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Sage phase – Days 22-29
Design tools that focus in on details, make decisions and solve problems
These tend to be the days when I get into the details of an issue, find the best solutions, refine the details, plan how to make progress and make solid decisions.
Permaculture tools that suit this stage include making implementation and maintenance plans, setting smart goals, doing detailed careful work like drawing base maps or recording finances. I also found this stage the best for writing up my designs as I was happy to spend whole days alone, quiet, focussed and deeply engaged in my work.
So, previously in this design, I'd made the decision to continue working on my Muddy Boots business 3-4 days per week and refine the activities I offered in order to maximise my enjoyment and profits. I'd also decided to seek employment in arts education with another company for 1 day per week. This felt like real progress, so I was able to begin to focus in on my business in detail and plan how to make it more effective for the coming year.
I have done lots of work on my 2017 and 2018 finances. This content is in another blog post here and is password protected. Message me to get the password and see this content.
So all of the work done to date can be summarised as 7 main suggested changes to make to my Muddy Boots business and career path. This is the core of my design.
- Look into buying or renting my own site.
- Create more efficient admin and marketing systems or buy in help from a person or service.
- Ensure I am paid for all hours that I work.
- Reduce expenses and increase profits
- Reduce time spent on kit management and moving kit around
- Ensure I am earning from poly-income sources
- Schedule in CPD time.
I decided to write my implementation plan and use this activity to break down each of the seven actions into the activities that I needed to do to create positive changes towards making each action happen.
|Look into buying or renting my own site
|I will sign up to woodland buying websites and aim to visit any woodland that comes up for sale within 25 miles of my home.
|I visited woodland 25 miles away from me in early Jan 2018 but it sold to someone else almost immediately. It was really interesting and I shall continue to ponder this option for the future and look at other woodland that appears for sale locally. Kirby wood
|I will consider the finances of buying a site and find out if I could get a loan for this purpose.
|I looked into the logistics of borrowing £30,000 from my mortgage lender. We considered using our savings and pensions to invest into a woodland
|I will join the small woodland owners FB group and do a few intro posts
|Yes I've done this and made some interesting new links
|Yes. Continue using the forum regularly
|I will speak to people locally who may be able to help me, local councillors, land owners, farmers etc.
|I need to follow up a possible lead on a woodland in s. Leicestershire that belongs to the council
|Create more efficient admin and marketing systems or buy in help from a person or service
|Research possible admin systems to use
|Not really done this
|I will look again at all my current admin systems and make changes to make systems more efficient to manage.
|I've re-done some of my more cumbersome admin systems to make them quicker to action
|Before march
|I will aim to keep admin time to less than 4 hours per week after the initial planning weeks are over.
|Still in the initial set up weeks at time of writing so lots of admin time is happening
|March onwards
|I will consider what marketing is most effective for me and draw up a strategy for 2018 spring/summer marketing of events.
|Decided to have longer block bookings and incentives for booking multiple blocks. I identified that I was likely to be able to fill most of my spaces via my mailing list. So extra marketing outside of my normal FB and Instagram marketing was probably not required. I will however produce some flyers and posters for my local library to raise the profile and awareness of MB locally.
|I will use an email-marketing tool to make my spring mail out as attractive and effective as possible.
|I chose to use 'campaign monitor' and did a lovely spring-summer mail out. It was really effective and helped to fill well over 50% of my spaces within 48 hours!
|Design the email in Jan
Goes live Feb. 1st
|Look into raising the profile of MB in local press or online link ups.
|I was the featured blogger on 'The crop club' website with an article I wrote about the importance of outdoor play and links to all my social media sites.
|First week in Feb.
|Ensure I am paid for all hours that I work
|I will do a financial review of 2017
|I looked back at all figures for 2017 and drew conclusions about which activities worked best.
|I will do a financial projection for 2018.
|I did lots of work on my finances so that I had realistic and achievable aims for 2018
|I will assign myself a weekly wage and set up a direct debit monthly from my business to personal accounts to pay my wages.
|I have decided on an hourly wage for admin work and face-to-face work. I have paid myself for the marketing and admin time done in Jan and early Feb. I will set up a monthly DD for March onwards.
|Reduce expenses and increase profits
|I will aim to use more found, donated and recycled items in my sessions and reduce the need for buying materials.
|I will set and abide by a maximum per session expenses cost.
|I don't think this is realistic due to differing sessions but will keep careful records instead and record the average.
|I will increase each session cost by 15%.
|Decided to put prices up by 15% for most sessions and factored this into the pricing.
|I will adjust the forest parties pricing to make it more profitable
|Reviewed and adjusted my Forest party packages to give more options to cater to a variety of price points and to make them more sustainable and profitable for me
|I will aim to keep the overall expenses at less than 1/3 of the income for 2018.
|Keep careful records and all receipts.
|Reduce time spent on kit management and moving kit around
|I will put more shelves up in my kit storage area
|I managed to find some shelves to re-purpose and set these up in my storage area.
|I will ensure all kit if tidy, labelled and re-stocked before sessions re-start in 2018.
|I will tidy my kit storage area and re-stock with what I need for the 2018 season
|Before end Feb.
|I will spend no more than 1 hour before each session preparing and packing kit.
|I will plan what kit to take to each session more effectively.
|March onwards
|I will record this time in a log.
|Need to set up a log book
|March onwards
|I will plan double sessions whenever possible into my diary.
|Planned in full days rather than half days, i.e. double sessions or a session and a party, so that I minimise kit movement and set up/pack up time.
|Ensure I am earning from poly-income sources
|I will plan to have five different MB income streams in 2018 (forest pre-school, allotment playgroup, forest family days, forest parties and women's retreat days)
|2018 planning winter 2017 onwards
|I will aim to work for other people at 2 festivals or events in 2018.
|I spoke to my Forest school colleagues and expressed an interest in doing some assisting work
|Dec 2017 onwards
|I will seek employment with another company for 1 day per week.
|I approached Soft Touch arts about taking up my 1-1 arts and photography teaching again. They offered me 2 hours per week starting in mid January, contracted initially for 6 months. I have now started this work every Wednesday morning.
|Dec 2017
|Schedule in CPD time
|I will attend a minimum of six CPD day courses.
|I have been in touch with the local FS network and have expressed my interest in attending their CPD days.
|Jan onwards
|I will attend three networking sessions during 2018
|As above
|Jan onwards
|I will renew my first aid certificate in spring 2018
|I have booked onto a course in late Feb
|I will look into adding children's yoga into my morning circles and gain the necessary training for this
|I have been watching online kids yoga for teachers course. I have been attending yoga classes myself at least twice a week
|I will learn more about foraging and herbal medicine
|I have booked onto a spring foraging workshop.
|I will gain more skills and confidence in tool use
|I need to book onto a tool workshop
|I will gain more confidence and skills in campfire cookery techniques
|I need to book onto a campfire cookery workshop and try out some new skills in my garden before sharing them at sessions
Maintainance plan
I decided the most useful way to write a maintenance plan would be to divide it into timely tasks. I looked at the tasks that I need to perform at various timescales that made sense to me; daily, before each session, after each session, weekly, per season and annually.
