The Legal Intelligencer Blog

Wettick Puts Gunn Case to Use

 A trial court has used its own reasoning on severance and stay to deny bad faith discovery in an underlying contract dispute. On Sept. 9, in Wutz v. State Farm Insurance Co., Judge R. Stanton Wettick denied a plaintiff discovery in a bad faith case relating to State Farm’s evaluation of the claim. All parties agree that information sought was relevant only to the bad faith case.  State Farm, for its part, further argued that to allow discovery relating to State Farm’s evaluation of the underlying UM/UIM claim, State Farm would be as unfairly prejudiced as would “the defense in a football game [being required] to furnish its defensive formation for the upcoming play to the Plaintiff before the Plaintiff selected the play that it would call.”  Wettick agreed with State Farm, and ruled pursuant to his earlier ruling in Gunn v. The Hartford Insurance Co., and disallowed the discovery. 

Wettick recalled that a court will not necessarily permit discovery of information in the files of the insurance company relevant to the bad faith claim, and that the insurance company should have an opportunity to show that the discovery of certain information relevant to the bad faith claim will unfairly prejudice the insurance company.  Thus, Wettick in the case before him refused to allow discovery of State Farm’s evaluation ranges relating to the underlying claim, as well as the factors what were considered in evaluating the claim.

In terms of the mechanics of his ruling, the judge denied the plaintiff’s motion for in camera review of the documents, and ruled that at the beginning of trial State Farm’s counsel should have ready an unredacted copy of the claims activity log and should furnish the documents to plaintiffs immediately after the beginning of jury deliberations in the UIM claim.  The order also noted that State Farm, inasmuch as it was not asserting advice of counsel in the bad faith claim, retained the right to assert attorney-client privilege and protect documents accordingly. 

The ruling by Wettick in the Wutz case was an early one in the wake of his ruling in Gunn, and one in which insurers may be able to protect from discovery in a UIM case, claims evaluation and mental impression which is relevant to a bad faith claim are certainly not relevant to the underlying UIM claim.  From this writer’s experience, rarely is a bad faith complaint limited to solely a claim of undervaluation.  Therefore, Wettick’s ruling in Wutz could have considerable impact in bad faith discovery going forward.

Charles Haddick 

Are Illegal Aliens Eligible for Unemployment Benefits?

The answer to this question seems pretty straightforward.  Aliens who are not authorized to work in the United States are not eligible for unemployment insurance benefits, or UI, in any state.  Unfortunately, over the years, illegal aliens have been paid millions of dollars in UI benefits nationwide. The reason for this is quite simple.  Many of these illegal aliens were not identified by state Employment Security Agencies as illegal aliens who were not eligible for such benefits.

If there were merely a way to screen claimants’ Social Security numbers adequately, the SESAs would be able to quickly identify which claimants are illegal aliens and are therefore not eligible to receive UI benefits.  There is a system in place called E-Verify, which is a voluntary program in all states except Arizona.  The system is coordinated by the Department of Homeland Security and the Social Security Administration as a means of determining the validity of a person’s Social Security number (i.e., whether the actual SSN is a real number or whether the SSN matches the employee’s name or that of another person).  Many employers now use this voluntary system as a means of determining a potential employee’s eligibility to legally work in the United States.   

In a similar fashion, if the SESAs used E-Verify, or some other comparable system, as a means of determining whether a claimant who is seeking UI benefits is eligible to legally work in the United States and is therefore also eligible to receive UI benefits, then certainly the abuses of illegal aliens seeking UI benefits would be curtailed.  Millions of dollars have been erroneously paid to illegal aliens who applied for UI benefits by state agencies that were unable to verify the SSNs used by these illegals.   If a system was in place to adequately screen these claimants’ SSNs, then certainly the benefits could have been paid to unemployed workers who were truly eligible to receive such benefits because they were legally eligible to work in the United States (e.g., U.S. citizens, permanent residents, foreign workers with Employment Authorization Documents under eligible visas).  Now, for foreign workers who are legally eligible to work in the United States under non-immigrant visa categories such as the H-1B, H-2A and H-2B, the question as to whether those individuals are eligible for UI benefits is another discussion altogether (which I will reserve for another day).  For now, it is clear that illegal aliens are not eligible for UI benefits.  Unfortunately, because there is no mandatory system used by the various states to determine the validity of the claimants’ SSNs, the abuses may continue (and millions of dollars lost) unless an effective screening method is employed, in my opinion. 

