February 20, 2014

Challenge to Modification of Custody Order is "Moot" Once Child Turned Eighteen

children-crossing-1319861-m.jpgWhen people think about child custody disputes, most often the concepts of legal and physical custody come to mind. While these issues are a large part of many family law disputes, parties and their attorneys must also address various jurisdictional related matters. This means that the court must have proper jurisdiction to hear a case before it may render any orders affecting the parties. In California, the Uniform Child Custody Jurisdiction and Enforcement Act (the "UCCJEA") governs questions regarding a court's jurisdiction of a child custody matter. Many of these issues are complicated and require strict attention to detail. Failure to adhere to legal requirements could result in unexpected and unwelcome consequences. To avoid this, parties facing a child custody dispute are encouraged to contact a local San Diego family law attorney with experience handling such matters.

In a recent custody case, the mother sought to modify the custody arrangement concerning her 17-year-old daughter. Since 2006, the teenager had been living with her father, who had opposed the change of custody. Although the parties did not come to an agreement while attempting to mediate a custody plan, the mediator met with the parties and received voice messages from the child's therapist detailing her on-going treatment. After conducting the evaluation, the mediator recommended that the daughter change her residence (at the end of the school year) from the father's home in Oakland to the mother's in Santa Cruz.

Three days prior to the hearing on the matter, the court notified the parties of the mediator's recommendation. The father raised a few objections, namely that they only learned of the recommendation three days before the hearing, and that the mediator never actually spoke to the child's therapist, but relied on the information in the voice messages. The court postponed the hearing a few weeks but still adopted the mediator's unchanged recommendation and modified the custody order. The father appealed the decision. The court then asked the father to prepare a brief addressing the issue of whether the appeal is "moot."

The court of appeals pointed out that an appeal is moot when an event occurs which makes it impossible for the court to grant relief to the appellant. Under the UCCJEA, the courts in California have jurisdiction over child custody matters. The statute defines "child" as a person who has not yet reached 18 years of age. This means that when a child turns 18, the court relinquishes jurisdiction. The court concluded that when the parties' daughter -- who is the subject of the lower court's custody order - reached her 18th birthday, the issue on appeal became moot.

Continue reading "Challenge to Modification of Custody Order is "Moot" Once Child Turned Eighteen" »

February 13, 2014

California Court of Appeals Sets Forth General Law Regarding Division of Marital Property

mortgage-and-money-6-966070-m.jpgCalifornia is a community property state. This means that marital property -- items acquired during the marriage -- will typically be divided equally upon divorce. A significant part of most divorce proceedings is identifying (and then valuing) marital property. But there are many complicated factors to take into account, such as whether one spouse or another separately holds the title to any of the property accrued during the marriage. To protect and maximize your rights in a divorce proceeding, it is essential that you contact an experienced family law attorney who is well versed in the local laws and the San Diego court rules and procedures.

In a recent California court case, the wife appealed from a judgment in her marital dissolution action. She argued that the trial court erred by identifying certain property as belonging solely and separately to her husband, including real estate as well as rights and benefits in a pension plan. The couple's first marriage together lasted from 1974 to 1986 when they divorced. They chose to remarry in 1990 but later separated in 2007, and are now going through their second divorce. At various points throughout these proceedings, the parties were represented by counsel, but as of the date of trial, both spouses were representing themselves.

Before, and during their marriage, the parties acquired various real properties in California, Nevada and Mississippi. At some point after the separation, the court approved the parties' stipulation that they each would retain temporary possession of certain personal property that they would not sell or otherwise dispose of until the court issued an order. The trial lasted two days and each spouse presented various items of evidence. The court ultimately handed down several findings, identifying certain real properties as belonging separately and solely to each of the spouses, respectively. The court also awarded each party the furniture and furnishings currently in his or her possession.

Continue reading "California Court of Appeals Sets Forth General Law Regarding Division of Marital Property" »

February 6, 2014

California Family Code Governs Jurisdiction for Child Custody Proceedings

california-flag-497343-m.jpgLegal proceedings that involve the welfare of children can be some of the most trying and stressful matters for all affected parties. Child custody disputes, in particular, require special attention to the best interests of the children. There are numerous legal issues that will need to be addressed every step of the way, many of which would never occur to parents, such as determinations related to "jurisdiction" of the matter. Because the outcome of a child custody case can significantly impact a family's future in terms of parenting arrangements, it is critical that an experienced family law attorney handle the matter with care and competence. If you are facing a child custody dispute of any kind, you are encouraged to contact a local San Diego attorney as early as possible in the proceedings.

