Defining your Marital Lifestyle in Divorce Post-Pandemic: Longing for (or Moving on from) the Life that Once Was

Alan R. Feigenbaum

In one of its hallmark songs, the Rock and Roll Hall of Fame band AC/DC proclaimed, “money talks.” For better or for worse, those two words find a way of ringing true in many facets of life, and contested divorce litigation is no exception. Yet during the year-long, or perhaps longer now, pandemic, if you find yourself in the middle of a divorce proceeding you might be questioning whether or not money talks anymore or has instead been tucked away until a time when normal life resumes.

The subject of your lifestyle during a marriage is bound to come up in divorce when you are quarreling over issues of child support and/or spousal support. For example, in the child support arena, when considering whether or not to award support above New York’s statutory cap for combined parental income, the law in New York considers the standard of living that a child would have enjoyed had the family unit not dissolved.

Then there is spousal support, which your lawyer will tell you, if being up front can be an ocean of uncertainty. You may have heard that New York, some years ago, established formulas for determining spousal support. But in high-net-worth cases, with incomes above and beyond the statutory cap for spousal support, those formulas can quickly give way to a focus on many factors including, you guessed it, the marital lifestyle (a fancy way of describing how you and your family lived economically during your marriage).

What do we mean by living, or lifestyle? What type of residence do you have and in what neighborhood? Do your children attend public or private schools? Does your family vacation, and if so, how many times per year and at what cost? Where do you dine out, and how frequently? At which stores do you buy clothing for you and your children? Do you belong to a gym or other private club, and if so, is it “high end”? Or, maybe you have a personal trainer at home?

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Blank Rome Matrimonial Recognitions Roundup

Stacy D. Phillips

Another new feature here is a roundup of the recent awards, recognitions, and other important accomplishments of Blank Rome’s Matrimonial & Family Law attorneys from around the country.

Lois Liberman on New York State Bar Association Panel

March 2021 – Lois J. Liberman spoke at the New York State Bar Association (“NYSBA”) webinar A Day in the Life: Personal Perspectives from General Counsels and Partners, held Tuesday, March 30, 2021. Lois and her co-panelists provided their personal perspectives on what it takes to excel in the GC and Partner roles, the paths one can follow, and the challenges that may come along.

Stacy Phillips Panel Moderator for Margaret J. Weber Distinguished Lecture Series 

March 2021 – Stacy D. Phillips was selected to serve as panel moderator for Women in Leadership: Navigating through Power Structures, Personal Challenges, and a Pandemic, part of the Pepperdine Graduate School of Education and Psychology Margaret J. Weber Distinguished Lecture Series. The program was held online via Zoom on Thursday, March 11, 2021.

The Art of Schmoozing

March 2021 – Morgan F. Mouchette served as a panelist for the New York City Bar Association New Lawyer Institute program, The Art of Schmoozing. She joined the other panelists in discussing how to develop schmoozing skills, providing tips on how to effectively and professionally speak to new contacts, colleagues, and even potential mentors in the virtual landscape as well as in person.

Podcast: Divorce During Covid

February 2021 – Stacy D. Phillips served as a guest speaker on America Connects, a podcast hosted by radio host and public relations professional Rob Dalton. In the episode, Stacy discusses the legal issues and difficulties with navigating through a divorce during the pandemic.

Ernestine Mings Selected as 2021 Leadership Council on Legal Diversity Pathfinder 

February 2021 – Ernestine J. Mings, an associate in New York, has been selected to join the 2021 Leadership Council on Legal Diversity (“LCLD”) Pathfinder Program. This hallmark program is designed to provide diverse, high-potential, early-career attorneys with practical tools for developing and leveraging professional networks through relationship-building skills, foundational leadership skills, and an understanding of career development strategies applicable to both in-house and law firm practice. 

Alan Feigenbaum Featured as Speaker for Celesq® AttorneysEd Center Live Webinar

February 2021 – Alan R. Feigenbaum, of counsel in New York, was a featured speaker for the Celesq® AttorneysEd Center live webinar, “Parenting Amidst Divorce in New York—Will Parenting Ever Be ‘Routine’ after 2020?” which was held on February 26, 2021. The hour-long CLE program explored the complexities of contested custody proceedings during the COVID-19 pandemic.

Will the Law Firm Diversity Push Falter as Protests Fade? 