Daily tasks
- Check emails
- Check Facebook and Instagram for messages that need a response
- Update to FB / Insta for marketing as required
- Check and update all diaries
- Write task lists and complete each days tasks
Before each session
- check the session plan and kit list
- Pack all kit required
- Pack all food and drink required
- Complete any outstanding admin tasks
- Arrive on site early to set up
After each session
- Wash all food and cooking kit in cool box
- wash all cloths and washing up boxes
- unpack and restock the shelves
- Note any observations about the session activities and the group
- Edit photographs taken and download onto computer
- Financial records and totals as required
Additional weekly tasks
- Check and update finances and paid lists
- Chase people for payments as required
- Order materials as required
- Purchase food and drink items for sessions
- Social media updates to advertise upcoming sessions and document events
- Working for Soft Touch every Wednesday – planning and face to face work.
Per season tasks
- Plan my sessions
- Book assistant/ volunteers as required
- Major email out for next season bookings
- Marketing for next season bookings
- Major kit check and wash
- Order new kit
- Check and update first aid boxes
- Create and distribute end of season feedback forms and make changes as appropriate.
Annual tasks
- Plan the years dates
- Consider my aims for the year
- Creative review/ forward plan for the year
- Financial review
- Financial forward planning
- Review feedback forms and make changes as appropriate
- Tax return
- Ensure all certification is up to date, first aid, DBS, etc
- Renew PL Insurance and send copies to all parish council


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"I would rate this decision positively for several reasons. First of all, Bolton is a hawk and an unconditional conductor of the brutal anti-Russian course, an adversary of all progressive regimes. He is the initiator of many aggressive foreign policy decisions of the United States. In fact, it was the former adviser who dragged Donald Trump into a confrontation with the legally elected heads of state of Latin America, "said the deputy.
According to him, Bolton put the US president in a "very difficult position on the Venezuelan issue."
"For Donald Trump, Bolton's departure is a chance to disown a number of US foreign policy failures and save face. Of course, it's too early to deceive yourself. But, in itself, such a signal is not bad. And, if this will contribute to adequate rotation, then some adjustments in the Russian direction are possible, "Novikov said.
Trump said earlier that he had dismissed Bolton.
He thanked Bolton for his work, noting that he would give the name of the new National Security Advisor next week.


text:
Assistant / Associate / Professor (D1 & D2) of Law
- Recruiter
- Location
- Beijing (CN)
- Posted
- Wednesday, 3 June 2020
- End of advertisement period
- Thursday, 31 December 2020
- Academic Discipline
- Social Sciences, Law
- Job Type
- Academic Posts, Professors / Chairs, Principal / Senior Lecturers / Associate Professors, Lecturers / Assistant Professors
- Contract Type
- Permanent
- Hours
- Full Time
Category: Talents
First-Level Discipline: Law
Second-Level Discipline for D1: Civil and Commercial Law, Intellectual Property Law, Information & Cybersecurity Law, Educational Law, Private International Law
Second-Level Discipline for D2: Civil and Commercial Law, Environmental Resources Law, Fundamental Theory of Law, Private International Law, Educational Law
Responsible for teaching, scientific research, talents training, and social services of the discipline
Hiring Criteria:
Meet the hiring criteria for Backbone Talents of D1 & D2 level of Humanities and Social Sciences.
For more details on the Eligibility, Remuneration and Benefits, please visit BNU Global Recruitment - Beijing Campus
For more information and to submit your application, please refer to below contact details.
Mr./Ms. Liu
Tel: +86-10-58800150 / +86-15010310279
Email: firstname.lastname@example.com
About Beijing Normal University (BNU)
Established in 1902, the Beijing Normal University (BNU or colloquially Beishida) began as the Faculty of Education of Capital Metropolitan University, which facilitated teacher training in Chinese higher education. It is one of the oldest and most prestigious universities in China and was recognised by the Chinese Ministry of Education as a Class A Double First Class University. BNU was one of the first Chinese institutions to recruit international students, and now has around 1,800 long-term international students from over 100 countries and regions. Known for its Mandarin Chinese study programmes, BNU also collaborates with Princeton University for the Princeton in Beijing program.
To learn more about us, please visit www.bnu.edu.cn
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Table of Contents :
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Without phonics skills, it's almost impossible, especially for kids, to learn how to read new words. Techniques to Handle Attention Issues It is extremely essential that should you discover your kid is inattentive to his learning especially when it has to do with reading and writing issues you must begin working on various ways and to improve it. Use a student's name in every sentence so there's a single sentence for each kid. Because he or she learns at his own rate, there is some variability in the age when a child is ready to learn to read. Teaching your kid to form the alphabets is quite a complicated practice.
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NICE pushes for better way to measure health-related quality of life
NICE is backing the collection of new data to measure health-related quality of life, which it hopes will resolve concerns about the existing EQ-5D-5L value set for England.
A new study will gather the public's views about which aspects of health matter the most. The results of the study will be used to create a value set which converts questionnaire responses into a number called a utility value. This information is used to inform many of NICE's decisions about whether treatments provide good value for money.


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Things to know for the Pharm. D. interview
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- This is a work in progress. If you have any comments or suggestions, please send them to me (Dr. Arthur Roberts) at audie @ uga . edu.
- The interview is absolutely critical for you getting into our Pharm. D. program, even if you have a GPA of 4.0 and a 99 on the PCAT.
- My motivation for writing this outline is that I have interviewed many students that did not have a clue how to interview. They are smart, have good grades and totally bomb the interview. Also, I am a strong believer in telling students clearly what they need to know.
- Disclaimer: I hope this outline helps you, but I take absolutely no responsibility implied or explicit from this work for getting you into our or any Pharm. D. program.
- University of Georgia interviews, at least when I was giving them, were 30 minutes with 2 interviewers. You were also given a tour prior to that.
