DINA M. KAUL VS. RICHARD A. KAUL (FM-18-0254-08, SOMERSET COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedJune 13, 2018
DocketA-2201-16T1
StatusUnpublished

This text of DINA M. KAUL VS. RICHARD A. KAUL (FM-18-0254-08, SOMERSET COUNTY AND STATEWIDE) (DINA M. KAUL VS. RICHARD A. KAUL (FM-18-0254-08, SOMERSET COUNTY AND STATEWIDE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DINA M. KAUL VS. RICHARD A. KAUL (FM-18-0254-08, SOMERSET COUNTY AND STATEWIDE), (N.J. Ct. App. 2018).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-2201-16T1

DINA M. KAUL,

Plaintiff-Respondent, v.

RICHARD A. KAUL,

Defendant-Appellant. __________________________

Argued May 9, 2018 – Decided June 13, 2018

Before Judges Koblitz, Manahan and Suter.

On appeal from Superior Court of New Jersey, Chancery Division, Somerset County, Docket No. FM-18-0254-08.

Richard Arjun Kaul, appellant pro se.1

Jessica Ragno Sprague argued the cause for respondent (Weinberger Divorce & Family Law Group, LLC, attorneys; Jessica Ragno Sprague, on the brief).

PER CURIAM

Defendant Richard A. Kaul appeals from a December 19, 2016

order denying his request to modify his support, assessing $1719

1 Although defendant requested oral argument, he did not appear to argue. in counsel fees against him, and denying his request for an order

directing the New Jersey Board of Medical Examiners to reinstate

his medical license.

Defendant presents the following arguments on appeal:

POINT I: THE COURT ERRED BY EITHER WILLFULLY OR NEGLIGENTLY FAILING TO FIND THE FACTS, AND ABUSED ITS DISCRETION BY FAILING TO REPORT THE ALLEGATIONS OF FORGED TRANSCRIPTS TO FEDERAL AUTHORITIES.

POINT II: THE COURT HAS INCORRECTLY INTERPRETED THE LAW OF GENERAL JURISDICTION, AND HAS WITHOUT LEGAL FOUNDATION, TRUNCATED ITS EQUITABLE AUTHORITY.

POINT III: THE COURT HAS INCORRECTLY PREMISED ON ITS FLAWED PRECEDING CONCLUSIONS [SIC], ITS GRANT OF THE PLAINTIFF'S CROSS-MOTION TO DENY THE DEFENDANT'S MOTION.

POINT IV: THE COURT HAS ABUSED ITS DISCRETION BY NOT DENYING WITH PREJUDICE THE PLAINTIFF'S REQUEST THAT THE DEFENDANT'S FUTURE MOTIONS ARE SCREENED.

POINT V: THE COURT ERRED BY NOT PERFORMING AN ECONOMIC ANALYSIS OF THE PARTIES, BEFORE ENTERING ORDERS OF LEGAL COST.

POINT VI: THE COURT ABUSED ITS DISCRETION BY FAILING TO CONSIDER THE DEFENDANT'S REPLY PAPERS, AND ERRED BY IGNORING APPELLATE AUTHORITY.

POINT VII: THE COURT ERRED BY FAILING TO ORDER AN ECONOMIC ANALYSIS OF THE PLAINTIFF AND FAILING TO FIND THAT THE PLAINTIFF HAS COHABITED SINCE 2014.

POINT VIII: PARAGRAPH SPECIFIC CRITIQUE OF COURT'S LEGAL CONCLUSIONS AND FINDINGS OF FACT.

2 A-2201-16T1 After reviewing the record in light of the contentions

advanced on appeal, we affirm substantially for the reasons

incorporated by Judge Hany A. Mawla into his December 2016 order.

We add the following.

The parties entered into a Property Settlement Agreement

(PSA) in August 2005, but were not divorced until October 2009.

Plaintiff Dina Kaul was awarded counsel fees by an October 7, 2009

order. Plaintiff appealed the enforcement of the PSA, and

defendant cross-appealed the award of counsel fees. We affirmed

both orders. Kaul v. Kaul, No. A-0177-09 (App. Div. Aug. 15,

2011) (slip op. at 14).

