In a Decision – Cunningham v. Mitkowski, (an "Unreported Decision") >> the Court Held:
The Appellate Division reversed the Trial Court determination that a party
make periodic payments and that Judgment enter
The Appellate division determined that the trial court erred in effectively preventing plaintiff from challenging the accuracy, validity and reliability of the billing and resolving material factual issues about plaintiff's ability to pay without a plenary hearing. Court also erred in allowing an entry of judgment without the filing for such a motion.