Interview Priority
- Below is my interpretation of the interview priority, but you must not be bad in any category.
- Personality/Personal Communication, Motivation and Health-care (preferably Pharmacy) Related Extracurricular Activities
- Grades and PCAT
- Recommendations, Personal Statement, the Answered Question and non-Health-care Related Extracurricular Activities
Personality/Personal Communication
- Do not assume that you will automatically get into our program because of your awesome grades and PCAT. Many don't because of the interview.
- Shake hands with the interviewers.
- Be yourself. Do not try to be something that you are not. We will pick up on it.
- Be honest. We are pretty good at detecting dishonesty. If we catch any dishonesty, we will not believe anything that you say.
- I know that you may be nervous, but try to be relaxed.
- Be friendly and smile. We want to know how you will interact with customers as a pharmacist.
- Why do you want to be a pharmacist?
- Good Answers
- I have always had a strong interest in science.
- I have always had an interest in drugs and drug-drug interactions, since I was young.
- I enjoy working with and helping people.
- Bad Answers
- I heard it pays a lot of money.
- I heard that the career does not require as many hours as a medical doctor. I don't like to work long hours.
- Good Answers
- Be enthusiastic about pharmacy and joining the school of pharmacy.
- If you are luke warm about it, we will feel luke warm about you.
- Maintain eye contact. Do not look away, when talking to us.
- Please answer the questions clearly and concisely.
- Avoid answering questions too quickly. When you are nervous, you might feel like you are pausing forever. However, some pausing is good, so that you can answer the question well. If you have trouble speaking in front of people, I recommend attending your local toastmasters.
- Sit up with good posture and look professional.
- Dress professionally.
- Do not move your hands or body around a lot. Avoid nervous tics. If you have a medical condition that causes you to do it, please explain that at the beginning of the interview.
- Avoid using filler words like um, ah, etc. If you have trouble with not using filler words, I recommend attending your local toastmasters.
- If you worked at a pharmacy (hint: we like that a lot), what did you like and not like about it?
- Good things to like.
- I enjoyed learning about different drugs/drug-drug interactions. Be ready to give specific examples.
- I enjoyed interacting with and helping customers.
- Good things to not like.
- I didn't like the complexity of the insurance paperwork.
- I didn't like the high cost of drugs for some of our customers.
- I didn't enjoy being forced by a customer's insurance to give them a generic drug, when the customer wanted a brand name drug.
- Bad things to not like.
- I didn't really care for the pharmacist that I worked with.
- I didn't really like the customers or being around people. <-- For most pharmacists, this is going to be your main job and you will have to be around customers a lot.
- Good things to like.
- We want to hear that you want to be pharmacist. Therefore, please do not talk about how you would like to do something else. For example, there was a student, who kept talking about how they wanted to be a cook and how they enjoyed cooking. This certainly did not give us a good impression on whether this person would be a good pharmacist or if they even wanted to be a pharmacist. Quite the opposite.
- Why do you want to be a pharmacist over being a medical doctor or other health related profession?
- Do not tell us that you wanted to be a pharmacist because you could not get into medical or dental school.
- If you have a blemish on your record, be ready to explain it.
- Example for Poor Grades as a Freshman: As you can see from my grades, I have greatly improved from my freshman days. I think I am a lot more mature, now. (Do not make a lot of excuses or be too verbose. There are a million reasons why someone gets bad grades as a freshman.)
- Do not talk about controversial topics.
- Examples
- Opinions about religion and politics.
- Tattoos and piercings
- At the end of the interview, thank the interviewers for interviewing you and shake their hands again, while maintaining eye contact.
Health Care-Related Extracurricular Activities
- If you start the extracurricular activities only a few months before the interview, they will not mean much and we will notice. We like to see people that have done activities for years.
- Get a job at a pharmacy (preferable) or in health-care such as a in a hospital or in a nursing home.
- Join a health-care or pharmacy- related club at your University.
- Take a leadership role in the club.
- If you cannot get a job in a hospital, nursing home or pharmacy, shadow a pharmacist (preferable) or doctor. You could also try to volunteer in a research laboratory. However, if you do this, you must do more than hang out in the laboratory. Don't waste the research professor's time.
Non-Health Care-Related Extracurricular Activities
- Just like health care-related extracurricular activities, we like to see people that have done thing for years.
- Please show that you have done more than study for your classes. We want someone in our program that is well balanced. We don't want to hear that you do nothing, but study.
- We like to see people that have some diversity in their extracurricular activities.
- We like to see people in leadership roles in their extracurricular activities. For example, if you are in a club, try to be the president.
- Do you know the difference between:
- Have you checked out the main website for UGA College of Pharmacy.
- This is what you are going to do for the rest of your life. Do you know all the possible careers in Pharmacy?
- PLEASE READ and KNOW the Pfizer guide to careers in pharmacy
- Apply to multiple Pharmacy Schools.
- Ideally, you will want to have worked for a pharmacist as a pharmacy tech, student worker or at least shadowed a pharmacist. If you have, be sure you know as much as you can about the job.
- What are the pro's and con's of being a pharmacist?
- What does a pharmacist do on a daily basis?
- If you get asked: "If you do not get accepted to pharmacy school this year, what are your plans next year?" Be honest. However, we want you to tell us that you will apply next year and the year after that, until you get in. We do not want to hear that you are going to give up.
- If you get less than a 80 on your PCAT, take it again. If you have taken it multiple times and your score is still below 80, be ready to explain why. We understand that some people are not good standardized test takers.
- Please DO NOT tell us that you are interested in Pharmacy because you heard it pays well or that it is not as much work as other professions.
- What interests you about pharmacy?
- Tell us about the first time that you showed an interest in pharmacy.
- Tell us what aspects of pharmacy interest you.
- Tell us how you see yourself in a pharmacy setting.
- Look up programs that are available within the College of Pharmacy.
- Please have questions to ask us that indicate your interest in our program.
- Try to get three recommendations. Two recommendations are probably OK.
- Talk with the person that is giving you the recommendation.
- At least one of the recommendations should be from a pharmacist or a health professional.
- Recommendations from a professor that you worked for or had a class with are OK
- Recommendations from friends or relatives do not mean much. We can recognize in 2 seconds, where the recommendations come from.
Personal Statement
- It should show a true interest in pharmacy as it relates to your life.
- When did you know that you wanted to be a pharmacist?
- What interests you about pharmacy?
- Personal Statement No No's
- I want to be a pharmacist because I will be paid well.
- I want to be a pharmacist because I do not want to work too hard.
- Significant grammatical and spelling mistakes.
