Child Relocation 2023

Last Updated September 12, 2023

USA - New York

Law and Practice

Authors

Nicholas W. Lobenthal
Jaime L. Weiss

Teitler & Teitler LLP is a 14-lawyer New York City litigation boutique with more than 50 years’ experience of counselling clients in navigating complex high-stakes disputes and crisis management situations. With extensive trial experience, Teitler & Teitler LLP stands ready to try the most difficult and important cases in New York state and federal courts. The firm has advised and represented domestic and foreign individuals and entities in family law, trust and estates, and commercial matters. This includes settlement and trial of ultra-high net worth matrimonial actions involving complex financial, business valuation, and custody issues, as well as the negotiation of pre- and postnuptial agreements.

New York does not by statute affirmatively delineate parental rights and powers. Nonetheless, “it is the natural right, as well as the legal duty, of a parent to care for, control and protect his child from potential harm, whatever the source” (Roe v Doe, 272 N.E.2d 567, 570 (NY 1971)). “Parents have a fundamental right to raise their children in the manner they choose, subject to the state’s ability to intervene to protect children in narrow circumstances” (Matter of Athena Y, 161 N.YS.3d 335, 337 (App Div 3d Dep’t 2021)) ‒ see also Matter of Hofbauer, 393 N.E.2d 1009, 1013 (NY 1979) (“every parent has a fundamental right to rear its child”) and Troxell v Granville, 530 US 57, 65 (2000) (“the interest of parents in the care, custody, and control of their children... is perhaps the oldest of the fundamental liberty interests recogni[s]ed by this court”).

Thus custodial parents may make decisions regarding – among other things – a child’s education, religious upbringing and training, and healthcare. They also have the right to discipline the child and promote the child’s welfare. In certain instances, parents are vicariously liable for destruction of property caused by children aged between ten and 18 years.

When parents fail to exercise their prerogatives, Section 1011 of the New York Family Court Act (FCA) permits the court to protect children from injury or mistreatment and safeguard their physical, mental and emotional well-being ‒ even over the objections of a parent.

Parents are responsible for the financial support of a child until age 21 ‒ see Section 413(1)(a) of the FCA (“the parents of a child under the age of twenty-one years are chargeable with the support of such child”). Section 240(1-b)(c)(2)-(3) of the NY Domestic Relations Law (DRL) and Section 413(1)(c)(2)-(3) of the FCA concern prorating obligation between parents. Additionally, Section 240(1-b)(c)(5) of the DRL and Section 413(1)(c)(5) of the FCA require parents to provide health insurance benefits.

New York does not impose requirements on a birth mother beyond those delineated in 1.1 Parental Responsibility. Both parents have the right to seek custody.

New York does not impose requirements on a father beyond those delineated in 1.1 Parental Responsibility. Both parents have the right to seek custody.

Where clear and convincing evidence demonstrates an agreement to conceive and raise a child together, the non-biological, non-adoptive partner has standing to seek custody ‒ even when the parties to a familial relationship are not married to each other.

See 1.1 Parental Responsibility. Both parents have the right to seek custody, regardless of whether or not they were married to each other at the point of the conception or birth of the child. Note that a child born of parents who at any time before or after the birth of the child are married to each other is presumed to be the legitimate child of the marriage.

As previously mentioned in the preceding sections, both parents have the right to seek custody. “Parents” is not exclusively defined as biological parents; parties to a familial relationship (even if not married), who agree to conceive and raise a child together, both have standing to seek custody (see 1.4 Requirements for Non-genetic Parents).

“A proper test for standing ensures equality for same-sex parents and provides the opportunity for their children to have the love and support of two committed parents” (Brooke SB v Elizabeth ACC, 61 N.E.3d, 498–99 (NY 2016)) – see also Weichman v Weichman, 158 N.Y.S.3d 154, 156–57 (App Div 2d Dep’t 2021), which vacated a portion of an interlocutory judgment that barred a lesbian parent from “tak[ing] the child to a place or expos[ing] the child to an activity that violates rules, practices, traditions and culture of the child’s Orthodox Jewish Chasidic Faith”). KG v CH, 79 N.Y.S.3d 166, 174 (App Div 1st Dep’t 2018) found that Brooke SB v Elizabeth ACC’s requirement that a plan to conceive and raise a child together “be in effect at the time a child is identified does not add any heightened barrier for same-sex families”.

