Alimony Modification

In a  Decision – Frangipane v. Frangipane (an "Unreported Decision") >>   the Court Held:

The Appellate  Division affirmed denial of appellant’s reconsideration which reduced her received alimony payments holding respondent-husband set forth a change in circumstances resulting from his retirement for health reasons and such change would be permanent.

Defendant called him approximately 30 times in the following two weeks. She sent him 45 emails over a five day period that accused him of hacking and monitoring her electronic devices, complaining because he did not respond to her messages and admitting that she trespassed on his property. Plaintiff asserted that he was afraid.
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In a  Decision – Dressner v. Dressner  (an "Unreported Decision") >>   the Court Held:

The statute prohibits the retroactive modification of a child support obligation to a date prior to the mailing of the notice of motion for such modification. Further, retroactivity is left to the sound discretion of the trial judge.

Following termination from his employment and efforts to obtain comparable employment, the Court  terminated his alimony obligation as of the date of the order and modified the amount of child support in accordance with the child support guidelines. Even though the notice was mailed 19 months prior to the order, the family part court did not violate the statutory provisions by failing to order the obligation modified retroactively nor was there any abuse of discretion in such decision

In a  Decision – Moodie v. Moodie  (an "Unreported Decision") >>   the Court Held:

The Appellate  Division determined that the termination of Alimony and Life Insurance was warranted when the Wife, pursuant to the Divorce Agreement, failed to make meaningful efforts to secure employment despite having a year in which to improve her income status despite sufficient education..

The proofs Wife submitted to show her good faith efforts to secure employment were not compliant with the Divorce Agreement or prior Court Order and were internally inconsistent. The Wife’s Master’s Degree, prior licensing and employment history supported the conclusion that appellant-wife had the potential and capacity to earn substantially more than she had been earning.
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In a  Decision – Abate v. Abate (an "Unreported Decision") >>   the Court Held:

The Appellate Division determined that the Father had not established the bases for the reduction in support. 

he court affirmed holding plaintiff-father’s unemployment may only be temporary and noted he was still receiving severance pay. As such, the family court properly found plaintiff-father “failed to demonstrate that his alleged change in circumstances was anything but temporary.” Further, denial was warranted as plaintiff-father failed to meet the requirements of Rule 5:5-4(a) which required a movant to submit both a current and a prior CIS.
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