Answered Question
- Each prospective student is given a question that requires a written answer. Most people do well on this section.
- Be clear and concise. The answer does not have to be long. Actually, long and unclear can hurt your application.
- Be sure that it is free of significant grammatical and spelling errors.
- Even if your grades are not the best when you start college, we want to see a positive trend grade-wise. Even with the same GPA, a negative trend reflects more negatively on you.
- It is always better to get good grades in all of your classes. However, at least, we want to see good grades in your core science classes.
- If you get less than a B in your core science classes, we want to hear that you are in the process of retaking it or you will retake it.
PCAT versus Grades
- When we see a very high PCAT and low grades, that suggests to us that the student is smart, but doesn't apply themselves, which means that they might not do well in Pharmacy School. We are more willing to see the reverse. In other words, high grades and a lowish PCAT (i.e. 50-60) are more acceptable because we recognize that many students have standardized test anxiety.


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Essential Tips Choosing the Right Speech Therapist
Did you find out that your kids had trouble in reading and spelling? A speech therapist is the solution for your problem for your kids. Through speech therapist, they can learn more on how to be good in reading and spelling. There are so many speech therapists out there that can provide the need that you want and some of them had an own website for easy contact. And last but not the least is the guidelines in finding the right speech therapist.
It is important to have an excellent equipment maintenance no matter the field you are working in. It will not matter even if you work into your computer or that of other IT equipment, or if you are out in the field driving around in that of the company vehicle or shop or that of the warehouse. It is also best to have not only the regular maintenance but to also have the preventive maintenance if possible.
If you will not make it sure that you will do some regular maintenance into that of your equipment, then you will have a huge problems that you will encounter along the way. Without the right fluids or oil into your vehicle, then you can eventually blow those motor. Without the regular cleaning, your nail guns, and your saws is going to seize up. Even your computer, and your printers, as well as the other related tools to have proper maintenance so that it will not eventually crash down.
You may often think that the time it will take to be able to do the routine maintenance can eventually lower the productivity of the equipment. But, while it will take half an hour or more to do the regular checking, it is less costly than the machine or that of other equipment breaking down, and having to have the specialized technical to fix it, or to replace the unit together. Not that it can create some downtime, but this can also cost a lot.
There are other software programs that can be able to aid that of the regular equipment maintenance that can be able to help you. They can be able to help you in setting up some of the routine schedule, walk with you through that of the job itself, and in many cases, when talking more about that of the computers, have them set up so that the maintenance will be done while you out of your office, automatically.
Also, there are some important thing that you need to look out for when it comes to the equipment maintenance software programs. Make sure that it will be very easy to understand and to be learned. If it can be very complicated, then the chances is that you will not be going to take the time to learn it, and then it can be able to waste your money. It is also important that it will be quick and easy to use and does all its job in the very timely manner.
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A Pennsylvania voter told Donald Trump during a Tuesday night town hall to "stop" interrupting her so she could ask him how he would use a second term to protect people like her who have a pre-existing medical condition.
"Please stop and let me finish my question, sir," Ellesia Blaque, a professor at Kutztown University, said as the president tried to talk over her question during an ABC News town hall in Philadelphia. Mr Trump immediately stopped his retort, but did not directly answer her question after she disclosed a serious medical condition she has had since birth.
"You've been trying to strike down pre-existing conditions."
In a @ABC2020 town hall, @GStephanopoulos presses Pres. Trump on claim he's preserving pre-existing conditions—as his administration argues in court against Obamacare, which protects them. Watch the full exchange. pic.twitter.com/GuOyqUKhen
— ABC News (@ABC) September 16, 2020
Instead, the president claimed to be close to rolling out a healthcare plan that would replace the law known as Obamacare.
He has been making that claim for three years, but has failed to produce a package that would pass both chambers of Congress. Last month, he said a new GOP plan would be unveiled in just a few weeks. But his White House has yet to produce such a blueprint, and no Republican lawmakers are running on a new health plan or talking about them in the halls of the Capitol.
The emotional moment was among a handful of times undecided voters pressed him during the Philadelphia event, his seventh stop in Pennsylvania this year alone. He and Democratic nominee Joe Biden are jousting for the key swing state's 20 electoral votes.
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It is unclear whether either major party candidate can put a plan in front of lawmakers that could one day become law.
Read more
'Lasting peace': Self-interested parties and key missing pieces blur Trump's Middle East declarations and risk instability
'Peace without blood all over the sand': Trump jokes about Netanyahu's love of war and both attack 'tyrants of Tehran' at peace summit
Trump says he didn't downplay coronavirus but 'up-played it' despite Woodward tape revelations


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June 1, 2019
Appellate Division, Second Department
Domestic Relations Law 253 does not provide that a defendant must provide plaintiff with a Get
In Cohen v Cohen, ‑‑‑ N.Y.S.3d ‑‑‑‑, 2019 WL 2112972, 2019 N.Y. Slip Op. 03764 (2d Dept.,2019) Supreme Court, in effect, directed the defendant to provide the plaintiff with a Get (a Jewish religious divorce decree) prior to receiving any distribution of marital property. The Appellate Division reversed. It pointed out that Domestic Relations Law 253 does not provide that a defendant in an action for divorce, where the marriage was solemnized by a member of the clergy or a minister, must provide the plaintiff with a Get. Since the court should not have directed the defendant to provide the plaintiff with a Get, the penalties imposed due to the defendants failure to do had to be vacated.
Motion to dismiss under CPLR 3012(b) denied where settlement discussions satisfy requirement of reasonable excuse for failing to serve a timely complaint.
In Patouhas v Patouhas, 2019 WL 2202430 (2d Dept.,2019) plaintiff commenced an action for a divorce on March 1, 2016, by service of a summons with notice upon the defendant. In a notice of appearance dated March 10, 2016, the defendant demand[ed] a copy of the Complaint and all papers in this action be served upon [him] at the address provided. In a letter dated April 1, 2016, counsel for the plaintiff acknowledged receipt of the notice of appearance, noted that the parties had engaged in discussions concerning a resolution of the matter, and requested certain disclosure. Defendant moved by notice of motion dated April 20, 2016, to dismiss the action based upon the plaintiffs failure to serve a complaint in accordance with CPLR 3012(b). On April 26, 2016, the defendant was served with a verified complaint. Supreme Court denied the defendants motion and deemed the complaint timely served on the basis that the short delay was not willful, was a result of settlement negotiations, and did not prejudice the defendant and that the plaintiff demonstrated a meritorious cause of action. The Appellate Division affirmed. It held that to successfully defend against a motion to dismiss for failure to serve a complaint pursuant to CPLR 3012(b), a plaintiff must generally demonstrate that his or her action is potentially meritorious and that he or she has a reasonable excuse for failing to serve a timely complaint. Supreme Court providently exercised its discretion in concluding that the delay caused by settlement negotiations was reasonable since the settlement discussions were undertaken in good faith and the delay was of a short duration. In addition, the plaintiffs submission of a verified complaint was sufficient to satisfy the requirement to demonstrate a [potentially] meritorious cause of action.
