Fort Lauderdale Divorce Lawyer Blog

Last month, a Hillsborough County Circuit judge ordered the arrest of John Dargan Stanton III, a successful Tampa area businessman, after he was found guilty of five counts of criminal contempt of court for failure to pay his child support and alimony obligations. Mr. Stanton failed to attend the contempt hearing where Judge Caroline Tesche sentenced him to almost six months in jail for repeatedly refusing to pay more than $6 million in alimony and child support.

Susan Stanton initiated divorce proceedings in 2009 and the former couple reached a final settlement agreement in July 2011. Although the couple has a 12-year-old son together, she stated her former husband has not supported them for several years. According to her attorney, Mr. Stanton now owes his ex-wife $10 million.

Mr. Stanton is a decorated Vietnam veteran, a former president of Cast-Crete, and he previously ran a building materials company which reported profits of more than $4 million per month at its height. At one point, he owned a mansion and regularly drove several high end sports cars. Now, Mr. Stanton claims he is financially insolvent. In fact, he filed for bankruptcy just three days prior to the contempt hearing. Still, Judge Tesche believes Mr. Stanton has the ability to pay.

Mr. Stanton reportedly owns stock in several large companies as well as other assets. His attorney has argued Mr. Stanton's hands are tied as the former couple's settlement agreement prohibits Mr. Stanton from selling his stock in order to generate cash. He also claims Mr. Stanton is unable to liquidate any of his assets and lives off of loans and a small monthly Department of Veterans Affairs disability check.

According to Susan Stanton, her ex-husband has the money and is merely hiding millions of dollars in assets from her. In November 2010, Mr. Stanton spent more than two weeks in jail for refusing to produce documents during the couple's divorce proceedings. When he filed for bankruptcy, Mr. Stanton estimated his assets as being in the range of $100 to $500 million and his liabilities at no more than $50 million. To further complicate the case, the Internal Revenue Service is also performing a criminal investigation into Mr. Stanton. His attorney has stated he is not aware of Mr. Stanton's current location.

Each year many Florida residents find themselves in the midst of a less than amicable divorce. Understandably, the host of emotions associated with the end of a marriage can be overwhelming. The financial damage can oftentimes make a bad situation even worse. If you are contemplating divorce, you need an experienced family law attorney to help you protect your financial interests.

Continue reading "Tampa Area Businessman Wanted for Failure to Pay $6 Million in Child Support and Alimony" »

Florida lawmakers are currently considering a bill which would end permanent alimony awards following divorce. If passed by the Florida Legislature, House Bill 549 would base an award of alimony on the length of the divorcing parties' marriage. For example, a marriage which lasted for 12 years would be eligible for a maximum alimony award of 12 years. The bill would also cap awards based on the payer's income and allow payments to cease upon the payer's retirement.

Earlier this month, the state legislature heard testimony in favor of House Bill 549 from members of the Florida Alimony Reform Group. A member of the group, Hector Torres, has also urged legislators to allow previous awards of permanent alimony to be revisited by courts. According to Torres, the state's laws are behind the times and it is unfair he must pay alimony until his death after a marriage which lasted only 14 years.

Although the bulk of divorces across the nation involve some sort of alimony award, the money is generally provided to assist a spouse as he or she works to become self-supporting. Today, several states are changing their alimony laws in response to the fact that more spouses work outside of the home. This fall, Massachusetts placed new limits on the length of time alimony may be awarded by courts and ended alimony payments when the payer reaches retirement or the payee begins residing with another partner. Florida recently amended state alimony laws to provide awards solely after marriages of long term duration. Permanent awards now also require a court determination stating no other alimony option is fair or reasonable given the parties' situation. New Jersey is currently considering legislation to limit alimony awards as well.

In Florida, two requirements must exist before a court will award alimony. They include a need on the part of the payee and an ability to pay on the part of the alimony payor. The first requirement takes into account the distribution of marital assets combined with the parties' standard of living prior to the end of the marriage. If the potential payee can maintain the same standard of living after all assets are distributed, a court likely will not award alimony.

Continue reading "Florida Legislators Consider End to Permanent Alimony" »

A bill filed before the Florida Legislature on November 2nd would prohibit judges presiding over a divorce from considering adultery when awarding alimony, place limits on the total amount and length of time alimony may be awarded, and allow divorce agreements in which alimony was awarded to be reopened and renegotiated. House Bill 549 would also terminate all alimony payments once the spouse ordered to pay reaches the age of retirement.