Rob C. Tonogbanua, Esq.
Dickie McCamey & Chilcote, P.C.
www.dmclaw.com

Two Confirmed for Philadelphia Common Pleas Bench

By Amaris Elliott-Engel
Of the Legal Staff

Attorneys Robert P. Coleman, an associate with Segal McCambridge Singer & Mahoney, and Donna M. Woelpper, who is sitting as a juvenile court master in Philadelphia family court, have been confirmed by the state Senate to serve as judges on the Philadelphia Court of Common Pleas. Coleman and Woelpper are also part of an unopposed slate running in the fall for 10-year terms on the court, so they're both on target to serve the next decade as judges.

Coleman and Woelpper were among the top vote-getters in the Democratic primary, and Robert J. Coleman, Coleman's father, told The Legal previously that it is traditional for the candidates who come in at the top in the Democratic primary to get judicial appointments if they become available.

The top four vote-getters in the May 19 Democratic primary were Coleman; Angeles Roca, who is already sitting on the court filling out a judicial vacancy; Diane Thompson, who ran without the endorsement of the city Democrats; and Woelpper. There were 22 candidates in the primary.

The state Senate also confirmed Johnny J. Butler to a second interim term on the Commonwealth Court. Gregory V. Hines and Jeffrey J. Valocchi were confirmed as magisterial district judges in Chester County.

September 25, 2009 – More Thoughts from the G-20 – Random Musings

Sometimes when you spend too much time alone in a deserted office overlooking the special security zone of a city hosting a summit conference or in a hotel room close to an airport, your mind begins to wander and you engage in the process of what can be described as random musing.  On the other hand, when I was in school, teachers more accurately described the random musing process as daydreaming when I should have been concentrating on something more practical, like the declination of Latin nouns as used in some passage from a minor Roman author or memorizing the upper reaches of the Periodic Table.

In any event, here are some random musings about the G-20 summit taking place in Pittsburgh today.

I was in Paramaribo, Suriname a few weeks ago in connection with a matter involving the trading prices of Surinamese rice and shrimp on the world market.  In Suriname, there is a minimum-wage law and a prohibition on the use of child labor.  But many other countries producing the same commodities do not have the same policies.  What can be done at a meeting like this one to help industries in countries like Suriname compete more effectively in the world market?

I have been in many meetings over the years where some egocentric lawyers and their clients sometimes seem to ramble on for hours making comments that are irrelevant or antagonistic or merely innocently inane.  Time is consumed as people effectively “talk past” each other.  Ultimately, with patience and after hard work and too many cups of coffee and stale bagels, it is possible to get the other side to begin to focus on the real issues in the transaction and reach a deal.  Can that happen at a summit or is the meeting no more than a show intended to give an illusion of meaningful discussion? Is it intended to do no more than provide publicity for a deal that has been struck in pre-conference conferences or is this itself a pre-conference conference for the next G-20 summit?

What makes 20 the correct number?  Why not 19 or 21?  The perhaps apocryphal story is that the pitcher’s rubber on a baseball diamond is 60 feet and six inches away from home plate because the man with the tape measure misunderstood an instruction to make it 66 feet.  Did some diplomat or finance minister a few years ago misunderstand a suggested number in the same way as the man laying out the baseball diamond misunderstood the word sixty-six? 

What makes the Europeans convinced that a limit on executive compensation for bankers will prevent any number of problems in banking?  Prime Minister  Angela Merkel of Germany and President  Nicolas Sarkozy of France are both strong proponents of such a proposal.  Will it work or will it simply result in intelligent people finding creative ways to skirt the rules?  Would adoption of such a rule be analogous to the building of an economic Maginot Line designed to prevent the last crisis and not particularly useful in a new crisis?

I had an interesting discussion with two journalists from a prominent European television network this morning at breakfast.  They commented on the limited extent that demonstrations and protests actually have taken place here.  As seasoned veterans of countless international conferences and the concomitant protests, I had the impression that they have concluded that the protesters here in Pittsburgh are not playing in the same league as the much more experienced protesters that they have seen in other cities around the world.  It was rather like hearing a serious European football fan commenting on the quality of play by an American soccer team.