Absent statute, party can't be held in Civil Contempt under Judiciary Law 753[A][3] for nonpayment money where enforcement can be accomplished through judgment execution
In Matter of Lew v Sobel, ‑‑‑ N.Y.S.3d ‑‑‑‑, 2019 WL 2202453, 2019 N.Y. Slip Op. 03972 (2d Dept., 2019) the Appellate Division held, inter alia, that Supreme Courts properly denied the fathers motion which were to hold the mother in civil contempt. The mother could not be held in civil contempt for her failure to pay money judgments obtained by the father. Absent statutory provision to the contrary, a party to an action or special proceeding cannot be held in civil contempt for nonpayment of a sum of money, ordered or adjudged by the court to be paid, where enforcement can be accomplished through judgment execution (see Judiciary Law 753[A][3]; Liang v. Yi Jing Tan, 155 A.D.3d 1023, 1024, 64 N.Y.S.3d 556; Cantalupo Constr. Corp. v. 2319 Richmond Terrace Corp., 141 A.D.3d 626, 627, 34 N.Y.S.3d 616).
Oral promise to pay credit card bills during the pendency of action unenforceable
In Novick v Novick, ‑‑‑ N.Y.S.3d ‑‑‑‑, 2019 WL 2202438 (Mem), 2019 N.Y. Slip Op. 03976 (2d Dept., 2019) the Appellate Division affirmed an order which denied the wifes motion to direct the plaintiff to pay her credit card bills during the pendency of the action. It held that the plaintiffs alleged promise to pay the defendants credit card bills during the pendency of the action was unsupported by any consideration and legally unenforceable.
Appellate Division, Third Department
Trial court can adjust equitable distribution award where it determines after trial that temporary maintenance award was excessive.
In Johnson v Johnson, ‑‑‑ N.Y.S.3d ‑‑‑‑, 2019 WL 2127532, 2019 N.Y. Slip Op. 03855 (3 Dept., 2019) the Plaintiff (wife) and defendant (husband) were married in 2003 and had one child (born in 2002). The wife commenced this action for divorce in December 2015. After the trial, Supreme Court, inter alia, ordered the husband to pay child support of $ 723.33 per month effective May 1, 2017, reimbursed the husband for overpaid support and awarded the wife $ 17,031, representing capital contributions from marital assets to two marital businesses.
The Appellate Division observed that after determining the parties respective child support obligations, Supreme Court proceeded to undertake an analysis of what the husbands temporary maintenance and support obligations would have been if the wifes actual salary had been considered during the pendency of the action and determined that the husband had overpaid support in the amount of $ 3,285.52. The parties agreed to the support payments during the pendency of the action, but it was not clear what portion of the agreed‑upon support payments were attributed to child support, and Supreme Courts final child support order was not retroactive to the date the action was commenced. Generally, absent certain circumstances not present here, there is a strong public policy against recoupment of support overpayments. However, a trial court has the authority to adjust an equitable distribution award where it is determined after trial that a temporary maintenance award was excessive. Under the facts and circumstances presented, it found no abuse of discretion in Supreme Courts determination to, effectively, adjust the equitable distribution award to reflect an excessive temporary maintenance award (see Johnson v. Chapin, 12 N.Y.3d at 466, 881 N.Y.S.2d 373, 909 N.E.2d 66).
The Appellate Division found no abuse of discretion in the Supreme Courts award to the wife of the amount that represented her share of the capital contributions to the marital businesses. Generally, the valuation of a business for equitable distribution purposes is an exercise properly within Supreme Courts fact‑finding power to be guided by expert testimony, and an equitable distribution award will not be disturbed absent an abuse of discretion or failure to consider the requisite statutory factors. It was not disputed that marital funds were used to create both businesses and that both were marital property. Although it was apparent that there was some value to the businesses, in the absence of any expert evidence, the court properly declined to value and distribute a share of the marital businesses. Under the circumstances presented, it found no abuse of discretion in the courts award to the wife representing her contributions from marital assets to start the businesses.
May 16, 2019
Appellate Division, First Department
Appellate Division Holds that Husband Not entitled to counsel fee hearing where trial court reviewed underlying bills and motion papers
In Wolman v Shouela, --- N.Y.S.3d ----, 2019 WL 1905670, 2019 N.Y. Slip Op. 03286 (1st Dept., 2019) the Appellate Division affirmed an order which awarded plaintiff wife $ 325,000 in counsel fees to be paid by defendant husband where the parties agreement provided, inter alia, that "the Husband shall pay all of his and the Wife's reasonable counsel fees in connection with" his motion to modify visitation. It rejected the husband's argument that he was entitled to a hearing on the issue of reasonable counsel fees because the billing statements submitted in support of the wife's motion for counsel fees were not reasonably detailed. It found that the trial court, being fully familiar with all of the underlying proceedings, appropriately determined that the fees sought were reasonable by reviewing the detailed billing statements and the motion papers.
