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We therefore concluded the "assignment violated the provisions of the Annuity Fund Plan and 29 U. None of those disqualifying facts are present here.

The alternate payee of the proposed QDRO was defendant's former spouse, by rollover, not her attorney or the forensic accountant. The attorney's fees related to enforcement of child support and equitable distribution obligations, not dissolution of the marriage.

The forensic accountant fees related to investigation of defendant's meritless marital asset dissipation claim. AT4 13 Other courts have held QDROs may be used to enforce a counsel fee award incurred in obtaining a child support order, Silverman v.

Spiro, N. Adler, N. Blatte, N. The Silverman court distinguished Johnson, noting the alternate payee was the child's father, not the attorney.

Silverman, N. While it recognized ERISA did not expressly permit the use of a QDRO to satisfy counsel fee awards, the court nevertheless explained: Necessarily implicit, however, in the Federal law's recognition of a QDRO, is authorization for the reimbursement of attorney's fees incurred in obtaining a proper order.

Were it otherwise, a former spouse or party who succeeded in obtaining an appropriate QDRO, would have the order reduced by the necessity of paying attorney's fees.

In some circumstances, a former spouse or party might even forgo seeking a needed QDRO because of the prohibitive nature of unreimbursed attorney's fees.

These results would undermine the intent of Congress in establishing the QDRO exception by denying deserving parties and children a recovery to which they are entitled.

A fundamental maxim of equitable jurisprudence is that "equity will not suffer a wrong without a remedy.

Bielski, 15 N. Plaintiff's court-ordered remedies will likely remain unsatisfied absent enforcement by QDRO.

BAPCPA amended the Bankruptcy Code to clarify that a debt for a "domestic support obligation" owed to, or recoverable by, a spouse, former spouse, or child of the debtor in the nature of alimony, maintenance, or support of such spouse, former spo use, or child, established by a separation agreement, divorce decree, property settlement agreement, or court order is non-dischargeable.

This exception to discharge has been interpreted as applying to counsel fees incurred to obtain or enforce a domestic support obligation.

See, e. Gruber In re Gruber , B. Ohio ; In re Uzaldin, B. Thus, a court-ordered obligation to pay an ex-spouse's counsel fees in matrimonial proceedings is a non-dischargeable domestic support obligation.

Court-ordered counsel fees incurred in post-divorce proceedings that are AT4 15 payable directly to the attorney are likewise non-dischargeable.

Gruber, B. Prensky In re Prensky , B. Ordinarily, QDROs should be utilized to enforce counsel and expert fee awards only when other assets sufficient to satisfy the awards either do not exist or have been made unavailable by the obligor.

We find that to be the case here. For these reasons, we hold plaintiff was entitled to enforce the counsel and expert fee awards through a QDRO naming her alternate payee.

The trial court failed to permit that relief. We next address the enforcement of the college tuition reimbursement arrears through a QDRO naming plaintiff as alternate payee.

For the following reasons, we conclude the college tuition reimbursement arrears were enforceable against defendant's annuity funds through a QDRO.

First, the trial court properly classified the college tuition payment as child support. Arrigo, 88 N. Ricci, N. AT4 16 , App. Gac, N. Second, both plaintiff and the child fall within ERISA's definition of permissible alternate payee because plaintiff is a former spouse and the child is defendant's son.

Third, the payment of the college tuition arrears does not violate the Annuity plan and the form of the proposed QDRO was approved by the Annuity.

It falls within the exception to ERISA's anti-alienation provision since it is part of defendant's obligation to support his son. It is also permissible as reimbursement to plaintiff for child support payments, to the extent plaintiff was forced to make them on defendant's behalf, because they "related to" defendant's child support obligation.

We hold plaintiff was entitled to enforce the college tuition reimbursement arrearages through a QDRO naming her alternate payee. AT4 17 C. Last, we address the enforcement of the counsel fee judgments by an enhanced wage execution.

Domestic support orders are enforceable through an enhanced wage execution of fifty-five percent of the obligor's disposable income pursuant to 15 U.

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First Name. Last Name. You can see how Orlowski families moved over time by selecting different census years.

The most Orlowski families were found in the USA in In there were 6 Orlowski families living in Michigan. Michigan had the highest population of Orlowski families in Use census records and voter lists to see where families with the Orlowski surname lived.

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You can see how Orlowski families moved over time by selecting different census years. The most Orlowski families were found in the USA in In there were 6 Orlowski families living in Michigan.

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You've only scratched the surface of Orlowski family history. The complex procedural history underlying this appeal necessitates a brief review of the proceedings that led to the arrearages owed to plaintiff Joanna B.

