In a Decision Moynihan v. Lynch, (an "Unreported Decision") >> the Court Held:
The Appellate Division affirmed in part, reversed and vacated in part, and
remand for further proceedings.
As the agreement was a promise by one party to a non-marital personal relationship to provide support or other consideration for the other party, either during the course of such relationship or after its termination, it was necessary that it not only be memorialized in a written document but also made with the independent advice of counsel for both parties, as unambiguously required by the 2010 amendment to the Statute of Frauds, N.J.S.A. 25:1-5(h). Neither party sought attorney review so the agreement was unenforceable consistent with the clear and unambiguous requirement of that statutory provision.