Asbeck v. Asbeck
Hardship exception is a discretionary finding, not a factual determination.
In Re Marriage of Popp v. Popp
Hardship redefined: (1) financial deprivation or difficulty (2) not essential needs only.
In Re Marriage of Doerr v. Doerr
Granting $100,000 lump sum payment due to hardship was not appropriate exercise of discretion. Court found that wife needed payment to achieve standard of living, not to avoid privation.