We have all sat in meetings and wondered about some of the other persons in the room.  Does that happen at the G-20 among the heads of state?  In other words, are they like the rest of us?  Does a prime minister sit at the table and wonder about a truly important question such as why did that other prime minister across the table choose to wear such an unattractive tie?  Does a president sit there and wonder where the other president with whom he just shook hands got such a bad haircut?  Will the finance minister at the next table notice if I yawn?  How long is it until the next coffee break?

I passed a sign painted on one of the temporary security walls in downtown Pittsburgh.  It was beautifully rendered with some real artistic skill.  The sign said that Africa is part of the global economic solution and entreated the conferees at the summit to not forget Africa.  Will Africa be the forgotten continent at the end of the conference?

Is a summit conference like this one really designed to produce a meaningful result or will it in the end be a series of high-level random musings?

 
Thomas R. Schmuhl, Duane Morris

September 25, 2009 – More Thoughts from the G-20 – The Equinox

While driving from Philadelphia to Pittsburgh on Wednesday afternoon, I was able to watch the course of the sun through the afternoon and early evening sky as I headed west.  Doing so caused me to think about the end of summer and the start of fall.  As we all remember from our seventh grade science classes, the end of summer in the northern hemisphere means that the northern autumnal equinox has just occurred.

The northern autumnal equinox took place this year at 9:19 p.m. UTC on Sept. 21. (UTC, or Universal Coordinated Time, is essentially the same thing as Greenwich Mean Time, but it sounds much fancier and more precise.)  In other words, at 9:19 p.m. London time on Monday, Sept. 21, 2009, there was a kind of astronomical balance in the world’s skies. Days and nights were essentially of equal length on both sides of the equator.  No nation or place on Earth received dramatically more hours of daylight than any other place. 

But the equinox is a fleeting moment.  It does not last for long, and it is produced only by the cycles of nature.  Governments cannot make an astronomical equinox happen no matter how often their leaders meet and speak in summits.

It is only a slightly easier task that the heads of state and finance ministers gathered here for the G-20 are trying to accomplish.  The balances that they are seeking are elusive. 

Importing nations want exporting nations to balance their exports with more domestic consumption.

Creditor nations want debtor nations to achieve a better balance between the need to borrow and the need for fiscal restraint.

Some nations may want to balance the utility of continuing use of the U.S. dollar as the world’s reserve currency with the possible benefit of creating a new kind of monetary instrument.

Some want to balance a perception of climatic needs against the world’s growing economic needs for energy consumption.

Many Europeans want to offset the dangers of further risk-caused problems in the banking industry that may have resulted in part from excessive compensation of banking executives by the development of strong and enforceable restraints on such compensation.

Developing countries want economic policies that will serve as a counterbalance to the daunting problems that they face in trying to grow their national economies.

Of course, balance is always difficult to achieve and, once it is achieved, it takes enormously hard work to maintain it.  It will be interesting to see the communiqués that are eventually issued by the participants at the end of this G-20 summit.  Where will the balance be found in those diplomatically worded statements?

Will they indicate any real progress toward the meaningful economic balance that each participating nation says that it is seeking?  Or by the time the northern vernal equinox arrives in March, will the results of this G-20 meeting be accurately described and understood by reference to the famous line from the Peter Sellers movie “Being There?”: “No matter what you are told, there is no such thing as an even trade.”
 
Thomas R. Schmuhl, Duane Morris 

September 2 5 , 2009 – More Thoughts from the G-20 – The Dream Assignment

Buried in the innumerable articles on this week’s G-20 economic summit in Pittsburgh, I noticed an offhand comment upon which only a lawyer might fixate.  It was something to the effect of the following: “The G-20 operates without a permanent secretariat or staff and does not have a formal set of rules or by-laws.”

Most normal ambitious people in the world would focus on the first part of the comment.  Their thoughts would turn to envisioning themselves as an important member of the G-20 staff or perhaps even as the first “Permanent Secretary General and Majordomo of the G-20” with a spacious office overlooking the gardens of a converted chateau somewhere on the outskirts of an appropriate city like Paris and an expense account befitting the first permanent official planner of the entire world’s economy.  Heads of state and finance ministers might change with the political winds, but the first Permanent Secretary General of the G-20 would be just that – permanent. 

However, lawyers are not normal ambitious people.  We do not focus as mere ambitious people do on the first part of the comment.  We do not care terribly much about the office in the chateau or the expense account or even the permanency of the post.

