Increases, during the marriage, in value of husband’s stock in newspaper could be classified as marital property divisible upon divorce only to the extent that increases were attributable to husband’s personal efforts as coeditor of paper and not to passive factors, such as increases in population of city and in number of households that could purchase newspapers, or to efforts of third parties such as husband’s fellow editor. Rowe v. Rowe 24 Va.App. 123, 480 S.E.2d 760 Va.App.,(1997).

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Divorce in Northern Virginia Child Custody

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