A recent case exemplifies the need to pay attention to every detail of a child custody matter. Here, a California court of appeals concluded that the juvenile court lacked subject matter jurisdiction over a custody dispute, where there was evidence that the child lived in San Diego for less than six months, and prior to that, lived in Mexico. According to the facts of the case, the child was born in San Diego in 2005, but lived in Mexico with his parents and attended school there. In January 2013, the mother brought the child to San Diego.

Two months later, the San Diego County Health and Human Services Agency (the "Agency") received a report indicating that the paternal grandfather had abused the child in Mexico. In response, the mother presented the Agency with letters from the Mexican government to show that there was a services assessment for the child. Further, a Mexican official confirmed that there was an active case against the grandfather. In April 2013, the Agency filed a dependency action for the child, arguing that both parents were currently in jail and unable to arrange for the child's care. He was placed in a foster home.

Continue reading "California Family Code Governs Jurisdiction for Child Custody Proceedings" »

January 30, 2014

Appeal of Child Custody and Support Order Must Include Complete Record of the Hearing

justice-srb-2-1040137-m (1).jpgMany litigants choose to represent themselves in court proceedings, and not hire an attorney. While most lawyers would advise against this, some people continue to conduct their cases "pro se" - without the assistance of counsel. It has been suggested in a recent article, however, that parties involved in family law cases, where the fate of a child is involved, would best be served by hiring an attorney. To take this point one step further, parents contesting child custody and support cases are encouraged not only to hire a family law attorney to protect their rights, but also to consult with an experienced practitioner with full knowledge of the local San Diego court procedures and requirements.

In a recent case, the California court of appeals denied the father's appeal of the lower court's order, pointing out that appellant failed to provide a compete record of the three-day hearing, and did not identify any legal error on the appellate record. The father was not represented by counsel and appeared in "propria persona" or for oneself (aka: pro se). Here, the couple married in 1991, had two daughters in 1998 and 2000. In 2004, the wife filed for divorce and the marriage was dissolved in December 2006. The court awarded the parents joint legal custody, and the mom received primary physical custody with an allocated time-sharing arrangement. The father was ordered to pay $2,000 per month in child support. There were other provisions in the support order identifying the sharing of certain additional expenses.

In 2009, the couple agreed to temporarily grant the mother sole legal custody, allowing the father to have limited supervised visits due to his pornography addiction (for which he agreed to seek treatment). In 2010, the couple entered into another stipulation acknowledging the father's progress in treatment and restoring the joint legal custody but affording the mother the authority to make all of the decisions concerning the children's health, education, activities and overall well being. The stated goal under the second stipulation was to eventually fully reinstate the original December 2006 order and judgment.

Continue reading "Appeal of Child Custody and Support Order Must Include Complete Record of the Hearing" »

January 23, 2014

Appellate Review of Child Custody Order Must Be Filed in a Timely Manner

calendar-840874-m.jpgCalifornia law governs many aspects of family court proceedings. Divorcing spouses are expected to follow the various rules of procedure applicable to their case, including matters relating to child custody and visitation. Failing to adhere to important time constraints can significantly impact the outcome of your case, and consequently, your family's future. In a recent California case, the father failed to timely appeal two separate child custody orders and was ultimately precluded from contesting certain dissatisfactory court rulings. For this reason and for many other critical needs, parties who are dealing with child custody and visitation matters are strongly encouraged to seek the advice of a local San Diego family law attorney.

In the case mentioned above, in February 2008, the court ordered the mother sole legal and physical custody of the couple's two daughters, ages one and three. The order also permitted the mother to move with the children from California to Michigan, where her parents lived. According to a court evaluator's report, the mother was more likely to promote a positive relationship between the non-custodial parent and the children, than the father would be if he were awarded primary custody. The father was entitled to monthly visitation and the mother would be required to bring the children to California each summer. The February 2008 order was a final judgment in the custody dispute. The father failed to appeal the order.