Family Court Act § 153 does not authorize the issuance of a warrant for the protective arrest of a child who is neither a respondent nor a witness in a Family Court proceeding
In re Zavion O., --- N.Y.S.3d ----, 2019 WL 1998393 (1st Dept., 2019) the Appellate Division held that Family Court Act § 153, relied on by Family Court, does not authorize the issuance of a warrant for the protective arrest of a child who is neither a respondent nor a witness in a Family Court proceeding for purposes of ensuring the child's health and safety rather than to compel his or her attendance in court. The Court observed that notwithstanding that such protective arrests may have become a practice of Family Court under very compelling circumstances, without more explicit statutory authority it could not endorse the legality of the practice. The issuance of an arrest warrant must proceed from explicit statutory authority. Such was lacking here, as was any authoritative decisional law. The two children in these cases were at high risk of bringing harm to themselves or putting themselves in positions where others may harm them if they were left to their own choice of absconding from foster care facilities to enter life on the streets. The record demonstrated the likelihood that they would run away again if not in a controlled setting of some nature, thereby repeating the cycle of being at risk on the streets. The Court noted that Family Court Act section 153 authorizes Family Court to issue "in a proper case a warrant or other process to secure or compel the attendance of an adult respondent or child . . . whose testimony or presence at a hearing or proceeding is deemed by the court to be necessary . . ." Section 153–a governs the execution of the arrest warrant, which, pursuant to subsection (c) may include "such physical force as is justifiable" by reference to the Penal Law. Although the decision accompanying an arrest in this case contemplated the absence of handcuffs, the statute nevertheless allows for it and a restriction in one case has no effect, of course, in other similar cases. The Court held that the statute does not authorize the arrest of a nonrespondent child who is not needed as a witness in a Family Court hearing or proceeding under these circumstances despite the seriousness of the concerns. These are not juvenile delinquency cases, and despite the court's gloss about securing neither child's attendance at a proceeding was required for testimonial purposes. A textual analysis of the statute did not support a conclusion that an arrest warrant may be issued as a protective rather than a coercive device for testimonial or quasi-prosecutorial purposes. The Court distinguished Family Ct Act § 718 which allows a peace officer to return a runaway child to home but does not authorize an arrest. The court noted that it has rejected a juvenile delinquency adjudication premised solely on contempt pursuant to Family Ct Act § 156 arising from a child's violation of a PINS dispositional order when he absconded from his ACS placement, nor are 22 NYCRR 205.26 or 205.80, addressing children who abscond from facilities to which they have been remanded, available for present purposes. Family Ct Act § 1037, authorizing a warrant to bring a child's parent or guardian rather than the child before the court, also provided no relevant authority.
Appellate Division, Third Department
Family Court lacks subject matter jurisdiction to determine a violation claim with regard to a Florida judgment registered for enforcement without the filing of a petition pursuant to Family Ct Act § 453.
In Matter of Pudvah v Pudvah, --- N.Y.S.3d ----, 2019 WL 1940265, 2019 N.Y. Slip Op. 03414 (3d Dept., 2019) Petitioner (mother) and respondent (father) were divorced by a 2014 judgment of a Florida court. Pursuant to the judgment, the father was obliged to pay the mother $ 84 a month in child support. The father resided in New York and, in 2016, the Florida agency responsible for collecting his child support payments transmitted the judgment and requested that it be registered in this state for enforcement purposes (see Family Ct Act § 580–602[1]). In November 2016, the Support Magistrate issued an order registering the 2014 judgment for enforcement and finding that the father owed arrears. The Support Magistrate also viewed the initial registration request as a "pending enforcement petition" and went on to find, in a February 2017 order, that the father had willfully violated the support order and recommended a suspended sentence of 30 days. The February 2017 order came before Family Court for confirmation (see Family Ct Act § 439[a]) and, although the father pointed out that a violation petition had never been filed. The Department of Social Services (DSS) subsequently filed a violation petition "to clean things up," but the review of the February 2017 order continued. Family Court confirmed the February 2017 order, noting the absence of any formal effort by the father to set it aside. The Appellate Division reversed. It held that Family Court lacked subject matter jurisdiction to issue the order. The Uniform Interstate Family Support Act (see Family Ct Act art 5–B) provides that "[a] registered support order issued in another state ... is enforceable in the same manner and is subject to the same procedures as an order issued by a tribunal of this state" (Family Ct Act § 580–603[b] ). In New York, proceedings for the violation of a support order "shall be originated by the filing of a petition containing an allegation that the respondent has failed to obey a lawful [support] order," and Family Court lacks subject matter jurisdiction to determine a violation claim without that petition (Family Ct Act § 453). DSS eventually did file a petition alleging that the father had failed to comply with the support provisions contained in the 2014 judgment (see Family Ct Act §§ 453[a]; 580–603[b]). This proceeding did not arise out of that petition, however, and was not rendered viable by its filing. Family Court accordingly lacked subject matter jurisdiction to render the appealed-from order, and "the claim that a court lacked subject matter jurisdiction 'may be raised at any time and may not be waived'
Where family court confirms finding of contempt but and arrears are paid prior to prior to the imposition of the sentence, Family Court abused its discretion by issuing the order of commitment.
In Matter of Marotta v Casler, -- N.Y.S.3d ----, 2019 WL 1940244 (Mem), 2019 N.Y. Slip Op. 03417 (3d Dept., 2019) after the father was found to be in willful violation of his court-ordered child support obligation, Family Court confirmed the Support Magistrate's finding of a willful violation and scheduled the matter for a sanctions hearing. At that hearing, the mother's attorney informed the court that the father had recently paid $ 500 to the support collections unit, thereby satisfying his arrears and bringing his account to a credit of $ 61.62. Nevertheless, Family Court sentenced the father to 20 days in jail. The Appellate Division reversed so much thereof as committed respondent to jail. It noted that upon finding that a respondent has willfully failed to obey a lawful order of support, Family Court may "commit the respondent to jail for a term not to exceed six months" (Family Ct. Act § 454[3][a]). "Such a sentence is in the nature of a civil contempt, which 'may only continue until such time as the offender, if it is within his or her power, complies with the support order'. Inasmuch as the father paid his child support arrears in full prior to the imposition of the sentence, Family Court abused its discretion by issuing the order of commitment.
Where party obtains order vacating support order on the ground that personal jurisdiction had never been obtained court must vacate the judgment absolutely, and may not impose conditions upon the vacatur. The support order and all subsequent proceedings are nullified by the determination.
In Matter of Bowman v Muniz, --- N.Y.S.3d ----, 2019 WL 1940201, 2019 N.Y. Slip Op. 03422 (3d Dept., 2019) in April 2016, the mother commenced a proceeding seeking child support. She attempted to serve the father by mail, but the mailing was returned to Family Court marked as unclaimed and unable to forward. In July 2016, the Support Magistrate issued an order of support on the father's default. The father moved to vacate the default order, asserting, among other things, that the mother had failed to serve him and that the court lacked personal jurisdiction. In April 2017, the Support Magistrate issued an order that vacated the July 2016 order of support on the ground that "personal jurisdiction was not obtained over [the father] when the order of support was issued the order restored the mother's petition to the calendar and scheduled a subsequent appearance. Neither the father nor his counsel appeared, and the Support Magistrate issued a second default order restoring the July 2016 order, effective as of the proceeding's commencement date in April 2016. The father filed objections to the second default order contending that the court never obtained personal jurisdiction and requesting vacatur of the second order and all accrued arrears as well as dismissal of the petition. The court denied the objections without prejudice on the basis that the order was entered on default and, as such, the father's remedy was to move before the Support Magistrate to vacate the order. The Appellate Division held that Family Court erred in denying the father's objections. The proper procedure for challenging an order of child support entered on default is ordinarily to move to vacate the order before the Support Magistrate and then, if necessary, to file objections from the denial of that motion. The father had already properly followed that procedure in challenging the July 2016 child support order and had obtained an order vacating the support order on the ground that personal jurisdiction had never been obtained. Upon making such a determination, a court "must vacate [a default] judgment absolutely, and may not impose terms and conditions upon the vacatur". The first order of support and all subsequent proceedings were nullified by the determination that there was no personal jurisdiction, and the Support Magistrate had no further authority. For the same reasons, Family Court was required to dismiss the petition. The court had no jurisdiction over the father and no authority to do anything but dismiss the petition. Accordingly, the second order of support was vacated and the petition dismissed.
