Ellerbe v. Ellerbe
Covenant not to compete upon sale of interest in insurance agency is not marital.
Kricsfeld v. Kricsfeld
Value of covenant not to compete in a professional practice is not a marital asset as it is dependent on the presence or reputation of the individual who provides the covenant.
Berger v. Berger
Part of value for dental practice was a restrictive covenant which represented goodwill and should be divided.