In 2011, after the parties separated, the mother received sole custody of the parties’ only child, who resided with her. The father was awarded access every weekend. The father subsequently filed a petition seeking increased access. After a hearing, Kings County Family Court Judge Maria Arias denied the pro se father’s petition.

The father appealed, contending that the Family Court should have granted his request for a copy of a forensic report prepared by a court-appointed forensic evaluator, and that the court erred in admitting the forensic report into evidence. In its July 10, 2019 opinion in Raymond v. Raymond, the Second Department affirmed.


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At a divorce trial, testimony by Skype will be allowed for the appraiser of an Oslo apartment. So held New York County Supreme Court Special Referee Louis Crespo in his April 3, 2014 decision in Steineger v. Perkins.

Among other discovery-related applications after the matter had been placed on the trial calendar, Referee Crespo,