The New Jersey divorce judge failed to conduct a plenary hearing to determine disputed issues of fact. Therefore, the post New Jersey divorce order in favor of the ex-husband is reversed. This order held the ex-wife responsible for $13,500, or 50% of the pre-divorce unreimbursed medical bills incurred by him for himself and on behalf of the parties' child, as well as ordered her to pay $35,000 for his counsel fees for her failure to comply with three prior court orders. Jankowitz v. Jankowitz, App. Div., August 9, 2006