NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.
SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3999-22
ANGELA M. CAFFERATA,
Plaintiff-Appellant,
v.
ABDEL M. ABDALLA,
Defendant-Respondent. _________________________
Submitted October 16, 2025 – Decided December 12, 2025
Before Judges Mayer and Jacobs.
On appeal from the Superior Court of New Jersey, Chancery Division, Family Part, Somerset County, Docket No. FD-18-0355-17.
Angela M. Cafferata, self-represented appellant.
Abdel M. Abdalla, self-represented respondent.
PER CURIAM
Plaintiff appeals from orders granting defendant's motion to reduce child
support and denying her motion for reconsideration. She contends the trial court erred by failing to demonstrate changed circumstances sufficient to warrant a
modification and omitting the required findings of fact and conclusions of law
pursuant to Rule 1:7-4. We affirm.
I.
Plaintiff and defendant, who were never married, share one child, Jacob,
born in 2005. Litigation between the parties over custody and child support has
proceeded under various docket numbers since Jacob was three years old. Our
summary of the procedural history is limited to the orders on this appeal.
In December 2022, during Jacob's senior year of high school, defendant
moved for a reduction in child support, claiming changed circumstances
consisting of financial support for two dependent children with his current wife.
Through tax returns and recent pay stubs, he further challenged the fairness of
the $60,000 annual income imputed to him under prior court orders. Plaintiff
cross-moved to enforce litigant's rights, arguing defendant failed to comply with
orders fixing a schedule for reimbursement of expenditures made on Jacob's
behalf.
The court conducted a plenary hearing on March 28, 2023, with both
parties testifying as the sole witnesses. In support of her contention that
defendant had not demonstrated a change in circumstances sufficient to warrant
A-3999-22 2 a child support modification, plaintiff relied on previous orders denying
defendant's applications for child support reduction. As the court aptly
observed, "child support obligations are always modifiable . . . [T]he fact that
[the court] entered an order in 2019 has absolutely almost nothing to do with
child support in 2023."
Following testimony, the court directed the parties to submit supplemental
proofs regarding the income of defendant's spouse and plaintiff's expenditures
related to Jacob.
After "meticulously review[ing] all documents submitted," the court
issued an April 28 order, adjusting defendant's annual income from the imputed
$60,000 to $33,280. Together with consideration of defendant's spousal income,
the court recalculated defendant's weekly child support obligation pursuant to
the guidelines, resulting in a decrease from $159 to $29.1 Finally, concerning
reimbursement of plaintiff's expenditures for Jacob, the court calculated plaintiff
incurred $2,033. The court assigned responsibility for that amount — 61% to
plaintiff and 39% to defendant — in accordance with the recalculated guidelines.
1 See Child Support Guidelines, Pressler & Verniero, Current N.J. Court Rules, Appendices IXA (14)(c)(2) and IX-D to R. 5:6A, www.gannlaw.com (2026). A-3999-22 3 Plaintiff moved for reconsideration, arguing the court erred by not
requiring defendant to first submit an updated case information statement (CIS).
Extrapolating from the purported value of defendant's home, extensive
vacations, and luxury vehicles, plaintiff further argued defendant
misrepresented his assets and income. She suggested defendant's wife was
complicit in manipulating his actual income because she oversaw payroll at his
place of employment. Plaintiff also claimed defendant garnered additional
income from two LLCs. Defendant countered that the LLCs belonged to his
wife, denied earning more than his reported income, and noted he had a
mortgage on his home.
Plaintiff again relied on the previous orders denying defendant's request
to modify child support. The court noted "that child support obligations are
always subject to modification" and explained it was not bound by the 2019
order denying a reduction in child support.
In an August 15 order, the court denied plaintiff's motion for
reconsideration, accompanied by a written statement of reasons supplementing
its findings as placed on the record during oral argument. In that order, the court
required defendant to submit a profit and loss statement regarding the LLCs.
