04-2- 9745 Wolkoff v. Wolkoff, N.J. Super. App. Div. (per curiam) (7 pp.) Defendant Arlette Sarfati Wolkoff appealed from the April 11, 2014, Family Part order enforcing a fee arbitration committee determination and directing the immediate dispersal of funds escrowed for legal fees in her divorce action. She also appealed the order denying her motion for reconsideration. The panel reviewed the history of the dispute, noting that defendant had appeared before it four times on the matter. It then noted that defendant was again challenging a May 2009 consent order she had executed that she had previously unsuccessfully challenged. Finding that it was elementary that a party could not submit to a court’s jurisdiction and then challenge that court’s jurisdiction after an unfavorable ruling, and that an order consented to by both parties was not appealable, the panel concluded that no further delay in the payment of fees owed to the attorney was warranted. It therefore directed that the attorney holding the escrow funds disburse them within 10 days of the opinion.

09-2- 9746 Hoffman v. Loiry, N.J. Super. App. Div. (per curiam) (20 pp.) The month after Superstorm Sandy struck, defendant began to advertise a “Superstorm Sandy Reconstruction Summit” by sending numerous electronic mail messages to consumers under the name “NY/NJ Restoration Leadership.” The emails included a link to the Sandy Reconstruction website, which prominently featured the official seal of President Obama next to a quote from him about rebuilding damaged areas. The bottom of the page stated that the name of the organization was the “United States Leadership Forum.” The emails stated the fee for attending the forum but did not specify a location. The Division of Consumer Affairs began an investigation that resulted in a complaint asserting that defendant and his organizations had engaged in business practices that violated the New Jersey Consumer Fraud Act and the advertising regulations promulgated thereunder. Defendant appealed from a final judgment and order that found that he had violated the CFA and regulations; enjoined him from committing further violations; and required defendant to pay civil penalties, restitution, attorney fees, and the costs of investigation and prosecution. The panel affirmed. It found that the record supported the trial judge’s finding that undisputed evidence showed that defendant used unregistered assumed names to solicit attendees for the summit, in violation of N.J.S.A. 56:1-2, and that by using those unregistered trade names, he had engaged in an “unconscionable commercial practice, deception, fraud, false pretense, false promise or misrepresentation” in violation of N.J.S.A. 56:8-2. The panel also concluded the judge had correctly found that defendant had violated the CFA by operating under unregistered assumed names that falsely implied he was associated with the United States government and other governmental entities, in violation of N.J.S.A. 56:8-2. The panel also found that the undisputed facts concerning the summit, the solicitations, the websites and the assumed names used by defendant supported the trial court’s determination that he had violated N.J.A.C. 13:45A-9.2(a)(9).

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