House Bill 549 was filed by Brevard County legislator Ritch Workman. Interestingly, Representative Workman filed the bill only eight days after his own divorce was finalized in Florida. Although alimony was not awarded in Workman's divorce, the Melbourne legislator has stated he believes current Florida alimony laws are inequitable.

Alimony is a tool used by Florida courts to maintain each party's standard of living after a divorce. Alimony is not awarded in all circumstances, however, as an award of alimony is contingent upon the financial needs of one spouse and the others ability to pay. Additionally, the length of the marriage also plays a factor in an alimony award.

House Bill 549 is part of a growing trend to reform alimony laws both in Florida and across the nation. Workman's bill was modeled after similar legislation passed recently in Massachusetts. If the bill passes in Florida, its effects would be far-reaching. Even routine divorce settlements could be reopened and reexamined. Since filing House Bill 549, Representative Workman has stated specific portions, such as a cap on awards, should be removed.

The bill closely follows on the heels of recent amendments to the permanent alimony provisions of Florida Statute 61.08 which took effect on July 1, 2011. Permanent alimony is normally awarded to a spouse who is no longer capable of meeting basic financial needs after a long term marriage of more than 17 years. Permanent alimony may also be awarded at the discretion of a judge after a moderate or short-term marriage is dissolved. Since July 1st, Florida courts must now determine no other alimony award is "fair and reasonable under the circumstances," when permanent alimony is awarded. For moderate-term marriages of 7-17 years, clear and convincing evidence permanent alimony is the appropriate award is now required.

Continue reading "New Florida Bill Would Limit Alimony and Ignore Cheating" »

A legislator in Florida, Representative Ritch Workman, is attempting to repeal a state law which makes it illegal to cohabit with a party who is not a spouse. Specifically, "if any man or woman, not being married to each other, lewdly and lasciviously associate and cohabit together..they shall be guilty of a misdemeanor of the second degree". This crime is currently punishable by 60 days in jail and a $500 fine.

Approximately 544,907 Floridians live in a relationship in violation of Florida law. This law is now viewed as both unenforceable and unrealistic. One advocate believes that there is a role for government to promote marriage instead of cohabitation. The rationale is that greater marriage rates have a lower likelihood of crime, less domestic violence and better educational results for children.

Individuals believe that there are governmental limitations in promoting marriage. Arresting individuals who live together is not realistic or fair. Many Floridians do not want to marry due to a prior Broward divorce which they experienced or lived through with their own parents.

There are also negative consequences pertaining to cohabitation which you should discuss with your divorce attorneys in Broward county. A court may reduce or terminate an alimony award if the receiving spouse is in a supportive relationship with a person who is not related by consanguinity or affinity and with whom the person resides.

At the Fort Lauderdale alimony trial, the court will examine whether the parties hold themselves out as married couples, how long they have resided together, whether they have pooled assets or income, whether they support the other party, whether they perform services for the other or their company, and whether they have acquired assets together. The court will also look at whether they have acquired real property, whether there is an express or implied agreement regarding assets and support and whether they support the others children.

In Sootin v. Sootin, the former husband and former wife divorced in Miami-Dade in 1998. The former husband was obliged to pay the former wife permanent alimony. During 2008, the former husband sought to modify or terminate his alimony obligation. The former wife successfully moved to dismiss the petition since she now resided in Tennessee.

Next, the former husband moved to Tennessee and filed a petition to register and modify the divorce decree previously entered in Miami-Dade. After the former wife moved to dismiss the petition for a lack of subject matter jurisdiction in Tennessee, the Miami-Dade court, after consultation with the Tennessee Court, transfered the case to Tennessee. The former wife appealed this order.

In reversing the trial court's transfer order, the Third District Court of Appeal held that the Miami divorce court erred in transferring the case to Tennessee. The court reasoned that Florida, under the Unified Interstate Family Support Act (hereinafter "UIFSA"), had continuing exclusive jurisdiction over the alimony order throughout the existence of the obligation.

Under UIFSA, a child support or alimony order issued in Florida can be registered in a foreign state for enforcement. However, the court of the foreign state is required to ask the court who issued the original order to consider either party's request for modification of the registered alimony or child support order in the issuing court that had original jurisdiction.

Divorce attorney's in Miami, Coral Gables, Hallandale, Plantation and other South Florida cities are preparing for a statutory overhaul regarding legislative modifications to the statute governing alimony. One of the most significant changes is the codification of bridge-the-gap alimony.