In November 2008, the father attempted to modify the custody and visitation order, but to no avail. The court entered an order on February 7, 2011, denying the modification request, finding that there had been no significant change in circumstances requiring such a change. The court noted that there was no evidence supporting the father's claims that the children were subjected to (or at risk of) sexual abuse by the grandfather. The court also refused to find "parental alienation" concerning father's allegations that the mother: 1) failed to accommodate his travel delays and 2) failed to encourage the girls to speak with him on the telephone.

Continue reading "Appellate Review of Child Custody Order Must Be Filed in a Timely Manner" »

January 16, 2014

A Voluntary Declaration of Paternity Does Not Guarantee Presumed Father Status

paper-family-ii-832858-m.jpgIn some family court cases, there may be a question related to the identity of a child's father. Under California law, a determination of paternity or "parentage" is a significant factor in a child's life. Identifying a child's legal parents has the potential to seriously impact many financial and emotional issues. In fact, before a court will render orders concerning child support, custody and/or visitation, the parties involved must establish paternity. With such important items to be resolved, it is critical that parties reach out to an experienced family law attorney to help sort through their rights. Parents with questions concerning child custody, support or visitation are encouraged to contact a attorney with in-depth and comprehensive knowledge of the local laws and procedures in the San Diego court system.

In a recent California court of appeals case, In re Jovanni B., two men claimed to be the child's father. The first is John B., who was living with the mother when the child was born, and who also signed a voluntary declaration of paternity. The other is Brian H., who submitted to court ordered DNA testing that ultimately revealed that he was in fact the child's biological father. Upon receiving the DNA test results, the juvenile court not only dismissed John from the proceedings, but offered "reunification" services to Brian.

At the beginning of this case, the Los Angeles County Department of Children and Family Services (the "DCFS") asserted jurisdiction over Jovanni under the state Welfare and Institutions Code, based on evidence that the mother and John engaged in violent behavior in Jovanni's presence. During the DCFS proceedings, the mother identified John as the child's father and he signed the voluntary family maintenance plan as such. During sessions with a state social worker, the mother indicated that Brian, and not John, was Jovanni's biological father.

Continue reading "A Voluntary Declaration of Paternity Does Not Guarantee Presumed Father Status" »

January 9, 2014

California Court of Appeals Affirms Decision Ordering Wife to Reimburse Husband's Spousal Support Payments

mortgage-and-money-2-963935-m.jpgDuring separation or divorce, spousal support is the payment that a court orders one spouse to pay to the other, on a monthly basis, for general support. Determining the amount of spousal support is a complicated process, and one that is not governed by any specific legal guidelines. The amount awarded fluctuates from case to case. Parties are encouraged to consult with an experienced San Diego family law attorney, someone who has detailed knowledge of the local laws and practices. Doing so will help to ensure that your right to receive a suitable amount of support is met (or to protect you from paying an unreasonable amount of spousal support).

Many surprising disputes have arisen over the right to receive spousal support in family law cases throughout California. In a recent court of appeals case, a husband sought to terminate his spousal support payments to his wife based on evidence that she remarried. The wife opposed the motion, arguing that she never actually remarried, but rather, merely procured a marriage license in Arizona without "consummating" the marriage. The parties later obtained an annulment, which she claimed was not the same as a divorce.

Here, the parties were married in 1985 and had two children who are both adults. The wife filed for divorce in 2000 and the judgment of dissolution was entered in 2001. After being awarded a temporary monthly support of $1,423, the wife was later awarded $2,400 in spousal support for five years beginning July 2002. At that point, the husband was also ordered to pay wife's attorney's fees of $25,000. Five years later, in October 2007, the wife sought a modification of spousal support - to permanent support, claiming that she had several medical conditions that prevented her from obtaining full-time employment. In June 2008, the court reinstated the $2,400 monthly payment, and the following year the award became permanent. The court ordered the husband to pay additional attorney's fees of $10,000.

Continue reading "California Court of Appeals Affirms Decision Ordering Wife to Reimburse Husband's Spousal Support Payments" »

December 26, 2013

California Court of Appeals Reviews Characterization, Valuation and Division of Wife's Bonuses in Divorce

dollars-1412644-m.jpgWhen it comes to divorce and the division of property, spouses should understand that California is a community property state. This means that an integral part of the marriage dissolution process entails the characterization of property as community, separate or quasi-community. This is a critical stage in the divorce proceedings, as proper characterization of property can impact the family's lifestyle long after the parties have gone their separate ways. A San Diego family law attorney, with extensive experience handling divorce and related matters, can be a tremendous asset when working through property division issues.