The court also directed the parties and Jacob to submit CISs addressing college-
A-3999-22 4 related expenses under Newburgh v. Arrigo, 88 N.J. 529 (1982). 2 The court
further detailed the breakdown of responsibility for the outstanding expenditures
in its April 28 order. In view of the parties' ongoing conflict and lack of
cooperation, the court required plaintiff to send defendant the relevant invoices
to allow defendant to pay his share directly to the providers rather than through
plaintiff.
This appeal followed.
As argued before the motion court, plaintiff contends the court failed to
recognize defendant's pattern of misstatements and inadequate financial
disclosures. She contends defendant's income and expenses were previously
litigated, and that his evidence presented was neither new nor credible. Plaintiff
further asserts the trial court failed to make explicit findings as to changed
circumstances or credibility, as required by Rule 1:7-4, and did not adequately
explain its rationale for the reduction in child support.
2 Submission of CISs in child support summary actions is optional. See R. 5:5- 2 ("The case information statement required by this rule shall be filed and served in all contested family actions, except summary actions, in which there is any issue as to custody, support, alimony or equitable distribution. In all other family actions, a case information statement may be required by order on motion of the court or a party."). A-3999-22 5 Defendant responds that his application demonstrated changed
circumstances because his documented income no longer aligned with imputed
income and because earlier rulings did not adequately account for his two
additional children. He argues the trial court adhered to applicable child support
guidelines, considered all relevant financial information, and that the decision
to reduce his child support obligation was neither arbitrary nor unsupported by
the evidence.
II.
We defer to a Family Part court's findings in recognition of its special
jurisdiction and expertise in family matters. Milne v. Goldenberg, 428 N.J.
Super. 184, 197 (App. Div. 2012) (quoting Cesare v. Cesare, 154 N.J. 394, 413
(1998)). Such findings will be disturbed only if they are "manifestly
unsupported by or inconsistent with the competent, relevant and reasonably
credible evidence." Ibid. (quoting Cesare, 154 N.J. at 413). However, we afford
no deference to the court's interpretation of law.
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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.
SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3999-22
ANGELA M. CAFFERATA,
Plaintiff-Appellant,
v.
ABDEL M. ABDALLA,
Defendant-Respondent. _________________________
Submitted October 16, 2025 – Decided December 12, 2025
Before Judges Mayer and Jacobs.
On appeal from the Superior Court of New Jersey, Chancery Division, Family Part, Somerset County, Docket No. FD-18-0355-17.
Angela M. Cafferata, self-represented appellant.
Abdel M. Abdalla, self-represented respondent.
PER CURIAM
Plaintiff appeals from orders granting defendant's motion to reduce child
support and denying her motion for reconsideration. She contends the trial court erred by failing to demonstrate changed circumstances sufficient to warrant a
modification and omitting the required findings of fact and conclusions of law
pursuant to Rule 1:7-4. We affirm.
I.
Plaintiff and defendant, who were never married, share one child, Jacob,
born in 2005. Litigation between the parties over custody and child support has
proceeded under various docket numbers since Jacob was three years old. Our
summary of the procedural history is limited to the orders on this appeal.
In December 2022, during Jacob's senior year of high school, defendant
moved for a reduction in child support, claiming changed circumstances
consisting of financial support for two dependent children with his current wife.
Through tax returns and recent pay stubs, he further challenged the fairness of
the $60,000 annual income imputed to him under prior court orders. Plaintiff
cross-moved to enforce litigant's rights, arguing defendant failed to comply with
orders fixing a schedule for reimbursement of expenditures made on Jacob's
behalf.
The court conducted a plenary hearing on March 28, 2023, with both
parties testifying as the sole witnesses. In support of her contention that
defendant had not demonstrated a change in circumstances sufficient to warrant
A-3999-22 2 a child support modification, plaintiff relied on previous orders denying
defendant's applications for child support reduction. As the court aptly
observed, "child support obligations are always modifiable . . . [T]he fact that
[the court] entered an order in 2019 has absolutely almost nothing to do with
child support in 2023."
