BARBARA WEINRIB VS. MAXWELL BROTHERS(FM-11-0501-09, MERCER COUNTY AND STATEWIDE), A-1730-15T4

Weinrib and Brothers divorced in 2010; their consent judgment awarded joint custody of son B.B., with Weinrib as primary residential parent and a parenting-time schedule.
The amended dual final judgment of divorce (ADFJOD) required each parent to pay 50% of B.B.'s unreimbursed medical and daycare expenses; it was silent on future educational/extracurricular costs.
In August 2015 Weinrib obtained temporary sole residential custody and suspension of Brothers' parenting time based on allegations of inappropriate conduct; restraints were later dissolved and parenting time reinstated.
Brothers sought makeup parenting time and counsel fees after the restraints; Weinrib moved to enforce the 50% obligation for unreimbursed medical expenses and to compel payment for future educational/extracurricular activities.
The Family Part ordered Brothers to pay 50% of unreimbursed medical expenses, to pay 50% of future educational/extracurricular expenses (without articulated findings), denied makeup parenting time and counsel fees, and awarded two extra parenting days when dissolving restraints.
On appeal the Appellate Division affirmed the medical-expense order and denials of makeup parenting time and counsel fees, but remanded for specific findings on apportionment of future educational and extracurricular expenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Enforcement of 50% payment for unreimbursed medical expenses	Consent judgment requires 50/50 split; enforce as written	Challenged obligation (but acknowledged responsibility in certification)	Affirmed — consent judgment controls; no changed circumstances shown
Liability for future educational and extracurricular expenses	Court should compel 50/50 contribution	Opposes being compelled without prior agreement or findings	Remanded — ADFJOD silent; trial court failed to make required factual findings
Request for makeup parenting time (for period restrained)	N/A (Weinrib opposed)	Sought makeup time for missed parenting days	Affirmed denial — court found missed time resulted from court order, awarded two extra days when lifting restraints
Request for counsel fees	N/A (Weinrib opposed)	Sought attorney's fees for motions/defense	Affirmed denial — fee awards discretionary; no abuse of discretion shown

Landers v. Landers, 444 N.J. Super. 315 (App. Div. 2016) (appellate review deferential to Family Part factual findings)
Gnall v. Gnall, 222 N.J. 414 (2015) (standard for reviewing trial court factual findings)
Rova Farms Resort, Inc. v. Investors Ins. Co. of Am., 65 N.J. 474 (1974) (reversal warranted when findings are manifestly unsupported)
Midland Funding, L.L.C. v. Giambanco, 422 N.J. Super. 301 (App. Div. 2011) (consent judgment treated as contract and judgment)
Heller-Loren v. Apuzzio, 371 N.J. Super. 518 (App. Div. 2004) (modification of matrimonial settlement requires changed circumstances)
Williams v. Williams, 59 N.J. 229 (1971) (discretionary nature of counsel-fee awards in matrimonial matters)
Tannen v. Tannen, 416 N.J. Super. 248 (App. Div. 2010) (standard for reviewing counsel-fee awards)
Chestone v. Chestone, 322 N.J. Super. 250 (App. Div. 1999) (counsel-fee discretion principles)
Ronan v. Adely, 182 N.J. 103 (2004) (necessity of findings of fact and conclusions of law for appellate review)
Curtis v. Finneran, 83 N.J. 563 (1980) (remand required when findings are inadequate)
Heinl v. Heinl, 287 N.J. Super. 337 (App. Div. 1996) (naked conclusions insufficient; need specific findings)