Patricia Ann Patten (Now Nave) v. William Early Patten

CourtCourt of Appeals of Kentucky
DecidedJune 20, 2024
Docket2023 CA 001006
StatusUnknown

This text of Patricia Ann Patten (Now Nave) v. William Early Patten (Patricia Ann Patten (Now Nave) v. William Early Patten) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patricia Ann Patten (Now Nave) v. William Early Patten, (Ky. Ct. App. 2024).

Opinion

RENDERED: JUNE 21, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-1006-MR

PATRICIA ANN PATTEN (NOW NAVE) APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE LIBBY G. MESSER, JUDGE ACTION NO. 10-CI-04382

WILLIAM EARLY PATTEN APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; ACREE AND CALDWELL, JUDGES.

ACREE, JUDGE: Patricia Patten (now Nave) appeals the Fayette Family Court’s

June 5, 2023 Order Denying Motion for Evidentiary Hearing and to Set Aside

Settlement Agreement, wherein the family court denied both Nave’s motion to

enforce Paragraph 18 of the parties’ Property Settlement Agreement and her CR1

1 Kentucky Rules of Civil Procedure. 60.02 motion, as well as Nave’s motion for attorneys’ fees. Because we do not

detect reversible error in the family court’s ruling, we affirm.

This appeal marks the third time these parties have appeared before

this Court related to the dissolution of their marriage.2 Nave and Appellee,

William Patten, were married in 1981. Nave filed her petition for dissolution of

the marriage in 2010. As we have noted previously, the divorce was contentious.

Nave believed Patten hid assets and concealed income. Prior to entry

of the Settlement Agreement, the parties engaged in substantial discovery which

revealed no such hidden assets or income. Despite this, the parties included the

following paragraph in the Settlement Agreement:

18. DISCLOSURE. The parties hereby agree that this Separation and Property Settlement Agreement has been reached after both parties have made full disclosure of all assets and liabilities and this agreement is predicated upon each party being fully aware of the financial resources of the other. If either party has failed to disclose any assets of any nature, said asset shall be deemed joint property of the parties subject to division by the Fayette Family Court and this Agreement shall be amended to provide for an equitable division of said asset.

The family court incorporated the Settlement Agreement in the parties’ December

11, 2011 decree of dissolution.

2 Patten v. Patten, No. 2015-CA-001812-MR, 2017 WL 729777 (Ky. App. Feb. 24, 2017); Patten v. Patten, No. 2017-CA-000784-MR, 2019 WL 2157580 (Ky. App. May 17, 2019).

-2- On December 11, 2015 – four years after the family court entered its

decree of dissolution – Nave filed a motion to enforce paragraph 18 of the

Settlement Agreement and a motion to set aside the decree of dissolution and re-

open the Settlement Agreement pursuant to CR 60.02(d) on the basis of fraud

affecting the proceedings. She filed an amended motion to enforce on January 28,

2016, and re-filed her CR 60.02 motion on April 18, 2016.

As the basis for her motions, Nave argued Patten produced documents

in a probate action in Oklahoma that contradicted his sworn testimony in the

parties’ divorce proceeding; she argued these documents revealed Patten made

purchases with and transferred money into undisclosed bank and brokerage

accounts in order to conceal marital assets. Additionally, she claimed she

discovered a compact disc in September 2015 containing, among other documents,

a 2001 letter referencing accounts with Merrill Lynch. Nave argued that, because

the letter requested that Merrill Lynch liquidate the accounts and send Patten a

check for the balance, Patten had lied when he testified his Merrill Lynch accounts

were depleted by 1984.

In response, Patten asserted he did not have Merrill Lynch accounts

when the parties filed for divorce in 2010, and that the funds from the Merrill

Lynch accounts were transferred to other accounts which he disclosed, and which

were specifically allocated in the Settlement Agreement. As for her arguments

-3- related to other undisclosed accounts, Patten asserted these arguments were

untimely.

On December 22, 2016, the family court entered an order denying

Nave’s CR 60.02(d) motion as untimely. On April 19, 2017, the family court

entered an order denying Nave’s motion to alter, amend, or vacate and which

stated specifically that the December 22, 2016 order denied Nave’s motion to

enforce the settlement agreement as well as all other pending motions.

Nave appealed, and this Court reversed and remanded this matter to

the family court. We determined that resolving Nave’s CR 60.02 motion did not

resolve her motion to enforce the settlement agreement and that this omission was

error. We concluded:

In sum, we find the trial court erred when it summarily denied Nave’s motion to enforce paragraph 18 of the Settlement Agreement. On this issue, we reverse and remand for additional proceedings. On remand, the trial court must find as fact under the agreement: (1) whether an asset not disclosed at the time the parties executed the Settlement Agreement existed; and (2) if it finds a non- disclosed asset, it must then equitably divide the asset between the parties, taking into consideration the Settlement Agreement and in accordance with KRS 403.190.

Patten v. Patten, No. 2017-CA-000784-MR, 2019 WL 2157580, at *7 (Ky. App.

May 17, 2019).

-4- As to Nave’s CR 60.02 motion, we determined the family court’s

analysis was insufficient. We instructed the family court on remand as follows:

On remand, the trial court must first determine whether Nave’s motion properly falls under CR 60.02(c), perjury or falsified evidence, or CR 60.02(d), fraud affecting the proceedings. It must then determine, based on that initial finding, whether the motion was timely filed. If Nave clears those hurdles, the trial court must determine whether she adequately established fraud affecting the proceedings to justify re-opening the decree and modifying or setting aside the Settlement Agreement.

Id. at *9. Further, we explicitly noted that “[n]othing in this Opinion should be

construed as dictating the outcome of either motion” and that these determinations

are left “fully and squarely to the trial court’s sound discretion.” Id.

Following remand, the family court learned Nave was engaged in

additional discovery when Patten filed a motion for protective order in November

of 2020. Patten requested the family court to prohibit Nave from conducting any

additional discovery beyond that which she performed for her original motion in

2015. The family court denied the motion and directed Patten to produce all

documents in his possession regarding the Merrill Lynch accounts referenced in

the letter discovered on the compact disc. The family court did so because this

information would be critical to both Nave’s motion to enforce and her CR 60.02

motion.

-5- On December 6, 2021, Nave filed a motion for an evidentiary hearing

on her motion to enforce the Settlement Agreement. Subsequent to the motion,

Patten again requested a protective order prohibiting Nave from engaging in

additional discovery, which the family court denied and permitted discovery to

continue. The family court scheduled the evidentiary hearing for June 3, 2022.

On May 10, 2022, prior to the hearing, Nave “stipulate[d] that at this

time she is not able, from third-party discovery performed in 2022, to meet her

burden of proof as set out in paragraph 2 of the Order entered of record on May 6,

2022 by this [c]ourt[.]” Paragraph 2 of the family court’s May 6, 2022 order states

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Patricia Ann Patten (Now Nave) v. William Early Patten, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patricia-ann-patten-now-nave-v-william-early-patten-kyctapp-2024.