Under California Family Code section 760, there is a presumption that any property acquired during the marriage, by either spouse - other than by gift or inheritance - is considered to be community property (unless traceable to separate property sources). In order to determine whether property is community or otherwise, the parties (and/or the courts) must ascertain the time period during which the property was acquired. In a recent unpublished decision, the court of appeals was asked to review a trial court's ruling concerning the characterization, valuation and division of a wife's employment-related bonuses. In this case, there were several bonuses at issue, either conditionally received or earned from her employer before the couple separated.

The spouses argued over whether and to what extent the husband was entitled to the wife's "book of business" and certain bonuses that her employer, Wells Fargo, conditionally agreed to pay her. The trial court awarded the wife's book of business to her, concluding that since she could not sell her client list, it had no value and the husband, therefore, had no interest in it. The lower court also ruled on the status of several other bonuses, holding that a portion of a "transitional" bonus was earned before the separation and constituted community property subject to division. As for the other bonuses, the court ruled that they were the wife's property because they were not paid or due until after the parties separated.

Continue reading "California Court of Appeals Reviews Characterization, Valuation and Division of Wife's Bonuses in Divorce" »

December 19, 2013

Secretion of Community Property Assets Through Pension Plan Not Protected by Federal Law (ERISA)

dollar-in-a-box-1-1086817-s.jpgUnder California law, any property that a couple accumulates during the marriage is considered "community property." Likewise, any debt acquired becomes "community debt." Both assets and debts are typically divided equally upon divorce. Determining the property and debt that belongs to the marital property can be very complicated. Properly identifying, valuing and dividing the assets and debts is a very serious part of the divorce process, one that can have lasting effects on the parties involved. If you are facing divorce, it is critical that you contact an experienced family law attorney who is fully familiar with the process in the San Diego county court system.

A recent case illustrates one of the problems that can arise when the divorcing couple is working toward assessing the community property that will ultimately be divided between them. Here, the couple married in 1993 and the husband filed for divorce in March 2003. The court ordered the husband to pay spousal and child support, but at some point he fell behind in his support payments. Once that happened, the California Department of Child Support Services got involved and issued an order requiring Morgan Stanley to withhold funds from the husband's retirement accounts in order to collect child support arrears.

Throughout the lengthy proceedings that began in 2003, the spouses filed many motions and opposing responses, all in an effort to resolve questions about the division of assets, namely, the husband's defined benefit pension plan. In late July 2010, the trial court issued a temporary restraining order prohibiting the husband from transferring any funds in any Morgan Stanley account in his name, the name of his law firm or its pension plan. Two weeks later, the husband transferred approximately $100,000 from his pension plan into his Merrill Lynch trust account.

Continue reading "Secretion of Community Property Assets Through Pension Plan Not Protected by Federal Law (ERISA) " »

December 12, 2013

California Court Applied the Wrong Standard When Ordering Payment on Child Support Arrears

the-calculator-2-1038102-m.jpgFor divorcing spouses with children, child support is one of the most important issues to resolve. It is the amount of money that a court orders one or both parents to pay each month to contribute to the support of the child, including the child's living expenses. The amount will undoubtedly impact the lifestyle of the parties involved. In California, there is a statewide formula (also known as a "guideline") for determining how much child support should be paid. If you or someone you know is confronting a divorce, it is critical to consult with a family law attorney who can guide you on the laws and procedures applicable to residents of San Diego.

In some cases, the party required to pay child support will find that they are unable to make the payments, or will fall behind in making the payments. Under California law, one must pay interest on the balance due on top of the amount that is owed. In fact, the law requires that interest charges must be applied to the amount owed and courts do not have discretion to alter those charges. In a recent case, the California Court of Appeals reviewed a family court's decision to order a monthly payment of "at least the interest owed" on the arrears.

Here, the couple divorced in 1990 and had four children. By 1999, the youngest child was 18-years-old. In 2007, a trial court ordered the husband to pay $850 a month in child support arrears. In 2012, the San Diego County Department of Child Support Services (the "Department") made a motion to increase the payment to a minimum of $10,000 per month, arguing that he owed more than $1.2 million and that the interest was accruing by an amount of $4,690 a month. The husband opposed the motion, claiming that he was unable to pay the amount of support ordered at the time of the divorce (even though records show he never moved for a downward modification). His tax returns showed that he had state and federal tax obligations totaling approximately $180,000, for which he was also making monthly payments.

