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IN A NEW YORK DIVORCE CASE, THERE ARE CONSEQUENCES TO INTERCEPTING EMAIL SENT BETWEEN YOUR SPOUSE AND THAT SPOUSE’S ATTORNEY

DIVORCE & FAMILY LAW LAWYER NASSAU COUNTY NY

H. Michael Stern, Esq., a New York matrimonial and family law attorney and mediator with over 33 years of experience suggests that communications between a party and his or her attorney should not be read or reviewed by the other party in a New York divorce case.

In a recent case determined by the Supreme Court, New York County, the trial Court found that the Husband had been intercepting and reviewing email between his wife and her attorney. The Court noted that the Preliminary Conference Order in the case directed the parties to preserve all electronic evidence which included email. The Court took drastic action to level the playing field regarding the interception of the wife’s privileged email communications to her lawyer. The terms of the order of the Court are thoroughly detailed and go far beyond the parameters of this blog. Among other things, the Court Ordered that: (1) the husband had to provide all intercepted email to the wife within five days; (2) after setting forth a detailed list of cloud based, app based and physical data storage locations, the husband had to provide copies all storage, regardless of the type of storage, from the date of the commencement of the action to the wife; (3) the husband had to deliver his laptop and all passwords (to access the wife’s email) to the wife’s forensic computer specialist within five days (and was prohibited from using the laptop in the meanwhile); (4) the husband had to preserve all of the wife’s email and documents concerning her email, without alteration, pending further Court order; and (5) to appear for a deposition concerning the wife’s email. The directives made by the Court affecting the husband’s former attorney, who had apparently revealed some of the wife’s privileged email to the Court during his representation of the husband, were even more astonishing. The husband’s former lawyer was similarly directed to provide copies of the wife’s emails within five days. The attorney was also directed to preserve all emails, privileged or not, and to suspend his offices’ document destruction practices until further Court order.

It is abundantly clear that the Court found the interception of the wife’s email to be disconcerting and repugnant. This case illustrates that the purposeful and intentional violation of privileged and confidential communications by a party to a New York divorce can have serious and costly consequences. In my professional opinion, such conduct should be avoided.

I have been trying divorce cases and Family Court hearings since 1987. My goal first and foremost is to win at trial when a settlement cannot be reached in the case. Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice for more than three decades. Feel free to contact me, H. Michael Stern, Esq. a Long Island Divorce and Family Law Attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Long Island office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road, Suite 555, in Garden City, New York.

Before you leave my website, I urge you take a few minutes to read the Testimonials of my former clients.

Written by, H. Michael Stern, Divorce Lawyer Nassau County NY

THWARTING TACTICS DESIGNED TO FORCE CAPITULATION IN DIVORCE CASES

DIVORCE LAWYER NASSAU COUNTY NY

Michael Stern, Esq., a New York divorce and family law Attorney with over 33 years of experience suggests that use of applications for civil contempt and counsel fees can be thwart refractory litigation tactics in divorce cases.

In a recent case determined by the Appellate Division of the Supreme Court, Second Judicial Department, the Court was presented with a situation where a party was held in contempt of Court and sentenced to 30 days in jail (subject to further extensions of time)  for failing to pay counsel fees of nearly $200,000.00 .

The party who was owed the counsel fee (the creditor) had fallen into more than $100,000 in debt and had been facing an onslaught of pervasive, non-stop litigation from the other party (the debtor). The litigation expenses of the debtor exceeded $1,000,000.00 and were apparently were paid by a family member. The Court found that the debtor had unlimited financial resources available from that family member. Under those circumstances, the Court affirmed the decision of the trial Court as well as the prison sentence.

Many litigants seek to overwhelm the other party with a never-ending bombardment of non-stop litigation. The purpose of this tactic is to drive the other party into insolvency, forcing them to capitulate to the demands of the litigious party. In the abstract, one way to combat the dilemma of pervasive and refractory litigation, is by way of applications for counsel fees and/or contempt of court. The decision which is covered in this blog punctuates that defensive strategy. The Appellate Court did not care if the debtor was penniless, where there was a deep pocket behind the litigation.

