In this divorce case, the COA adopted a new legal framework that “blends” the “contractual approach” and the “balancing approach” to determine the disposition of a frozen embryo.

The plaintiff, Elizabeth Silverman, filed a breach of contract suit against the defendant, Lawrence Korn, because he refused to pay for legal work that she had performed in his divorce case.

Because of a failure to disclose a possible personal injury claim in a pending bankruptcy action, the defendants’ motion for summary disposition.