By contrast, Ms. Blige never moved in with Mr. Blige, even after the marriage, and there was nothing in Mr. Blige's lifestyle to indicate that he might have enormous sums of cash stashed away somewhere.Mallen v. Mallen, 280 Ga. 43 ( 622 SE2d 812) (2005). We agree with the courts of most other states that "[t]hough not required, a fairly simple and effective method of proving disclosure is to attach a net worth schedule of assets, liabilities, and income to the [antenuptial] agreement itself."

Although a number of Georgia cases have applied the first and second Scherer factors, we are aware of only four cases where Georgia appellate courts have considered what changes in facts and circumstances might render a prenuptial agreement unfair and unreasonable. See Sides v. Sides, 717 S.E.2d 472, 473 (Ga. 2011); Alexander v. Alexander, 610 S.E.2d 48, 49 (Ga. 2005); Mallenv. Mallen, 622 S.E.2d 812, 814 (Ga. 2005); Hiers v. Estate of Hiers, 628 S.E.2d 653, 657 (Ga. Ct. App. 2006). Mallen is the most instructive on the issue before us.

“Whether an agreement is enforceable in light of these criteria is a decision made in the trial court's sound discretion. [Cit.]” Alexander v. Alexander, 279 Ga. 116, 117, 610 S.E.2d 48 (2005). Mallen v. Mallen, 280 Ga. 43, 43–44, 622 S.E.2d 812 (2005). Here, evidence supports the trial court's conclusions that full financial disclosures were made to Wife before she agreed to sign the Prenuptial Agreement and that the agreement was not unconscionable.

This is not sufficient to void the contract. Mallen v. Mallen, 280 Ga. 43, 45 (1) (b) ( 622 SE2d 812) (2005) (refusing to marry pregnant woman absent prenuptial agreement held not to be duress). (2) Fraud or Misrepresentation of Material Fact. There is no evidence that the husband's 1994 financial statement contained any material mistakes or misrepresentations. Although the 1994 documents did not list a lake house (that the wife admitted she knew about because she had stayed in it), there is no evidence that the husband was the actual owner of the house at the time of the agreement and, thus, had any duty to disclose it.

In light of the extensive evidence in the record showing Ms. Lawrence's familiarity with Mr. Lawrence's business dealings and personal financial condition, garnered over the course of a lengthy premarital relationship including over two years of cohabitation, and the absence of evidence that Mr. Lawrence had any material income or assets of which Ms. Lawrence was unaware, we cannot say that the trial court abused its discretion in concluding that there was full and fair disclosure of Mr. Lawrence's financial condition prior to the execution of the antenuptial agreement. See Mallen v. Mallen, 280 Ga. 43, 47 ( 622 SE2d 812) (2005) (no abuse of discretion in finding adequate disclosure where parties cohabited for four years, husband's financial statement attached to agreement revealed him to be wealthy man with significant income-producing assets, and wife was well aware from standard of living they enjoyed prior to marriage that husband received substantial income from business bearing his name and other sources). Compare Blige, 283 Ga. at 66 (no abuse of discretion in finding inadequate disclosure where couple did not cohabit before marriage and husband concealed substantial wealth by living modest lifestyle); Alexander, 279 Ga. at 117-118 (no abuse of discretion in finding inadequate disclosure where husband, who owned house and $40,000 investment account, failed to disclose the investment account prior to execution of antenuptial agreement).

(Citation and punctuation omitted.) Mallen v. Mallen, 280 Ga. 43, 47 (2), 622 S.E.2d 812 (2005). [6–9] This Court evaluates "a trial court’s ruling regarding the enforceability of an antenuptial agreement under the familiar abuse of discretion standard of review."

Id. at 219.Blige, 283 Ga. at 66-70; Grissom v. Grissom, 282 Ga. 267 ( 647 SE2d 1) (2007); Corbett v. Corbett, 280 Ga. 369 ( 628 SE2d 585) (2006); Mallen v. Mallen, 280 Ga. 43 ( 622 SE2d 812) (2005); Langley, 279 Ga. 374; Alexander, 279 Ga. at 116; Adams v. Adams, 278 Ga. 521 ( 603 SE2d 273) (2004); Allen, 260 Ga. at 778. Accord Hiers v. Estate of Hiers, 278 Ga. App. 242 ( 628 SE2d 653) (2006).

The defense of duress sets a very high hurdle for those seeking its refuge—it requires no less than a showing of conduct “amounting to coercion, or tending to coerce the will of another, and actually inducing him to do an act contrary to his freewill.” Mallen v. Mallen, 280 Ga. 43, 46, 622 S.E.2d 812 (2005).

See Dodson, 298 Ga. at 118-119, 779 S.E.2d 638 (first prong of Scherer not satisfied where, although prenuptial agreement listed "all of Husband’s assets, it contain[ed] no values for [those] assets — including the value of Husband’s bank accounts and two closely-held businesses owned by him"). Cf. Mallen v. Mallen, 280 Ga. 43, 47 (1), 622 S.E.2d 812 (2005) (affirming enforcement of prenuptial agreement where, although husband’s financial statement did not include income, "it did reveal Husband to be a wealthy individual with significant income-producing assets, including an 80% ownership share of the business bearing his name[,]" and having lived with husband for four years prior to marriage, wife knew from their standard of living that husband had significant income from his business). [8] We also agree with Husband that the trial court erred as a matter of law in finding that he had an obligation to seek information about Wife’s finances.

Lawrence v. Lawrence, 286 Ga. 309, 314(4), 687 S.E.2d 421 (2009). See also Mallen v. Mallen, 280 Ga. 43, 47(1), 622 S.E.2d 812 (2005). That authority was not altered by the fact that no disclosure statements were attached to the agreement and, moreover, the body of the agreement specifically lists major assets of the parties.