I have been making these applications and utilizing this strategy in my practice for many years.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice over the past 33 years. Feel free to contact me, H. Michael Stern, Esq. a  Long Island Divorce and Family Law Attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Nassau County, Long Island office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road in Garden City, New York.

Written by, H. MICHAEL STERN, Divorce Lawyer in Nassau County, Long Island NY.

THE TERMS OF A CHILD CUSTODY AGREEMENT WILL BE ENFORCED IF THEY ARE IN THE CHILD’S BEST INTERESTS

CHILD CUSTODY & FAMILY LAWYER NASSAU COUNTY

Michael Stern, Esq., a New York Divorce and Family Law Attorney with over 33 years of experience suggests that some thought must be given to the proposed terms of a Child Custody Stipulation, because the Courts will only enforce those provisions that are in the best interests of the child.

In a recent case determined by the Appellate Division of the Supreme Court, Second Judicial Department, the Court was presented with a situation where a stipulation of settlement contained a mandate that the father refer to the child by his English legal name. Both parties were represented by counsel when the settlement was reached. The trial Court held a hearing on the issue and determined that the father was required to refer to the child by his English legal name. Apparently, the father conceded that he refers to the child by another name. On appeal, the Court found that this type of provision should be enforced as it was in the child’s best interests. The father was directed to refer to their child by his English legal name when addressing him, introducing the child to others, or when the father was in conversation with others with the child present.

During my long career, I have assiduously avoided drafting settlement agreements that are unenforceable. Accordingly, I give a great deal of thought to the terms of each agreement that I draft. It is better to overstate the terms of a Family Court or Divorce Settlement than to leave it up to the parties to sort it out later in contested post-judgment litigation. I strive to carefully draft agreements relating to issues of child custody, child support, the disposition of assets and apportionment of liabilities.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice over the past 31 years. Feel free to contact me, H. Michael Stern, Esq. a  Long Island Divorce and Family Lawyer, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Long Island office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road in Garden City, New York.

Written by, H. MICHAEL STERN, Divorce & Family Lawyer, Nassau County NY

PRESSURED TO SETTLE YOUR CASE?

FAMILY LAWYER NASSAU COUNTY, NY

Michael Stern, Esq., a New York Family Lawyer with over 33 years of experience suggests that as an aspect of Family Court practice that an open Court record should be made if a litigant in a New York Family Court case believes that a settlement was made under duress before it is finalized.

In such cases, the Family Court will usually reject the settlement where consent is not unequivocal. However, in the rare instances where it does not do so, the record may prove invaluable when filing Objections or on appeal thereafter.

In a recent case determined by the Appellate Division of the Supreme Court, Second Judicial Department, the Court held that it was not error for the Family Court to deny a party an adjournment in a proceeding to enforce a support Order. Apparently, in the case, the parties entered into a settlement of the enforcement proceeding and a downward modification proceeding. The Family Court entered separate Orders resolving each of the pending actions. The Father contended on appeal that he was under duress in entering into the settlement agreements. The Father appealed the denial of his Objections and the appeal was unsuccessful. The Appellate Division noted that the Father’s remedy was to move in the Family Court to vacate the orders as opposed to appealing from them. When moving to vacate an Order upon a stipulation, a critical issue is whether a defense to the making of a valid contract is asserted. In this case, the defense was duress. I suggest that it is important for a litigant to elaborate on any potential contract defense in open Court while the Stipulation is being placed on the record to ensure that the point is preserved for Objections or appeal. This is especially important if the stipulation is not truly on consent for any number of reasons.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice. Feel free to contact me, H. Michael Stern, Esq. a  Long Island Divorce and Family Lawyer, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Nassau County office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road in Garden City, New York.

Written by, H. Michael Stern, Divorce & Family Lawyer, Long Island NY.