Continue reading "California Court Applied the Wrong Standard When Ordering Payment on Child Support Arrears" »

December 5, 2013

California Court of Appeals Settles Dispute over Date of Separation

times-1124434-m.jpgDivorcing spouses have plenty of serious issues to resolve before moving on with their new lives. From child custody to spousal support - there is an overwhelming number of difficult matters to deal with and hopefully settle as quickly and fairly as possible. In many cases, the date of separation can play an important role in determining the distribution of marital assets. There are many factors that a family court in San Diego will look to when making this determination. If you are considering divorce, it is critical to consult with an experienced family law attorney who can help guide you through the sometimes-tumultuous process with relative ease and confidence.

The data of a divorcing couples' separation is not always clear. Many factors can cloud the issue, such as a situation where a couple agrees that the marriage is over, but they both remain in the marital household beyond that date. Courts will look to a variety of items to make the best possible determination concerning the date. A recent decision by the California Court of Appeals sets forth a standard by which divorcing spouses may ascertain the date of separation.

Here, the couple were married in 1993 and have two children, born in 1995 and 1999. According to the facts of the case, the couple had differing opinions concerning the date of separation. The wife testified that she announced her intent to end the marriage on (or about) June 1, 2006. At that point, she prepared a financial ledger itemizing household expenses and allocated their equal contributions to the running of the home and taking care of the children's expenses. They each contributed to the joint fund and were separately responsible for their own personal expenses.

Continue reading "California Court of Appeals Settles Dispute over Date of Separation" »

November 28, 2013

Olympic Skier Bode Miller in a Cross-Country Custody Dispute with Ex-Girlfriend

silhouettes-7-1282782-m.jpgThe ongoing child custody battle that has divided Bode Miller and ex-girlfriend Sara McKenna, both emotionally and physically, is not yet over. Miller lives in San Diego, where he and McKenna first met and started dating. According to news reports, she now lives in New York and has recently been awarded temporary custody of their nine-month-old son by a family court referee in that state. Sadly, the baby has been back and forth in each parents' homes as the courts in two separate states attempt to work out an appropriate custody arrangement that will serve the best interests of the child. While the circumstances surrounding this widely publicized dispute are not necessarily the norm, child custody cases can evoke many intense emotions and positions by both parents. If you find yourself facing a child custody matter, it is critical that you contact an experienced San Diego family law attorney who can help you to navigate the sometimes-complicated, emotional process.

McKenna and Miller dated for a short while and although their relationship did not last, Miller did become pregnant. A former United States Marine, McKenna left California for New York to attend Columbia University with the help of the GI Bill. She was pregnant at the time, but claimed that Miller wanted nothing to do with the baby when he learned that she was pregnant. Miller initiated child custody proceedings in a San Diego family court. Once McKenna was in New York, Miller complained to a New York referee that she "absconded" with his baby by moving away. The court granted his request that the case be assigned back to California.

A California court then granted Miller custody of the baby boy. McKenna appealed. Just this month, a five-judge appeals panel in New York said that McKenna's basic rights had been violated and that jurisdiction belongs in New York because the baby was a resident of the state. This decision effectively sent the case back to the family court referee who awarded temporary custody of the baby to McKenna, until the next custody hearing that is scheduled for December 9 in New York.

Continue reading "Olympic Skier Bode Miller in a Cross-Country Custody Dispute with Ex-Girlfriend" »

November 21, 2013

Parents Suing San Diego County for Alleged Loss of Custody over Medical Marijuana Use

pedestrian-zone-sign-1422766-m.jpgAccording to the Courthouse News Service in San Diego, a Gulf War veteran and his family are suing the county of San Diego and assorted employees for taking their two children away from them for a year. The city claims that they received a tip that the parents were running an illegal daycare center at the home and smoking marijuana around the children. Although authorities discovered that there was no illegal daycare center, they did find marijuana at the home. In his defense, the war veteran argues that he received a medical marijuana recommendation from a doctor to treat migraine headaches that resulted from exposure to chemical weapons during the war.