February 2021 – Morgan F. Mouchette was interviewed by Bloomberg Law on whether law firms will follow through on pledges to improve diversity and inclusion, months after the mass protests over racial justice and equity. “What has helped me to stay in this industry and at my firm has been strong relationships with advocates. They consistently look out for me and ensure that I have the things I need to succeed in this corporate environment,” Mouchette said. 

Michelle Gervais Named Among America’s Top 100 High Stakes Litigators 

January 2021 – Michelle M. Gervais has been named to America’s Top 100 High Stakes Litigators, an annual directory that recognizes the nation’s most exceptional attorneys in high value, high stakes litigation matters. To be considered for selection to America’s Top 100 High Stakes Litigators®, an attorney must have litigated (for either plaintiff or defendant) a matter with the fate of a business worth at least two million dollars at stake.

Article: A Decade Later: Are We Far Afield From ‘Fields v. Fields’? 

January 2021 – Alan R. Feigenbaum authored a New York Law Journal article looking back over the ten years since the Fields v. Fields decision: “It has been just over a decade since the Court of Appeals issued its decision in Fields v. Fields, 15 N.Y.3d 158 (2010). Fields ignited a discussion about how courts would, going forward, assess separate property claims. More specifically, the decision in Fields indicated at least to some degree that perhaps some assets (namely, a marital home) are so fundamental to the concept of marriage as an economic partnership that a spouse’s separate property claim to an asset of that sort—no matter how strong—would have its limits.”

Ory Apelboim Among 13 Attorneys Elected Partner at Blank Rome 

January 2021 – Ory Apelboim, an attorney in New York, has been elected partner at Blank Rome LLP effective January 1, 2021. He concentrates his practice on complex matrimonial and family law matters for high-net-worth individuals, including divorce, property distribution, child custody, spousal and child support, and marital agreements.

Podcast: Maintaining Wealth in Divorce with Michelle Gervais, Partner at Blank Rome 

December 2020 – Michelle M. Gervais served as a guest speaker on In House Warrior, a daily podcast presented by the Corporate Counsel Business Journal. In the episode, Michelle discusses the complex nature of maintaining wealth in divorce and other setbacks with host Richard Levick of LEVICK. She also shares her wisdom to our inclination to engage the triumph of hope over experience.

Blank Rome Named a “Most Admired Law Firm” by Los Angeles Business Journal

December 2020 – Blank Rome LLP has been named a “2020 Most Admired Law Firm” by the Los Angeles Business Journal as part of a special supplement recognizing the “top law firms to work for in Los Angeles.” The annual list honors regional law firms that excel in key workplace factors, including company culture, employee compensation, benefits, programs, diversity and women’s initiatives, and work-life balance. The Firm’s Los Angeles office has grown significantly over the years and boasts a robust team of 10 Matrimonial & Family Law attorneys, including four partners.

Michelle Gervais Featured as Speaker on Hot Topics on Prenups and Postnups December 2020 – Michelle M. Gervais served as speaker for the session, “Hot Topics on Prenups and Postnups,” at the 28th Annual Nuts & Bolts of Family Law Seminar, presented by the Dade County Bar Association’s Family Courts Committee and the Dade Legal Aid / Put Something Back Program, held Friday, December 4, 2020.


On behalf of Blank Rome, I continue to wish you good health and safe surroundings. As always, my colleagues and I stand ready to assist you with all of your legal concerns.

Partner Spotlight: Tampa

Stacy D. Phillips

In honor of her city’s recent string of professional sports championships over the past year, this edition of Partner Spotlight highlights my Tampa Matrimonial & Family Law colleague and friend—Michelle M. Gervais. Michelle is a trusted adviser to high-profile individuals, athletes, and celebrities, as well as businesses and financial institutions, in the areas of sports and entertainment, matrimonial and domestic relations, commercial and business litigation, and consumer finance. Please enjoy learning more about her.

Michelle M. Gervais, Tampa
“She Likes Being Known as ‘the Fixer.’”



