The American Dream

By The Honorable Juna M. Pulayya, Ninth Judicial Circuit of Florida

On August 28, 1963, Martin Luther King, Jr. stood on the steps of the Lincoln Memorial and delivered what became known as his “I Have a Dream” speech. He eloquently addressed our nation calling for equality, and I believe, calling for a nation where anyone could achieve the American dream. 

Just under 20 years after Martin Luther King, Jr’s speech, my parents immigrated to this nation from a country where the idea of equality denoted by Dr. King seemed unattainable. They came here to be part of the nation Dr. King dreamed our country could be. 

As a child, my immigrant parents, albeit possibly unknowingly, instilled in me the hope of Dr. King’s speech - the hope and belief that in this country, with hard work, determination, perseverance, and education, my younger brothers and I could achieve the American dream despite the color of our skin. 

I hold the same hope of Dr. King that in this nation I will continue to be judged by the content of my character and not the color of my skin, because I have faith that this country, and the people I have encountered along the way, will continue to support the American dream.

New Year, New You!

By Jeannette D. Genova, FRP

As the calendar rolls to 2025, embracing Health and Wellness and the theme of “New Year, New You” resonates deeply with many of us. For me personally the new year offers a fresh start and a renewed focus on health and wellness.

This new year let’s not miss the momentum. Let’s prioritize our well-being with these timely strategies that can not only transform our lives but help us achieve long lasting health benefits.

One of the cornerstones of a healthy lifestyle is mindful eating. The emphasis should be on choosing nutrient-dense foods that support overall wellness. We should Incorporate a variety of fruits, vegetables, lean proteins, and whole grains into our diets. These foods are rich in essential vitamins, minerals, and antioxidants that boost our immune system and promote optimal health. We should pay attention to portion sizes and eating habits and avoid distractions during meals, such as watching TV or scrolling through our phones. We should put a special emphasis on savoring each bite, listen to our body’s hunger cues, and stop eating when we feel satisfied. This practice not only helps with weight management but also enhances the enjoyment of food.



Regular physical activity is another important practice of a healthy lifestyle and is vital for maintaining a healthy body and mind. Let’s aim to incorporate at least 150 minutes of moderate-intensity exercise or 75 minutes of vigorous-intensity exercise into our weekly routine. This can include activities like brisk walking, cycling, swimming, or group fitness classes. To stay motivated, find an exercise routine that you enjoy. Whether it’s dancing, yoga, or playing a sport, the key is consistency. Regular physical activity not only improves cardiovascular health, and strengthens muscles, but it also boosts our mental well-being by releasing endorphins, the body’s natural mood elevators. 

Mental health is as important as physical health. Make it a priority to manage stress effectively and nurture your mental well-being. Practices such as mindfulness meditation, deep breathing exercises, and journaling can help reduce stress and promote a sense of calm. Additionally, ensure you get adequate sleep each night. Quality sleep is crucial for cognitive function, emotional balance, and overall health.

Start by setting realistic and achievable goals. Instead of aiming for drastic changes, focus on small, manageable steps that lead to long-term success. Commit to drinking more water daily, taking short walks during breaks, or incorporating more vegetables into your meals. Accountability can also play a significant role in habit formation. Consider partnering with a friend or joining a wellness group to stay motivated and share progress.

Technology continues to revolutionize the way we approach health and wellness. Utilize fitness apps, wearable devices, and online platforms to track your progress, set goals, and access personalized workout plans. Telehealth services also make it easier to consult with healthcare professionals from the comfort of your home.

Lastly, fostering a sense of community and connection is essential for overall well-being. Engage in social activities, join clubs or groups that interest you, and maintain strong relationships with family and friends. Social support can provide emotional comfort, reduce feelings of isolation, and contribute to a happier, healthier life.

As we step into 2025, embrace the opportunity to prioritize your health and wellness with a holistic approach. By focusing on mindful eating, regular physical activity, mental health, building healthy habits, leveraging technology, and nurturing community connections, you can achieve a “New Year, New You” and enjoy a new year filled with vitality and well-being.

Remember, the journey to better health is a continuous process, and each positive change you make brings you one step closer to a healthier, happier you.

