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MICHIGAN
FAMILY LAW JOURNAL
A PublicAtion of the StAte bAr of MichigAn fAMily lAw Section • chriStoPher J. hArrington, chAirPerSon
editorS in chief: AntheA e. PAPiStA & AMy M. SPilMAn
ASSiStAnt editorS: dAniel b. bAteS, JAMeS w. chrySSikoS, Shon A. cook, JoSePh l. hohler iii,
MeliSSA kelleigh, JeSSicA lArSon, ryAn M. o’neil & Shelley r. SPivAck
voluMe 52 nuMber 7, AuguSt/SePteMber 2022
From the Chairperson ................................................................... 1
Christopher J. Harrington
Who Enforces the Court Rules? ................................................ 4
By Ryan M. O’ Neil
Case of the Issue: In re estate of GreGory PrIce Burnett ............. 6
By Henry S. Gornbein and Christina M. DiMichele
How Family Court Practitioners Could Save Lives ................... 9
By Elinor Jordan and
MICHIGAN FAMILY LAW JOURNAL A PublicAtion of the
Advertise in the MICHIGAN FAMILY
List of Advertisers ICLE—Family Law Institute ..
To All Prospective Family Law Journal Authors:
From the Chairperson Christopher J. Harrington,
team effort of Council members to work critically
NOVEMBER 17–18, 2022 | NOVI 21ST ANNUAL Family
LEGAL THEORY Who Enforces the Court Rules? By R
pleading as being violative of the Michigan Court
THE CASE OF THE ISSUE In re estate of GreGory Pr
probate court to enter an order granting summary
QUALIFIED DOMESTIC RELATIONS ORDERS and Retiremen
DOMESTIC VIOLENCE COMMITTEE PRESENTS How Family
necessarily mean that the parent will be successf
Endnotes 1 Corbin Cesaric, Four Family Members
In re Donald F. Clark Trust: The Potential Import
In reviewing the facts of the Lewis and Clar
be used and accessed and nothing remotely suggest
About the Author Sandra D. Glazier, Esq.,
Pensions and retirement accounts are often the la
How to Determine a Child’s Habitual Residence Bet
Implications in Michigan The Monasky decision
Michigan Federal Courts’ Treatment of Hague
ing the defense.”71 Respondent raised the Hague C
36 Id.
TAX TRENDS AND DEVELOPMENTS Estimated Tax Paymen
Tax Refunds and Overpayments Applied to Next Year
BOOK REVIEW New Resources for High-Conflict and
respond to the child, and implications for custod
The Family Law Section Great Lakes Honor Roll S
THE FAMILY LAW SECTION GREAT LAKES HONOR ROLL Th
Recent Appellate Decisions By Alicia K. Storm
Division of Marital Debt and Attorney Fees Hans v
Modification of Custody
factors of fault, fraud, and discovery violations
Legislative Update By Stephanie Johnson and Kirs
deadlocked on certifying the measure. This propos
State Bar of Michigan FAMILY LAW SECTION MID-SUM
MID-SUMMER CONFERENCE 1. Le
Guidelines for Requesting Appearance of the Famil
Michigan Family Law Journal Family Law Section St