Paralegal Essay

1027 words - 5 pages

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. ...view middle of the document...

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...

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