1994)], and the Partnership Model Division, is not a valid assumption in this case.20. A Family Court may formulate an appropriate method for responding to a party's unilateral reduction of the marital estate.Ahlo v. Ahlo, 1 Haw.App. 324, 328, 619 P.2d 112, 117 (1980).21. While ordinarily income or increased value of separate property belongs to the marital partnership, and is subject to division, the disparity in this case between the value of separate property and contributions of Plaintiff, and the accumulation of losses and a large debt burden, combined with Defendant'sgreater responsibility for causing the accumulation of losses and debts, confounds to a substantial degree the distinct evolution of premarital separate property, marital separate property, and marital partnership property, and requires a just and equitable adjustment of asset distribution that is strongly in favor of the Plaintiff.

In addition, the parties presented some argument as to whether the family court was required to hold an evidentiary hearing on Geraldine's Rule 60 motion. For example, counsel for Nancy argued that, "[s]ince under Ahlo [v. Ahlo, 1 Haw.App. 324, 619 P.2d 112 (1980),] and Hayashi [v. Hayashi, 4 Haw. App. 286, 666 P.2d 171 (1983)], the [Hawaii S]upreme [C]ourt has authorized the family court to have a threshold determination without an evidentiary hearing on whether [the] Rule [60(b)] motion should proceed and since we are the proponents of the essential dismissal of that, it would appear appropriate that we would argue first." Counsel for Nancy later reiterated:

For an appellate court to conclude that there has been an abuse of discretion, it must appear that the trial court clearly exceeded the bounds of reason or disregarded rules or principles of law or practice to the substantial detriment of a party litigant.Raupp v. Raupp, 3 Haw. App. 602, 609, 658 P.2d 329, 335 (1983) (quoting Ahlo v. Ahlo, 1 Haw. App. 324, 619 P.2d 112 (1980)). "Undue emphasis on a particular factor is abuse of discretion" in division of property by trial court upon divorce under HRS § 580-47.

Consequently, the standard of appellate review of that decision is the abuse of discretion standard. Ahlo v. Ahlo, 1 Haw. App. 324, 619 P.2d 112 (1980). Wife left high school at age 17.

An appellate court will not reverse the decision of a family court judge on property division issues unless there has been a manifest abuse of the judge's wide discretion. Ahlo v. Ahlo, 1 Haw. App. 324, 619 P.2d 112 (1980). Discretion is abused when the lower court clearly exceeds the bounds of reason or disregards rules or principles of law or practice to the substantial detriment of a party litigant.

It is well-settled in American jurisprudence that the amount of an award of maintenance, spousal support, or alimony is within the sound discretion of the trial court and its determination will not be disturbed on appeal absent a showing of manifest abuse of discretion, or the decision is contrary to the manifest weight of the evidence. Washburn v. Washburn, 101 Wn.2d 168, 677 P.2d 152, 158 (Wash. 1984) (internal citations omitted); Ahlo v. Ahlo, 1 Haw. App. 324, 619 P.2d 112, 117 (Haw. Ct. App. 1980). The burden is on the appellant to show that the court abused its discretion.

Id. at 71, 660 P.2d at 532. In Ahlo v. Ahlo, I Haw. App. 324, 619 P.2d 112 (1980), that court recognized that the source of the asset is but one of the "circumstances of the case," as is a spouse's positive or negative effect on the accumulation or preservation of the separate property of the spouse. Horst v. Horst, 1 Haw. App. 617, 623 P.2d 1265 (1981).

An appellate court will not reverse the decision of a family court judge on property division issues unless there has been a manifest abuse of the judge's wide discretion. Ahlo v. Ahlo, 1 Haw.App. 324, 329, 619 P.2d 112, 117 (1980). Discretion is abused when the lower court clearly exceeds the bounds of reason or disregards rules or principles of law or practice to the substantial detriment of a party litigant.

These monies were marital assets, and subject to equitable distribution. As in Rosenfeld v. Rosenfeld, 597 So.2d 835 (Fla. 3d DCA 1992), where, during the parties' separation, a spouse expends marital assets, the trial court must account for the expenditures in distributing the marital assets. See Ahlo v. Ahlo, 1 Haw. App. 324, 619 P.2d 112 (1980). Accordingly, I would remand for the trial court to credit the husband in the equitable distribution scheme with the appropriate amount.

Barbara's authorities are simply not in point.Zohlman v. Zohlman, 235 So.2d 532 (Fla.App. 1970), cert.denied,, 238 So.2d 430 (Fla. 1970); Parsons v. Parsons, 68 Wis.2d 744, 229 N.W.2d 629 (1975), overruled on other grounds, Bloomer v.Bloomer, 84 Wis.2d 124, 267 N.W.2d 235 (1978); Ahlo v. Ahlo, 1 Haw. App. 324, 619 P.2d 112 (1980); Karr v. Karr, 628 P.2d 267 (Mont. 1981); In re Marriage of Smith, 114 Ill. App.3d 47, 69 Ill. Dec. 827, 448 N.E.2d 545 (1983), criticized, In re Marriage ofO'Neill, 185 Ill. App.3d 566, 133 Ill. Dec. 617, 541 N.E.2d 828 (1989), followed, In re Marriage of Getautas, 189 Ill. App.3d 148, 136 Ill. Dec. 509, 544 N.E.2d 1284 (1989), overruling, In re Marriage ofO'Neill, supra; In re Marriage of Paulsen, 677 P.2d 1389 (Colo.App. 1984); Kuehn v. Kuehn, 594 S.W.2d 158 (Tex.Civ.App. 1980); Roachv.