CHILD SUPPORT ENFORCEMENT

THE COURT CAN DENY AN ADJOURNMENT IN A CHILD SUPPORT VIOLATION PROCEEDING WHERE THE ACCUSED HAS NOT PAID CHILD SUPPORT!

Divorce & Child Support Lawyer Nassau County NY

H. Michael Stern, Esq., a New York matrimonial and family law attorney and mediator with over 33 years of experience suggests that every effort should be undertaken to obtain enough time from the Court to present a defense to a support violation petition.

In a recent case decided by the Appellate Division First Judicial Department, the Court was presented with a situation where the Family Court had directed that the accused non-paying parent be incarcerated for 90 days unless $5,000 was paid to the Support Collection Unit. The Family Court had appointed counsel the day before the hearing. However, the Court-appointed attorney did not argue to the Family Court Judge that counsel needed more time to prepare for the hearing. The accused non-paying parent did not request an adjournment or seek additional preparation time with newly appointed counsel either. The Appellate Court noted that newly appointed counsel did not raise an effective representation issue. Counsel did not deny the charge of non-payment, and counsel confirmed that the accused non-paying parent could have moved for a downward modification but had not done so. Counsel apparently conceded that the accused non-paying parent earned an income, albeit that it was unpredictable and fluctuated. The Appellate Court determined that given the accused non-paying parent’s lack of any excuse for nonpayment, any such adjournment request could have been reasonably denied by the Family Court and upheld the sentence of 90 days in jail.

The point here is that where counsel is appointed or privately retained, appearing on very short notice and the accused non-paying parent is facing incarceration, the attorney must try to make a lack of effective representation argument if there is insufficient time to prepare a e defense. This should be done before any of the non-payment issues are explored by the Family Court Judge at the dispositional hearing. It is my unrelated opinion that it may be the constitutional responsibility of the Family Court Support Magistrate (who hears the case first) to offer Court appointed counsel prior to any willfulness hearing, where the accused is given the opportunity to oppose any finding of a violation of a support Order, as such a finding can quickly result in a term of incarceration before a Family Court Judge. After all, the client’s liberty is at stake if the Support Magistrate finds that a willful violation occurred. I cannot emphasize enough how critical it is to make the necessary arguments to defend the client in such cases, including a request to serve any term of incarceration on weekends only. This enables the accused parent to avoid falling further behind in support payments while continuing to work.

I have been prosecuting and defending Family Court child support cases for more than three decades. My personal preference is to use highly experienced private Counsel in these situations.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice for over 30 years. Feel free to contact me, H. Michael Stern, Esq. a Long Island divorce and family law attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290. My office is conveniently located adjacent to the Roosevelt Field Mall Ring Road at 666 Old Country Road in Garden City, New York.

Written by, H. MICHAEL STERN, ESQ. – Family Law Attorney, Long Island, NY.

SELLING YOUR HOME AFTER DIVORCE

ANOTHER EXAMPLE OF HOW IMPORTANT IT IS TO SPELL OUT ALL OF THE CONTINGENCIES CONCERNING THE SALE OF A HOME IN A NEW YORK DIVORCE AGREEMENT

DIVORCE LAWYER NASSAU COUNTY, NY

H.Michael Stern, Esq., a New York matrimonial and family law attorney with over 33 years of experience suggests thatall possible contingencies should be addressed in drafting a New York Stipulation of Settlement or Separation Agreement concerning the sale of a residence.

In a recent case determined by the Appellate Division, First Department in New York, the Appellate Court reversed the trial judge’s ruling that set forth terms of sale of the parties’ residence that were omitted from the parties’ stipulation which settled their divorce case. The parties divorce settlement agreement set forth an asking price for the marital residence and a commitment that it would be sold but left out further details. The lower Court judge ruled that if the marital residence was not sold by a certain date, then the parties were to consult their broker to reset the asking price of the residence at an amount set by the broker, The lower Court ruling also permitted the parties to apply for a receiver to sell the property if not sold three months later. A receiver is a person appointed by the Court to sell the property (taking a commission in the process). The Appellate Court rejected the lower Court’s decision, stating that since the parties’ stipulation was not challenged by either party and that the parties did not consent to change the terms, the lower Court judge lacked the authority to add those additional terms (where the parties had already provided for pricing and sale terms in their stipulation).