Orlowski, her enforcement efforts, and defendant Robert Orlowski's bad faith, unclean hands, frivolous litigation in both state and federal court, and willful, sustained failure to comply with court orders.

Before we discuss the pertinent facts and procedural history, we note defendant appealed numerous orders and directed our attention to several AT4 2 alleged trial court errors.

Defendant's appeal, however, was dismissed for failure to timely file a brief, so we do not consider those issues. Accordingly, our review of the facts and procedural history is limited to those relevant to plaintiff's cross-appeal.

The parties were married in May and had two sons. Plaintiff's divorce action was finalized in The amended final judgment of divorce amended judgment required defendant to pay his child support obligations by wage garnishment.

The amended judgment incorporated the parties' "partial" property settlement agreement PSA , which addressed the equitable distribution of various marital assets, including the former marital residence and a k investment account.

The parties' mediator authored a supplemental letter to the PSA that addressed certain child support and tax issues, and stated two issues remained unresolved: 1 counsel fees; and 2 any claims or credits relating to the fees incurred for the forensic accountant used to investigate the parties ' reciprocal claims of dissipation of marital assets.

On the other hand, the trial court found defendant did not demonstrate plaintiff dissipated marital funds.

As a result, plaintiff was successful in her dissipation claim. As for counsel fees, the trial court recognized defendant's greater annual income, assets, and lesser debt relative to plaintiff.

It noted plaintiff moved three times for enforcement of prior court orders and served sixteen subpoenas to obtain discovery, which defendant obstructed.

The court also stated the case featured an "extensive litigious history" and plaintiff's dissipation claim was successful, whereas defendant's was unsubstantiated.

Thereafter, defendant refused to comply with the PSA and subsequent court orders. His obstinance prompted plaintiff to move for enforcement in April, May, September, and December of AT4 5 enforcement motions and her successful defense of an order to show cause filed by defendant, in an amount to be determined.

Defendant remained noncompliant. Plaintiff sought enforcement of the prior orders, including payment of the previously awarded counsel fees, from defendant's annuity funds through a QDRO.

The trial court declined to enforce the counsel fee arrearages "as alimony, by QDRO. Defendant also filed a federal civil rights action against sixteen defendants, including plaintiff, her attorney, the forensic accountant, the mediator, Governor Christie, three Superior Court judges, and plaintiff 's former attorney.

The defendants named in the action moved to dismiss the complaint with prejudice pursuant to Fed. District Court Judge Susan D.

Wigenton dismissed the action with prejudice but denied the application for sanctions. AT4 6 Incredibly, in May , defendant filed yet another application for removal, which the District Court denied.

The District Court also prohibited defendant from filing any additional pleadings without permission of the court. The court explained that plaintiff had to file several motions to enforce the terms of the PSA.

It recognized defendant acted in bad faith throughout the litigation by engaging in efforts to prevent the enforcement of the amended judgment, PSA, and subsequent orders.

The trial court ordered defendant to pay his portion of the college tuition expenses but declined to impose coercive sanctions. The trial court declined to impose an enhanced wage garnishment to collect unpaid counsel fee awards and the forensic 2 In addition to dissipating and transferring marital assets to a trust, defendant also routinely submitted baseless filings that generated otherwise unnecessary counsel fees and delayed enforcement of plaintiff's rights.

For example, defendant filed meritless motions for recusal of the trial judge, to dismiss plaintiff's applications for want of subject-matter jurisdiction, and for leave to appeal.

AT4 7 accountant fee reimbursement. Although the court stated on the record that an enhanced wage garnishment would be established against defendant for th e college tuition reimbursement, the order does not reflect that an enhanced wage garnishment was ordered.

A subsequent March 23, amended order provided defendant's disposable earnings would be garnished at fifty-five percent pursuant to 15 U.

Plaintiff cross-appealed certain aspects of several orders. She argues: 1 the trial court erred by not enforcing the counsel fee judgments and college tuition award through a QDRO against defendant's annuity funds; and 2 the trial court erred by not enforcing the counsel fee judgments by an enhanced wage garnishment.

Plaintiff contends that she will be unable to enforce the counsel and expert fee awards absent a QDRO due to defendant's manipulation of his 3 15 U.

AT4 8 assets. She argues she is entitled to this remedy as a matter of equity to prevent the injustice she would otherwise suffer.

ERISA was enacted by Congress to protect employees and their dependents who rely on retirement plans. Hawxhurst v. Hawxhurst, N. The primary safeguard is ERISA's "broadly worded preemption clause which establishes the regulation of pension plans 'as exclusively a federal concern.

Raybestos- Manhattan, Inc. ERISA also safeguards pension funds through its "spendthrift" provision, which mandates each pension plan contain an anti-alienation provision that prohibits the assignment or alienation of pension benefits.

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