Bridge-the-gap alimony assists a party in making the transition from being married to being single. It assists a party with identifiable short term financial needs. A marital and family law judge may not award bridge-the-gap alimony for a period in excess of 2 years. Bridge-the-gap alimony terminates upon the death of either party or upon remarriage of the party that receives alimony. Last but not least, bridge-the-gap alimony is non-modifiable in amount or duration.

Another important change to alimony relates to rehabilitative alimony. Rehabilitative alimony assists a party in redeveloping previous skills or credentials. It also helps a spouse acquire education, training or work experience necessary to develop employment skills. In the Final Judgment of Dissolution of Marriage, the court must detail a defined rehabilitative plan. A party may modify or terminate rehabilitative based upon a substantial change in circumstances or compliance with the rehabilitative plan.

Next, durational alimony will be used by courts when permanent alimony is not appropriate but a party needs economic assistance for a period of time after a short or moderate term marriage. A recipient of durational alimony can not receive this alimony for a period of time that exceeds that of the marriage. While the length of durational alimony is non-modifiable absent exceptional circumstances, the amount can be modified once there has been a substantial change in circumstances. Durational alimony terminates upon the death of either party or if the recipient gets remarried.

Finally, permanent alimony can be awarded after a long or moderate term marriage. It is generally used to provide for the needs and necessities of life established during the marriage for a party who does not have the financial ability to meet his or her needs. An award of permanent alimony can be modified or terminated based upon a substantial change in circumstances or if the recipient is involved in a supportive relationship. Permanent alimony alimony terminates upon the death of either party or if the recipient gets remarried.

When a client meets with their Broward divorce lawyer, nine times out of ten they will ask if they will have to pay alimony or if they will receive alimony. Effective July 1, 2010, there will be significant revisions to Florida law governing alimony. The amendments apply to all initial awards and modifications of these awards entered prior to July 1, 2010. However, the statutory amendments will not serve as a basis to modify alimony awards or change the amount or length of alimony awards entered before July 1, 2010.

The Florida marital and family court will now consider three additional statutory factors when awarding alimony. First, the court will consider each party's responsibilities for children of the marriage. Next, the court will consider the tax consequence of the alimony award and whether all or a portion of the award should be nontaxable and nondeductible. Finally, your Fort Lauderdale divorce lawyer will now have the ability of presenting evidence of all sources of income available to either party from investments and assets.

Another significant change to Florida's alimony law are the statutory presumptions regarding length of marriages which will help the court determine which type of alimony is the most appropriate. A short term marriage is now considered a marriage that is less than 7 years. A moderate term marriage is a marriage greater than seven years but less than 17 years. Last but not least, a long term marriage is a marriage that is in excess of seven years.

In my next blog, I will discuss the statutory codification of bridge-the-gap alimony, changes to rehabilitative and permanent alimony and the newest form of spousal support., durational alimony.

In Purrinos v Purrinos, the wife appealed the decision of the Miami-Dade divorce court that failed to award her any type of alimony. The parties were married for 16 years. At the time of the dissolution of marriage action, the husband and wife has three young children. The only marital asset was the marital residence. While both parties were employed during the marriage, the husband earned more than the wife. At the trial, the husband testified that he was involuntarily and temporarily employed. However, he expected to find a new job in the future.

In reversing the decision of the divorce court, the Third District Court of Appeal held that the trial court abused its discretion in failing to award the Wife alimony. The court reasoned that while an alimony award was inappropriate at the time of trial because of the husband's inability to pay at that time, he may possess the ability to pay alimony in the future. Accordingly, the case was remanded to the trial court with instructions to award the wife a nominal amount of permanent periodic alimony.

In Greenwald v Greenwald, the husband and wife were married on May 18, 2004. Fourteen months later, the parties filed for divorce in Miami-Dade. In support of her claim for permanent alimony, the wife claimed that the husband induced her to quit her job were she earned $100,00 per year. At trial, e-mail evidence proved that this claim was false since the wife wanted to quit her job prior to the marriage.

While the wife's request for permanent periodic alimony was denied, Judge Scott Bernstein awarded her $65,000 in attorney's fees and costs to be paid by the husband. In reversing the trial court's award of attorney's fees and costs to the wife, the Third District Court of Appeal held that the Miami divorce court should have denied the wife's request for attorney's fees and costs. The court reasoned that the wife made a claim for permanent alimony in a short-term marriage which is rarely successful, the case went to trial on the permanent alimony issue, the basis of the claim was false and the wife turned down a favorable opportunity to settle the alimony matter before trial in a lump sum payment of $36,000.

