In a Decision – K.M.F. v. W.L.F. (an Unpublished Opinion) >> the Court Held:
The Appellate Division determined that that a proposed settlement could not serve as proof of the invalidity of a party’s Domestic Violence claim. (Husband had argued that the Trial Court erred in refusing to admit into evidence a proposed agreement to consent to entry of civil restraints.) The Appellate Division stated that that argument was without sufficient merit to warrant a discussion in a written opinion.
The unsigned civil restraints agreement was not admissible in evidence, because it was a proposed settlement of the Domestic Violence application. Under N.J.R.E. 408, a proposed settlement agreement cannot be admitted as proof of the invalidity of a party's claim. That was the purpose for which Husband offered the document, and the judge properly exercised discretion in excluding it.