Jeannette is a Florida Registered Paralegal and the Firm Manager for Genova Family Law in Weston. She is married to Attorney, Anthony Meehan Genova. They met on eHarmony 16 years ago. They live in Weston with their three small pooches; a MalteePoo named Bentley and two Havanese puppies called Louis and Bailey. 

Tech Tip – Use of Adobe AI Assistant to Analyze Documents

By Matthew E. Thatcher, BCS

One of the essential characteristics of a law practice, especially a family law practice, is the review and analysis of documents under the framework of issues in the case. It could be reviewing bank statements to determine a party’s income or expenses. It could be reviewing credit card transactions to pull out evidence of marital misconduct. It is often reviewing prior agreements, orders, and judgments. Many times we find ourselves having to review communication records (e-mails, text messages, or messages in the various parenting applications) because of the issues that we need to present at an evidentiary hearing or seek to inquire into as part of a discovery deposition. Needless to say reading is fundamental, but it is also time consuming especially when the documents we need to review are voluminous.

Advancements in artificial intelligence are being incorporated into our existing office tools to help us be more efficient. One of those efficiency improvements that could be of help to our practices is the AI Assistant which is now included on the Adobe Acrobat platform.[1]

The Adobe AI Assistant is in the directory of available tools along with other existing tools for exporting a PDF, combining a PDF, and redacting a PDF. It is also displayed at the top right hand corner of your screen while in the Adobe Acrobat Reader. To engage the AI Assistant all that you need to do is to click on the AI Assistant button after opening a PDF file.

Immediately upon engaging the Adobe AI Assistant it will scan and process the open PDF file. The Adobe AI Assistant will then generate a short summary paragraph about the document. The document summaries generated by the Adobe AI Assistant for Section 61.13, Florida Statutes and Section 61.30, Florida Statutes are:

• [Fla. Stat. 61.13] This document outlines the support of children, parenting, timesharing, and court powers in family law cases.

• [Fla. Stat. 61.30] This document outlines child support guidelines, including factors considered in determining child support amounts and income calculations for parents.

In addition to the summary overview of the PDF document, the AI Assistant includes a question prompt through which you can inquire about the contents of the document. Basically you can ask the AI the things you want to know about the document and the AI will then find those answers. 

The answers that the AI Assistant generates are pulled directly from the text of the document and often contain hyperlinks to the specific portions of the document referenced. Answers can include identifying specific word usage or transactions, including counting the number of times that certain words are used. The AI Assistant will provide suggested questions for you to ask based upon its review of the document and the questions which you have presented.

The Adobe AI Assistant is not limited a single PDF file. The Adobe AI Assistant tool permits you to add additional PDF files so that multiple PDFs can be reviewed simultaneously. This could be a helpful tool in reviewing voluminous financial records, or a history of communications, or medical records, or anything where you need to extract data from a larger set of information. When applied over multiple documents the Adobe AI Assistant can identify commonalities and themes which tie the documents together.

As practitioners we should make use of these new AI tools to become more efficient in reviewing discovery, case files, case law, and other documents. The time we save in our initial first look at documents will enable us to move cases forward more expediently for our clients. 

But remember that nothing is foolproof. While these AI software platforms are learning and improving, they will still make mistakes. Even though AI can help us quickly begin to understand and make use of documents, it remains incumbent upon us as practitioners to still verify the information it provides to us. We know inherently that we should check case law before relying upon it. This is no different. The AI may point us in the right direction in our review of documents, but ultimately we need to validate what it shows us.

[1] There are other software platforms which provide a similar document analysis through an AI interface. For purposes of this TechTip the references will be limited to the Adobe AI Assistant.

Case Law Update

State Farm v. Nicholas, 12 Fla. Law Weekly D25

(Fla. 1st DCA December 24, 2024)

By Reuben A. Doupé, Esq.

While not strictly a family law case, this civil opinion merits discussion in all avenues of the law concerning the application of Florida’s Long Arm Statute. 