Over the past couple years, the concept of alimony has changed and evolved as a result of recent appellate decisions in Florida. Many women who hire an attorney and file for divorce in Fort Lauderdale are now employed, self supporting and earning comparable pay as to their husband. In addition, the average length of a marriage has decreased. Accordingly, the amount of cases in which Broward divorce lawyers have permanent alimony awarded to their client has decreased. Also, the amount and duration of alimony has also been reduced.

The Florida legislature amended Florida Statute 61.14 to permit a payor spouse to seek to reduce or eliminate his or her alimony obligation when their former spouse is in a supportive relationship while remaining unmarried. The court will look at many different factors such as how long the recipient has resided with another person, whether they have pooled their assets or income and the extent to which the recipient has supported the other and whether or not they have jointly acquired any assets or property.

Alimony is based upon the need of one spouse for alimony and the other spouse's ability to pay. However, the days of focusing on the standard of living that the parties have been accustomed to during the course of the intact marriage is not as significant. In the past, a divorce attorney in Broward would hire a forensic accountant to perform a lifestyle analysis. The forensic accountant would analyze tax returns, bank statements, check registers and credit card statements to ascertain a spouse's needs, the other spouse's ability to pay and the historical spending during the marriage. However, gone are the days that a spouse receives alimony which comprises of all of the luxuries accustomed to during the marriage including, but not limited to, spa visits, country club memberships, vacations and clothing allowances.

The Fourth District Court of Appeal, which handles divorce, child support and other marital and family appeals filed by attorneys in Broward and Boca Raton now believes that when there is a high standard of living during a marriage, the purpose of alimony is to provide for the impecunious spouse above the bare subsistence levels, but not to fund every little luxury enjoyed before your Ft. Lauderdale divorce. Marital and family attorneys now have a difficult time including "unnecessary personal expenses" such as computer supplies, gifts and country club memberships as part of a recipient spouse's need for bridge-the-gap, rehabilitative or permanent alimony.

While the importance of many of the statutory criteria to award alimony has now changed, alimony has not been eliminated. If you are going through a divorce in Broward and reside in Coral Springs, Davie, Margate, Miramar or Southwest Ranches, you should speak to a Fort Lauderdale divorce lawyer to determine your entitlement to alimony.

During a Broward divorce, your Fort Lauderdale divorce lawyer may request that you be awarded alimony. A Florida marital and family court can award you bridge-the-gap, temporary, lump sum, rehabilitative or permanent periodic alimony. However, after the conclusion of your Broward divorce case, one spouse may have their Broward child support, child custody and divorce attorney ask the judge to reduce or terminate the alimony because of a statutorily created supportive relationship.

In determining whether an existing award of alimony should be reduced or terminated because of an alleged supportive relationship between an obligee and a person who is not related by consanguinity or affinity and with whom the obligee resides, the court shall elicit the nature and extent of the relationship in question. The court shall give consideration, without limitation, to circumstances, including, but not limited to, the following, in determining the relationship of an obligee to another person: the extent to which the obligee and the other person have held themselves out as a married couple by engaging in conduct such as using the same last name, using a common mailing address, referring to each other in terms such as "my husband" or "my wife," or otherwise conducting themselves in a manner that evidences a permanent supportive relationship; the period of time that the obligee has resided with the other person in a permanent place of abode; the extent to which the obligee and the other person have pooled their assets or income or otherwise exhibited financial interdependence; the extent to which the obligee or the other person has supported the other, in whole or in part; the extent to which the obligee or the other person has performed valuable services for the other; the extent to which the obligee or the other person has performed valuable services for the other's company or employer; whether the obligee and the other person have worked together to create or enhance anything of value; whether the obligee and the other person have jointly contributed to the purchase of any real or personal property; evidence in support of a claim that the obligee and the other person have an express agreement regarding property sharing or support; evidence in support of a claim that the obligee and the other person have an implied agreement regarding property sharing or support and whether the obligee and the other person have provided support to the children of one another, regardless of any legal duty to do so.

In Baumann v Baumann, the Second District Court of Appeal reversed the decision of a Florida divorce court that reduced the former husband's alimony obligation to the Former Wife. The former husband was required to pay the former wife $1800 per month in permanent periodic alimony. In 2007, the former husband petitioned the Florida marital and family law court to reduce or terminate his alimony obligation since the Former Wife was involved in a supportive relationship.