Following testimony, the court directed the parties to submit supplemental
proofs regarding the income of defendant's spouse and plaintiff's expenditures
related to Jacob.
After "meticulously review[ing] all documents submitted," the court
issued an April 28 order, adjusting defendant's annual income from the imputed
$60,000 to $33,280. Together with consideration of defendant's spousal income,
the court recalculated defendant's weekly child support obligation pursuant to
the guidelines, resulting in a decrease from $159 to $29.1 Finally, concerning
reimbursement of plaintiff's expenditures for Jacob, the court calculated plaintiff
incurred $2,033. The court assigned responsibility for that amount — 61% to
plaintiff and 39% to defendant — in accordance with the recalculated guidelines.
1 See Child Support Guidelines, Pressler & Verniero, Current N.J. Court Rules, Appendices IXA (14)(c)(2) and IX-D to R. 5:6A, www.gannlaw.com (2026). A-3999-22 3 Plaintiff moved for reconsideration, arguing the court erred by not
requiring defendant to first submit an updated case information statement (CIS).
Extrapolating from the purported value of defendant's home, extensive
vacations, and luxury vehicles, plaintiff further argued defendant
misrepresented his assets and income. She suggested defendant's wife was
complicit in manipulating his actual income because she oversaw payroll at his
place of employment. Plaintiff also claimed defendant garnered additional
income from two LLCs. Defendant countered that the LLCs belonged to his
wife, denied earning more than his reported income, and noted he had a
mortgage on his home.
Plaintiff again relied on the previous orders denying defendant's request
to modify child support. The court noted "that child support obligations are
always subject to modification" and explained it was not bound by the 2019
order denying a reduction in child support.
In an August 15 order, the court denied plaintiff's motion for
reconsideration, accompanied by a written statement of reasons supplementing
its findings as placed on the record during oral argument. In that order, the court
required defendant to submit a profit and loss statement regarding the LLCs.
The court also directed the parties and Jacob to submit CISs addressing college-
A-3999-22 4 related expenses under Newburgh v. Arrigo, 88 N.J. 529 (1982). 2 The court
further detailed the breakdown of responsibility for the outstanding expenditures
in its April 28 order. In view of the parties' ongoing conflict and lack of
cooperation, the court required plaintiff to send defendant the relevant invoices
to allow defendant to pay his share directly to the providers rather than through
plaintiff.
This appeal followed.
As argued before the motion court, plaintiff contends the court failed to
recognize defendant's pattern of misstatements and inadequate financial
disclosures. She contends defendant's income and expenses were previously
litigated, and that his evidence presented was neither new nor credible. Plaintiff
further asserts the trial court failed to make explicit findings as to changed
circumstances or credibility, as required by Rule 1:7-4, and did not adequately
explain its rationale for the reduction in child support.
2 Submission of CISs in child support summary actions is optional. See R. 5:5- 2 ("The case information statement required by this rule shall be filed and served in all contested family actions, except summary actions, in which there is any issue as to custody, support, alimony or equitable distribution. In all other family actions, a case information statement may be required by order on motion of the court or a party."). A-3999-22 5 Defendant responds that his application demonstrated changed
circumstances because his documented income no longer aligned with imputed
income and because earlier rulings did not adequately account for his two
additional children. He argues the trial court adhered to applicable child support
guidelines, considered all relevant financial information, and that the decision
to reduce his child support obligation was neither arbitrary nor unsupported by
the evidence.
II.
We defer to a Family Part court's findings in recognition of its special
jurisdiction and expertise in family matters. Milne v. Goldenberg, 428 N.J.
Super. 184, 197 (App. Div. 2012) (quoting Cesare v. Cesare, 154 N.J. 394, 413
(1998)). Such findings will be disturbed only if they are "manifestly
unsupported by or inconsistent with the competent, relevant and reasonably
credible evidence." Ibid. (quoting Cesare, 154 N.J. at 413). However, we afford
no deference to the court's interpretation of law. Thieme v. Aucoin-Thieme, 227
N.J. 269, 272 (2016). Accordingly, we review its legal conclusions de novo.