Similarly, adoption is available to individuals and cohabiting couples, both heterosexual and same-sex – the procedures are no different. Section 110 of the DRL includes “any two unmarried adult intimate partners” on its list of persons permitted to adopt. The New York Governor’s Approval Memo of 17 September 2010 contains a “delineated list of those who may adopt” that “includes same-sex couples”. “By replacing references to ‘husband and wife’ [in prior statute] with the gender-neutral term ‘married couple’, this measure will help ensure that all married couples, regardless of their sexual orientation, have equal rights to adopt a child together” (Memo in Support, Chapter 509, 2010 NY Laws).

An adoption must be in the child’s best interests. Pursuant to Sections 112 and 115 of the DRL, a person who wants to become an adoptive parent must file a petition specifying ‒ inter alia – the following:

  • whether they are of full age;
  • whether they are married or unmarried and, if married, whether they are living together as husband and wife;
  • the religious faith of the petitioners;
  • the religious faith of the adoptive child and that of the child’s parents as accurately as can be ascertained;
  • the manner in which the adoptive parents obtained the adoptive child;
  • the period of time during which the adoptive child has resided with the adoptive parents;
  • the occupation and approximate income of the petitioners; and
  • whether the adoptive parent or parents has a history of child abuse and maltreatment.

Both parents are guardians of their children ‒ with equal powers, rights and duties – and there is no prima facie right to sole custody of children in either parent. Under Article 3 of the Convention of 25 October 1980 on the Civil Aspects of International Child Abduction (the “1980 Hague Convention”), to which the USA is a party, the removal or retention of a child is unlawful if:

  • it is in breach of the rights of custody attributed to a person under the law of the state in which the child was habitually resident immediately before the removal or retention; and
  • at the time of the removal or retention those rights were actually exercised or would have been so exercised but for the removal or retention.

Thus, as a practical matter, the other parent’s consent is required to allow relocation.

Within the context of a matrimonial action, the issue of relocation can be resolved by trial pursuant to Section 240(1)(a) of the DRL. Outside a matrimonial action, the issue of relocation can be resolved by habeas corpus petition under Section 70 of the DRL or Section 651 of the FCA.

Relocation requires evaluation of “all the relevant facts and circumstances... with predominant emphasis being placed on what outcome is most likely to serve the best interests of the child... These factors include, but are certainly not limited to, each parent’s reasons for seeking or opposing the move, the quality of the relationships between the child and the custodial and non-custodial parents, the impact of the move on the quantity and quality of the child’s future contact with the non-custodial parent, the degree to which the custodial parent’s and child’s life may be enhanced economically, emotionally and educationally by the move, and the feasibility of preserving the relationship between the non-custodial parent and child through suitable visitation arrangements” (Tropea v Tropea, 665 N.E.2d 145, 150‒51 (NY 1996)). See the New York Trends and Developments chapter in this guide for further discussion.

The child’s wishes and feelings are not controlling but are entitled to great weight where the child’s age and maturity would make the child’s input particularly meaningful. See the New York Trends and Developments chapter in this guide for further discussion.

Generally, the older the child, the greater weight the child’s wishes and feelings carry. Some recent examples include:

  • Cortes v Bryant, 188 N.Y.S.3d 186, 188–89 (App Div 2d Dep’t 2023) – the trial court properly exercised discretion in not conducting in camera interview with children aged five years and three years;
  • Morgan v Eckles, 185 N.Y.S.3d 790, 793 (App Div 2d Dep’t 2023) – the preferences of children aged 12 and 13 years were entitled to great weight;
  • Daniel G v Marie H, 151 N.Y.S.3d 475, 477, 483 (App Div 3d Dep’t 2021) – owing to their “advanced age”, a 14-year-old child’s wishes were entitled to great weight; and
  • Anwar RR v Robin RR, 151 N.Y.S.3d 214, 215–16, 218 (App Div 3d Dep’t 2021) – the wishes of children 13 and 15 years of age were entitled to great weight.

See the New York Trends and Developmentschapter in this guide for further discussion.

In general, siblings should be kept together. However, the rule is not absolute and may be overcome where the best interests of each child lie in residing apart.

Loss of contact with the left-behind parent is a factor. See the New York Trends and Developments chapter in this guide for further discussion.

“The rights and needs of the children... must be accorded the greatest weight” (Tropea v Tropea, 665 N.E.2d 145, 150 (NY 1996)). See the New York Trends and Developments chapter in this guide for further discussion.