On April 2, 2012, defendant's medical license was suspended,

and on February 12, 2014, his license was revoked. Plaintiff

successfully filed for support enforcement three times. Defendant

appeals from the denial of his second motion to modify unallocated

support of $10,000 per month, although the parties agreed in the

PSA that there would be no modification regardless of future

"increases or decreases in their income."

The parties were married in 2003. Two children were born of

the marriage. Defendant was a doctor with a hugely successful

minimally invasive surgery practice. He claims that his success

caused professional jealousy that led other specialists in his

field to bribe then-Governor of New Jersey, Chris Christie, who

3 A-2201-16T1 arranged for defendant's medical license to be revoked.2 He also

claims that the record of his medical license revocation contains

many forged transcripts and seeks intervention from the Family

Court.

Defendant alleges that after his medical license was revoked,

his income decreased by 90% and many parties filed lawsuits against

him. His business declared bankruptcy and he sought to reduce his

support payments from $10,000 a month to $500 a month. At the

time he filed his first motion seeking a reduction, he was $280,000

in arrears. He claimed at that time that his income had been

reduced from many millions to $500,000 per year. He presently

claims that, as of July 2014, he has no income. He asked the

Family Court to reinstate his medical license, arguing that the

Superior Court has jurisdiction to do so and that he needs his

license to support his family. He filed a case information

statement (CIS) alleging that he was fully supported by others and

has no assets, income or expenses. He did not attach a tax return,

financial records or his prior CIS. See R. 5:5-4(a).

Judge Mawla found that "[d]efendant has provided no financial

documentation necessary to demonstrate a substantial and permanent

change in circumstances" and denied the motion "without

2 He adds that insurance companies have a policy of coercing medical boards or politicians into revoking a person's medical license so the companies do not have to pay the doctors. 4 A-2201-16T1 prejudice." The judge noted the deficiencies in defendant's CIS

and stated that letters from his relatives and friends did not

constitute objective proof that he unsuccessfully sought

employment, or was fully supported by others.

Plaintiff points out that the PSA contained an anti-Lepis3

clause precluding modification regardless of defendant's loss of

income. See Kaul, No. A-0177-09 (slip op. at 4); Morris v. Morris,

263 N.J. Super. 237, 241 (App. Div. 1993). The PSA, however, does

not entirely prevent modification.

Paragraph 14 of the PSA calls for a termination of support

in the event of "the [w]ife's cohabitation with another person in

accordance with existing case law." Of course, cohabitation would

not affect the child support component of this agreed-upon

unallocated support.

Defendant filed a reply certification in support of his

modification motion one day before oral argument. The judge did

not consider this certification, in which defendant alleged that

plaintiff had been cohabiting for several years with "a male,

whose income, it is believed, is derived from the operation of a

privately held business." The obligor has the burden of proof to

make a prima facie showing that cohabitation exists. Ozolins v.

Ozolins, 308 N.J. Super. 243, 248 (App. Div. 1998). Additionally,

3 Lepis v. Lepis, 83 N.J. 139 (1980). 5 A-2201-16T1 new issues are not the proper subject matter of a reply

certification, which should only respond to opposing affidavits

or certifications. R. 1:6-3(a).

Judge Mawla granted plaintiff's "request [to] compel

[d]efendant to pay for her legal fees and costs associated with

this [m]otion," totaling $1719. He stated: "Defendant has acted

in bad faith by filing the same [m]otion he filed in May 2016.

Defendant is self-represented and [p]laintiff has incurred $1719

in legal fees in connection with this [m]otion." He continued:

"Pursuant to the May 1, 2014 Order, [p]laintiff was awarded

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DINA M. KAUL VS. RICHARD A. KAUL (FM-18-0254-08, SOMERSET COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/dina-m-kaul-vs-richard-a-kaul-fm-18-0254-08-somerset-county-and-njsuperctappdiv-2018.