Appellate Court of New Jersey approved for publication an appeal filed by Ronald G. Lieberman on Dec 5, 2016

In sum, the Appellate Division held that regardless of the parties’ agreement for a final restraining order to continue, if it was void from the start, it was void for settlement purposes. Thus, the Appellate Division agreed with me that judges must find that an act of domestic violence occurred and that victim needs protection even if the defendant consents to the entry of the final restraining order. “A domestic violence final restraining order may not be entered by consent or without a factual foundation.”


Date Published: June 5, 2017

Written by: Ronald Lieberman

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