Although the only "hazard" the investigators found at the home was the marijuana, authorities returned three days later with instructions to take the children from the home and to bring them to an emergency shelter for allegedly abused and neglected children in San Diego County. Interestingly enough, according to the complaint, neither parent was ever criminally prosecuted for the possession and/or use of the marijuana. Under California law, there are procedures to follow when someone suspects a child is subject to abuse or neglect. When someone makes a report about the safety of a child, the police or a social worker must investigate. But taking children away from their parents, for any length of time, is a serious matter and can have lasting effects on the entire family. Parents who are facing a child custody matter of any sort are encouraged to contact a local, experienced family law attorney who can help to protect and preserve their rights.

In this case, the parents allege that the city took their children away without conducting a proper investigation into the facts of the case. The complaint alleges that the California Welfare Code obligates social workers to err on the side of keeping children at home with their parents so long as it is safe to do so. At some point during the proceedings, the juvenile court made the children "wards of the court" and placed them in a foster home.

Continue reading "Parents Suing San Diego County for Alleged Loss of Custody over Medical Marijuana Use" »

November 14, 2013

Getting Married and Avoiding Divorce Can Be Good for The Economy and Your Health

valentines-series-ii-6-1414426-m.jpgIn two separate but equally intriguing studies, getting and staying married has been proven to be good for your health and beneficial for the economy. This may come as no real surprise. Getting married is usually a joyous occasion; when couples embark on a new life together, they are usually filled with hope and optimism for the future. At this point in their lives, couples are not usually anticipating the possibility of divorce and any attending negative ramifications (unless they decide to prepare a prenuptial agreement).

Divorce can impact many aspects of a person's life, including one's financial situation, living arrangements, relationships with other family members, including in-laws, and of course, if children are involved, the extent to which they may spend time with them. And now it seems, divorce may be bad for your health. At the end of a marriage, many of the issues that arise are complicated and require strict attention to detail and knowledge of the local court process. If you are considering divorce, it is important that you reach out to an experienced San Diego family law attorney as early in the proceedings as possible.

According to a recent Gallup Poll, married people spend more money than single folks, suggesting that if more people got married, then the economy would likely improve. The poll was conducted by telephone interviews with more than 135,000 Americans aged 18 and older. Of those polled, Americans who are married reported spending $102 on average each day. That number decreased to $98 for couples in domestic partnerships, $74 for people who are divorced, $67 for single -- and never married people, and $62 for widowers and widows. A research scientist who has examined wealth in relation to marital status essentially confirmed these results by suggesting that married couples had about four times the wealth of those who had never been married.

Continue reading "Getting Married and Avoiding Divorce Can Be Good for The Economy and Your Health" »

November 7, 2013

Demi Moore and Ashton Kutcher Finalize Divorce Two Years After Separation

1193021_dark_dollar_2.jpgIn their highly publicized divorce, actors Demi Moore and Ashton Kutcher have finally reached a settlement. According to reports, both parties are satisfied with the agreement and have signed the paperwork to end their marriage. While they were only married for six years, it took the two famous actors two years to resolve their differences, many of them financial. One of the contested issues was Moore's request for spousal support. Under California law, when a couple divorces or enters into a legal separation, a court may find it appropriate to order one spouse to pay the other a certain amount of money each month.

In an earlier blog post, we reported on the two actors' separate filings for divorce. Moore, who is 50-years-old, asked Kutcher for spousal support and, to pay her attorney's fees, despite that she is worth (financially) more than he is. This case seems to be more about hurt feelings than any real financial need: Kutcher was thought to be having an affair with a 23-year-old woman right before their separation. Contrary to this scenario, most spousal support cases involve one spouse's financial need to maintain the marital standard of living.

In San Diego County, there are no legal guidelines for courts to follow when rendering an award of spousal support. Therefore, when a couple is considering a divorce, it is extremely important to consult with, and ultimately hire, a widely experienced, local family law attorney. The California court system sets forth procedural steps to follow when seeking spousal support. The very first item is to initiate a divorce or legal separation case with the court. As in the Moore/Kutcher divorce, sometimes it takes a great deal of time to work through the contested issues. Parties may seek a temporary order for spousal support to get through the process until there is a final judgment in the case.

Continue reading "Demi Moore and Ashton Kutcher Finalize Divorce Two Years After Separation" »