Articles in the ‘Cohabitation and Partition’ Category

Cohabitation and Alimony Termination

This case arises out of an ex-husband’s claim that his agreed-upon obligation to provide alimony and life insurance benefits to his ex-wife should cease because she is allegedly cohabiting with another woman. The ex-wife denied such cohabitation, asserting that the other woman maintained a separate apartment at the same residential address and that the two of them were not financially dependent upon each other. After considering three days of testimony at a plenary hearing and making detailed credibility findings, the Appellate Division affirmed the trial court’s determination that cohabitation had not been proven.   Partenio v. Partenio, New Jersey App. Div., June 7, 2012

Cohabitation Alone Insufficient to Terminate Alimony

The Appellate Division determined the trial court correctly rejected the  former husband’s request to reduce or terminate alimony on the basis of the former wife’s relationship with another man.  The record below demonstrated the parties  maintain separate residences, they do not share financial accounts or assets and the moneys loaned were documented by appropriate legal instruments.        Bell v. Bell, New Jersey App. Div., June 1, 2012

Post Judgment CoHabitation Leads to Alimony Reduction

Post judgment cohabitation leads to downward modification of ex-husband’s alimony obligation to his former wife.   Clayton v. Clayton, January 19, 2012

Cohabitation and Alimony Reduction

The Appellate Division affirmed the trial court’s determination that alimony should have been reduced due to cohabitation and the economic benefit derived by the supported spouse, hwoever  it was error for the judge to do so arbitrarily without current Case Information Statements from each party and make specific findings as required by Konzelman and Ozolins.     Azzari v. Azzari, New Jersey App. Div., April 28, 2011

Financial Interdependence and Cohabitation Sufficient to Terminate Alimony

This case reinforces the two-prong Gayet analysis when seeking to terminate alimony.  Here the ex-wife stipulated to cohabitating with an unrelated male partner.   The ex-husband presented compelling proofs demonstrating  “economic interdependence” effectively terminating his alimony obligation even without a plenary hearing.     Proctor, n/k/a Pizzutti v. Proctor, New Jersey App. Div., March 31, 2011

Evidence of Cohabitation Warrants Hearing

Former husband made a sufficient showing that his former wife was co-habitating with another man and the parties financial circumstances dramatically changed warranting a post judgment plenary hearing modifying his alimony obligation.   Wonderlin v. Wonderlin, Jr., New Jersey App. Div., February 3, 2011

Alimony and Cohabitation

This case illustrates the importance utilizing the services of a private investigator as a tool demonstrating a prima facie showing of cohabitation triggering the need for a plenary hearing to determine whether alimony should be reduced or terminated.   Gallagher v. Gallagher, New Jersey App. Div., November 10, 2010

Cohabitation and Partition

In this partition action the Appellate Division affirmed the trial court’s determination to directing defendant to transfer all right, title and interest in one residence to plaintiff and granted plaintiff an equitable interest in a second residence titled solely to him.  The parties lived together for many years and never married.  The trial court applied equitable distribution

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