Grounds for opposition to relocation include:

  • the relocation not being economically necessary;
  • the relocation not enhancing the children’s lives socially and economically; and
  • negative impact on the parent opposing relocation.

See the New York Trends and Developments chapter in this guide for further discussion.

The parties may be required to pay their own attorney’s fees and, in some instances (where there is a financial disparity), those of the other party. Parties’ prior settlement agreements may also contain fee-shifting provisions, which are generally enforced. One or both parties may be required to pay the fees of an attorney or guardian ad litem for the child, as well as the fees of ancillary professionals such as forensic mental health evaluators.

The applicable statutes impose the following deadlines:

  • to determine a motion for emergency relief ‒ 20 days after the motion is submitted for decision (Civil Practice Law and Rules (CPLR) 2219(a));
  • to determine any other motion ‒ 60 days after the motion is submitted for decision, CPLR 2219(a);
  • for a judge to render a decision after a trial ‒ 60 days after the cause or matter is finally submitted for decision (CPLR 4213(c)); and
  • for a referee to render a decision after a trial ‒ 30 days after the cause or matter is finally submitted for decision (CPLR 4319).

However, because of heavy court calendars in certain parts of New York, these deadlines are often not met.

The authorities do not favour either parent when determining the outcome of an application. Each application is decided on its own facts.

The answers provided throughout 2.3 Application to a State Authority for Permission to Relocate a Child do not change if the proposed is not a new country but, rather, within the USA.

Although kidnapping is a felony, Section 125.30 of the Penal Law provides that it is an affirmative defence if:

  • the defendant was a relative of the person abducted; and
  • the defendant’s sole purpose was to assume control of the person abducted.

A “relative” is defined in Section 135.00 of the Penal Law as “a parent, ancestor, brother, sister, uncle or aunt”.

The defence “was designed to treat more leniently the tragic taking of a child by a relative, often a parent, because of a custody battle” (People v Brown, 702 N.Y.S.2d 739, 741 (App Div 4th Dep’t 2000)). The defence is not available, and the defendant would therefore be guilty, if the defendant’s conduct “is so obviously and unjustifiably dangerous or harmful to the child as to be inconsistent with the idea of lawful custody” (People v Leonard, 970 N.E.2d 856, 859 (NY 2012)). In People v Leonard, the defence was not available to the defendant father who – when confronted by police at child’s home – held a knife to the child’s chest and throat and threatened to kill child if police came closer.

Under federal law, “whoever removes a child from the United States, or attempts to do so, or retains a child (who has been in the United States) outside the United States with intent to obstruct the lawful exercise of parental rights shall be fined under this title or imprisoned not more than three years, or both” (Section 1204(a) of Title 18 of the US Code). Pursuant to Section 1204(c) of Title 18 of the US Code, it is an affirmative defence if the defendant:

  • acted under a valid court order granting the defendant legal custody or visitation rights in effect at the time of the offence;
  • was fleeing an incidence or pattern of domestic violence; or
  • the defendant had physical custody of the child pursuant to a court order granting legal custody or visitation rights, failed to return the child because of circumstances beyond the defendant’s control, and the defendant notified or made reasonable attempts to notify the other parent or lawful custodian of the circumstances within 24 hours after the visitation period expired and returned the child as soon as possible.

If the country to which the child has been removed is a party to the 1980 Hague Convention, or if the child is removed from another US state to New York State, a proceeding may be brought under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The UCCJEA is codified in New York at Sections 75 to 78-a of the DRL, which includes enforcement under the 1980 Hague Convention. The Hague Convention is codified in the USA at Sections 9001 to 9011 of Title 22 of the US Code. The UCCJEA is also available if the child has been removed to a country that is not a party to the 1980 Hague Convention.

The USA is a signatory to the 1980 Hague Convention.

  • The US Department of State administers the Hague Convention Attorney Network to assist low-income parents in treaty-partner countries in finding attorneys to bring 1980 Hague Convention cases in US courts.
  • Annual reports on international child abduction prepared by the US Department of State are available on its website.
  • Whether return is immediate or defences are accepted depends on the particular case.
  • The UCCJEA may be used to seek return of an abducted child to a non-signatory country. Further legal information for parents can be found on the US Department of State website.
  • The timescale for 1980 Hague Convention applications is set forth in the country-by-country breakdowns provided in the above-mentioned annual reports. The expenses will vary from case to case.