 

Michelle M. Gervais is a fiercely loyal and tenacious advocate for her clients with a uniquely wide range of experience across the worlds of sports and entertainment, matrimonial and domestic relations, commercial and business litigation, and consumer finance law. Growing up in rural Michigan, Michelle always knew she was destined to be a lawyer and has found fulfillment in the legal profession’s ability to help people both in business and relationships by bringing them together when they are happy and keeping them apart when it no longer works. She began her career in Miami at a boutique matrimonial law firm before moving to Carlton Fields and then Duane Morris. In 2015, Michelle joined Blank Rome’s Tampa office shortly after several of her former colleagues founded the Blank Rome’s Pittsburgh office. During the COVID-19 pandemic, Michelle has been surprised by the emotional dynamics that have led to less cost-benefit litigation decisions and more relentless fights to the finish. However, Michelle has found that the recent transition to remote video hearings has allowed her to be more effective and efficient for her clients because she no longer must travel to appear in person in court cases around the country. And because she can also more easily take pro bono cases outside her jurisdiction, she appreciates that access to justice has become stronger than ever.

To learn more about Michelle and the role football has played in her personal and professional career, read her feature article, My Winning Playbook: Fading into the Fix, in the 2021 edition of NFL THREAD’s The Playbook (Volume 3).

Keeping Your Sanity during a COVID Custody Fight

Stacy D. Phillips

As we mark one year since the first shelter-in-place orders were imposed, there is practically no part of divorce that the COVID-19 pandemic has not impacted. In too many ways, the frustration at our lack of control over the events of this last year and now well into the first quarter of 2021 has exacerbated the emotional, psychological, and legal wars of separation and divorce. A particularly active battlefield where control becomes a constant tug-of-war has been the highly charged disagreements that come with fights over child custody.

With tensions as high as ever, I have taken note that many of my divorce cases that would normally settle are not settling—not just the ones involving custody. Moreover, as tensions are higher than usual, parents who are separating or divorcing are now, all too often, using disagreements over their children to score points against their ex-partner. Making matters worse, these unhappy couples have often been stuck in the same household without the normal boundaries between life and work or they may be living in separate homes but do not look at COVID-19 protections the same way, causing an accelerated unraveling.

Keeping sane during a custody fight is not easy, and especially so during COVID-19. It requires positive thinking, setting aside pettiness, and finding creative solutions that are in the best interest of your children. Despite the ongoing uncertainties of managing this school year, securing vaccine appointments for loved ones, and worrying about our health and safety, there are many ways to keep your cool during one of life’s most stressful and unfortunate circumstances.

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Blank Rome Matrimonial Recognitions Roundup

Stacy D. Phillips

A new feature here is a roundup of the recent awards, recognitions, and other important accomplishments of Blank Rome’s Matrimonial & Family Law attorneys from around the country.

U.S. News & World Report – Best Lawyers® Highly Ranks Blank Rome’s Matrimonial & Family Law Group

November 2020 – The 2021 “Best Law Firms” survey by U.S. News & World Report – Best Lawyers® has highly ranked Blank Rome’s Matrimonial and Family practice group in Los Angeles and New York City.

Stacy D. Phillips Named 2020 “Top Women Lawyer in California” by Daily Journal 

November 2020 – Stacy D. Phillips has been named to the Daily Journal’s 2020 list of Top Women Lawyers in California, which recognizes regional women attorneys who have made a difference to their clients, their firms, and their profession. Stacy has been recognized every year since the list’s inception in 2003.

Nicky Rooz Receives Certification of Recognition at New York State Courts Pro Bono Awards Event

October 2020 – Anita (Nicky) Rooz, an associate in New York, received a Certificate of Recognition for dedicated service to the New York State Courts Access to Justice Program at a virtual pro bono awards event on Thursday, October 29, 2020. The certificate was presented by the New York Unified Court System Office for Justice Initiatives, the New York State Bar Association, and the New York County Lawyers Association.

Michelle M. Gervais Named to List of “500 Most Influential Executives” by Florida Trend

September 2020 – Michelle M. Gervais, a partner in Tampa, has been named to the “Florida 500” for the second year in a row. Published annually as a special supplement of Florida Trend magazine, the notable “Florida 500” list highlights the most influential executives in different economic sectors throughout the state.

On behalf of the Blank Rome family, I wish you and yours a healthy and peaceful holiday season.

