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Paralegal

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COUNTY OF SOMERSET

Early Settlement Panel Statement
THIS POSITION STATEMENT MUST BE SENT TO THE PANELISTS AT LEAST FIVE (5) DAYS PRIOR TO THE ESP DATE. NO SUPPORTING DOCUMENTS ARE TO BE ATTACHED, EXCEPT AS INSTRUCTED. BRING DESIRED SUPPORTING DOCUMENTATION WITH YOU ON THE PANEL DATE

Docket Number: FM-18-123-12W Panel Date: 5/21/12
Plaintiff: Betty Smith
Defendant: Ronald Smith
Attorney: Janet B. Coven, Esq
Attorney for: X Plaintiff/Defendant (circle one)

THE FAILURE OF AN ATTORNEY AND/OR LITIGANT TO APPEAR WITHOUT HAVING SUBMITTED THIS FORM AND UPDATED CASE INFORMATION STATEMENT, WILL BE REPORTED TO THE TRIAL JUDGE, WHO MAY AWARD COUNSEL FEES OR IMPOSE ASSESSMENT(S).

1. Issues in Dispute: (check if applicable)
Cause of Action Visitation (x)
Custody Equitable Distribution (x)
Alimony (x) Marital Tort
Child Support (x) Counsel Fees
Other

2. List Discovery Completed:
Exchanged CIS.

List Discovery in Process:
N/A
List Additional Discovery Needed:
Plaintiff requests information regarding $50,000.00 which was depleted by Defendant. Plaintiff requests information regarding inheritance Defendant received from his father.

3. Date of marriage:
March 1, 1986

4. Date of Separation:
N/A

5. Date of Complaint for Divorce:
March 3, 2012

6. Age of Plaintiff: 52 Age of Defendant: 52 Number of Children: 2 Age of children: 14 & 17 Do the children have any special needs? If so, what are they?
No

7. State your client’s work history and earnings for this calendar year and the preceding calendar years.
The Plaintiff is a clinical psychologist and is in private practice located at 123 Brown Street, Green Brook, new Jersey 08812. Her income varies depending upon the number of patients she counsels on a weekly basis. Her 2011 gross income was $150,000.00.

8. Are there any unresolved custody and/or time-sharing issue? If so, what are they and how are they being resolved?
The parties have agreed on joint legal custody of their children. Plaintiff will be the primary residential parent with Defendant having a liberal parenting schedule. Plaintiff believes Defendant’s parenting time should be supervised due to his substance abuse problems.

9. Are there any other open or closed family dockets involving these parties? If so, state the caption and docket number.
There was a Domestic Violence matter under Docket No. FV-18-1400-11 which was dismissed on March 30, 2011.

10. State what issues relative to alimony, child support and equitable distribution have been resolved and the resolution thereof.
None as of yet.

11. State your client’s position with regard to contested issues and proposed settlement as to the following:
a) Child Support: (please provide, as an attachment to the within statement, an analysis of the Child Support Guidelines, if applicable)

b) Alimony: (please provide your tax analysis as an attachment):

c) Medical/Dental Insurance and Expenses for Children:
The Plaintiff would like the parties to equally divide this expense for their children, which will be $300.00 per month after the divorce.

d) Medical/Dental Insurance and Expenses of Spouse:
Defendant will obtain his own medical expense after the divorce. Plaintiff will pay for her own medical upon divorce.

e) Childcare Expenses:
N/A

f) Private School Tuition:
The children currently attend a private school, St. Joseph’s School, which is located in Piscataway, New Jersey. Plaintiff would like them to continue at this school and the parties to be equally responsible for this tuition which is $500.00 per month. Plaintiff wants the Defendant to equally share in any summer camp expenses for their children which are $400.00 per month from June though August each year.

g) College Tuition:
Plaintiff would like Defendant to contribute toward such expense in the future on financial ability at the time after all grants, scholarship and loans are obtained.

h) Equitable Distribution: i. Marital Residence:
The marital residence is located at 232 Pine Drive, Warren, New Jersey 07059, in Somerset County. The appraisal of such property reflects that the market value as of December 31, 2011 is $205,000.00 The outstanding mortgage on this property is approximately $122,000.00. Therefore, there is equity in this asset of approximately $83,000.00. Plaintiff seeks sixty percent(60%) of any equity accumulated during the marriage in the marital residence as she has been the party paying the mortgage via her income throughout the marriage. ii. Other Real Property:
The Plaintiff wants to receive the Time Share which is owned by both parties. iii. Bank Accounts:
Plaintiff would like her husband to account for the $50,000.00 he took as well as return the $50,000.00 to their joint savings account at PNC Bank. Plaintiff wants 100% of this asset upon divorce. iv. Automobiles:
Parties have a 1990 Jeep which is titled in the Defendant’s name and has an outstanding loan balance of $1,500.00. Plaintiff wants Defendant to take his Jeep and be responsible for the remaining loan balance on this asset. Plaintiff leases a 2010 Honda Accord through the corporation and the monthly payments are approximately $195.00. Plaintiff wants to keep her Honda and will pay said lease. v. Stocks/Bonds:
N/A
vi. Pension/Retirement Plans:
Plaintiff has annuities with an approximate value of $38,700.00. She does not want Defendant to receive this asset. A QDRO will need to be prepared if it is divided. vii. Significant Personal Property:
Plaintiff has a practice which is incorporated and known as Smith Counseling, Inc. Plaintiff wants to retain this asset and values it at approximately $132,000.00 viii. Other Assets:
N/A
ix. Debts:
The parties accumulated marital credit card debt on their Visa and Discover cards. Te Visa has Approximately $4,500.00 in purchases and the Discover card has approximately $2,500.00. Plaintiff seeks payment of credit card debt from Defendant.
i) Life Insurance Coverage for Both Parties:
N/A

j) Tax Exemptions/Dependant Deductions:
N/A
k) Counsel Fees:
Plaintiff is willing to pay her own counsel fees.

12. Attach copies of any relevant Pendente Lite Orders.

Submitted by: Janet B. Coven, Esq. 30 Vreeland Road Building A, Suite 230 Florham Park, NJ 07932

Dated:

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