This section is not applicable to the USA, which is a signatory to the 1980 Hague Convention.

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Trends and Developments


Authors

Nicholas W. Lobenthal
Jaime L. Weiss

Teitler & Teitler LLP is a 14-lawyer New York City litigation boutique with more than 50 years’ experience of counselling clients in navigating complex high-stakes disputes and crisis management situations. With extensive trial experience, Teitler & Teitler LLP stands ready to try the most difficult and important cases in New York state and federal courts. The firm has advised and represented domestic and foreign individuals and entities in family law, trust and estates, and commercial matters. This includes settlement and trial of ultra-high net worth matrimonial actions involving complex financial, business valuation, and custody issues, as well as the negotiation of pre- and postnuptial agreements.

Introduction

New York State courts will implement shared custody and access when it is both feasible (ie, the parties are capable of co-parenting with one another) and also in a child’s best interest. Especially in the context of shared parenting arrangements, requests to relocate can – in the words of New York State’s highest court some 25 years ago – “present some of the knottiest and most disturbing problems that our courts are called upon to resolve. In these cases, the interests of a custodial parent who wishes to move away are pitted against those of a non-custodial parent who has a powerful desire to maintain frequent and regular contact with the child. Moreover, the court must weigh the paramount interests of the child, which may or may not be in irreconcilable conflict with those of one or both of the parents” (Tropea v Tropea, 665 N.E.2d 145, 148 (NY 1996)). This clash between shared parenting and relocation has not been tempered in the slightest in the quarter century since those words were written, even by advances in travel, remote work, and communication technology.

A parent seeking to relocate with a child must demonstrate, by a preponderance of the evidence, either:

  • that there has been a “substantial change in circumstances” (if there already has been a custody determination concerning the subject child); or
  • that relocation is in the child’s best interests, taking into account all of the relevant factors (if the court is making a de novo custody determination).

The basic inquiry is whether relocation provides enough benefits to the child to outweigh the impact the relocation will have on the child’s relationship with the non-relocating parent, taking into account ameliorative steps such as implementing different but substantially equivalent time-sharing arrangements. The court will look into:

  • the quality of the two relationships between the child and the relocating and non-relocating parents;
  • the impact of the move on the quantity and quality of the child’s future contact with the non-relocating parent;
  • the degree to which the relocating parent’s and child’s lives may be enhanced economically, emotionally and educationally by the move; and
  • the feasibility of preserving the relationship between the non-relocating parent and child through suitable alternative access arrangements.

Additionally, the court will attempt to ascertain the “real” motive of each parent for proposing/opposing relocation; in some cases, wishing to remarry or make a “fresh start” is a permissible motivation. When evaluating all factors, the court will consider – among other things – the credibility, character, temperament and sincerity of the parties. Appellate courts tend to defer to the trial courts on these issues and not disturb relocation decisions supported by a “sound and substantial” basis in the record.

Child’s Bond With Each Parent

The court will examine how the proposed relocation can be consistent with the non-relocating parent’s continuing meaningful involvement in the child’s life. This may be achieved through a parenting schedule that provides the non-relocating parent with longer periods of parenting time with the child during school vacations, as well as through other arrangements such as sharing the labour and financial burden of bringing the child and non-relocating parent together during the school term – all taking into consideration the age, needs and maturity of the child. Technology platforms such as FaceTime are also among the tools for promoting frequent access.

The court will also determine whether or not (and to what degree) the non-relocating parent is actually involved in the child’s life and makes full use of available parenting time.

Finally, the court will be very interested in whether the relocating parent will in fact foster the child’s relationship with the non-relocating parent or take unfair advantage of distance to engage in “negative gatekeeping.”

Representative recent cases include the following.

  • Nancy A v Juan AB, 180 N.Y.S.3d 908 (App Div 1st Dep’t 2023) – relocation to Florida permitted where the relocating parent was the child’s primary caretaker, the child suffered when left alone under the other parent’s care, and the “left-behind” parent was awarded liberal access time including during summer and other school vacations.
  • Thomas v Mobley, 170 N.Y.S.3d 172, 176 (App Div 2d Dep’t 2022) –relocation to the US state of Georgia permitted where the relocating parent was the child’s primary caregiver and the left-behind parent could keep in contact by phone and video and have extended access during school breaks.
  • TD v LMD, 191 N.Y.S.3d 42, 43 (App Div 1st Dep’t 2023) – relocation within New York State denied where it would negatively impact the child’s relationship with the remaining parent (who had been actively involved in the child’s life since birth and was a 50/50 parent in all respects) and the mother’s proposed revised parenting schedule eliminated the majority of the father’s overnight visits, reduced parental time to three weekends a month, and barred his involvement in school-related and after-school activities.

