NOTICE OF PROPOSED FINAL JUDGMENT: ROBERT PIERDINOCK V. KIM PIERDINOCK, SUPERIOR COURT OF NEW JERSEY, CHANCERY DIVISION, FAMILY PART, MIDDLESEX COUNTY, DOCKET NO. FM 12-1898-24-F
To: Kim Pierdinock
5 Fresh Ponds Road
Monroe, NJ 08831
TAKE NOTICE in accordance with R. 4:43-1 or R. 4:43-2, the court has entered default in the above matter. The plaintiff will seek equitable distribution of all assets and debts listed herein after.
This application for a proposed judgment shall be made by the undersigned counsel for plaintiff at time set to be heard, and such application shall be made before the Honorable Judge Jaquelin Boulos, on April 9, 2026 at 9:00 a.m. at the
Superior Court of New Jersey, Middlesex County Superior Court, 120 New Street, New Brunswick, NJ, at Court Room 402,for a resolution of issues arising out of the parties' marriage as follows:
1. Marital Home. The plaintiff proposes to keep the marital home located at 5 Fresh Ponds Road, Monroe, NJ. The plaintiff proposes a $175,000 buy out. There is a mortgage on the property for approximately $10,422 with Wells Fargo. The cost of sale is approximately $20,000. This is a low estimate. The plaintiff proposes a buy out of $175,000 payable to the defendant. The home is now valued at $335,000.
2. Furniture - All of the marital furniture will be equally split.
3. Vehicles - The plaintiff is proposing that he retain his Dodge Bronco, and his three motorcycles. The defendant can keep her own vehicle(s). The plaintiff is also requesting that he be permitted to retain his 1989 Harley Davison Softail. The plaintiff is requesting that he be permitted to retain his 2006 Harley-Davidson Softail. The plaintiff is requesting that he be permitted to retain his 2021 Harley-Davidson Touring bike.
4. Bank Accounts - The plaintiff proposes that all of parties the basic bank accounts be equally split. The plaintiff proposes that the Wells Fargo account with a balance of $1,500 be split. The plaintiff proposes that the PNC Checking account with a balance of $4,700 be equally split. The plaintiff proposes that the PNC savings account of $3,600 be equally split. The plaintiff also proposes that the Wells Fargo account with a balance of $20 be equally split.
5. Retirement Accounts - The plaintiff proposes that his wife will receive her marital share of his pension at the UFCW Local 1262. The plaintiff proposes that the defendant will receive her marital share of the pension via a QDRO. The parties will use Troyan to assist with the effectuation of the QDRO. The plaintiff will pay for the costs to effectuate the QDRO of his pension. The defendant shall only be awarded her marital share of the pension.
6. Stocks and Brokerage Accounts - The plaintiff has a Edward Jones account with a balance of $1,010,093. The defendant obtained these funds as an inheritance from his deceased sister, and this asset is exempt from any claims of equitable distribution.
7. Credit Card Debt - The plaintiff proposes that both parties pay for their own individual credit card debt(s).
8. Alimony - The parties were married in 1991. This is a 33 year marriage. The plaintiff proposes a ten year limited term of alimony. He proposes a $200 per week alimony award.
9. Life Insurance - The plaintiff submits that neither party shall be required to maintain any life insurance for the benefit of each other.
PLEASE TAKE FURTHER NOTICE a copy of this notice has been filed with the County Clerk for Middlesex County, located at 120 New Street, New Brunswick, NJ where this matter is being heard. This notice and the file may be examined by the defendant at the County Clerk's Office during normal business hours.
/s/ Theodore Sliwinski, Esq. Date: March 2, 2026
_______________________
THEODORE SLIWINSKI, ESQ.
ATTORNEY FOR PLAINTIFF
March 11 2026
LNYS0471038
$67.94