A home owner (only referred to by his first name, Ebeneezer) originally reported that in the early morning hours of December 25, 2022, he suffered significant damage to the roof of his home. Some previously installed decorative lights were ripped from the house, and shingles were damaged in a straight line as if “A plane had landed on the home, bah!” Plaintiff, the home owner’s insurance carrier, covered the damage and sued Defendant to recover the damages. Defendant is a package delivery service from outside of the United States, and although it does business in Florida, is not registered with the State. 

Defendant was served via the Florida Secretary of State, based upon 48.181 (4). According to this statue, if a foreign business entity “conceals its whereabouts” and the suit arises from a “business venture carried on in this state,” then such business is legally “deemed to have appointed the Secretary of State as its agent on whom all process may be served.” Defendant learned of the service and filed a Motion to Quash, which was granted and appeal ensued. 

The First District affirmed, citing to Farouki v. Attel et Cie, 682 So.2d 1185 (Fla. 4^th DCA 1996). “When service process under statutes authorizing service on nonresidents of Florida, the plaintiff must plead the actual statutory language, or allegations of the ultimate facts that invoice the statute.” Id. at 1186. In this case, Plaintiff failed to allege a sufficient factual basis to invoke the service statute. 

While this particular set of facts is unlikely to appear in a family law case, the law set forth in Farouki is equally applicable when serving a respondent based upon long arm jurisdiction. See also F.R.F.P. 12.070 (j) (2004). 

Gonzalez v. Calles, 2024 WL 5059288 (Fla. 3d DCA 2024)

By Cash A. Eaton, Esq.

From the Third District is the post-judgment modification case of Gonzalez v. Calles. At issue was the Former Wife’s supplemental petition to modify child support and the Former Husband’s petition to modify the parties’ Parenting Plan.

In 2021, the Former Wife sought a modification of child support. The Former Wife asserted that the Former Husband’s income had substantially increased since the entry of the final judgment, that there was a greater need by the child, and that the Former Husband had not complied with the existing timesharing agreement.

In response, the Former Husband alleged that, at the time of the dissolution, he had been living in a small efficiency with no room for the child, but had since purchased a home which has a bedroom for the child. The Former Husband further alleged that he has since remarried, that his marriage has provided him more “financial flexibility” and that his new wife can “share in the duties of caring for the child.”

Ultimately, the trial court determined that the Former Wife met her burden of showing that the Former Husband’s income had substantially and materially increased. Further, the trial court determined that the Former Husband had not shown a substantial, material, and unanticipated change in circumstances to support modification of the timesharing schedule.

The Appellate Court determined that the trial court did not err in granting the child support modification. The Former Husband’s income had more than doubled. The Appellate Court affirmed the denial of the Former Husband’s supplemental petition. The Appellate Court reasoned that, “Florida courts have repeatedly held that a parent's mere move or life improvement to an environment more conducive to children is not a substantial, material, and unanticipated change in circumstances to justify modification of timesharing.”

Leonard v. Gordon, No. 4D2024-1309 (Fla. 4th DCA Dec. 11, 2024)

By Ronald H. Kauffman, Esq.

A mother appealed a paternity judgment arguing the trial court's written judgment conflicted with its oral pronouncement regarding the dependency tax exemption.

The mother filed a petition for paternity against the father. At the end of trial, the trial court orally pronounced it wouldn’t address the dependency tax exemption because neither party presented evidence regarding the tax consequences. The trial court proposed each party claim one child. The father agreed, but the mother objected. The trial court responded, “Then I will make no ruling on the taxes.”

The trial judge entered a final judgment awarding the mother 285 overnights and the father 80 overnights. But the court incorporated a guidelines worksheet showing the parties’ alternating tax exemptions for the children annually. On rehearing, the mother argued the guidelines worksheet referencing the tax issues was contrary to the judge’s oral pronouncement it would make no ruling on tax exemption because there was no agreement and insufficient evidence. The court then entered an amended final judgment but attached the same guidelines worksheet alternating the tax exemptions.

On appeal, the district court reversed and held a trial court's oral pronouncement controls over a later written order. The parent who has the majority of the timesharing is presumptively entitled to the dependency tax exemption. While a court has discretion to transfer the exemption, in this case the lower court did not exercise its discretion. The district court affirmed the oral pronouncement and remanded for the trial court to strike references in the child support guidelines worksheet allowing the father to claim the children for tax purposes.