At the trial, the trial court found that the former husband had proven that the former wife was in a supportive relationship and was receiving $1400 per month from her supporting partner. Accordingly, the former husband's alimony obligation was reduced to $400 per month. However, following a hearing on the former wife's motion for rehearing the trial court acknowledged the existence of a supportive relationship but found that the Former Husband did not meet his burden in proving that the Former Wife's need for alimony decreased as a result of the supportive relationship and required him to continue to pay the former wife $1800 per month in permanent periodic alimony.

In reversing the decision of the Florida divorce court, the Second District Court of Appeal held that the trial court improperly placed the burden of proving a reduction of the former wife's need for alimony on the former husband. The court reasoned that the burden was on the former wife to establish that her original financial need continues to exist despite the supportive relationship after the former husband proved its existence.

When you meet with your Broward divorce lawyer, he or she will explain to you that there is a four point analysis for the marital and family law judge to award alimony. First, the starting point is to determine the need of one spouse and the ability to pay of the other spouse. Next, it is important to determine how long you will need alimony and what type of alimony you should request. Divorce attorneys in Fort Lauderdale will explain to you the differences between permanent periodic, rehabilitative, bridge the gap, lump sum, temporary and nominal alimony. Next, the recipient spouse must have a need for alimony based upon the standard of living established during the marriage in order for the Broward marital and family law judge to determine the amount of alimony that should be awarded. Finally, the court must consider and make findings of fact relative to the factors enumerated in Florida Statute, 61.08 in awarding or denying alimony. For the purposes of this blog, I will discuss bridge the gap alimony.

Bride the gap alimony is typically awarded during a Broward divorce to fulfill a specific and limited purpose of meeting short term financial difficulties as a result of the transition from married to single life. Unlike rehabilitative alimony, bride the gap alimony is for a shorter duration of time. Your Fort Lauderdale divorce lawyer will explain to you that bridge the gap alimony is typically awarded during a short term marriage of one to three years. However, there are no presumptions for or against this type of alimony.

There is no direct reference to bridge the gap alimony under Chapter 61, Florida Statutes. Rather, this form of alimony is recognized in many of the appellate districts in Florida. In the First, Third and Fourth districts, bridge the gap alimony is fully modifiable short term periodic payments. On the other hand, in the Second district, bridge the gap alimony is considered lump sum alimony payable in installments, is non-modifiable and generally does not terminate upon death or remmarriage.

Bridge the gap alimony can be awarded during a Ft. Lauderdale divorce in conjunction with permanent periodic alimony to meet the short term gap of financial need of a spouse where rehabilitative alimony is not appropriate. By definitional concept, bridge the gap alimony is for a short durational period not to exceed three years. The effect of remarriage on bridge the gap alimony is unclear.

In Vigo v. Vigo, the Florida marital and family law court awarded the wife permanent periodic alimony in the amount of $5,500 per month. The Third District Court of Appeals, located south of Broward County, reversed the Florida Divorce Judge Maxine Cohen Lando's decision to award the wife permanent periodic alimony because under Florida law, the wife is not a candidate for permanent periodic alimony.

Permanent periodic alimony is generally reserved for long term marriages, or for marriages where a major inequity is created by the dissolution. This type of alimony is used to maintain the lifestyle that the parties were accustomed to during the duration of the marriage. When determining whether permanent periodic alimony is appropriate, the court also considers the need of the party requesting alimony and the ability of the party who is obligated to pay.

In this case, need turned on whether the Wife would be able to work after the divorce. During the seven and one half year marriage, the Wife worked for three and a half years as a housekeeper and for one year operating her own used car business. In 2005, when she stopped working, the Husband supported her. The evidence on record reflected that the Wife had "serious chronic health problems;" however, the appellate court found that she lived a rather active lifestyle, attending church for three hours at a time, shopping, taking her dog to the park for two hours a day, and visiting the beauty salon. The appellate court found that her ailments would not prevent her from obtaining a sedentary job.

Furthermore, the record indicated that the Wife was capable of being trained. The evidence in support of this was that the Wife, not a native English speaker, took English classes, passed the GED in English and passed the United States Naturalization test in English. Additionally, the Wife had worked as a housekeeper, nurse assistant, seamstress, an independent sales consultant, a masseuse and she has owned her own business. After careful review of the record, the appellate court determined that the Wife was capable of earning approximately $28,000 per year after taking a year of English courses and acquiring either an Associates Degree or a Certificate of Competency.