Appellate Division, Fourth Department
The Appellate Division, noting this was a fact pattern of first impression, held that the collective provisions of Domestic Relations Law § 76 are limitations on the subject matter jurisdiction of the New York courts in custody matters. Once home state jurisdiction has attached in New York under section 76(1)(a), it continues for six months after the child's permanent departure from New York so long as a parent continues to reside here.
In Nemes v Tutino, --- N.Y.S.3d ----, 2019 WL 1872475, 2019 N.Y. Slip Op. 032365 (4th Dept., 2019) the parties were the parents of a child born in New Jersey on February 18, 2015. Following his birth, the child lived in New Jersey. The mother relocated with the child to Steuben County, New York, and she commenced the custody proceeding on January 8, 2016 in the Family Court. In her petition the mother averred that the child was moved from New Jersey to New York on July 15, 2015. The mother argued the New York courts had subject matter jurisdiction over this matter because "this state is the home state of the child on the date of the filing of the petition." When the father did not appear and could not be reached telephonically the court then dismissed the father's cross petition and granted the mother's petition. The father then moved to vacate the order, arguing that the court lacked subject matter jurisdiction over this proceeding because, at the time of its commencement on January 8, 2016, New York was not the child's "home state" for purposes of the Domestic Relations Law. The mother argued, that the court had subject matter jurisdiction over this proceeding because: "[the father's] own facts indicate that, at most, the child was present in the State of New Jersey for five and a half months. Subsequent to that, the child was then present in the State of New York for five and a half months. Based on those facts, it is undisputed that either state could assume jurisdiction as the child, in fact, did not have a 'home state.'" The court denied the father's motion to vacate.
The Appellate Division, noting this was a fact pattern of first impression, reversed. It observed that DRL §76, which is colloquially known as "home state jurisdiction," applies when New York "is the home state of the child on the date of the commencement of the proceeding, or was the home state of the child within six months before the commencement of the proceeding and the child is absent from this state but a parent ... continues to live in this state" (Domestic Relations Law § 76[1][a] ). When read in conjunction with the statutory definition of "home state" (§ 75–a [7]), jurisdiction under section 76(1)(a) attaches when the child has resided with a parent in New York either since birth or for the six consecutive months immediately preceding the commencement date of a custody proceeding. Once home state jurisdiction has attached in New York under section 76(1)(a), it continues for six months after the child's permanent departure from New York so long as a parent continues to reside here. The three alternative jurisdictional predicates come into play only when another state lacks or waives home state jurisdiction under the uniform criteria established by the UCCJEA and codified in New York as Domestic Relations Law § 76(1)(a). The collective provisions of Domestic Relations Law § 76 are limitations on the subject matter jurisdiction of the New York courts in custody matters. In the absence of an emergency situation (see § 76–c), a New York court "has jurisdiction to make an initial child custody determination only if" one of its enumerated jurisdictional predicates exists (§ 76[1]). A court that makes a custody determination in derogation of section 76(1) has exceeded its subject matter jurisdiction, and the corresponding order is properly vacated under CPLR 5015(a)(4).
The Appellate Division rejected the notion that the father waived any objection to the court's subject matter jurisdiction. It is black letter law that a "defect in subject matter jurisdiction may be raised at any time by any party or by the court itself, and subject matter jurisdiction cannot be created through waiver, estoppel, laches, or consent. It also held that the Court did not have home state jurisdiction over this proceeding as of the commencement date. Under either party's proffered time line, the child had not lived in New York either since birth or for six months as of January 8, 2016. New York therefore was not the child's "home state" on January 8, 2016 and, as the mother now conceded, the court simply did not have home state jurisdiction over this proceeding under section 76(1)(a). Instead of claiming home state jurisdiction under Domestic Relations Law § 76(1)(a), the mother argued that the court had subject matter jurisdiction over this proceeding under the safety net provision of section 76(1)(d), which confers jurisdiction to make custody determinations when, insofar as relevant here, "no court of any other state would have jurisdiction under the criteria specified in [section 76(1) ] (a)." The Appellate Division rejected the mother's reliance on section 76(1)(d). Under the special UCCJEA definition of "home state" applicable to infants under six months old (Domestic Relations Law § 75–a [7]; NJ Stat Ann § 2A:34–54), New Jersey was the child's "home state" between the date of his birth (February 18, 2015) and the alleged date of his move to New York (July 15, 2015). Because the UCCJEA confers continuing jurisdiction on the state that "was the home state of the child within six months before the commencement of the proceeding" if a parent lives in that state without the child (Domestic Relations Law § 76[1][a]; NJ Stat Ann § 2A:34–65 [a][1] ), it follows that New Jersey retained continuing jurisdiction of this matter until January 15, 2016, i.e., six months after the child's alleged move to New York on July 15, 2015 and one week after the proceeding was commenced on January 8, 2016. Thus, New York lacked jurisdiction under section 76(1)(d) because New Jersey could have exercised jurisdiction under the criteria of section 76(1)(a) on the date of this proceeding's commencement (see NJ Stat Ann § 2A:34–65 [a][1] [identical New Jersey provision to Domestic Relations Law § 76(1)(a)]). Section 76(1)(d) applies only when no state could have exercised jurisdiction under the criteria of section 76(1)(a) at the commencement of the proceeding, and that is simply not the situation here.
The Appellate Division also rejected the mother's argument that the court had subject matter jurisdiction because "New York was the state in which the child was present at the commencement of the proceedings." That contention is interdicted by Domestic Relations Law § 76(3), which says that the subject child's "[p]hysical presence ... is not necessary or sufficient to make a child custody determination." Indeed, by examining the court's jurisdiction through the lens of the child's physical presence instead of his "home state," the mother would have us resurrect a jurisdictional modality that has been defunct for over 40 years.
