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Pretrial Brief Essay

1683 words - 7 pages

COMES NOW, the Defendant, Gary H. Rappold, and files this, his Pretrial Brief,
and further alleges:
1. The subject presented on this brief is the appropriate legal and fair adjudication
of the contested issues for equitable distribution, alimony, and counsel fees in addition
to the affirmation of the Plaintiff’s ability to be gainfully employed and capacity to
contribute to her own support.
2. Plaintiff is requesting an equitable distribution award of $140,000, permanent
alimony in the amount of $350 per week, and payments of her counsel fees (Exhibit A).
Defendant believes these requests are exorbitant, unreasonable, and without merit.
This opinion is consistent with ...view middle of the document...

The Certification of Robert W. Mayer was filed on October 23, 2013.
The Reply to same certification was filed by Defendant on October 28, 2013. On
the return date of November 8, 2013, (a) Order to strike Defendant’s Oral Argument was
denied, (b) Order for Plaintiff to serve the defendant with reply certification of the original
motion of October 3, 2013 was denied, (c) Order for reconsideration as to the issue of
pendent lite support was denied.
7. A Case Management Conference was held on October 22, 2013. Entry of
Order for this matter was assigned to the Standard Track. It was furthered ordered
that (a) both parties shall propound Interrogatories/Notice to Produce by November 4,
2013 and answer Interrogatories and comply with Notice to Produce by December 19,
2013, (b) this matter be scheduled before the County Early Settlement Panel on
January 8, 2014.
8. Plaintiff received interrogatories from Defendant on November 4, 2013.
Defendant received a Notice to Produce Documents on November 5, 2013. Plaintiff
received all petitioned documents from Defendant on December 16, 2013. Plaintiff did
not respond to Defendant’s interrogatory requests. Plaintiff received Final Request for
Answers to Interrogatories from Defendant on December 26, 2013.
9. The Matrimonial Early Settlement Panel-Pre was held on January 8, 2014.
Following the Conference, an Order of Referral to Post-ESP Mediation Program was
entered for February 11, 2014 and a Post-Mediation Conference Call for March 4, 2014.
10. On January 24, 2014, the matter was reassigned to the Court of the HON.
TERRY PAUL BOTTINELLI from the previous Court of the HON. ESTHER SUAREZ. A
Case Management Conference was scheduled for February 26, 2014. Subsequently,
the original Post-ESP Mediation Program for February 11, 2014 and Post-Mediation
Conference Call for March 4, 2014 were canceled, and the former was rescheduled to
February 27, 2014.
11. A Motion to Enforce Litigant’s Rights was filed by Defendant on February 26,
2014 for the reason Plaintiff had not provided answers or objections to Interrogatories
Defendant had requested. Defendant received answers to interrogatories via USPS
mail on March 1, 2014 and withdrew said motion on March 4, 2014.
12. On March 10, 2014, the matter was scheduled for a status Case Management
Conference for April 9, 2014. At the Case Management Conference, the matter was
scheduled for a Trial, on August 4, 2014.
13. The parties were married on July 14, 1999 in Pompton Lakes, Passaic County,
New Jersey (Exhibit B). There was one minor child born to this marriage, to wit: Gary
O. Rappold, born October 15, 1986.
14. Plaintiff had a brain tumor surgically removed on March 1, 1988 and was
prescribed Dilantin (phenytoin sodium) for the prevention and treatment of seizures,
routinely occurring following neurosurgery. The neurosurgeon received two conflicting...

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