ON July 31, 2001, the front page of the New York Law Journal heralded: “Doctor Forfeits Pension Account in Divorce Case,” reporting on the ruling in Ayuyao v. Ayuyao[1] , and the outwardly tough penalty imposed by Justice Jacqueline Silbermann upon a discovery-recalcitrant ex-husband.

The disclosure-disobedient Dr. Ayayao was ordered to surrender his entire known pension account, valued at some $400,000. One-half of that amount was to go directly to Mrs. Ayuyao for equitable distribution, and the other half was to be held in escrow for various other expenses, including the cost of obtaining whatever additional financial documentation Mrs. Ayuyao needed that Dr. Ayuyao had failed to provide.