Instead we focus on the second part of the comment.  We focus on the brief clause about there being no formal set of rules or by-laws.  That is the kind of thing that grabs our attention. 

What an assignment!  We could undertake to write the corporate governance document for the functional equivalent of the world’s economic board of directors.

An assignment like that has real importance. Let yourself dream of it for a moment.

Presiding over countless drafting sessions involving lawyers from twenty different legal systems writing in almost as many languages.  Heroically sitting through all-night debates about the differences between theories of comma placement in the rule establishing the procedures applicable to decisions involving economic emergencies.  Resolving the diplomatic intricacies of whether to number the rules with Arabic numbers or Roman numerals by suggesting that they be identified by letters using only those letters that are found in the Esperanto alphabet.  Finding a way to perhaps even ultimately create a special international court of arbitration (based in the Hague of course) as a peaceful means of interpreting the hundreds of confusing rules that we have written. 

Those are things that appeal to lawyers.  The fact that normal people could not care less about them is irrelevant.  If normal people want to be extra normal, they can go to law school like we did.

Then, of course, we cannot forget the ultimate value that would come as a result of having focused on the truly important task of writing the rules, namely the business development value. 

Just imagine the laudatory comments that could appear on the firm’s website:  “In addition to his active practice with respect to the allocatur and certiorari petitions to the Supreme Court involving parking ticket appeals in cities of the fourth class, Mr. _____ was the principal draftsman of the G-20’s bylaws which determine the future of the world.”  That is the kind of record that could guarantee success in any competition to get a new client. 

It’s a good thing that normal people do not think the way we do.  They might try to take away our dream assignment.  Just imagine it – “Draftsman of Bylaws for the World.”

Thomas R. Schmuhl, Duane Morris 

September 24, 2009 – More Thoughts From the G-20 – The Commute

As lawyers, we sometimes undertake unusual assignments for clients.  However, my unusual assignment for today was not on behalf of a client. 

Instead it was to get from a hotel near the Pittsburgh Airport to the Duane Morris office on the 50th floor of 600 Grant St. in Pittsburgh.  Normally, this would be a simple task of taking a cab or car and driving to the heart of the city’s famous Golden Triangle and riding an elevator to the 50th floor.  In light of the traffic restrictions prevailing today and the somewhat dire sounding warnings coming from various national and local media about anarchical protestors, I made the sensible decision to drive several miles to the terminus of a light rail line into the city. 

When I left my hotel I had all the typical thoughts that enter the mind of an experienced international corporate lawyer heading to an office tower in a major city.  Can I still run fast enough to evade an angry protestor concerned about the status of unknown species of flora and fauna on the steppes of Central Asia?  Will my dry cleaner be able to effectively remove the paint or other noxious liquid that will probably be thrown at me as I walk past an angry crowd?  Will the police confuse me with someone who is seeking to overthrow the government simply because the real culprit also wears glasses and, like me, does not have an overabundance of hair?  Why did I ever return my gas mask to the supply sergeant when I left the Army? 

As is usually the case when we get “psyched up” about a meeting or a trip, the reality turns out to be quite different from what we imagined.

The tram ride through the suburbs where the leaves have just begun to take on their autumnal colors, a week or two before the same thing will happen in Philadelphia, was quiet and efficient.  The streets were filled with police and troops and they outnumbered the small number of residents and visitors who were quietly standing around with cameras waiting to take a snapshot of a passing president or prime minister.  Even Pittsburgh’s famous rivers were filled with police boats with flashing lights. 

The only loud noises were coming from the sirens of motorcades.  (Obviously the sirens are needed as an extra precaution in case someone inexplicably fails to notice the enormous number of flashing lights on the police motorcycles that precede the official cars of the motorcade.)  In fact, there are so many police motorcycles here that I have almost concluded that the real purpose of this event is to provide a special subsidy to Harley Davidson.

The streets are also filled with signs saying that “Pittsburgh Welcomes the World.”  It is a sad commentary on the state of the world that the leaders who will gather here will not really be able to respond to that sincere welcome as they will, of necessity, be surrounded by a temporary addition to the Pittsburgh streetscape, namely chain link fence barricades seven feet tall that form a wall surrounding areas closed off to even pedestrians.  The barricade required for security is also a barricade in many respects between the people who come to work every day in this city and in cities like it around the world and the leaders who will be shaping the economic policies that will have an impact on the residents of Pittsburgh and all those other cities and towns of the world.