Ibid.
Child support orders may be amended by the court as circumstances may
require. N.J.S.A. 2A:34-23(a)(1)-(10); Rule 5:6A; Lepis v. Lepis, 83 N.J. 139,
A-3999-22 6 157 (1980). The party seeking modification bears the burden of showing
changed circumstances that warrant an alteration in the prior order. Jacoby v.
Jacoby, 427 N.J. Super. 109, 116 (App. Div. 2012); J.B. v. W.B., 215 N.J. 305,
327-28 (2013). Such changes may include a significant increase or decrease in
income, new dependents, or other financial circumstances. J.B., 215 N.J. at 327-
28. Once a prima facie showing is made, the court must then determine the
appropriate level of support based on the current circumstances. Ibid.
A trial court's modification of child support will not be disturbed unless
it is "manifestly unreasonable, arbitrary, or clearly contrary to reason or to other
evidence, or the result of whim or caprice." J.B., 215 N.J. at 325-26 (internal
citations omitted).
Rule 1:7-4 requires a judge to make findings of fact and state conclusions
of law on every written order appealable as of right. While a trial court's
findings may have been brief or implicit, an appellate court may fill in the
evidence if the factual basis is otherwise clear and supported by the record. See
Farmingdale Realty Co. v. Farmingdale, 55 N.J. 103, 106 (1969); R. 2:10-5.
On review of the record, we discern no abuse of discretion in the trial
court's reduction of defendant's child support obligation. During the litigation,
the court previously imputed an annual income of $60,000 to defendant due to
A-3999-22 7 lack of documentation and credibility issues. However, at the plenary hearing
for the orders on appeal, defendant provided pay stubs and tax returns reflecting
an annual income of $33,280, approximately half the previously imputed
amount. Moreover, it is undisputed that defendant now supports two additional
minor children residing in his household, a factor which must be considered in
child support calculations under New Jersey's guidelines and case law. Martinez
v. Martinez, 282 N.J. Super. 332, 341-42 (Ch. Div. 1995). The reduction in both
defendant's income and his increased responsibility for two additional
dependents amply supports the trial court's determination of a change of
circumstances warranting downward modification.
Although the reduction from $159 to $29 per week is significant, the trial
court applied the child support guidelines worksheet without deviation, and
plaintiff points to no specific error in the income figures or application of the
guidelines. There is no basis to reverse or remand solely on the requirement of
more detailed findings. As required, the court referenced documents and other
evidence of the parties' current incomes, their respective standards of living and
economic circumstances, as well as the needs of defendant's minor children, and
Jacob's capacity for education and need for ongoing support. N.J.S.A. 2A:34-
23(a)(1)-(10).
A-3999-22 8 Based on our review of the record, we are satisfied the trial court closely
examined apparent discrepancies between defendant's reported income and
lifestyle. In the absence of credible evidence demonstrating underemployment
or hidden income that would justify imputation, we decline to disturb the trial
court's ruling.
Even if this court disagreed with the trial court's ruling, which we do not,
that would not evidence an abuse of discretion warranting reversal. This was
not a case where the trial court's findings were "so manifestly unsupported by
or inconsistent with the competent, relevant and reasonably credible evidence
as to offend the interests of justice." Amzler v. Amzler, 463 N.J. Super. 187,
197 (App. Div. 2020) (quoting Rova Farms Resort, Inc. v. Inv'rs Ins. Co., 65
N.J. 474, 484 (1974)).
Although the court did not expressly employ the term "change in
circumstances," it was not required to do so. The record reflects the trial court's
findings were supported by adequate, substantial, credible evidence in the
record, including the parties' testimony. The evidence as a whole demonstrated
a change in circumstances sufficient to support the resulting modification of
child support.
Affirmed.
A-3999-22 9