Stability Versus Potential Enhancements to the Status Quo

Custodial stability, even with a “less-than-perfect” parent, is generally considered a plus. Thus, a proposed relocation should have a quality of permanency such that the child will not frequently be asked to set down roots elsewhere prematurely. Courts will look into a child’s ties to the current jurisdiction – school, friends, doctors, care-providers, extracurricular activities, family members (including other siblings), and other cultural and/social connections – and how, if at all, such ties can be preserved and/or replicated.

The relocating parent will need to explain concretely how the child will be integrated into the new community through school, activities, childcare and social engagement – and the benefits of each. The relocating parent will also need to show specifically how the child will benefit economically, emotionally and/or educationally from relocation. By way of an example, relocation may:

  • enable the relocating parent to obtain otherwise unavailable employment or enhanced employment and business opportunities;
  • enable the child to be closer to extended family providing emotional, caretaking and/or financial support; and
  • enhance education and/or medical treatment, which may be particularly important where a child has special needs.

Sometimes emotional enhancement and financial enhancement go hand-in-hand – for example, when family and friends are available for childcare or where the relocating parent has more flexible work hours permitting more time to be spent with the child.

In a bit of a Catch-22, however, the parent wishing to relocate may be unable to make these specific enhancements concrete (ie, selecting a specific school or consulting with a specific doctor) until and unless leave to relocate is granted. Similarly, one court rejected relocation premised in part on the willingness of the relocating parent’s family to relocate to the same jurisdiction as being based on a wished-for resource as opposed to a resource already present.

Representative recent cases include the following.

  • WH v LH, 2023 WL 3331274 (NY Sup Ct NY Cnty 2023) – relocation to Pennsylvania with nine-year-old denied where the child had strong connections and ties to New York, including friends, school, activities, doctors and care providers.
  • SR v SW, 2022 WL 18396321 (NY Fam Ct Tomkins Cnty 2022) – relocation to North Carolina permitted to enhance the child’s life economically and emotionally as the relocating parent had a strong support system of extended family in the new location, where housing and childcare would be provided for free, allowing the relocating parent to work more hours and earn more income, and the child would be able to enjoy a close relationship with family members.

Wishes of the Child

A child’s wishes or preferences may be considered by the court and given greater or lesser weight depending on age, maturity, and other facts and circumstances. These wishes or preferences can be communicated through counsel for the child, through a forensic evaluator, or even by the court directly interviewing the child in chambers with the child’s counsel present (but not the parties).

Children may sometimes express a desire to live with one parent or continue to attend (or to change) school. At the same time, and paradoxically, the relocating parent can be criticised for – or even barred from – informing the child (especially a young one) about even the possibility of relocation such that the child may not have a meaningful opportunity to express a preference for or against changing the status quo. To the extent the child does express a preference, the court is more likely to consider that of a child of “advanced age”, which – albeit not specifically defined – appears to encompass teenagers. Of course, children change their mind over time, and preferences that may have been expressed in a former custody proceeding will not be given much weight if no longer current.

Representative recent cases include the following.

  • Daniel G v Marie H, 151 N.Y.S.3d 475 (App Div 3d Dep’t 2021) – relocation denied despite potential to enhance the child’s life financially, where the child was strongly bonded to the remaining parent, was of an advanced age, and expressed the desire to remain with the left-behind parent and attend local high school.
  • Louis B v Jennifer L, 131 N.Y.S.3d 335, 336 (App Div 1st Dep’t 2020) – relocation permitted after taking the fact that the teenage child expressed preference for relocation into consideration.
  • Alevy v Herz, 214 A.D.3d 582 (App Div 1st Dep’t 2023) – relocation permitted even though the court-appointed forensic evaluator found that the child’s best interests were not served by the relocation, where the court-appointed forensic evaluator based his conclusion on his conversations with the child that occurred more than one year before the trial, the child’s wishes had changed by the time of trial, and the attorney for the child recommended that the court permit the relocation.

Distance

Geographical distance is not per se determinative. Even a small distance can unreasonably impede parental access where it would burden weekend access (if not render it impossible).

