NEW JERSEY PALIMONY
The parties had an extramarital romantic relationship that spanned over 70 years. They never cohabited during the entire period of their relationship. The trial court's dismissal of the case is affirmed. In order to establish a prima facie case for palimony, a plaintiff must present competent evidence showing: (1) the parties cohabitated; (2) in a marriage-type relationship; (3) during the cohabitation, defendant promised plaintiff that he/she would support him/her for life; and (4) this promise was made in exchange for valid consideration. Levine v. Konvitz, et al., New Jersey App. Div., ___N.J. Super.___(App. Div. 2006); February 3, 2006