The practical effect of this decision enables the recalcitrant home occupant to do nothing to facilitate the sale of the residence, depriving the other party from access to his or her home equity. The party in possession may be able to live in the residence during his or her lifetime under the circumstances. Hypothetically, if the party in occupancy was granted exclusive occupancy of the residence pending sale in the stipulation, the remedy of partitioning the property may also be unavailable, depending on the facts of the case.

Thus, in my opinion it is critical to hire a seasoned and experienced matrimonial lawyer, with a record of success, to make sure that all the contingencies are covered in drafting the contractual provisions concerning the sale of the marital residence. I have created clauses which protect the party out-of-possession to ensure that he or she never faces the harsh, bitter reality of the out-of-possession party in the case discussed in this blog.

I also successfully litigated and settled a matter for the out-of-possession party with a similar fact pattern within the past year.  

Since 1987, I have been trying divorce cases and Family Court hearings. I handle all types of post-divorce applications and hearings as well. My goal, first and foremost, is to win at trial when a settlement cannot be reached in the case.  Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice over the past 33 years.

Feel free to contact me, H. Michael Stern, Esq. a  Long Island divorce and family law attorney, if you are interested in a Free Consultation to discuss your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Long Island office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road in Garden City, New York.

Written by, H. Michael Stern, Divorce & Family Law Attorney

SPENDING MARITAL FUNDS DURING YOUR DIVORCE

IF YOUR SPOUSE IS SPENDING YOUR SAVINGS DURING YOUR DIVORCE CASE, THIS WILL BE OF INTEREST TO YOU

Nassau County Divorce Lawyer

H. Michael Stern, Esq., a New York matrimonial and family law attorney and mediator with over 33 years of experience suggests that it is important to be vigilant about how marital funds are expended following the commencement of a divorce action.

In a recent case determined by the Appellate Division of the Supreme Court, Second Judicial Department, the Court held that the parties were accountable for the use of marital funds in paying their post-commencement separate obligations.

Allow me to explain what this means in a plain language example. The parties have a joint savings account that has a balance of $100,000.00 at the time the divorce action was filed. The money represented their combined earnings during the marriage and is considered “marital”. Once a divorce case is filed, future ordinary weekly earnings are no longer considered marital. That is because no additional marital property is created after the divorce case is filed. All money and property acquired after the filing of a divorce case is considered “separate.” So, in this example, one spouse removes money from the joint savings account to pay for a personal gym membership including monthly dues. That same spouse also uses the joint savings account to pay the household electric bill. The Appellate Court’s ruling permits the trial Court to recover the money used to pay for the cost of the gym membership which is considered a “separate” obligation (not related to family purpose). However, the Court would not recoup the money used to pay the electric bill for the family home, which would not be considered a separate obligation, even if the utility account was in the name of that spouse alone.

Accordingly, if marital savings or investment accounts containing pre-filing funds are being depleted after the commencement of a divorce action, it is important to carefully review the purpose of each expenditure made by the party using those funds during pre-trial discovery. During pre-trial discovery, documents can be obtained and reviewed, and questions posed to determine how the post-filing expenditures should be classified (as either marital or separate for recoupment purposes).

The above example only addresses ordinary and customary living expenses that may be permissible withdrawals under the ‘automatic orders,” a topic which exceeds the scope of this blog.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice over the past 31 years.Feel free to contact me, H. Michael Stern, Esq. a Long Island divorce and family law attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Nassau County office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road in Garden City, New York.

