimony, as the law in 1999 / 2000 should be applied (certainly not the new statute, or even the "real world" changes - Cox v. Cox etc - since then). In 1999 / 2000, a 10 year marriage was more than likely permanent alimony; certainly a 15 year marriage was.

    And, of course, he should cover all her counsel fees and costs -- including, if necessary, an expert on the changes in "real world" alimony including the time, if needed, to review all decisions (published and otherwise) from back then and put a good expert report together.

    I'm really, really surprised this is going to trial and the guy hasn't made a generous settlement offer.


    PS - while it doesn't seem 100% relevant as you're already over the hump and have succeeded in having it declared fraudulent, I just researched the issue of an attorney representing both parties in a closing and then representing one in a divorce. While it isn't preferred, it surprisingly isn't automatic disqualification unless there is evidence that confidential information was provided: See Ethics Opinion 216 -- http://njlaw.rutgers.edu/collections/ethics/acpe/acp216_1.html ("The test is whether the policy expressed in Canons 6 and 37 would be violated. ... On the facts stated in this case and assuming that there were no confidences or confidential information obtained with respect to the financial capacity or resources of the husband, we conclude that it would not be improper for the attorney to represent the wife in the matrimonial litigation.")

    <x-sigsep></x-sigsep>

    - Dave

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






  • 6.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-29-2016 08:33 PM
      The sliminess of these facts makes me wonder if dear husband might be planning on filing for bankruptcy after settlement/verdict.  It's always so interesting how business owners can make X when nobody is suing them and make 0 when somebody is.  Not like they can control their own income stream . . .
      I bring this up because I would want to do some bankruptcy research before I agreed to specific settlement terms or sought a verdict with judgments for various items. I would want to look at the parameters and application of the fraud exception to dischargeability under a Chapter 7 and debt reduction under a Chapter 11.  
      As to the attorney initially involved.  Any way to bring him or her in for a malpractice claim? Any way still within the SOL?  Should be pretty easy to get an expert on these facts.  

    Anne Cralle, Esq.

    Sent from my iPad





  • 7.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 01-30-2016 08:35 AM

    Thank you for the observations and I appreciate the "outside the box" thoughts to consider. 

    ------------------------------
    Richard Diamond
    Managing Partner
    Diamond & Diamond P.A.
    Millburn, New Jersey
    973-379-9292
    [email protected]



  • 8.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 02-01-2016 01:31 PM
    If anyone has the name of a lawyer for me to recommend to the client, I am happy to pass on the information. Initially, when the court set aside the agreement, I recommended that she reach out to a lawyer to discuss her rights ( if any) and discuss whether the statute had passed or whether she still had time to file some type of claim. Armed with a specific recommendation, presume she will at least make the call.
    Thank you again.
    Richard Diamond
    Diamond & Diamond P.A.
    225 Millburn Avenue, Suite 208
    Millburn NJ 07041
    973-379-9292

    The information contained in (and attached to) this e-mail is intended only for the personal and confidential use of the designated recipient(s) named above. This message may be an attorney/client communication and  is privileged and confidential. If you are not the intended recipient, any review, dissemination, distribution or copying of this message is  prohibited. If you received this communication in error, please notify us immediately by reply e-mail to [email protected] or call us at 973-379-9292 and delete the original message (including attachments).  To the extent that there is any tax advice contained in this communication (including any attachments), it was not intended or written to be used, and cannot be used, for the purpose of (a) avoiding penalties that may be imposed under the Internal Revenue Code or by any other applicable tax authority or (b) promoting, marketing or recommending to another party any tax-related matter addressed herein. The information in this email does NOT constitute professional legal advice and transmission of an email request for information, any information provided in this email, and/or receipt of this email does NOT create an attorney-client relationship.





  • 9.  RE: Retroactive Modification of Alimony & Child Support - Post Divorce

    Posted 02-02-2016 10:00 AM

    For bankruptcy non-dischargeability issues, look at 11 USC 523(a)(2) and 523 (a)(5)

     

    ABS0049_LeslieFarber_Logo25

    33 Plymouth Street, Suite 204

    Montclair, NJ 07042-2607

    Ph. 973.509.8500 x 213

    Fax: 973.860.1174

    eMail:  [email protected]

    web:  http://www.LFarberLaw.com

    Note: The contents of this electronic message are intended for general information purposes only and should not be construed as legal advice or opinion in any specific facts or circumstances. Confidentiality Note: This electronic message transmission contains information from Leslie A. Farber, LLC, which may be confidential, privileged, or otherwise protected from disclosure.  The information is intended only for the use of the individual(s) listed above.  If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is strictly prohibited.

    IRS CIRCULAR 230 DISCLOSURE: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in, omitted from, or implied by this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.