Fourth Department Holds that enforcement of the parties' choice of law agreement provision in favor of New Jersey was unenforceable where it would violate New York's strong public policy enunciated in Child Support Standards Act.
In Matter of Brooks v Brooks, 2019 WL 1871032 (4th Dept.,2019) the parties 2011 New Jersey judgment of divorce incorporated but did not merge the parties' separation agreement, which in pertinent part stated that, "[n]otwithstanding the future residence or domicile of either party, this Agreement shall be interpreted, governed, adjudicated and enforced in New Jersey in accordance with the laws of the State of New Jersey." In 2016, when the parties and their children were all living in New York, the mother filed a petition in Family Court seeking modification of the support order. During that proceeding, the mother also registered the support order in that court (see generally Family Ct. Act § 580–601 et seq.). The Support Magistrate held that a modification of the support order was proper under the terms of the agreement, which permitted the parties to seek modification of the father's child support obligation every two years, and calculated the amount of child support pursuant to New Jersey law. The mother filed objections asserting that New York law should govern that calculation (first objection), that the matter should be remitted for a hearing to recalculate the father's child support obligation (second objection), and that she was entitled to attorney's fees. Family Court denied the objections, concluding that, pursuant to the choice of law provisions of Family Court Act § 580–604, "the law of the issuing state (New Jersey) governs the nature, extent, amount and duration of current payments under a ... support order [that has been registered in New York]."
The Appellate Division reversed and granted both objections. It concluded that the court had jurisdiction pursuant to the Uniform Interstate Family Support Act ([UIFSA] Family Ct Act art 5–B) to resolve the issues raised and objections (see § 580–613[a]). The UIFSA unequivocally provides that where, as here, the parents reside in this state "and the child does not reside in the issuing state, a tribunal of this state has jurisdiction to enforce and to modify the issuing state's child support order in a proceeding to register that order" (§ 580–613[a]; see also 28 USC § 1738B [e][1]; [i] ). It held that New York law had to be applied to determine the father's child support obligation inasmuch as the statute further provides that "[a] tribunal of this state exercising jurisdiction under this section shall apply ... the procedural and substantive law of this state to the proceeding for enforcement or modification" (Family Ct. Act § 580–613[b] ). It also held that section 580–604 did not control inasmuch as that section applies to proceedings seeking to enforce prior child support orders or to calculate and collect related arrears and does not apply to proceedings, as here, seeking to modify such an order.
The Appellate Division further held that the Support Magistrate erred in determining that the choice of law provision in the separation agreement controlled over the statute. Although courts will generally enforce a choice of law clause " 'so long as the chosen law bears a reasonable relationship to the parties or the transaction', courts will not enforce such clauses where the chosen law violates " 'some fundamental principle of justice, some prevalent conception of good morals, some deep-rooted tradition of the common weal' " (Loucks v. Standard Oil Co. of N.Y., 224 N.Y. 99 [1918] ). New York has a "strong public policy that obligates a parent to support his or her child" (Matter of Vicki B. v. David H., 57 N.Y.2d 427 [1982]; see Schaschlo v. Taishoff, 2 N.Y.2d 408 [1957]). Under New York law, child support obligations are required to be calculated pursuant to the Child Support Standards Act ( [CSSA] Family Ct. Act § 413), and " '[t]he duty of a parent to support his or her child shall not be eliminated or diminished by the terms of a separation agreement' " (Keller–Goldman v. Goldman, 149 A.D.3d 422, 424,[1st Dept. 2017], affd 31 N.Y.3d 1123 [2018] ). In addition, whereas New Jersey law provides that child support obligations generally end when a child reaches the age of 19 (see N.J. Stat Ann § 2A:17–56.67), in New York, "[a] parent's duty to support his or her child until the child reaches the age of 21 years is a matter of fundamental public policy". Under the circumstances, and given that the parties did not have a valid agreement to opt out of the CSSA (see generally Domestic Relations Law § 240[1–b] [h]), it concluded that enforcement of the parties' choice of law provision would violate those strong New York public policies. It reversed the order insofar as appealed from, granted the mother's first two objections, and remitted the matter to Family Court for further proceedings.
Family Court
Full time undergraduate child's participation in the Air Force Reserve Officer Training Corps did not constitute entry into the military service for purposes of emancipation
In Matter of J.M., v. T.A. — N.Y.S.3d ----, 2019 WL 2017922, 2019 N.Y. Slip Op. 29133 (Fam.Ct., 2019) the Family Court denied the objections to the Support Magistrates determination that the child was not emancipated. The Court held that the child's participation in the Air Force Reserve Officer Training Corps ( 'ROTC') did not constitute entry into the military service. The child was a full time undergraduate student attending a university outside of New York State and was employed on a part-time basis and resides with the Respondent during academic breaks. The Support Magistrate found a distinction exists between enlistment in military service and participation in a Reserve Officer Training Corps program for purposes of determining whether or not a child is emancipated. Thus, the Petitioner had a continued obligation to provide financial support for the child to the custodial parent. The Court noted that the child was not considered a regular member of the military. She was not provided health care, a salary, payments for room and board, tuition, nor other types of allowances by the Air Force. (Zuckerman v. Zuckerman, 154 A.D.2d 666, 546 N.Y.S.2d 666) The Court also found that the contract entered into by the child established membership in the ROTC program but that such participation does not equate to "entry into military service". It is only upon fulfilling the contract terms by continuing military training, remaining a full-time student, pursuing a degree in ICAD (Business Management), passing the Air Force Officer Qualifying Test and graduating college, would the child then be commissioned and thus, emancipated. The Court found that the child was not emancipated as none of the enumerated events had occurred which would qualify the child as having entered into active military duty service.
The child was attending college on a full time basis, relied upon the Respondent-Mother for health insurance coverage and was assisted by the custodial parent in obtaining educational loans as well as being provided with monies for motor vehicle insurance and repair costs. Family Court held that the income derived as the result of a 'stipend' in the amount of $ 450.00 per month through ROTC and part-time employment did not warrant a finding of economic independence. The Court found the child was not economically independent nor self-supporting in order to render a finding that she was emancipated. (Matter of Drumm v. Drumm, 88 A.D.3d 1110, 931 N.Y.S.2d 180; Matter of Cedeno v. Knowlton, 98 A.D.3d 1257, 951 N.Y.S.2d 412).