 

Partner Spotlights: Los Angeles

Stacy D. Phillips

Blank Rome has one of the top Matrimonial & Family Law practice in the country, with 10 attorneys in Los Angeles, 20 attorneys in New York, one attorney in Tampa, and two attorneys in Philadelphia. In this new feature, I will spotlight some of my partners from across the Firm. In this edition, I wanted to highlight two of my Los Angeles Matrimonial & Family Law colleagues—Ashley Silberfeld and Kevin B. Martin. Many of you reading this know that I was very close to my father. It struck me that Ashley and Kevin are also close to their fathers, who are also ethical, learned attorneys like my father. Their fathers also created children that are similarly ethical people (mensches). Please enjoy learning more about them.

Ashley Silberfeld, Los Angeles
“A go-to person for anyone who has a thorny issue.”

Ashley Silberfeld is an experienced civil litigator and fierce advocate with trial skills that are unique among family lawyers. Ashley followed her father’s footsteps into the legal profession, beginning her career as a toxic tort defense attorney at Steptoe & Johnson. She later decided to transition to matrimonial & family law to help fight for the vulnerable and protect the things most important to them. As the child of a divorce herself, she knows firsthand what families are going through during difficult times. What Ashley finds most rewarding is when she gets to see her clients and their children thrive in their new lives. And as the single mother of a toddler, she also deeply understands the challenges that families with young children are experiencing during the COVID-19 crisis. Ashley even recently conducted a successful argument at a virtual hearing while her daughter sat on her lap.

Kevin B. Martin, Los Angeles 
“Attacks legal problems like a dog with a bone.”

Kevin B. Martin is a dynamic litigator who is also skilled at forensically analyzing balance sheets and other financial and business records. Kevin began his legal career at Alschuler Grossman Stein & Kahan, a boutique civil litigation firm, before following in his father’s footsteps to practice law at the Securities & Exchange Commission (“SEC”) in its enforcement division. He later left the SEC to return to Alschuler Grossman Stein & Kahan and then Bingham McCutchen where his practice focused on SEC defense and corporate internal investigations. Kevin then started his own, first of its kind, litigation insurance program that he eventually sold to a publicly traded insurance carrier. After Stacy Phillips represented him in his own custody battle where, together, side by side, they succeeded in obtaining 50-50 custody of Kevin’s two daughters (who are now in college), he decided to help other families in crisis by “paying it forward” and returning to practice with Stacy as a family law attorney. His unique set of professional and personal experiences allows him to see cases with a different lens that is uncommon in the family law bar. Kevin also brings insights and understanding of the financial side of divorce, while, at the same time never losing sight of the emotional toll this type of litigation has on his clients. Although he always prefers amicable resolution, where the parties retain most control over their own destinies, if the need arises due to unsurmountable legal disputes, Kevin fights tenaciously side by side with his clients, as Stacy did for him.

Promoting Peace during the Holidays

Stacy D. Phillips

There is almost nothing else that brings underlying family tensions to a head quite like the holidays. For separating, separated, divorcing, and divorced families, this time of year can be highly emotional and stressful. The primary reasons that personal relationships break down—mismatched value systems and power struggles over things big and small—are often on display at the Thanksgiving table or when planning Christmas/Hanukkah gifts for your children or in deciding which side of the family to visit at which time.

We can anticipate that, much like everything else 2020 has impacted, this year’s family in-person and virtual gatherings may be uniquely high on tension and disagreement. Many people are anxious about their health amid another rise in COVID-19 cases or uncertainties surrounding their personal financial situations in the current economy. Add in the political and social unrest in this country and you have a recipe for feeling like you have a lack of control over what is happening in your world.

Like addressing the emotional, psychological, and legal wars of separation and divorce, finding peace during the holidays often requires responding rather than reacting, positive thinking instead of negative strategies, and finding new peaceful solutions to ongoing differences. Despite the political, cultural, and public health uncertainties, there are many opportunities to making the 2020 holiday season a peaceful one.

Reach Out & Be Kind

At the beginning of the COVID-19 lockdowns, people were more likely to empathize with each other, make sacrifices, and reach out to each other with a heightened sense of humanity to say: “we are in this together.” Now that we are nearly nine months into the pandemic, many people, especially those that are separating and divorcing, are fighting over things that are not quite earth-shattering and hating each other with a vengeance.

This holiday season remember that people are struggling, whether impacted by COVID-19 or those who lost work. In addition to focusing on what you can do for others by making that extra donation to the food bank and expressing gratitude to doctors, nurses, first responders, and essential workers, call and check in on family and friends. They may be having a tougher time with loneliness than anyone realizes. When you look back on this time many years from now, you will want to remember the holidays as a positive time when you could focus on others and set aside the strife.

