COMES NOW, the defendant, Gary H. Rappold, and files this, his pretrial brief, and further argues:1. The subject matter presented in this brief is the appropriate legal and equitable adjudication of disputed issues for equitable distribution, alimony and attorney's fees as well as affirmation of the plaintiff's ability to gain gainful employment and ability to contribute to his or her own support. 2. The plaintiff seeks equitable distribution of the $140,000 award, permanent alimony in the amount of $350 per week, and payment of attorney's fees (Exhibit A). Respondent believes these requests are exorbitant, unreasonable, and without merit. This opinion is consistent with long-standing precedents in New Jersey case law and jurisprudence.3. In short, Defendant will have to present irrefutable documentary evidence as well as conclusive inferences consistent with New Jersey law to substantiate its position, as opposed to Plaintiff's exhaustive and misleading judicial ploy, irrelevant and deficient evidence, and undue reliance on erroneous suspicions . The Complaint for Divorce was filed on August 8, 2013. An Answer and Counterclaim for Divorce were filed by the Respondent on September 12, 2013.5. A motion for Pending Lite Relief was filed by plaintiff on August 28, 2013. Defendant filed a cross-motion to the prior motion on September 18, 2013. As of the return date of October 3, 2013, (a) Order for defendant to pay Robert W. Mayer's retainer of $5,000.00 denied without prejudice, (b) Order to freeze all accounts of Gary H. Rappold denied, (c) Order to exempt checking account of the defendant from freezing to pay all monthly and daily expenses was granted, ( d) Order the defendant to pay alimony pendente lite to…… half of the paper…….24. The Defendant's inability to retain counsel and his inferior bargaining position to defend a divorce action should not allow the Plaintiff to gain additional leverage due to inequality of representation.25. New Jersey law requires a court to consider the earning abilities, education levels, professional skills and employability of the parties when deciding alimony and equitable distribution. Defendant offers clear and convincing evidence to rebut Plaintiff's inability to engage in gainful employment. For the reasons set out above, the Court should decide to impute the relevant income to the applicant for the purposes of calculating alimony and the distribution of marital debt. Furthermore, appellant's request for monetary compensation and payment of attorney's fees must be denied with prejudice.