The DC Court of Appeals in ANGULO v. GOCHNAUER, deconstructed a divorce property settlement agreement as it related to the Foreign Service Act. Parties in advance of divorce, had reached a property settlement agreement that in general terms released one another from any future property claims with no specific mention of the statutory provisions of the Foreign Service Act. Specifically, parties had incorporated in a general release clause of the property settlement agreement that they desired: to settle all rights, interests and obligations between them and to obtain a full, complete and final property settlement and agreement, including a settlement
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