Cooperate to Make New (or Simplify Old) Traditions

If there was ever a year to be flexible and cooperate with your ex for the good of your children, 2020 is it. Many of us will experience frustration that, because of COVID-19, we cannot have the same large family gatherings or have our children easily split time between both parents.

Although nobody knows when the pandemic will end, we will all have to find patience and adapt to the current circumstances. That does not mean old traditions need to end and we should resign ourselves to being alone. Instead, there are new opportunities to see relatives from both your and your ex’s families via Zoom and find creative ways to share time with old friends and family members and carry out old traditions together virtually. Make time for your ex’s family and in-laws if you can, even if only online. When deciding who to have at your table (safely!) or which relatives to invite to Zoom, be as inclusive as possible.

Take Care of Yourself COVID-19 has taken a heavy toll on us physically and psychologically. Not only has the disease directly impacted many of us, but we have all been hit with fatigue and stress. Many of us have been rightfully concerned about others and may be caring for someone else during this time, but do not forget that your physical and mental health matters too. Find time to engage in more of what you love about the holidays. Continue to get regular and proper exercise to vent frustration, tune up your mind and body, and give yourself more energy to face challenges. When you have taken care and control of yourself, it is that much easier to let the happiness and positive energy from the holidays happen.

Mediation for Family Law Disputes—Is It a Cure-All, a Band-Aid Precursor to Litigation, or Something in Between?

Alan R. Feigenbaum

If during the ongoing COVID-19 pandemic you, and/or your spouse, have made the decision to part ways, then there’s a good chance you have considered or read about mediation as a potential way forward. Mediation, including online mediation, is seemingly all the buzz right now. It has become an integral part of the judicial systems in California, Florida, New Jersey, Pennsylvania, and New York.

Think before you act. All else being equal—if you were asked whether you prefer to “mediate” or “litigate,” you probably would choose the former. What you should consider, carefully, is whether or not your family dynamic and your relationship with your soon-to-be ex-spouse is suitable for mediation.

What are the factors to consider when you make your decision? What due diligence should you undertake before saying “yes” or “no” to mediation? Cost is an obvious factor, but let’s dig deeper. Start by asking a simple question: how did your spouse treat you during the marriage—emotionally, financially, as a parent, as a partner? If the answer to all of these categories is resoundingly awful, then think twice about mediation. It may be emotionally taxing to dredge up what has played out during your marriage when you make this calculus, but the alternative is to dive right into the process, cold. Continue reading

Perhaps Your Biggest Asset Following Divorce: The Bank Account of Emotional Capital

Alan R. Feigenbaum

A necessary part of every divorce action is financial disclosure in the form of a “Statement of Net Worth,” in which a client details their assets, liabilities, and monthly expenses. When clients send the form back, we attorneys are laser-focused on whether each and every asset and liability has been disclosed: bank accounts, business interests, real estate, whole life insurance, loans, mortgages, etc.

What you will not find on any Statement of Net Worth is what I have come to call the Bank Account of Emotional Capital. I’m sure you’re wondering how we go about defining this mysterious, intangible asset. Very simply: what you have in this invisible but quite essential account represents your ability to transition to the next chapter of life—after divorce.

Each divorce case is unique. Everyone’s familial circumstances are unique. There will always be divorce cases that do not lend themselves to a resolution prior to trial. That said, in many divorce cases, the time will come when the attorney can see an “Exit” door for their client, meaning a path to resolving the dispute, well before trial is on the horizon. When that happens, the opportunity to make a sizeable deposit to a client’s Bank Account of Emotional Capital is there for the taking. Continue reading

Coronavirus Reality Checks: Surviving Divorce or Separation during the Pandemic

Marilyn B. Chinitz

Amid these unusual times, everybody has on their minds the ripple effects of COVID-19 because we know it has infected everything. Divorcing individuals are not immune. Those contemplating and those in the middle of divorce need to know that COVID-19 will impact their lives in previously unimaginable ways. It will affect your marital estate, investment portfolio, real estate, retirement assets, business assets, and your most important asset—your children.