-- Thomas R. Schmuhl, Duane Morris      

September 24, 2009 – More Thoughts from the G-20

We have all heard the phrase so often that it has become a bit of a cliché. Yet, like most such phrases, it is a cliché because the thought at its core makes sense and thus makes it something that merits repetition.

The phrase in question is, "Think globally and act locally."

Here in Pittsburgh for two days as the G-20 summit takes place, the sonorous speeches and compromised communiqués released to the media will be focused on the global issues of world economics. However, as practical lawyers, we know that behind the scenes there are real ramifications of a summit meeting like this one that already will have forced some good lawyers to think through some issues in a local sense and provide some good practical advice to their clients.

In addition to the practical advice that the city's and state's lawyers will have had to give to the police and National Guard about the constitutional aspects of crowd control, public safety and demonstrators, other lawyers will have had to think about such issues as the employment law aspects of a summit meeting.

For example, in a city that will experience the inherent tensions between the right of Americans to demonstrate versus the need to safeguard the lives of 20 heads of state and their delegations, the seemingly mundane task of getting to and from work in some parts of the city will be difficult and perhaps even dangerous. As an employment lawyer, how would you advise a client to deal with its employees during the summit?

To answer the question, I decided to start by speaking to someone with experience on the somewhat esoteric topic of summit meeting employment law. So I called Jon Heuvel of Penningtons in London, the city where the last G-20 meeting was held in April. Jon is the head of his firm's employment team and the chairman of the skills and employment forum at the London Chamber of Commerce & Industry. His firm issued a client alert in advance of the London G-20 meeting in which he advised that under English law, "businesses have a duty to ensure the health and safety of their staff and that they should not either directly or by implication force people to travel to work against the advice of the authorities and thereby put them at risk." He said that in England, not observing that duty could cause an employer to be held liable in the event that an employee were to be injured. As a result, Jon said managers need to be flexible in such situations.

Interestingly, when the April summit arrived, Jon's own firm remained open, while some other large firms in the immediate vicinity closed their offices for a few days (at least one of which apparently may have done so after reading a copy of Jon's client alert).

I also spoke with my partner, Jane Dalton, the former chancellor of the Philadelphia Bar Association and an employment law specialist. Jane said it is important for employers to have an emergency plan so that their employees know in advance what to do in various situations, and employers need to have a means of communicating with their employees whether the emergency plan is in effect. Echoing Jon's words, Jane also said employers have a duty to handle a situation like the G-20 in such a manner that their employees will not have to come to work unless they can do so without being recklessly endangered and that they not be asked to leave the workplace if doing so would put them at risk. Jane added that employers might also have to make special arrangements with respect to workers with disabilities.

In summary, the need to act locally often results from occasions of global thinking.

-- Thomas R. Schmuhl, Duane Morris

September 23, 2009 – Thoughts from the G-20

It's 10:00 p.m. on the evening of Wednesday, Sept. 23, 2009, and I am in a hotel room near the Pittsburgh Airport. Tomorrow the leaders of the G-20 member nations and various other invited countries and groups will descend on this city, accompanied by their large retinues and the cameras and microphones of the world's media, to attend an economic summit meeting at which they will discuss the state of the world's economy and assess the progress (or lack thereof) that has occurred since they last met in April in London.

To a certain extent, it is rather difficult to keep track of the G-20, which has gone through a number of incarnations over the years. At various points, its predecessors have been known as the G-22, the G-33, the G-7 and the G-8. I understand that officially it is supposed to be a collection of the finance ministers and central bank governors of the 20 largest national economies. Of course, not all of the 20 largest economies are actually included in the G-20 (for example, Spain is not in the list of the chosen), so that there can be some regional balance (for example, Argentina will be there) and so that the European Union as a whole can be at the conference table (thereby giving some of its individual countries, such as France and Germany, a kind of double representation). In any event, the gross national products of the economies that will be represented here comprise approximately 80 percent of the world's gross global product.

So that interested readers will not have to look up the membership list of the G-20 club, it is the following: Argentina, Australia, Brazil, Canada, China, France, Germany, India, Indonesia, Italy, Japan, Mexico, Russia, Saudi Arabia, South Africa, South Korea, Turkey, the United Kingdom, the United States and the European Union.

