The parties state that on September 3, 1981, they executed a written separation agreement, bearing the date September 3, 1980, prepared at their instance by their previous attorney for the conceded purpose of enabling plaintiff to secure a conversion divorce (see, Domestic Relations Law § 170 [6]). In fact, a judgment of divorce in plaintiff's favor was entered December 28, 1981 (Walsh, Jr., J.), on the ground that the parties had...
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