Plaintiff ex-wife appeals from post-judgment orders denying her application for a QDRO payable to plaintiff from defendant's ERISA protected annuity funds to enforce unpaid counsel fee, expert fee, and tuition reimbursement awards. She also appeals from the denial of enforcement of counsel fee judgments by an enhanced wage garnishment. The court reverses, finding the counsel fees, expert fees, and tuition reimbursement related to child support or property distribution, and enforcement of those awards by a QDRO payable to plaintiff did not violate ERISA's anti-alienation provision. The counsel fee judgments were also enforceable by an enhanced wage garnishment to the extent they related to an underlying support obligation