Based on the evidence presented at trial, the appellate court found that the trial court abused its discretion because this was a short term marriage. The court also found that the parties lived a modest lifestyle while married, the Wife had been awarded a $250,000 lump sum, no children were born of the marriage, the Wife was immediately employable or could be retrained over a three to four year period, and finally despite her health problems the Wife lived an active, healthy lifestyle. Thus, the Third District reversed the award and remanded for the court to consider an award of rehabilitative alimony instead.

Rehabilitative alimony is used to provide the recipient with money to eventually become self sufficient. To receive rehabilitative alimony the parties must establish a rehabilitative plan. A rehabilitative plan must be specific and should address the object of the rehabilitation, the cost of the plan, and the projected period necessary to establish the recipient's self sufficiency.

In Bengisu v. Bengisu, the Fourth District Court of Appeals reversed and remanded a Florida divorce court's decision awarding the Wife temporary child support and alimony. The Wife filed a petition for dissolution of marriage with two minor children in the Florida divorce Court. Subsequent to filing for dissolution of marriage, the Wife also filed a motion seeking temporary child support and alimony. The Broward County divorce court awarded the Wife temporary support in the amount of $5,500 per month, and the Husband appealed.

At a hearing on the motion for temporary child support and alimony, the court looked at the parties' financial affidavits as well as heard their direct testimony. The Wife's financial affidavit listed that she was unemployed, had monthly expenses of $11,898.00 and a net worth of $744,123.00. The Husband's financial affidavit listed he was a lawyer employed as a solo practitioner, that he had a net monthly income of $2,585.00, total monthly expenses of $4,886.58 and a monthly deficit of $2,720.29. He listed a net worth of $322,230.00.

In her direct testimony, the Wife told the court that the household expenses were $12,600 per month, that her Husband was responsible for all of the bills and that throughout the marriage the couple accrued no debt to pay their monthly expenses. Additionally, the Wife explained that her Husband left his solo practice to work for a law firm for four months leading up to the divorce and, while there, his salary was $85,000. Additionally, the Wife's accountant testified that based on the financials she needed $5,500.00 per month during the pendency of the divorce and that he believed the Husband's tax returns did not accurately reflect the Husband's real income. The Husband testified that the reason the couple did not have any debt was because his parents had helped pay for their household expenses, but were no longer in a position to continue to provide this assistance. At the conclusion of the hearing the trial court awarded the Wife $5,500 per month in temporary support.

On appeal the Fourth District concluded that the trial court abused its discretion in awarding monthly support of $5,500 to the Wife because this amount greatly exceeded the Husband's monthly net income. The appellate court explained that the trial court failed to make specific findings based on competent substantial evidence that the Husband's actual monthly income exceeded his stated monthly income. Moreover, the trial court erred because it imputed income to the Husband without making specific findings indicating the source and amount of the Husband's imputed income.

In determining whether and to what extent temporary alimony is required, the trial court must consider the needs of the spouse requesting the alimony and the ability of the other spouse to pay alimony. Both the requesting spouse's need and the other spouse's ability to pay must be supported by competent, substantial evidence.

In determining a spouse's ability to pay, the trial court will impute income where it is demonstrated that a parent is voluntarily unemployed or underemployed. In order to calculate this figure, the trial court takes into consideration the spouse's recent work history, occupational qualifications, and the prevailing earnings level in the community. The trial court may not impute income based on gifts or loans.

In conclusion, the appellate court reversed and remanded for the trial court to make the necessary finding based on competent, substantial evidence regarding the Husband's income, and to award an appropriate amount of temporary support to the Wife based on those findings.

Prior to filing for your divorce in Broward County, Florida, your divorce lawyer may want to hire a private investigator to catch your spouse cheating on you. If it is discovered that your spouse has cheated on you, this is a factor that the Fort Lauderdale divorce court may consider in awarding your alimony. However, hiring a private investigator to help your divorce lawyer find out if your spouse is cheating on you at a restaurant or hotel in Hollywood, Weston, Pembroke Pines or Cooper City, Florida with a paramour may become expensive.

GPS, or global position system tracking, is a useful tool that may be used to catch your spouse cheating. GPS systems cost less than $1,000.00 for certain models. During your dissolution of marriage case, a party that owns a car can may be able to conceal a GPS system in a glove compartment or other hiding place legally.

Electronic toll information has now become a thing of the past because of the fact that GPS information is more detailed. Last year, 88 percent of divorce lawyer reported an increase in using electronic information such as GPS and toll-pass date and computer records.