Written by, H. Michael Stern, Divorce & Family Lawyer

CHILD SUPPORT VIOLATIONS

THREE MONTH INCARCERATION DIRECTED FOR CHILD SUPPORT VIOLATION WHERE ONLY $3,500.00 NEEDED TO AVOID JAIL TIME! 

CHILD SUPPORT & FAMILY LAWYER, Nassau County NY
Michael Stern, Esq., a New York matrimonial and family law attorney and mediator with over 33 years of experience suggests that a competent defense is necessary in any child support violation case even if the mount of child support arrears are nominal.  

In a recent case decided by the Appellate Division First Judicial Department, the Court was presented with a situation where the Family Court had directed the incarceration (on a weekend only basis) for three months unless the violator paid the sum of $3,500.00 to purge the violation.  While the Court could have sentenced the violator to six months in jail, a three-month sentence is a lengthy term of incarceration, nonetheless.  This is an eye-opening decision, due to the length of the jail time imposed, considering the relatively small sum of $3,500.00 needed to avoid the sentence altogether. Usually the amount of child support arrears is much higher (for the imposition of a three-month sentence) as is the amount needed to be paid to avoid the jail time.  The Appellate Court allowed the Family Court decision to stand. What is encouraging is the recent approval by the Appellate Court for the sentence to be carried out on weekends only, which allows the violator to continue to work and pay support. I have been taking this approach for years and it is good to see an Appellate Court’s recent approval of it. A sentence of continuous incarceration can lead to unemployment and in most cases the accrual of additional arrears while the violator was jailed.  The legal threshold to show a willful violation of the payment of support is low. A high burden of proof falls upon the shoulders of the violator to avoid the prospect of jail time.

A highly experienced attorney is needed to defend a violation of child support or maintenance.

I have been prosecuting and defending Family Court child support cases for more than three decades. Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice for over 30 years.

Feel free to contact me, H. Michael Stern, Esq. a Long Island divorce and family law attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Long Island office is conveniently located adjacent to the Roosevelt Field Mall Ring Road at 666 Old Country Road in Garden City, New York.

Written by:  H. Michael Stern, Divorce & Family Law Lawyer

SELECTING THE RIGHT LAWYER FOR YOUR DIVORCE OR FAMILY LAW CASE

DIVORCE LAWYER NASSAU COUNTY NY

H. Michael Stern, Esq., a New York matrimonial and family law attorney and mediator with over 33 years of experience raises the question:

Is an Associate Attorney the right choice to handle your matrimonial case?

Before I get to the question, I want to emphasize that this Blog represents my personal opinion and is not based upon any empirical data or studies.

At the outset, let me address some definitions.
A solo practitioner is a lawyer who works alone in a law practice and does not have any subordinate lawyers within the firm.
A lawyer who is “of counsel” may not be a member of the law firm but may provide services to the clients of another law firm. Accordingly, a solo practitioner can have another lawyer on the firm letterhead who of is “of counsel”, but that lawyer is not an employed subordinate attorney in the firm. The “of counsel” lawyer may have her own independent practice and an affiliation with another firm to provide legal services. A partner or junior partner are attorneys who have an equity (ownership) interest in a law firm.
An associate attorney is an employee of a law firm, working under the supervision (hopefully) of a partner or junior partner.

The purpose of this blog is not to disparage associate attorneys in any way, but there are many questions that the client should ask when a divorce or family law case is delegated to an associate of the firm. Associate attorneys may be upcoming talents in their own right, but there are concerns that should always be addressed before a hiring decision is made by the client.