It is also interesting to note that the heads of state of the various members have started to attend these meetings, in addition to the finance ministers and central bank heads. Clearly, the heads of state know this is a good opportunity to be photographed with each other that they do not want to forego in favor of their finance ministers. Thus, Pittsburgh is the venue for a heads of state meeting of the G-20, as opposed to a meeting of finance ministers.

The meetings will take place on Thursday, Sept. 24, and Friday, Sept. 25. The heads of state will then depart, and life in Pittsburgh presumably will return to normal. However, the next two days promise to be memorable ones in the history of this city, which has already witnessed some significant events, including the French and Indian War, the Homestead Strike of 1892 and Bill Mazeroski's home run at Forbes Field to win the 1960 World Series for the Pirates over the New York Yankees.

-- Thomas R. Schmuhl, Duane Morris

The New Economic Realities of Family Court

I have had a hiatus from The Legal Intelligencer blog, but I am now comfortably situated at Duane Morris and Eckert Seamans Cherin & Mellott is lucky to have my friend, Mike Meehan, and many of my former Wolf Block partners as members.

Thanks to Meehan, I recently spoke with Judge Margaret Murphy at Family Court in Philadelphia. Murphy explained to me that the economy has had a big impact on decisions in Family Court.  Just as the economy has hit us all, parties in Family Court have suffered from layoffs, work hour reductions, changes in benefits and decreased retirement assets. Murphy said she isn’t necessarily seeing a change in the volume of cases, which always seems remarkably high.  Rather, the economy has changed the types of the disputes that she hears relating to child and spousal support and equitable distribution.

It’s not just that support payments are being reduced because of income changes. Other aspects of support are also affected by economic circumstances. By way of example, an issue arising with frequency is school choice.  Parents unable to agree on the school that a child will attend often seek judicial intervention.  In the past, arguments focused on what type of private or parochial school would most benefit the child.  With layoffs and changes in income, Murphy is seeing more parents financially unable to pay for any private school.  In other settings, one parent may agree to provide support while a child attends college.  More and more parents are unable to afford this form of agreed upon support.  Sometimes it is a simple inability to pay because of a lost job.  Other times, a lender may refuse to allow a parent to co-sign a student loan because of the parent’s decreased income or because real estate values are so depressed as to make the parent non-creditworthy.

The loss of medical coverage, either because of a lost job or because job benefits are cut, is occurring more frequently.  For example, if a parent loses a job and thus loses health coverage, the cost of COBRA can be exorbitant, particularly when coupled with a loss of income.  The loss of medical coverage affects not only well-care checkups of dependent children, but other types of treatment as well, such as orthodontic treatment.  While Murphy routinely refers dependent children to the CHIP program, parents may have little choice but to go without health care or elective medical treatment for children. 

According to Murphy, the economy also is changing the dynamics of equitable distribution calculations.  Businesses that were at one time flourishing, or at least profitable, may be subject to significant reductions in value, thereby changing the equation for the division of marital property. 

The same is true for depressed real estate values.  In the past, refinancing was a method of choice to divide the marital home, allowing one spouse’s interest to be purchased by the other through refinancing.  With decreased property values and less credit available, refinancing is not always an option.  As a consequence, Murphy said she is seeing more marital homes being marketed for outright sale.  The sale of the marital home in a depressed market brings on its own set of problems, as sales may be slow and at reduced sale prices.  Some families may own vacation property, which replicates the problems in the division of the marital home.  The vacation home market is challenging for the additional reason that the market is driven by buyers who can afford the luxury of a second home – a relative rarity in this economy.  Families also have been hit hard by the expenses that come with second homes, such as increased taxes in some states and the costs of maintaining these properties.

All of us shuddered to watch our retirement accounts decline last year.  Murphy calls these passive declines.  Passive declines in IRAs and 401K plans have had a decided effect on equitable distribution.  In the past, if one party to the marriage had established a sizeable retirement account, alimony could be reduced or the marital estate partitioned based on the assets in the account.  Although few and far between, Murphy has seen parties claim that these declines were not passive, and that the accountholder should have foreseen the economic collapse and invested more conservatively.

In short, the economy is having a significant impact in the way in which issues are heard in Family Court. As the economy establishes its footing, no doubt these issues will be revisited under yet another set of changing economic circumstances. 

Charlotte E. Thomas
Duane Morris LLP
cthomas@duanemorris.com