[brief] Plaintiff/Appellant, [...] (formerly [...]) (“Plaintiff”) appeals from the lower court’s Order of January 23, 2024 that denied nearly all of the Plaintiff’s Motion to Enforce Litigants’ rights (P-1), including almost all of the $470,561.82 that Plaintiff seeks from her ex-husband Defendant/Respondent, Mr. Edward [...], Sr., (“Defendant”), reflecting his share of their two children’s unpaid medical expenses and educational expenses that Plaintiff was forced to pay due to Defendant’s defaults.  Plaintiff also seeks counsel fees and costs, in addition to a directive that Defendant obtain life insurance or provide some type of valid financial assurance that any debt Defendant owes Plaintiff will still be paid, even in the event of Defendant’s death or disability.  The purpose of this Motion, originally filed seven (7) years ago, was simply to compel Defendant to pay his fair share of the parties’ two (2) children’s medical expenses, tuition and educational costs, which Defendant has routinely shirked, much to the financial ruin of Plaintiff.  The trial court abused its discretion when it found that Plaintiff was only owed $186.70 for medical expenses, not owed anything for educational expenses, and then ordered Plaintiff to pay $2,372.50 for Defendant’s counsel fees.  At the outset, it must be emphasized that Defendant lacks all credibility where he committed perjury on his CIS by omitting his one-half interest in his father’s home that was deeded to him 2 months prior to his execution of that CIS, and where his matrimonial attorney, [...], also prepared the deed transferring the one-half interest in Defendant’s father’s house to Defendant, thus suborning perjury, and where [...] invoked the Fifth Amendment during the pre-trial deposition when the Undersigned attempted to explore this issue, entitling Plaintiff to an adverse inference, which was requested but not given.  Moreover, with all due respect to the lower court, this is not the first time the trial court has summarily ignored Plaintiff, who has been forced to provide nearly all of her children’s financial support, requiring her to liquidate assets, including stocks and retirements plan assets.  On April 23, 2020, this Court acknowledged the trial court’s failure to even hold a plenary hearing with respect to Plaintiff’s claims, and reversed the trial court’s March 14, 2019 Order and remanded for a plenary hearing as to the foregoing issues.  Of significant importance to this second appeal is the trial court’s abuse of discretion when ignoring Plaintiff’s testimony and evidence of her hardship due to Defendant’s failure to meet his financial obligations or have meaningful relationships with his children after he remarried, to include evidence that Defendant fraudulently hid assets, such an interest in his father’s home, from his CIS (with the help of his attorney).  Instead, the trial court abused its discretion by taking Defendant at his word that he ”couldn’t afford it” and did not agree to pay for his children’s higher education, despite requesting 1098-T forms reporting [...]’s tuition.  To add insult to injury, the lower court ordered Plaintiff to pay Defendant’s counsel fees.  Respectfully, for the reasons set forth below, the trial court abused its discretion.  Specifically, the lower court erred when it found that Defendant did not agree to pay for the children’s college education and was not required to reimburse Plaintiff for amounts she paid on his behalf towards the children’s loans.  The lower court further erred when it found that Plaintiff’s claims for medical expenses prior to 2014 were barred by the doctrine of laches.  The lower court further erred by ordering Plaintiff to pay Defendant’s counsel fees after failing to consider all of the factors required to make that determination.  **PROCEDURAL HISTORY & STATEMENT OF FACTS**