I shall list some of the questions that a client should consider below:

1. How will decisions be made in the client’s case?
2. Will the associate be making decisions in the client’s case with or without consultation with the supervising partner?
3. Will the client be billed at the hourly rate of the associate, or of the partner, or both, for intra-office communications concerning the client’s case?
4. What is the procedure for decision making (and billing practices) if input of the partner is required for all decisions in the case?
5. How will the charges for intra-office communications or partner input be reflected on the client’s bill?
6. Are there meetings in the firm that the client is billed for where the client’s case is discussed in a group setting attended by the partner and other attorneys?
7. Is the client billed (and how is the client billed) for the time spent in brainstorming the client’s case in the group meeting attended by the partner and other attorneys?
8. Does the associate have experience in handling cases similar to the client’s case?
9. How much experience (and in what specific contexts) does the associate have in handling cases similar to the client’s case?
10. Will the associate be going to Court on the client’s case without the partner?
11. Who does the client contact at the firm concerning the client’s case, the partner or the associate, or both?
12. How accessible will the partner be after the client’s case is delegated to an associate?
13. Will the partner be accessible directly or through a secretary or assistant to buffer the client’s communications?
14. Will access to the partner be limited or restricted in any way?

Without a doubt, there are many more questions that can be listed. However, I think I addressed a sufficient number for the purposes of this blog.

The client’s decision to hire a multi-lawyer matrimonial firm is typically based upon reputation, success, exclusivity or fame of one or more of the partners. Typically, a client seeks out the multi-lawyer matrimonial firm to have a well-known, prestigious attorney handle the client’s divorce case. What may occur is that following the payment of the retainer, the case is delegated to an associate to handle. Oftentimes, the partner will be the trial attorney and the associate do most everything else, sometimes with the partners direct supervision, sometimes without any supervision. I want to point out that many associates have significant experience and have the ability to handle a case from beginning to end with extraordinary skill, without any need for supervision. In my 33 years of experience, I can count those associates on two hands, they are few and far between.

I have been in solo practice in the area of matrimonial and family law for over 30 years and I handle the client’s case from start to finish. I make all decisions on each client’s case. There are no concerns about associate attorney competency in my office because I do not have any. While there is much to be said for the additional income an associate can generate for a busy law firm, I have chosen quality of representation above all else. Indeed, this blog just scratches the surface of the issue and I may add more on the topic in the future.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice over the past 30 years. Feel free to contact me, H. Michael Stern, Esq., a Long Island divorce and family law attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My Long Island office is conveniently located adjacent to the Roosevelt Field Mall Ring Road at 666 Old Country Road in Garden City, New York.

AVOID AMBIGUOUS TERMS IN DIVORCE AGREEMENTS

DIVORCE LAWYER NASSAU COUNTY NY

H. Michael Stern, Esq., a New York matrimonial and family law attorney and mediator with over 32 years of experience suggests that it is important to exhaustively spell out each and every term of a Divorce Stipulation of Settlement to avoid future litigation.

In a recent case determined by the Appellate Division of the Supreme Court, Second Judicial Department, the Court was presented with a divorce settlement which contained ambiguous terms regarding the sale of the party’s former residence. The Appellate Division rejected the suggestion that the delay in seeking the sale of the residence did not constitute a waiver of the defendant’s right to compel a sale. The party’s judgment of divorce provided that the party’s residence “should” be immediately listed for sale and that Defendant was entitled to 25% of the equity in the residence. It also provided that the parties shall “cooperate” in selling the residence. The Court determined that the only reasonable interpretation of those terms was that the residence was supposed to be sold immediately.

I try to avoid drafting Agreements that contain loose or ambiguous terms. It is better to overstate the terms of a Divorce Settlement than to leave it up to the parties to work out later. In many cases that does not happen, and litigation ensues. I strive to carefully draft Agreements relating to the disposition of assets and apportionment of liabilities.

Focusing on the needs of the client and the results sought have always been a hallmark of my Long Island practice over the past 30 years.

Feel free to contact me, H. Michael Stern, Esq. a  Long Island Divorce and Family Law Attorney, if you are interested in discussing your matrimonial, divorce or family law matter at hmsternesq@gmail.com or by phone at 516-747-2290.

My office is conveniently located adjacent to the Roosevelt Field Mall ring road at 666 Old Country Road in Garden City, New York.

Written by, H. MICHAEL STERN, Divorce Lawyer, Nassau County NY