Representative recent cases include the following.

  • Schwartz v Schwartz, 132 N.Y.S.3d 34, 37 (App Div 2d Dep’t 2020) –relocation 12.5 miles within the same county denied where it would negatively impact the quantity and quality of the contact with the other parent whose religious practices prevented car travel on weekends and certain holidays and thus would bar access according to the parenting time schedule in place and significantly hamper attendance at activities.
  • Thomas SS v Alicia TT, 206 A.D.3d 1534 (App Div 3d Dep’t 2022) –relocation permitted despite requiring the non-relocating parent to travel an additional 15 minutes by car, where the move would not have a substantial impact on the non-relocating parent’s access and the child’s life would be enhanced economically by the move.

Parties’ Prior Agreements

Where the pre-existing custodial relationship results from the prior agreement of the parties, and such agreement has successfully been implemented over time, such prior agreement will be given significant deference as a prior recognition of the child’s best interest. Agreements containing a “radius clause” permitting and/or restricting relocation are particularly relevant.

Incidentally, during the COVID-19 pandemic, some parents made informal or temporary changes to pre-existing formal parenting arrangements and later argued the pandemic changes warranted more permanent relocations; courts have consistently enforced parties’ formal custodial arrangements as the pandemic has ebbed. During the COVID-19 pandemic, courts were mindful of not allowing parents to shoehorn temporary pandemic arrangements into more permanent ones.

Representative recent cases include the following.

  • Cleary-Thomas v Thomas, 155 N.Y.S.3d 316 (App Div 1st Dep’t 2021) – denying relocation from Manhattan to Long Island where the parties’ informal agreement to reside in their second homes during the COVID-19 pandemic did not alter the five-mile radius clause of their existing custody agreement.
  • WH v LH, 2023 WL 3331274 (NY Sup Ct NY Cnty 2023) – in denying relocation from New York to Pennsylvania, the court heavily weighed the non-relocation “radius clause” in the parties’ existing custody agreement as a factor against relocation despite the fact that the parties temporarily navigated exchanges during the pandemic.

Other Factors

Proven domestic violence or abuse/neglect will certainly impact a court’s consideration of relocation. One representative recent case is Lavery v O’Sullivan, 169 N.Y.S.3d 632 (App Div 2d Dep’t 2022), in which relocation to Ireland was permitted even though it would disrupt the remaining parent’s regular access, given credible evidence that the remaining parent engaged in verbal and substance abuse and subjected the relocating parent to domestic violence.

Conclusion

Relocation proceedings, as with all custody-related proceedings in New York State, ultimately turn on whether the particular facts and circumstances serve the best interest of the child. Although relocation requests frequently appear to conflict with shared parenting arrangements, courts must determine how (if at all) shared parenting can be restructured to preserve the non-relocating parent’s involvement where relocation is otherwise best for the child because the facts – taken as a whole – militate in favour of relocation.

Teitler & Teitler LLP

230 Park Avenue
Suite 2200
New York
NY 10169
USA

+1 212 997 4400

+1 212 997 4949

nwlobenthal@teitler.com www.teitler.com
Author Business Card

Law and Practice

Authors

Nicholas W. Lobenthal
Jaime L. Weiss

Teitler & Teitler LLP is a 14-lawyer New York City litigation boutique with more than 50 years’ experience of counselling clients in navigating complex high-stakes disputes and crisis management situations. With extensive trial experience, Teitler & Teitler LLP stands ready to try the most difficult and important cases in New York state and federal courts. The firm has advised and represented domestic and foreign individuals and entities in family law, trust and estates, and commercial matters. This includes settlement and trial of ultra-high net worth matrimonial actions involving complex financial, business valuation, and custody issues, as well as the negotiation of pre- and postnuptial agreements.

Trends and Developments

Authors

Nicholas W. Lobenthal
Jaime L. Weiss

Teitler & Teitler LLP is a 14-lawyer New York City litigation boutique with more than 50 years’ experience of counselling clients in navigating complex high-stakes disputes and crisis management situations. With extensive trial experience, Teitler & Teitler LLP stands ready to try the most difficult and important cases in New York state and federal courts. The firm has advised and represented domestic and foreign individuals and entities in family law, trust and estates, and commercial matters. This includes settlement and trial of ultra-high net worth matrimonial actions involving complex financial, business valuation, and custody issues, as well as the negotiation of pre- and postnuptial agreements.

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