I had identical but not same situation so I know this first-hand. This is what you need to know: The judgment of a Court has two aspects: Legal and factual. The factual conclusions of a Court, once set and not appealed are more-or-less final. There are numerous theories in law which can be applied to assert that these are final and can no longer be litigated. Among the theories that are applicable are res judicata, constructive res judicata and estoppel, among others. Each of them merit a book, so cannot be discussed in a para. I say more-or-less because there are legal issues such as civil vs. criminal, the Act under which one set of facts were determined, etc. That said, a Family Court's findings are required to be honored by a Magistrate in a family court matter. If I find time, I can forward a Judgment or two... Its been a while since I went through this.
When you do file your response or arguments, you need to present certified copies of the judgments. If cross-examination is not done, MAKE SURE that you bring the judgments officially on the record by presenting them to her and asking her specifically on the same topic and reading the section of the judgment, with respect to factual conclusions, that favor you. In your arguments, do not fail to use the terms Res Judicata, Constructive Res Judicata and Estoppel among other. Do some reading on them so you know what they mean.
Remember, factual conclusions are different than application of law. For example, if you claim that she was cruel to you and some Court has proved that she was, then thats favorable to you. But under some law, she may still qualify for maintenance and possibly under another law, she may not. These are interesting areas of law which I learned first hand...
DISCLAIMER: I am NOT an advocate