Underlying conflicts often emerge when couples are together in close proximity of each other for long periods of time. The abrupt and drastic lifestyle change of staying home may have caused more harm than good for couples already dealing with conflict in their marriage. Social distancing, working from home, having limited mobility, and caring for children full time without traditional support systems have become the norm, and it seems that it’s going to be for the foreseeable future. While quarantine is hard on everybody, it’s even harder on those whose marriage have already cracked. It’s not COVID-19 that’s ruining your marriage, but it can cause a divorce to happen a lot sooner.

In my recent webinar, Lunch & Learn: Successfully Navigating Divorce and Separation Amid COVID-19, I was joined by the dynamic family therapist Dr. Kathryn Smerling as we highlighted potential solutions and strategies for unprecedented financial issues, custody and visitation, and family mental health during these challenging times.

If you’re considering divorce, you must examine your options and have reality checks:

Reality Check #1 ‒ Assemble Your Team

While everybody is at home there is an opportunity to contact different attorneys, speak to them, and do your research. Given that a lot of people are working from home and practicing social distancing, you have more time to do your research online, including looking into potential divorce attorneys, therapists, financial experts, and financial advisors.

Whoever ends up on your team, it takes a village to successfully navigate your way through a divorce. You must work collaboratively with your team to decide which battles are worth fighting and what is best to let go of.

Reality Check #2 – Obtain Financial Records & Know Your Financial Picture

A significant part of divorce hinges on dividing assets. Because most of us are home more often than ever now, your spouse is likely at home working as well. Chances are the mail that was going to the office is coming to the home. That mail could include brokerage account statements, financial statements, and other financial documents that are now being sent to your home.

This is an opportunity.

Don’t view it as being a snoop. Instead, look at it as becoming educated on your own financial situation. This is an appropriate time to learn your income from all sources, what debts you have, and get familiar with your expenses. Look for bank statements, canceled checks, credit card statements, tax returns, and life insurance policies. Remember that you’re free to open the mail when it’s addressed to you. And in some cases, go into your spouse’s home office, and even before uttering any word about “divorce,” say you’re concerned because there’s a pandemic going on and want to know what we have.

Reality Check #3 – Get Acquainted with a Forensic Accountant & a Financial Wealth Manager

Couples who are contemplating a divorce or are in a middle of one, have a lot of questions about the COVID-19 economic crisis’ impact on support requirements, property division, and the valuation of assets. Virtually every individual worldwide who has money invested in the markets has now seen their accounts fluctuate dramatically from the February 2020 high (on Valentine’s Day, believe it or not).

Uncertainty will be ongoing, causing values to seesaw for a very significant time and making it difficult for attorneys to predict exactly what’s going to happen. There’s no question that negotiating your financial settlement during this turmoil is going to get more difficult and complex. For business owners, timing may be important in asking for appraisals while those assets have lower values, but they will also have resources available such as the Paycheck Protection Program and Federal Reserve lending programs.

Markets have historically bounced back from deep declines, so we need to brace ourselves for a significant period of low valuations before the markets fully recover. However, like everything else, this is an opportunity for rebalancing and tax planning opportunities. Find the best financial experts you can if you want to maximize the amount you will walk away with in a divorce.

Reality Check #4 – Expect Modifications Aplenty Going Forward

In the post-COVID world, I anticipate there will be more custody and support modifications. There will likely be quite a few cases where a modification of custody will be justified when a parent has intentionally withheld a child from their ex-spouse. In pending cases, where an ex-spouse may have lost income, there will be support modifications. It’s important to realize that merely losing your job doesn’t mean you’ll be entitled to a downward modification of support and relief from your obligations. If you have other assets sitting somewhere, you’ll be required to use those them to support your children. Many valuations will likely need be redone as well.

And as courts begin to emerge with large backlogs, there are opportunities to work collaboratively with other attorneys. With difficulties getting judges on the phone, instead attempt to first work out the issues that come up with other attorneys. Given the backlog, judges won’t want to hear mundane issues—only important things impacting peoples’ lives.

I invite you to watch and share the recording from the recent webinar for further details on these vital topics and concerns, and to hear Dr. Smerling’s perspectives on handling pandemic anxieties and difficult situations involving children during these treacherous times. Contact me if you have questions about navigating the challenges of separation or divorce amid COVID-19.

Please click here to listen to the recording of our Lunch & Learn webinar.